IR 05000382/1999002

Insp Rept 50-382/99-02 on 990117-0227.Violations Noted. Major Areas Inspected:Operations,Maintenance,Engineering & Plant Support Activities

ML20205J884
Person / Time
Site:	Waterford
Issue date:	04/05/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20205J881	List: IR 05000382/1999002 ML20205J878
References
50-382-99-02, 50-382-99-2, NUDOCS 9904120230
Download: ML20205J884 (28)

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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

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Docket No.: 50-382 License No.: NPF-38 Report No.: 50-382/99-02

. Licensee: Entergy Operations, In Facility: Waterford Steam Electric Station, Unit 3 Location: Hwy.18 Killona, Louisiana Dates: January 17 through February 27,1999 Inspectors: T Farnholtz, Senior Resident inspector J. Keeton, Resident Inspector G. Johnston, Senior Project Engineer R. Nease, Reactor inspector, DRS 3 M. Runyan, Reactor inspector, DRS J

Approved By: P. H. Harrell, Chief, Project Branch D ATTACHMENTS: Supplemental information )

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9904120230 990405 i

PDR ADOCK 05000382 G PM

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EXECUTIVE SUMMARY Waterford Steam Electric Station, Unit 3 NRC Inspection Report 50-382/99-02 This routine, announced inspection included aspects of operations, maintenance, engineering, and plant support activities. The report covers a 6-week period of resident inspectio j l

Operations l

The performance of the operations staff associated with coastdown of reactor power prior to a scheduled refueling outage (RFO) and subsequent plant shutdown and cooldown were conducted appropriately and conservatively (Section 01.2).

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The operators' actions to drain the reactor coolant system (RCS) and place the plant in midloop conditions were comprehensive and effective in maintaining the plant in a safe condition. The crew briefing and operations involvement were very good. Independent levelindications were utilized as required. Refilling the RCS was in accordance with procedures (Section 01.3).

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The licensee's actions regarding a series of loose barges on the river was appropriat Damage from the barges striking the circulating water intake and discharge structures was limited to the dolphin.s which were designed to protect these structures during this type of event (Section O2.1).

Maintenance

The licensee's activities concerning the performance of the 5-year preventive .

maintenance program on Emergency Diesel Generator (EDG) A were well organized )

and effective to determine the condition of the unit. Inspections of the internal portions j

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of the engine, including the combustion chambers and cylinder walls, did not reveal any areas of concerns (Section M1.1).

With the exception of the failure to control a lift of the Calvert duct during midloop operation, replacement of Startup Transformer (SUT) B was well controlled i'

(Section M1.2).

An infrequently performed surveillance test involving leak checking the postaccident sampling system (PASS) using the high-pressure safety injection (HPSI) system pressure was appropriately conducted. Communications among participants were very good (Section M1.3).

• The EDG system engineer was very responsive to a potential problem with loose or missing bolts on the EDG air start headers. Material condition of the EDGs was found to be good (Section M2.1).

• A temporary diesel generator was installed during the RFO to provide backup power to the protected safety train on a loss of all other power sources. The safety evaluation, operating procedures, and operator training were very good (Section M3.1).

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• A violation of License Condition C.9," Fire Protec.ica," was identified for the failure to have operable fire barriers in place to protect redundant trains of static uninterruptible power supplies (SUPS). This Severity Level IV violation is being issued as a noncited violation per the guidance provided in Appendix C of the Enforcement Policy (Section E8.5).

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A violation of 10 CFR 50.71(e) has been identified for the failure to correct inaccurate information in the Updated Final Safety Analysis Report (UFSAR). This Severity Level IV violation is being issued as a noncited violation per the guidance provided in Appendix C of the Enforcemont Policy (Section E8.6).

• A violation of 10 CFR Part 50, Appendix B, Criterion lil, " Design Control," was identified for the failure to perform adequate calculations to ensure that environmentally sensitive equipment in the containment building would be adequately protected from submergence during a loss-of-coolant accident (LOCA). This Severity Level IV violation I is being issued a s a noncited violation per the guidance provided in Apperdix C of the Enforcement Policy (Section E8.7).

• A violation of Technical Specification (TS) 3.6.4.1 was identified for failure to meet the appropriate action statement following an extended period when both hydrogen analyzers were inoperable because of inadequately sized heater overloads. This Severity Level IV violation is being issued as a noncited violation per the guidance provided in Appendix C of the Enforcement Policy (Sectien E8.9).

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• A violation of TS 3.6.3 was identified for failure to enter the appropriate action statement within the allowable time when feedwater isolation valves were inoperable. This Severity Level IV violation is being issued as a noncited violation per the guidance provided in l Appendix C of the Enforcement Policy (Section E8.10).

Plant Sucoort

• Inadequate security lighting in the protected area was identified as a violation of Section 6.3 of the Waterford 3 Physical Security Plan. This violation was corrected after prompting by the inspectors. This Severity Level IV violation is being treated as a noncited violation per the guidance provided in Appendix C of the NRC Enforcement Policy (Section S1.2).

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Report Details Summary of Plant Status

At the beginning of this inspection period, the plant was operating at 100 percent power. On January 19,1999, the plant entered end-of-cycle coastdown when RCS boron concentration effectively reached zero parts per million. On February 19, the plant was shut down from approximately 77 pement nawer for RFO 9. At the end of this inspection period, the plant was in Mode 6 in preparation for refuelin . Operatio Conduct of Operations (71707)

O1.1 General Comments (71707)

The inspectors performed frequent reviews of ongoing plant operations, control room panel walkdowns, and plant tours. Observed activities were performed in a manner consistent with safe operation of the facility. The inspectors observed operators using self-checking and peer-checking techniques when manipulating plant equipmen Operators consistently used three-way communication techniques, both in the control room and in external communications with auxiliary operators and maintenance personne O1.2 Plant Coastdown. Shutdown. and Cooldown in Preparation for RFO 9

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i Inspection Scope (71707. 60710) l The inspectors conducted frequent observations of control room operations during the coastdown, shutdown, and cooldown activities. Special requirements for RCS temperature bands to support the requirements for axial shape index during coastdown 4 were reviewed. Procedures and surveillances required for entry into the RFO were reviewe ; Observations and Findinos On January 19,1999, the operators reduced power at the rate of approximately 1 percent per day. Boron concentration in the RCS had been reduced to minimal levels !

