ML19327B380
| ML19327B380 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 10/16/1989 |
| From: | Chamberlain D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19327B376 | List: |
| References | |
| 50-382-89-26, NUDOCS 8910310071 | |
| Download: ML19327B380 (12) | |
See also: IR 05000382/1989026
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APPENDIX'B'i
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U' S. NUCLE'AR REGULATORY COMMISSION
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REGION IV
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NRC Inspection Report: - 50-382/89-26
, Operating License: ' NPF-38 ,
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' Docket:
50-382,
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' Licensee:
LouisianaPower&LightCompany'(LP&I.)
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317 Baronne Street
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New Orleans, Louisiana 70160
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Facility Name: Waterftrd Steam Electric Station, Unit 3 (Waterford 3)
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Inspection At:
Taft, Louisiana
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' Inspection Condected:
September 1-30, 1989'
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, Inspectors:
W. F. Smith, Senior Resident Inspector
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Project Section A, Division of Reactor Projects
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T. R. Staker, Resident Inspector
Project Section A, Division of Reactor Projects
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S. D. Butler, Resident Inspector
Project Section A. Division of Reactor Projects
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Approved:
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D. D. O amberlain.' Chief,' Project Section A
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Inspection Summary
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Inspection Conducted September 1-30, 1989 (Report 50-382/89-26)
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Areas Inspected:
Routine, unannounced inspection of plant status, onsite
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followup of. events, monthly maintenance observation, monthly surveillance
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., observation, operational safety verification, followup of previously identified
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ctitems, licensee event report followup, and engineered safety feature system
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Results:
Two violations were identified.
One violation (paragraph 9.a)
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involve 8 failure of the licensee to implemont a five minute stabilization
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period prior to taking data during Inservice Testing (IST) of safety-related
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pumps.
While the specific issue of failing to itnplement the requirement had
minimal safety significance, this was another example of inadequate
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implementation of the IST program required by the Technical Specifications and
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ASME Code Section XI.
Sae Inspection Reports 50-382/89-01 and -89-09.
The
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secondviolationwasalicensee'(paragraph 6)identifiedfailureto'f$110w
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procedures resulting.in a "near miss" for a potential loss of shut down
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Due to the-licensea's prompt identification.of the problem and
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appropriate corrective action,'a Notice of Violation was not cited as allowed
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py the NRC' enforcement policy.'
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During the engineered' safety feature system walkdown-(paragraph 9), three-
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. deficiencies found will require:further evaluation as.to whether NRC,
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regulations were'followed.
These,are being. tracked as an Unresolved Item.
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DETAILS
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Persons Contact'ed
Principal Licensee Employees
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- J..R. McGaha, Plant Manager, Nuclear
P. V. Prasankumar, Assistant Plant Manager, Technical Support
0, F. Packer, Assistant Plant Manager, Operations and Maintenance
- A. S. Lockhart, Quality Assurance Manager
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D. E. Baker, Manager of Nuclear. Operations Support and Assessments
R. G.'Azzarello, Manager of Nuclear. Operations Engineering
W.' T. Labonte, Radiation Protection Superintendent
G.' M. Davis, Manager of Events Analysis Reporting & Responses
- L. W. Laughlin, Onsite Licensing Coordinator
T. R. Leonard, Maintenance Superintendent
- R. F. Burski, Manager of Nuclear Safety and Regulatory Affairs
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R. S.:Starkey, Operations Superintendent
- Present at exit interview.
Also present was Mr. J. M. Sharkey,
Regional Coordinator for NRC Region IV.
In addition to the above personnel, the inspectors held discussions with
various operations, engineering, technical support, maintenance, and
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administrative members of the licensee's staff.
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2.
Plant Status (71707)
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The plant operated at full power until the unit was shutdown on
September 22, 1989, for the third refueling outage.< As of the end of this
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inspection period, the plant was shut down, cooled and depressurized to
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ambient conditions, and drained to mid loop to facilitate entry into the
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primary side of the steam generators for eddy current testing.