arvj a reduction in reactor power was required to maintain the RCS within the required temperature band. The . inspectors observed operator performance and plant response during this time. Both the primary and secondary plants responded well, with no ;

unexpected perturbations resulting from the reduced steam, feedwater, or heater drain l flows. No concerns were identifie On February 2, the inspectors identified a maintenance action item tag that was hung on the wrong train of the fuel pool cooling system. A work item related to a metallic sound coming from the Fuel Pool Cooling Pump B discharge check valve had been discussed during a licensee planning meeting. The residents performed an independent verification and found that the maintenance action item tag had been correctly written to

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-2-address the maintenance on Fuel Pool Cooling Valve FS-104B. However, the tag had been inappropriately attached to Valve FS-104A in the adjacent room. The inspectors notified the shift superintendent, who dispatched an operator to repost the tag on the

- appropriate component. The OperatioC Superintendent followed up by discussing, with all operations shift personnel, the importance of attention to detail and use c'

self-checking techniques during independent activitie On February 19, the plant was shut down to begin RFO 9. Reactor power was approximately 77 percent following the end of coastdown operations. Control room operators performed the shutdown in a controlled manner in accordance with the approved procedures and placed the plant in a condition to allow a subsequent cooldown. A dedicated shuown cooling system operator was stationed in the control

. room to place the plant on s itdown cooling and to continuously monitor plant conditions. The inspectors ( wrved portions of these operations and considered the actions to be appropriate anc . 3rvativ Conclusions The performance of the operations staff associated with coastdown of reactor power prior to a scheduled RFO and subsequent plant shutdown and cooldown were conducted appropriately and conservativel .3 RCS Draindown. Midlooo Operation and Fill Operations Durina Scheduled Refuelina Activities al Inspection Scooe (71707. 60710)

The inspectors reviewed the applicable procedures and observed portions of the -

'draindown of the RCS and establishment of midloop operation. Operations at midloop were monitored on a continuous basis. Preparations for RCS draindown, midloop, and shutdown cooling, including time-to-boil calculations, were reviewed and assesse Also, the inspectors observed the RCS fill operation to greater than 5 percent pressurizer leve Observations and Findinas

. On February 22,1999, the inspectors observed preparations for draindown to midloop and reviewed the draindown Operating Procedure OP-001-003, " Reactor Coolant System Draindown," Revision 18. The inspectors attended the crew briefing conducted l

- prior to the draindown evolution, The briefing was detailed and it was evident that the crew had previously trained on execution of the procedure. Specific assignments were i discucsed with the control room supervisor. The briefing and operations involvement were very good.~

' On February 23, the operators commenced draining the RCS to midloop to allow steam generator nozzle dam installation, shutdown cooling system valve work, and pressurizer heater assembly replacement. The draindown operation was conducted, as specified by I

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-3-approved procedures.- Three separate level' indications.were placed in service at the appropriate time. These included a sight glass, differential pressure indicator, and thermal level indicator. All level indications tracked within the required tolerance as level decreased. Level was stabilized and maintained within a band of 13.75 to 14.00 fee ~

The inspectors monitored and observed the licensee's activities on a continuous basis during draindown and midloop operation. _ The conduct of operations and control of other work activities were observed. Control room operators demonstrated a good -

awareness of plant conditions and work in progress. Access by nonoperations personnel to the control room was carefully controlled during the period of reduced inventory operations.' Contingency plans were established and implemented to protect electrical Train B and Trains A and B of the shutdown cooling system. Other work in progress at this time included preventive maintenance on EDG A and replacement of the Train B SUT. The inspectors considered the actions of the operators during this time to be comprehensive and effective in maintaining the plant in a safe conditio On February 25, the operators commenced filling the RCS to a band of 18.5 to 19.5 feet. At this level, work continued on several valves and the pressurizer heater The dedicated shutdown cooling watch in the control room was maintained to monitor shutdown cooling system operation. The RCS was maintained at this level until-February 27, when level was increased to greater than 5 percent in the pressurizer. The dedicated shutdown cooling system watch was discontinued at that time. The inspectors observed plant operators and considered the control of the plant during these times to be in accordance with procedures and expectation .

The crew briefing and operations involvement were very good. Independent level indications were utilizes v required. Operations to fill the RCS to greater than -

5 percent in the pressurizer were in accordance with procedures and expectations.- Conclusions The operators' actions to drain the ROS and place the plant in midloop conditions were comprehensive and effective in maintaining the plant in a safe condition. The crew briefing and operations involvement were very good. Independent levelindications were utilized as required. Refilling the RCS was in accordance with procedure , O2 . Operational Status of Facilities and Equipment O2.1 Loose Baraes on the Mississiooi River

. Insoection Scope (71707)

The inspectors reviewed the licensee's actions and observed the extent of damages caused by numerous loose barges on the Mississippi Rive ,

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-4- Observations and Findinas On February 12,1999, at 3:38 a.m., a report was received in the control room, from security personnel at the circulating water intake structure, that indicated a noise was heard that sounded like barges striking the intake structure. At 3:40 a.m., the St. Charles Parish Emergency Operations Center reported to the control room that up to 100 barges (the number was later found to be in excess of 200) had broken loose upstream and that Waterford could start seeing barges soon. An auxiliary operator was dispatched to the intake structure and reported 12 barges headed for the intake structure and a large number of barges headed for the discharge structure. In addition, the operator reported that barges were trapped between the dolphins (a pylon located a short distance in front of the structure to protect the structure from damage) and the intake structure. It was noted that some damaga had be'en identified on several dolphins at both the intake and discharge structure The inspectors observed the situation at both the intake and discharge structures as daylight allowed a more detailed inspection. A total of five barges had been trapped between the intake structure and the dolphins, with one hung up on the weir. No barges were trapped near the discharge structure. Damage appeared to be limited to the dolphins. The contents of the barges were identified as grain products and were not considered dangerous. The plant circulating water system functioned as required for continued operation of the facility. The licensee reacted appropriately by monitoring the situation closely and was prepared to shut down the plant in the event of severe damage to plant system Later in the day, the U.S. Coast Guard and shipping company employees secured the barges near the intake structure and formulated a plan to remove them at the earliest opportunity. The barges were removed within the next 2 days and a detailed inspection of the intake and discharge structures indicated no substantial damage with the exception of the dolphin Conclusions The licensee's actions regarding a series of loose barges on the river was appropriat Damage from the barges striking the circulating water intake and discharge structures l

was limited to the dolphins, which were designed to protect these structures during this type of event.

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5-11. Maintenance M1 Conduct of Maintenance (61726,62707)

The inspectors observed all or portions of the following maintenance and surveillance activities as specified by the referenced Work Authorization (WA) or surveillance procedures:

• OP-903-110 RAB Fluid Systems Leak Test

• OP-903-068 Emergency Diesel Generator and Subgroup Relay Operability Verification

- STA-001-006 Leak Rate Testing

• STA-001-004 Local Leak Rate Test, Penetration 33

• WA 01167405 Inspect and Replace Permanently Lubricated Bushings and Washers on Both Ends of the Terry Turbine Governor Valve Lever

• WA 01160313 SUT B Replacement j in general, the inspectors considered the observed work activities to have been performed in an acceptable and effective manner. The technicians were knowledgeable and conducted the work, as required by the applicable procedures. Appropriate support personnel, including health physics, quality control, and supervisory personnel, were at the work site when require The inspectors conducted frequent tours of the facility to assess plant conditions related to work in progress. General conditions were found to be good with limited clutter and ongoing efforts to maintain the plant cleanliness. The inspectors toured the containment i building and determined that some areas did not appear to have adequate lighting to '

allow safe and effective work practices. These areas included the lower sections of the l steam generators and the reactor coolant pump motor areas. TN inspectors identified I this to the licensee and additional lighting was installed in these areas. Subsequent tours by the inspectors revealed a much improved lighting condition in these area M1,1 EDG 5-Year Preventive Maintenance Activities Inspection Scoce (62707)

b The inspectors observed the licensee's activities during the performance of the 5-year preventive maintenance program on EDG A. These preventive maintenance activities included partial disassembly of the engino and generator and inspection of internal portions of the component I'

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6- Observations and Findinas On February 22,1999, the licensee performed a premaintenance run of EDG A in preparation for the scheduled 5-year preventive maintenance activities. The EDG was

' then tagged out and work commenced to partially disassemble the engine and generator to inspect the internal components and assess the overall condition of the EDG. Access to the EDG A room was made easier by devitalizing the area and providing access by authorized personnel via the protected area yard. This mt de bringing tools, parts, and supplies into the area easier and more convenien Parts removed from the EDG were appropriately marked and tracked for reassembl Foreign material exclusion controls were in place and utilized when critical components were open for access to perform work or inspection activities. Surfaces were cleaned in preparation for detailed inspection and replacement of gasket material. The lube oil sump was pumped out to allow inspection of the crankcase are The inspectors observed this work in progress and concluded that it was well coordinated and conducted, as required by the applicable procedures. The inspectors did note that the bottom of the lube oil sump showed signs of damage to the pirted surfaces. The paint _was chipped off in places, but no signs of flaking paint were observed. - The inspectors questioned the system engineer at the work site to determine if this presented any concems for operability. The engineer responded that this damage had occurred during past maintenance activities on the engine and that no concerns had been identified since any paint that did flake off would be picked up by the strainers and filters located in the lube oil system before they could be transported to the critical

. portions of the engine. In addition, this area of the engine would not be expected to be subject to corrosion due to the presence of tube oil. The inspectors concluded that this condition would not adversely affect the EDG operabilit As part of these preventive maintenance activities, an inspection of all 16 combustion chambers was perfo.rmed using a remote TV camera and light instrument. A video tape was made of these inspections, which primarily were concerned with the intake and

- exhaust valve condition and the condition of the cylinder head. The inspectors observed these inspections in progress and viewed the video tape. The condition of these areas appeared to be good. In addition, the licensee performed a visual inspection of the

~ cylinder walls using a small scope. No areas of concern were note j

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At the end of the inspection period, the EDG was being reassembled for a l postmaintenance run. The inspectors considered th'e licensee's activities concerning l EDG A to be well organized and effective to determine the condition of the ED .j Conclusions

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~ The licensee's activities concerning the performance of the 5-year preventive maintenance program on EDG A were well organized and effective to determine the

~ condition of the unit. Inspections of the internal portions of the engine, including the combustion chambers ad cylinder walls, did not reveal any areas of concern i .

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7-M1.2 SUT B heolacement Insoection Scope (71707. 62707)

The inspectors observed portions of the SUT B replacement activities to verify compliance with WA 01160313 and commitments to safety during midloop operations, Observetions and Findinas The inspectors periodically observed personnel working on SUT B to ensure that safe work practices around the SUT were maintained. Equipment and tools that were not in use were collected and overhead connections were tied off. Personnel on scaffolding were secured with safety belts and protective clothing was in use when required. The work area was cordoned off from the rest of the switchyard by the use of barrier tap Vehicle access to the roadway adjacent to the work area was also restricted with the use of barrier tape. No unauthorized personnel were observed by the inspectors in the sequestered area of the switchyard during the work to replace the SU On February 23,1999, while the reactor was at midloop operations, the inspectors observed disassembly of the SUT E> Calvert ducts using WA 99100012. A crano was used to lift a section of the Calvert bus enclosure from above the transformer. The sheet metal structure was about 12 feet long by 2 feet wide and weighed about 150 pounds. The workers failed to attach a tag line to help stabilize the load. When the duct was lifted high enough to clear SUT B and the other Calvert duct (about 40 feet in the air), wind gust caused the load to swing uncontrollably. The inspectors were concerned that the duct could have caused damage to surrounding electrical equipment or cause a power loss, which could have affected midioop operations. The inspectors discussed the activity with the supervisors providing oversight for the crane crew. The activity was stopped and the crew was counseled on appropriate lift techniques prior to resuming the work. The inspectors notified the shift superintendent. Condition Report (CR) 99-0194 was alsu writte Conclusions With the exception of the failure to control a lift of the Calvert duct during midloop operation, replacement of SUT B was well controlle M1.3 Reactor Auxiliary Buildino Fluid System Leak Test Inspection Scope (61726)

The inspectors observed the pretest briefing, systems preparation, and systems walkdown for the leak chec n;

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On February 11,1999, the inspectors observed the infrequently performed surveillance test required by TS 6.8.4.a. Specifically, the surveillance required pressurization of the PASS using the HPSI and walkdown of the PASS piping downstream of the containment penetrations to check for leakane. The surveillarice was performed in accordance with Surveillance Procedure OP-903-110, "RAB Fluid Systems Leak Test," Revision 4, and Technical Procedure CE-003-900," Operation of the Post Accident Sampling System,"

Revision 1 The surveillance required coordination of operations, chemistry, and radiation protection

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personnel. Communications among the participants were three-way and effective. The prejob briefing was very good.