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Onsite Followup of Events (93702)
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' Failure of Main Steam Isolation Valve (MSIV) MS-124B
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On September 27, 1989, while inspecting MS-124B internals with a
boroscope, the licensee noted what appeared to be a crack in the
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valve stem where it attaches to the valve gate.
The purpose of the
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inspection was to ensure the valve internals were intact after the
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past fuel cycle because of valve guide rail failures found in
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MS-124 A & B during the past refueling outage.
For details, refer to
Inspection Reports 50-382/88-08 and -13.
The licansee attempted to
open the valve, but the stem separated from the gate assembly
indicating that it may have already been broken.
The licensee
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initiated actions to disassemble the valve and determine the cause of
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the failure.
The licensee's initial evaluation concluded the failure
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would not have prevented the valve from performing its intended
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safety' function of closing.
The MSIVs at Waterford-3 were
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manufactured by W-K M Valve Division of ACF Industries.
They are
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40x30x40 Class 600 hydraulically opened, nitrogen pressure closed,
Model D-2, " Pow-R-Seal" gate valves.
The inspectors will continue to
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follow the licensee's actions during the next inspection period.
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No violations or deviations were. identified.
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Monthly Maintenance Observation (62703)
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The station maintenance activities affecting safety-related systems and
components below listed were observed and documentation reviewed to
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ascertain that the activities were conducted in accordance with approved
procedures,~ Technical Specifications, and appropriate industry codes > or
standards.
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a.
Work Authorization 01042344.
On September 8 and 9, 1989, the
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inspectors observed portions of the installation of a new cylinder
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block on Coolant ~ Charging Pump B.
The mechanics appeared to be
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applying good work practices and were signing off the applicable
portions of the work authorization as the work progressed.
A delay.
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was experienced because the cylinder block studs were not easily
removed.
The work package was amended to provide for removal of an
interfering pipe which prevented sliding the block off the studs so
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they wouldn't have to be forced out.
The inspectors noted that as
many times as the licensee has performed major corrective maintenance
on charging pumps, the work instruction was still not well sequenced,
thus the mechanics had to skip steps and then return to them later to
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accomplish the work correctly.
This was discussed with licensee
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management with comments that there should'have been a well developed
procedure for dismantling and performing maintenance on the charging
pumps.
The licensee acknowledged the comments,
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Work Authorization 0104173.
The inspector observed portions of the
routine maintenance performed on the A emergency feedwater pump motor
on September 11, 1989.
Work was performed in accordance with
Procedure ME-04-371, Revision 4, " Emergency Feedwater Pump Motor."
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No problems were identified.
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Work Authorization 01043988.
On September 19, 1989, the inspector
observed portions of the staking of the outboard bearing thrust
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collar on Component Cooling Water Pump 8.
During work activities,
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the maintenance technicians identified that the work authorization
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did not include steps to disassemble the bearing as required or
replace the sealant between the casing halves during reassembly.
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instructions were then added to the work authorization and the work
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was completed.
This was a positive indication of maintenance
technicians being more sensitive to procedural requirements.
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Work Authorization 01046364.
On September 23 and 30, 1989, QJ
inspector observed portions of the disassemb?y of MS-124B which was
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the MSIV discussed in Paragraph 3.a above.
The inspector noted that
the valve manufacturer's representative was at the work site, good
work practices were being used, and the work instructions appeared
adequate up to the point of removing the valve gate, since there was
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no stem t.o lift from.
The step covering gate removal appeared
ambiguous, however, licensee management at the job site indicated it
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would be necessary to determine the best method with vendor
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assistance after the v31ve was disassembled.
The inspectors will
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continue to closely monitor licensee activity in this area during the
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next inspection period.
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No violations or deviations were identified.