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' The inspectors reviewed the test procedures and data sheets. Test data was co:r.plete, accurate, and appropriately reviewed. TS requirements were me ~ Conclusions An infrequently performed surveillance test involving leak checking the PASS using the HPSI system pressure was appropriately conducted. Communications among participants were very goo M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Inspection of EDG Air Start Headers Inspection Scope (71707)

The inspectors checked the air start headers on both EDGs and discussed a potential problem with the EDG system enginee . Observations and Findinas

On February 18,1998, another nuclear facility reported finding the bolts on Cooper Bessemer EDG air start header either missing or loose. Based on this information, the

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inspectors walked down both EDGs and found that the air header bolts appeared ta be in place and tigm The inspectors discussed the issue with the EDG system engineer, who performed additional followup to determine the extent of the issu : The system engineer reported that the problem was not evident at Waterford 3. He had Jverified that none of the bolts were missing nor loose. The bolts had been torqued to 30 ft-lbs in accordance with the technical manual and had not been removed in recent year o

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The EDG system engineer was very respon.sve to a potential problem with loose or j missing bolts on the EDG air start headers. Material condition of the EDGs was found {

I to be goo M3 Maintenance Prot.edures and Documentation I

M3.1 Temocrary EDG Inspection Scoce (71707. 62707)

The inspectors reviewed the electrical distribution lineup,10 CFR 50.59 screening, operating procedure, and operator training for use of a temporary ED Observations and Findinas i The temporary EDG was insta!!ed to provide an alternate source of backup power for the protected train EDG. The temporary EDG was connected to nonsafety 4kV Busses 3A2 and 3B2 such that either 4kV safety bus could be manually supplied by the temporary emergency diesel. The inspectors observed the setup and connections to the busse l Temporary Operating Procedure OP-TEM-006," Temporary Emergency Diesel Generaior," provided operators with guidance Ior alignment of the temporary generator for any of several postulated loss-of-power scenarios. Operators were trained to use the procedure for startup and alignment of the generato l During midloop operations, the tempora y EDG was started each day on day shift to verify operability. The generator was checked by operations each shift. The inspectors independently toured the generator area and found no discrepe.ncie Conclusions A temporary diesel generator was installed during the RFO to provide backup power to ;

the protected safety traia on a loss of all other power sources. The safety evaluation, operating procedures, and operator training were very goo M8 Miscellaneous Maintenance issues (92902)

M8.1 (Closed) Violation (VIO) 50-382/9705-02 and -03: Failure to establish adequate measures to ensure that welding activities were properly controlle .

-10-This violation was inadvertently issued with two different numbers in NRC Inspection Report 50-382/97-05. The numbers were 50-382/9705-02 and 50-382/9705-0 Closing this violation closes both number The licensee initiated four CRs to document each of the exarnples of failure to control welding activitie In response to this violation, the licensee identified both specific and generic corrective actions for each of the four examples. Specific corrective actions included revising Administrative Procedures MM-001-053,"Contrcl of Welding Consumables";

MM-001-050, " General Welding Requirements"; MD-001-012, " Tool Control"; and MM-001-054," Control and Documentation of Welding." Maintenance Directive 7,

" Guidance for Conducting Pre-Job Briefings," was also revised. To address the broader implications of this violation, the licensee planned to conduct additional training for welders, tool room attendants, and quality assurance welding inspectors. All maintenance personnel were briefed by the maintenance manager concerning the need for positive component identification, the use of the STAR (Stop, Think, Act and Review)

process, and the importance of a complete job turnover. The inspectors reviewed the corrective actions for each issue and found them to be acceptabl M8.2 (Closed) Inspection Followuo item (IFI) 50-382/9707-01: Unauthorized control room panel symbol Main control room panel placards displayed incorrect information regarding the input signals needed for automatic closure of two containment isolation valve The licensee corrected the indicated signal inputs on the control room panel for automatic Containment isolation Valves CVR-400 and -401, in addition, the licensee reviewed the remaining control board symbols and did not identify any additional discrepancies. The inspectors examined the control board in the main control room and verified that the signal input placards for Valves CVR-400 and -401 had been correcte jll. Enaineerina E8 Miscellaneous Engineering issues (92903)

E (Closed) VIO .50-382/9407-02: Failure to provide an adequate procedur Diesel generator maintenance Procedures MM-003-041,"Five Year Emorgency Diesel Engine Inspection," Cliange 1, Revision 1, and MM-003-042, " Ten Year Emergency Diesel Engine inspection," Change 4 Revision 0, did not provide instructions to lubricate fuel injector pump mounting fasteners b accordance with vendor specification As an initial response, the licensee revised these two procedures to remove the lubricant selection from being a critical step in the fastener installation proces Previously, the procedures required the fasteners to be torqued to 52 ft-lbs. The revised procedures required the installer to measure the rundown torque (torque needed to

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l thread the fastener prior to any elongation) and to apply a final torque of 52 ft-Ibs, plus the rundown torque. The differen::es in lubricants woula be seen as a difference in the rundown torque and the bolts would be torqued to 52 ft-lbs, as specified by the vendo Subsequently, the licensee revised Procedure MM-003-041, Revision 2, to specifically

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require the use of Lubriplate 630-AA or the equivalent. Procedure MM-003-041 was then deleted because the licensee was transitioning to a 20-year inspection schedul J The 20-year inspection procedure had not been developed. The inspectors determined '

that the licensee had satisfactorily addressed the issu E8.2 (Closed) VIO 50-382/9710-06: Failure te promptly identify and correct conditions adverse to qualit Two examples of failure to comply with 10 CFR Part 50, Appendix B, Criterion XVI, were identified: (1) failure to correct a deficiency in the design basis for tornado protection of the ultimate heat sink, and (2) failure to identify and correct nozzle ring setting )

deficiencie j The licensee determined that the reason for the design deficiency was that design controls did not ensure that field-routed, safety-related conduit was protected against design-basis tornados. The licensee performed walkdowns to identify other missile vulnerable safety-related equipment, implemented modifications to relocate exposed conduits '.o areas that provide missile protection, and implemented Revision 5 to Drawing LOU-1564-B-288 SH.21 A-1. This procedure revision added a note requiring design personnel to review new cable and conduit installations for tornado effect and tornado-generated missile loading. In addition, during a review of the design and licensing basis of tornado missile protection, the licensee identified a potential common-mode failure of the safety-related SUPS. This issue was reported to the NRC 1 in Licensee Event Report (LER) 97-020-00, dated July 3,1997, and is discussed in Section E8.5 of this repor The inspectors reviewed the licensee's operability determination for the six valves found with incorrect settings and found it to be acceptable. The inspectors also reviewed Procedure MM-007-01," Safety and Relief Valve Bench Testing and Maintenance,"

which was revised to include the proper method for determining the nozzle ring zero j reference point, L .d found it sufficient to prevent future errors in setting of relief valves. l Other corrective actions included the procurement of test equipment that can control pressure buildup and permit detailed relief valve testing under high volume flow rate For both examples discussed above, the licensee stated that they will address the '