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Monthly Surveillance Observation (61726)
The inspectors observed the surveillance testing of safety-related systems
and componcats listed below to verify that the activities were being
performed in accordance with the' Technical Specifications.
The applicable
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procedures were reviewed for adequacy, test instrumentation was verified
to be in calibration, and test data was reviewed for accuracy and
completeness.
The inspectors ascertained that any deficiencies identified
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were properly reviewed and resolved.
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Procedure OP-903-003, Revision 7. " Charging Pump Operability Check."
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On September 9 and 10, 1989, the inspectors observed portions of the
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retest of Coolant Charging Pump B subsequent to replacement of the
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cylinder block.
This inservice test (IST) established new reference
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data for the periodic IST in accordance with the Technical
Specifications and ASME Code Section XI.
The inspectors reviewed the
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completed data form and noted satisfactory results.
No problems were
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identified.
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Procedure GP-903-046, Revision 7. " Emergency Feed Pump Operability
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Check." On September 11, 1989, the inspector observed part of the
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post maintenance testing of Emergency Feedwater Pump A.
After the
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pump was started and the operator attempted to read and record
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recirculation flow, it was noted tht,t the flow gauge (PPIS-TW8320AS)
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was reading in excess of the gauge range of 50 gpm, but not hard
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against the peg.
The operator aborted tne test because he could not
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obtain meaningful data.
This problem was identified on March 27,
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1989, in Inspection Report 50-382/89-08, at which time a condition.
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identification was initiated by the licensee.
The disposition of the
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condition identification was to replace the gauge with one that has
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an adequate range.
The licensee has been waiting for material to
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arrive so that the gauge can be changed.
In the meantime, after
aborting the test on September 11, 1989, the licensee implemented a
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temporary chan2e (called a " deviation") to use a test gauge of the
appropriate range and accuracy.
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No violations or deviations.were identified,
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Operational' Safety Verification (71707)
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The objectives of this inspection'were to ensure that this facility was
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being operated safely and in conformance with. regulatory requirements, to
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ensure that the licensee's management controls were effectively
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discharging the licensee's responsibilities for continued safe operation,
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to assure that selected activities of the licensee's radiological
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protection programs are implemented in conformance with plant policies and
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procedures and in compliance with regulatory requirements, and to inspect
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the licensee's compliance with the approved physical security plan.
The inspectors conducted control room observations, plant inspection
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tours, and reviewed Ings and licensee documentation of equipment prablems,
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Through in-plant observations and attendance of the licensee's
plan-of-the day meetings, the inspectors maintained cognizance over plant
status and Technical Specification action statements in effect,
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The inspectors observed operator actions as the plant was being partially
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drained in accordance with Operating Procedure 09-001-003, Revision 9
" Reactor Coolant Drain Down." The evolution included obtaining data to
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confirm the acceptability of the r:ew remote Reactor Water Level Indicating
Systems (RWLIS) installed during the last refueling outape and which was
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the subject nf a near loss of shutdown cooling event (see Inspection
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Report 50-382/88-16).
The data was being taken in accordance with Special.
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Test Procedure STP99000076-A, Revision 2. "RWLIS Level Correlation." The
operators exhibited considerable care and attention to the entire drain
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down process.
The plant was drained to about mid-loop without incident.
After achieving mid-loop conditions and stabilizing level and shutdown
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cooling, on September 28, 1989, at 4: 30 p.m., a near miss occurred with
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regard to loss of shutdown cooling becaese of a personnel error on the
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part of an instrument and controls (I&C) technician.
While I&C was
calibrating Saturation Margin Monitor Loop A, the technician erroneously
connected his test equipment to a transmitter which caused a signal to
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isolate the operating shutdown cooling loop by closing Isolation Va've
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S1405B.
This is an auto closure interlock feature (AIF) in the plant to
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prevent overpressurization of the shut down cooling system during a plant
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heatup.
An annunciator alarmed, but the valve did not close because it
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was gagged open because of a previous maintenance problem with the
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' actuator.
There are four valves associated with this feature, two in
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series in each shutdown cooling loop (Valves SI-401 A&B, and 51-405 A&B).
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As a precaution to prevent such an isolation from occurring, the licensee
implemented temporary alterations so that all four valves would be blocked
open while in this mode.
The licensee took appropriate personnel action
with the I&C technician.
The inspectors reviewed the licensee's safety
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evaluation relative to the temporary blocking of the four valves and
verified that no other important safety functions are lost.
The
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inspectors also verified that controls were in effect to ensure the AIF
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would be restored prior to the next plant heatup.
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The licensee also initiated a significant occurrence report which placed
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the incident into their corrective action grogram, and the issue was
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identified on the industry's " Nuclear Net.
Hiilure to connect to the
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correct transmitter required by the work instruction is an apparent
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violation of NRC regulations.
In view of the licensee's prompt attention
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and corrective actions, a Notice of Violation for this violation is not
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being issued because the criteria of Section V.G.1 of the NRC's
Enforcement Policy have been met.
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7.
Followup of Previously Ioentified Items
(92701.92702)
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a.
(Closed) Violation 382/8731-03: For the first example regarding
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problems with cable splice instructions, the inspector verified that
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Procedure ME-004-809, " Low Voltage (600 Volts and Less) Pwer and
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Control Cable / Conductor Teminations and Splices," and
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Drawing LOV-1564-B 288, " Cable and Conduit List Installation Detail "
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have been revised to correct the teminal splicing instruction
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' deficiencies.
In response to the second example of the violation on
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torquing requirements, the licensee has been performing a review to
ensure that vendor torque requirements are included in repetitive
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task work packages.
Each package was reviewed as the task became
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due. This violation is closed.
b.
Followup on employee technical concerns: On April 19, 1989, the
inspectors were infomed by the licensee that one of their
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nonlicensed employees hao filed a Department of Labor complaint
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relative to some personnel matters, and that the employee had also
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expressed some technical concerns over how some of the work was done
at the plant during the second refueling outage. The inspectors
reviewed all of the concerns and the actions taken by the licensee to
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address those concerns. There were three issues which gave rise to
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potential impact on safety-related equipment or systems, and they are
oiscussed below:
(1) Wet Cooling Tower Basin Cracks: The concern was that
contractors painting the basins could not apply the paint
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satisfactorily because of cracks in the basemat (bottom) which
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were seeping water. The licensee produced a memorandum stating
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that engineering had been requested by Nuclear Operations
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Construction to evaluate cracks in the walls. The engineer
stated in the memorandum that in the area of the cooling towers,
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the wall was designed to resist lateral soil pressure and ground
water on the outside and the latera'l water pressure from the
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basin on the inside. He noted that the cracks wete typical of
other hairline cracks in other sections of the cooling tower
area.
He stated that when he first inspected the cracks, they
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were damp, but they dried out after being exposed to the air for
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a day or so. Therefore, he concluded that the surface dampness
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was due to moisture that hati seeped between the paint film and
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the concrete.
He stated that there was no evidence of gmund
water seeping through the wall. The memorandum did not address
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the concerns about cracks in the basemat. The inspectors
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discussed this with the cognizant licensee rvpresentatives.
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They stated that there were no problems with cracks in the
bottom of the basins seeping water to the best of their
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knowledge, and that if there had been, they would have been
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notified to resolve such a problem.
In accordance with Licensee
Condition 2.C.17, the licensee has a basemat cracking
surveillance pmgram. Cracks in the basemat have not been a
problem, and as such. it is unlikely that any significant
cracking problems would be isolated to the basin bottoms, which
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are not monitored due to them being full of water all the time,
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The inspectors determined that licensee action for this concern
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was appropriate.
(2) Planners closing out work authorization packages with measuring
and test equipment (MTE) deficiencies uncorrected: The concern
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was that the licensee was not taking corrective action during
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work package closeout when a flag appeared indicating that the
i%TE used during job performance was found out of calibration.