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human performance aspects of this violation in their Performance improvement Plan, l and the quality of documents will be considereo as part of their Design Basis i l Reconstitution Program. The inspectors determined that the licensee's corrective i actiens for this violation were acceptabl ;

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E8.3 . (Closed) VIO 50-382/9721-02: Failure to follow procedure Two examples of a failure to comply with the requirements of 10 CFR Part 50, Appendix B, Criterion V, were identified: (1) failure to update the Technical '

Requirements Manual (TRM) in accordance with Site Procedure W4.503," Changes to the Technical Specifications, Technical Requirements Manual, or Core Operating i

Limits," Revision 4.1; and (2) failure to initiate a CR as required by Procedure W2.501,

" Corrective Action," Revision 6, in response to identifying an error in Calculation EC-191-027, Revision The licensee failed to initiate a TRM change request for changes made to Table 3.8-1 of the TRM and failed to evaluate the changes under the 10 CFR 50.59 process, as required by procedure. As part of their corrective actions, the licensee initiated and completed TRM Change Request 98-001 and its associated 10 CFR 50.59 safety-evaluation and reinforced management expectations for processing corrective actions during engineering and licensing department staff meetings. The inspectors reviewed TRM Change Request 98-001 and the 10 CFR 50.59 safety evaluation and found them to be acceptabl The licensee's immediate corrective actions for the failure to write a CR included:

revising Calculation EC-191-027 to consider density changes in the water column and reviewing all other level instrument error calculations to determine if any failed to consider water density. No other calculations were identified. In addition, the Director,

! Design Engineering issued a memorandum to all design engineering personnel providing guidance on when to write a CR, which was included as part of the formal I

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engineering support personnel training. The inspectors found the licensee's corrective actions to be acceptabl E (Closed) VIO 50-382/9725-04: Failure to follow CR procedure In a letter to the NRC, dated April 28,1998, the licersee denied this violation. In a response to the licensee, dated June 9,1998, the NRC withdrew this violation, therefore

' this issue is closed.

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E8.5 ' (Closed) LER 50-382/97-020-00: Potential Safety-Related Static Uninterruptible Power Supply (SUPS) Common-Mode Failur The licensee discovered that a fire or tornado could cause a momentary loss of both trains of one set of the safety-related SUPS. This could resuit in a workaround during an accident recovery for operatcrs to manually realign some safety-related loads ' l needed for safe plant shut down. The licensee stated that no safe shutdown equipment I would have been permanently lost in the scenario and all of the assumptions of the accident analysis would have been me I

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-13-The licensee immediately established fire watches in the areas where vulnerabilities existed and have maintained them to the date of this inspection. Plant operators were trained to understand the situations under which the SUPS could lose power and the actions that might be necessary to realign safety-related load As a permanent solution to the problem, the licensee will modify the Train B SUPS, as specified in Design Change DC-3546, with a new unit that will provide a current limiting feature that would prevent most of the postulated faults from causing a momentary loss of power to the unit. However, control room / cable vault area faults that would deliver higher current levels could still result in a momentary loss of power to the SUPS or a voltage degradation problem. To address this vulnerability, the licensee revised procedures to require the operators to isolate all nonessential unprotected loads receiving power from the Train B SUPS. These procedure changes willintroduce an extra 2 minutes in operator actions for a control room fire, but this was still well within the time profile for design basis safe shutdown actions. In plant areas other than the control room / cable vault, the licensee will reroute and fire wrap cables for configurations that are not rescIved by the SUPS modification. The final result of these actions will be to establish Train B as the protected train of the SUPS. All of these actions are scheduled to be completed during the RFO scheduled to begin on February 19,199 Based on discussions and review of plant documents, the inspectors determined that the modifications and procedure changes would satisfactorily address the identified vulnerabilit )

The inspectors identified this issue as a violation of License Condition C.9," Fire Protection," for the failure to have operable 1-hour fire barriers in place for redundant affected circuits routed through the same fire area. This Severity Level IV violation is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as CR 97-0157 (50-382/9902-01).

Conclusions A violation of 10 CFR Part 50, Appendix R, Section Ill.G.2.c, was identified for the failure to W operable fire barriers in piace to protect redundant trains of SUPS. This Seveniy Level IV violation is being issued as a noncited violation per the guidance ,

l provided in Appendix C of the Enforcement Polic E (Closed) Unresolved item (URI) 50-382/9725-01: HPSI and containment spray (CS) net I positive suction head (NPSH) margin inaccurately stated in the UFSA The licensee identified inconsistencies between a design calculation and the UFSAR conceming the available NPSH for the CS and HPSI pumps during a LOCA. The margins stated in the UFSAR were not supported by the calculations, which listed lower l (but still positive) margins.

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-14-The licensee revised Calculations MN(0)-6-4, " Water Levels inside Containment,"

Revision 1, and MN(O)-6-27,"NPSH Calculation for HPSI and CS Pumps During Recirculation," Revision 3, to more accurately assess the NPSH available to the CS and HPSI pumps during the recirculation phase of a LOCA. Licensing Document Change Request LDCR 97-0212 was processed on July 29,1998, to revise UFSAR Sections 6.2.2.3.2.1, "NPSH Calculations"; 6.3.2.2.2.3, " Net Positive Suction Head"; and Table 6.2-22," Design Data for Containment Spray System Components." After these revisions, the design calculations and UFSAR were consistent. The licensee also updated the applicable design basis document Safety Evaluation 98-046 was performed to address the 10 CFR 50.59 implications of the UFSAR changes. This evaluation concluded that an unreviewed safety question did ,

not exist. The inspectors noted that no physical changes were made to the plant, but l

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that the calculated minimum available NPSH margins for the CS and HPSI pumps had decreased significantly (94.8 to 36.78 percent for CS and 40.8 to 8.86 percent for HPSI). However, the NPSH margin was not defined in the bases of the TS or the safety analyses. Since a positive NPSH tc.argin still existed for all pumps (including consideration of vortexing), the assumed flow rates were not affected and no TS bases or safety analysis parameters related to 99 performance of these pumps was affecte The inspectors considered the UFSAR errors discussed above to be a violation of 10 CFR 50.71(e). This Severity Level IV violation is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as CR 97-0806 (50-382/9902-02).