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Instead, the flag was deleted. The licensee explained that the
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MTE flag was a feature incorporated into the software many
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years ago, and it was not a viable tool because it did not
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adequately provide for work packages that were closed out prior
to discovery of MTE deficiencies.
Removal of this feature from
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the software was not cost effective, so the licensee chose to
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ignore and cancel the flags as they appeared. MTE
accountability has been adequately provided for in other
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licensee programs. The inspectors sampled 4 of 11 work
authorization packages identified as having MTE flags deleted
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and noted that they were not safety related. This issue is
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closed,
(3) Planners cicsing out work packages with no work being done:
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concern was that the licensee was closing out work packages on
valves as if the work had Deen satisfactorily completed when it
was alleged that no work was done. The inspectors sampled 3 of
10 work a'Jihorizations listed as having problems of this nature.
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In each case, the work authorizations had annotations to the
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effect that no work was done, and referenced the work
authorization under which the work was done. The inspectors
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reviewed the referenced work authorizations and found objective
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evidence that showed the work was satisfactorily completed in
each case. Again, none of the work involved safety-related
equipment. The inspector determined that there is no evidence to
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support the concern. This issue .4 closed.
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No violations or deviations were identified.
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Licensee Event Report (LEit) Followup (92700. 92702)
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The following LER was reviewed and closed. The inspectors verified that
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reporting requirements had been met, causes had been identified,
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corrective actions appeared appropriate, generic applicability had been
considered, and that the LER form was conglete. The inspectors confinied
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that unreviewed safety questions and violations of technical
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specifications, license conditions, or other regulatory requirements had
been adequately described.
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(Closed)LER 382/88-032, " Auxiliary Component Cooling Water Valves Not
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Seismically Qualified Due to Inadequate Control of Design Modification."
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The inspector observed that the positioner and regulators on Valves
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ACC-1E6A and ACC-126B have been replaced with seismically qualified
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components. This LER is closed.
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9.
Engineered Safety Feature (ESF) System Walkdown (71710)
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The inspectors conducted a walkdown of the accessible portions of the High
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Pressure Safety Injection (HPSI) System. Trains A and B, to verify system
operability. The licensee's operating procedures and system drawings were
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reviewed and compared with the as-built configuration. Equipment
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condition, valve and breaker positions, housekeeping, labeling, permanent
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instrument indication, and apparent operability of support systems
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essential to activation of the ESF system were all noted as appropriate.
One violation was identified regarding an inadequate procedure for
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implementation of ASME Section XI testing requirements.
Proceoure OP-903-030 Revision 6. " Safety injection Pump Operability
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Verification " did not require conformance with IWP-3500. " Duration of
Tests," of ASME Section XI.
IWP-3500 requires that pumps are run for
5 minutes under conditions as stable as the system permits prior to
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observing and recording data if bearing temperatures are not required to
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be taken.
If bearing temperatures are required to be taken, then data is
not to be recorded until after bearing temperatures stabilize. These
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requirements were not provided in OP-903-030. This problem was discussed
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with the licensee so that the licensee could evaluate the validity of past
testing without these requirements being prescribed. The licensee
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indicated on October 2,1989, that all of the applicable surveillance test
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procedures were revised to include the requirements.
Failure to provide a
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procedure that implemented all of the testing requirements of ASME
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Section XI for testing the HPSI and LPSI pumps is an apparent violation of
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NRC requirements (Violation 382/8926-01).
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The inspectors also identified three issues during this walkdown which
could have affected component or system perfonnance. These were discussed
with licensee management and the licensee is evaluating the effect of
these as-found conditions on system performance,
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A bolt was missing from the cover of the motor casing on motor
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operated Valve $1 121A. The bolt was replaced prior to the end of
the inspection period.
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A tag was'found on a support for the suction line of HPS! Pump A
which identified support HER.SIRR-749 as nonsafety-related.