I Conclusions l

A violation of 10 CFR 50.71(e) has been identified for the failure to correct inaccurate I information in the UFSAR. This Severity Level IV violation is being issued as a noncited violation per the guidance provided in Appendix C of the Enforcement Polic ;

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E8.7 / Closed) URI 50-382/9725-02: Inadequate containment flooding calculations and nonqualified equipmen The licensee identified and corrected errors in a containment flooding calculation and discovered thal the new maximum flooding level would cause submergence of the cooling coils of a containment fan cooler and three safe shutdown instruments that nad not been qualified for submergence. As a short-term measure to alleviate the flooding concern, the licensee administratively reduced the refueling water storage pool (RWSP)

upper limit to a level of 90 percen The licensee issued Calculation EC-M89-004, " Water Levels inside Containment (Post i

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LOCA)," Revision 4, on September 3,1998, to more precisely determine the post-LOCA flooding levels in containment. The new levels identified in the calculation required the application of a more restrictive limit on the maximum RWSP level (87 percent). At this RWSP level, taking into account instrument uncenainties, no safe shutdown instruments were calculated to be submerged or adversely affected durirg a LOCA. The cooling

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-15-l coils of some containment fan coolers could become partially submerged, but this would have a negligible effect on the overall performance of this system (approximately a 0.15 psig difference in peak containment pressure). The 10 CFR 50.59 safety evaluation for Calculation EC-M89-004 concluded that an unreviewed safety question did not exist. The inspectors agreed with this conclusio The inspectors observed that the current operating band of the RWSP was only 83-87 percent of the indicated level. The licensee stated that efforts were underway to raise the elevation of the affected instruments in containment to allow use of the full .

volume of the RWSP. This modification was tentatively planned for the RFO scheduled for September 200 Based on the revised calculation and its accompanying safety evaluation, along with the ]

current RWSP level operating limits, the inspectors considered the current containment i flooding situation to be satisfactory. However, it appeared that past operability or adherence to Regulatory Guide 1.97," Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an l Accident," Revision 2, particularly at times that the RWSP was at or near full level, was i questionable. The principalinstruments of concern were the steam generator l wide-range level instruments, since no backup instruments existed. These instruments supply an input to the emergency feedwater (EFW) system flow logic. EFW is not l required for a large break LOCA, which floods containment in a short period of tim EFW is required for a small break LOCA, but the time to reach maximum flooding levels is much greater. By the time the wide-range instrument would be flooded, the steam generator levels would be in the narrow range, where operators could establish manual control as prescribed by the emergency operating procedures. The narrow-range instruments would not be affected by the postulated flood water Based on this, the licensee concluded that the submergence of the wide-range instruments would have had no effect on me outcome of the accident analysis. All other instruments affected by potential flooding conditions had bachp instruments capable of providing the required parameters during accident conditions. Based on these facts, the I licensee determined that this condition was not reportabl !

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The inspectors considered the inadequate design calculations that permitted the potential exposure of safe shutdown equipment to an unqualified submergence condition to be a violation of 10 CFR Part 50, Appendix B, Criterion ill," Design Control."

This Severity Level IV violation is being treated as a noncited violation, consistent with 1 Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as CR 97-1287 (50-382/9902-03).

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-16-Conclusions A violation of 10 CFR Part 50, Appendix B, Criterion l!I, " Design Control," was identified for the failure to perform adequate calculations to ensure that environmentally sensitive equipment in the containment Duilding would be adequately protected from submergence during a LOCA. This Severity Level lV violation is being issued as a noncited violation per the guidance provided in Appendix C of the Enforcement Polic E8.8 (Closed 1 LER 97-032-00 and -01: Hydrogen Recombiner Analyzer System Containment Isolation Valves Did Not Meet Geraral Design Criterion 5 On November 25,1997, while evaluating a related issue reported in LER 97-031-00, the licensee found that the hydrogen recombiner analyzer system containment isolation valves did not meet the redundancy requirement of General Design Criterion 54, " Piping Systems Penetrating Containment."

The hydrogen recombiner analyzer system consists of two trains, each of which draw and return containment air samples through Penetrations 66 and 67, respectively. The two sample supply lines each have solenoid-operated inboard valves (HRA 109A and-1098) and solenoid-operated outboard valves (HRA-110A and -1108) for containment isolation. The two return lines each have solenoid-operated outboard containment isolation valves (HRA-126A and -1268) and check valves (HRA-128A and -1288) for inboard containment isolation. Hydrogen recombiner analyzer system Containment isolation Valves HRA-109A, -1098, -126A, and -126 B were classified in the UFSAR as automatic containment isolation valves and were maintained normally closed. As such, they are required by General Design Criteria 54 to be designed to have redundant power source The licensee determ;.1ed that, because all valves in the same train are powered through the same relay, a single failure of that relay at the same time the valves are open for testing would prevent all valves in that train from closing upon a containme.it isolation signal. As immediate corrective action, on November 26,1997, the licensee removed power from the outboard containment isolation valves (HRA-110A and-110B) and declared them inoperable. Because the valves share the same power source, this also I I

rendered hydrogen recombiner analyzer system containment isolation valves HRA-101 A, -109B, -126A, and -126B inoperable, which resulted in both hydrogen i analyzers being declared inoperable. On November 28, the licensee reclassified l automatic hydrogen recombiner analyzer system containment isolation Valves j HRA-109A, -1098, -110A, -1108, -126A, and -126B as manual / remote manual,  !

locked-closed containment isolation valves, thus eliminating the single failure vulnerability. The licensee then declar?d the hydrogen recombiner analyzer system containment isolation Valves HRA-101 A, -1098, -126A, and -126B and the hydrogen 4

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analyzers operabl This event was discussed in NRC Inspection Report 50-382/97-25, dated l

March 12,1998, as an example of Apparent Violation 6.c, for making a change to the facility under 10 CFR 50.59, which involved an unreviewed safety question. The NRC, (

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t-17-in the Notice of Violation issued to the licensee on June 16,1998, withdrew this example of Apparent Violation 6.c. This letter stated that reclassification of the hydrogen recombiner analyzer system containment isolation valves did not involve an unreviewed safety question. The inspectors reviewed the licensee's corrective actions to the event, the 10 CFR 50.59 safety evaluation, and proposed changes to the UFSAR and found them to be adequat E8.9 (Closed) LER 50-382/98-003-00: Inoperable Hydrogen Analyzer Due to Undersized Thermal Overload The licensee identified that the sample pump overloads for Hydrogen Analyzers A and B were undersized, rendering both analyzers inopcrable for a period exceeding the allowed outage time specified in TS 3.6. The undersized overloads had been installed since June 1988. Although the thermal overloads were undersized, engineering determined that the analyzers would have functioned in an accident, meaning the inoperability determination was conservativ Had the analyzers not functioned, the emergency operating procedures would have had the operators start the hydrogen recombiners or the containment atmosphere release system, thereby maintaining hydrogen concentrations at safe levels. Therefore, the overall safety significance was lo In response, the licensee replaced the hydrogen analyzer heater overloads with properly cized units. The licensee performed a walkdown of a sample of safety-related motors and their overicads, a task that involved approximately 100 motors. From the sample, two inconsistencies were identified. The control room air handling unit motor (HVCEMTR311 A/4F) had slightly oversized heater overloads, possibly because of nuisance tripping during startup testing. The incorrectly sized overloads were replace The second inconsistency involved two EDG A and B air compressor motors that had slightly undersized heater overloads, which were also replaced. Neither inconsistency involved an operability proble The failure to meet the requirements of TS 3.6.4.1 was identified as a violation. This Severity Level IV violation is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as CR 98-0291 (50-382/9902-04).

Conclusions A violation of Technical Specification 3.6.4.1 was identified for failure to meet the appropriate action statement following an extended period when both hydrogen

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analyzers were inoperable because of inadequately sized heater overloads. This Severity Level IV violation is being issued as a noncited violation per the guidance i provided in Appendix C of the 2nforcement Policy E8.10 (Closed) LER 50-382/98-006: increased Differential Pressure fur Feedwater Isolation l Valves Requ!T Both Accumulators to be in Servic l

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-18-Having discovered that the maximum expected differeritial pressure (MEDP) was greater than previously assumed, the licensee determined that both nitrogen accumulators, which service each feedwater isolation valve, must de in service for the valve to be operabl TS 3.6.3 requires each containment isolation valve to be operable. Previously, the licensee had assumed an MEDP of 1400 psig for the fradwater isolation valves, which allowed the feedwater isolation valves to be operable with only one nitrogen accumulator in service. Therefore, the 4-hour limiting condition for operations (LCO) for TS 3. was not entered during times that only one accumulator was inoperable. As a result of further investigation, the licensee determined that the correct MEDP was 1581 psig. At this differential pressure, the feedwater isolation valves would require both accumulators to be operable to perform its design function to close. As a result, the licensee implemented an administrative control to Operations Procedure OP-100-014. " Technical Specification and Technical Requirements Compliance," Revision 9, requiring entry into TS 3.6.3 should a feedwater isolation valve hydraulic accumulator be declared l

inoperable. The inspectors reviewed Procedure OP-100-014 and verified that the '

administrative control was in plac The licensee's investigation of the event revealed that maintenance work to restore an accumulator to service could have been completed within about 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and, thus, would not have exceeded tne 4-hour LCO; however, without the LCO identified, it was very likely that on some occasions the 4-hour LCO period was exceeded. On this basis,

~t he licensee issued this L.2R for failure to meet TS 3. The licensee's failure to enter TS 3.6.3 for past hydraulic accumulator outages that exceeded the 4-hour LCO period was identified as a violation. This Severity Level IV violation is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as :

CR 98-0337 (50-382/9902-05).

Conclusions

A violation of Technical Specification 3.6.3 was identified for failure to enter the appropriate action statement within the allowable time when feedwater isolation valves'

hydraulic accumulators were not in service. This Severity Level IV violation is being issued as a noncited violation per the guidance provided in Appendix C to the 1

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Enforcement Polic ' IV. Plant Support t

R4 Staff Knowledge and Performance On February 22,1999, during an evening tour of the contro; led access area, the inspectors observed an individual reaching across a contaminated area boundary without wearing protective clothing required by the appropriate radiation work permi The inspectors notified a radiation protection technician who was in the area. The

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l technician escorted the individual to the controlled access area egress point and i checked him through the contamination and radiation monitors. The individual was not contaminated. The licensee issued CR 99-0184 for corrective action followup. The individual was counseled on using proper radiological work practice S1 Conduct of Security and Safeguards Activities S Security Searches of Personnel and Eculoment

{ Inspection Scope (71750) '

The inspectors conducted extended observations of personnel and vehicle access to the i protected area. These activities included personnel, hand-carried item, and vehicle l searche l Observations and Findinas On February 10,1999, the inspectors made eue d observations of security l personnel conducting personnel and vehicle st. - .aes at the primary access porta Security officers at the access portal performed x-ray searches of hand-carried articles and pocket material and monitored explosive detectors and metal detectors as personnel processed through. No concerns were identified by the inspectors during l these observation !

The inspectors also observed vehicle searches being conducted by security officers at the primary access portal. A large crane and a flatbed trailer carrying air conditioning l equipment were observed. The snrches were conducted using Procedure PS-011-103," Vehicle Access Control," Revision 9. All requirements of this procedure were adequately addressed. However, the inspectors did note that the security officers conducting the searches did not use any flashlights or other form of lighting to illuminate darker areas, such as engine compartments. In addition, the primary method used by the security force to conduct the search of the top portion of irregularly shaped vehicles, such as the crane and the air conditioning equipment, was to use a remote controlled camera mounted on a pole located just east of the vehicle search area. The inspectors considered the searches to be adequate but that they could be enhanced by the use of better lightin Conclusions Personnel and vehicle searches conducted at the primary access portal were performed in accordance with applicable procedures.

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. S1.2. Protected Area Liahtina Insoection Scope (71750)

The inspectors performed a walkdown of the protected area to observe the status of temporary security lightin Observations and Findinas On February 23,1999, during an evening tour of the protected area, the inspectors )

noted areas beneath temporary trailers that appeared to be inadequately illuminate Several trailers and other vehicles had been moved into the protected area to support the RFO. The inspectors reported the observations to the security supervisor who stated that he would investigate. He also stated that cartain areas of low lighting were l- ' patrolled on a scheduled basis. The inspectors reviewed the security patrol worksheets and found that some of the equipment was identified for a 6-hour check by the security patrol. A general item requiring a check under all vehicles, carts, and wagons was on '

the checklist. On February 24, a specific check on vehicles identified by the NRC inspectors was added to the check shee The inspectors noted that lights had net been installed until the evening of February 25 3

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in cnc specific area of poor illumination. This area was beneath and behind the trailer situated against the west side of the condensate polisher building and was not specified on the patrol sheet, i

A revievf of previous inspection reports revealed that the licensee had two violations of protected area lighting in 1995 and 1996. CR 99-0433 was written after prompting by the inspector This Severity Level IV violation is oeing treated as a noncited violation, consistent with L Appendix C of the NRC Enforcement Policy. > s violation is in the licensee's corrective action program as CR 99-0433 (50-382/9902- : Conclusions inadequate security lighting in the protected area was identified as a violation of Section 6.3 of the Waterford 3 Physical Security Plan. This violation was corrected after prompting by the inspectors. This Severity Level IV violation is being treated as a noncited violation per the guidance provided in Appendix C of the NRC Enforcement

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l V. Manaaement Meetinos X1- Exit Meeting Summary The inspectors presented the inspection results to members of licensee management on l March 8,1999. The licensee acknowledged the findings presente ]

I The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie l i

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t ATTACHMENT 1 SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee R. F. Burski, Director Site Support C. M. Dugger, Vice-President, Operations E. C. Ewing, Director, Nuclear Safety & Regulatory Affairs C. Fugate, Operations Superintendent A. Harris, Acting Superintendent, System Engineering J. G. Hoffpauir, Manager, Operations T. R. Leonard, General Manager, Plant Operations D. C. Matheny, Refuel 9 Coordinator E. Perkins, Jr., Manager, Licensing G. D. Pierce, Director of Quality B. Thigpen, Director, Planning and Scheduling A. J. Wrape, Director, Design Engineering i

INSPECTION PROCEDURES USED i 37551 Onsite Engineering 60710 Refueling Activities i

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61726 Surveillance Observations 62707 Maintenance Observations 71707 Plant Operations 71750 Plant Support Activities 92700 Onsite LER Review 92301 Followup-Plant Operations 929r)2 Followup-Maintenance 92904 Followup-Plant Support ITEMS OPENED. CLOSED. AND DISCUSSED Opened 50-382/9902-01 NCV Failure to have operable fire barriers in place (Section E8.5).

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,k-2-50-382/9902-02 NCV HPSI and CS NPSH margin inaccurately stated in UFSAR (Section E8.6).

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50-382/9902-03 NCV Failure to perform adequate calculations for containment flooding (Section E8.7).

50-382/9902-04 NCV Failure to meet appropriate TS action statement for inoperable hydrogen analyzers (Section E8.9).

50-382/9902-05 NCV Failure to enter the applicable LCO for inoperable feedwater isolation valves (Sect!cn E8.10).

50-382/9902-06 NCV Failure to provide adequate security lighting (Section S1.2)

Closed 50-382/9705-02 VIO - Failure to establish adequate measures to ensure that and -03 welding activities were properly controlled (Section M8.1).

50-382/9707-01 IFl Unauthorized control room panel symbols (Section M8.2).

50-382/9407-0 VIO Failure to provide an adequate procedure for EDG  ;

inspections (Section E8.1).

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50-382/9710-06 VIO For failure to promptly identify and correct conditions adverse

' to quality (Section E8.2).

50-382/9721-02 VIO Failure to follow procedures for updating the TRM and issuance of a CR (Section E8.3).

50-382/9725-04 VIO Failure to follow CR procedures (Section E8.4).

50-382/97-020-00 LER Potential Safety-Related SUPS Common-Mode Failure (Section E8.5).

50-382/9902-01 NCV Failure to have operable fire barriers in place (Section E8.5). l 50-382/9725-01 URI HPSI and CS NPSH margin inaccurately stated in UFSAR (Section E8.6). l 50-382/9902-02 NCV HPSI and CS NPSH margin inaccurately stated in UFSAR (Section E8.6).- I 50/382/9725-02 URI Inadequate containment flooding calculations and nonqualified equipment (Section E8.7).

50-382/9902-03 NCV Failure to perform adequate calculations (Section E8.7).

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-3-150-382/97-032-00 LER Hydrogen Recombiner Analyzer System Containment and -01 Isolation Valves Did Not Meet General Design Criterion 54

/ (Section E8.8).

50-382/98-003-00- LER- Inoperable H2 Analyzer Due to Undersized Thermal Overloads (Section E8.9).

50-382/9902-04 NCV~ Failure to meet appropriate TS action statement for inoperable hydrogen analyzers (Section E8.9).

50-382/98-006-00 LER Increased Differential Pressure for Feedwater Isolation Valves Require Both Accumulators to be in Service (Section E8.10).

50-382/9902-05 NCV Failure to enter the applicable LCO for feedwater isolation valves (Section E8.10).

50-382/9902-06 NCV Failure to provide adequate security lighting (Section S1.2)

LIST OF ACRONYMS USED

..CFR Code of Federal Regulations CR condition report CS- containment spray EDG, emergency diesel generator EFW emergency feedwater ft-Ibs - foot-pounds IFl inspection followup item LHPSI - high-pressure safety injection kV kilovolt LCO ' limiting condition for operation-LE Licensee Event Report i LOC loss-of-coolant accident MEDP maximum expected differential pressure NCV noncited violation NPS net' positive suction head l

NRCI Nuclear Regulatory Commission l

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l PASS postaccident sampling system PDR Public Document Room RCS- reactor coolant system L

RFO refueling outage .

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l RWSP- refueling water storage pool SUPS static uninterruptible power supplies SUT startup transformer -

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'TRM Technical Requirements Manual TS Technical Specification UFSAR updated final safety analysis report URI unresolved item

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VIO violation i/A work authorization

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