Scaffolding was installed at Column 9 in the overhead in Safeguards
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Room A which would interfere with the movement with a spring hanger
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installed on safety injection piping. This was promptly corrected by
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the licensee.
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These items which are listed above will be tracked as Unresolved
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Item 382/8926-02 pending Mview of the licensee's evaluation.
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In addition, several minor deficiencies were identified which had no
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apparent effect on system operability. These were discussed with the
licensee for corrective actions. The include the following:
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a.
Procedure OP-903-030 Revision 6 " Safety Injection Pump Operability
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Verification," had the following deficiencies:
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(1) Step 6.1.1 mquired the installation of temporary gauges for
recording pump data. The procedure did not provide a step for
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gauge removal.
(2) Steps 8.2.6, 8.2.16, 8.3.6, and 8.3,16 required operation of the
low pressure safety injection (LPSI) pump suction pressure gauge
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isolation valves, but there were no valve identification numbers
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provided.
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b.
Procedure OP-009-008, Revision 7. " Safety Injection System," had the
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following deficiencies:
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(1)
In Step 6.6.6, the safety injection tank 1B fill / drain valve,
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SI-3078, was incorrectly designated as SI-0378.
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(2) Section 6.5 includes a note to warn personnel in containnent
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prior to venting the safety injection tanks.
Section 6.6 vents
the safety injection tanks but does not include a similar note.
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(3) Steps 4.12.1 and 4.12.2 specify the minimum safety injection
tank pressure for Modes 3 and 4.
These steps should have
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included the safety injection tank uoper pressure limit. The
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inspectors noted that within a few days of the inspection,
Revision 8 of this procedure was issued which did not contain
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the above deficiencies.
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c.
Procedure OP-903-026, Revision 4, " Emergency Core Cooling System
Valve Lineup Verification," required venting of the LPSI pumps by
opening the pump casing vents. These valves had no identification
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numbers and were nut shown on system drawings.
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The following equipment conditions were observed:
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(1) Several caps were missing from vent / drain' tail pieces on both
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7,
4,
trains of the safety injection system.
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- (2) . Slight oil leaks were observed at both bearings on HPSI' Pump B.3.
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- (3) The label on the 4.16 KV breaker for HPSI Pump _A did"not include
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the "A" designation and only identified the breaker as the~"High
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Pressure Safety Injection Pump" breaker.
(4) Lagging was missing from the discharge piping on both HPSI
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Punps A and B.
Lagging was also missing from the "miniflow"
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line for the HPSI Pump B.
Damaged lagging was. observed in.
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Safeguards Room B.
No CI tags were observed.
It was apparent
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that the lagging was removed to perform maintenance and not
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reinstalled.
(5) Several screws were missing from the vent screens on the HPSI
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Pump B motor.
No CI tag was. observed.-
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(6) Vent screenr. were not installed on the bottom of the' motor case
,
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for HPSI Pump A.
No CI tag was observed.
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(7) A large "U" shaped section of electrical conduit was found
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stowed on the floor below Valve SI-129A.
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(8) Several ropes were observed hanging from the overhead in the
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Safeguards Room B.
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(9) The identification tag for Support SIRR-307 had wire ends that
were not properly trimmed creating a personnel safety hazard.
e.
Two Condition Identification Tags (Nos. 1388-AA, March 28, 1986 and
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02235-BB,' April 29, 1989) were found on safety-related equipment even
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though the conditions had been corrected and the tags were
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administrative 1y cleared.
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f.
The basis for Technical Specification (TS) 3/4.1.2, "Boration
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Systems," appeared inconsistent with the TS for minimuu refueling
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water storage pool level.
It stated that "the higher limit of
447,100 gallons is specified to be consistent with
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Specification 3.5.4 in order to uset the ECCS requirements."
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However, the inspector noted that TS 3.1.2 and 3.5.4 now specify
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475,000 gallons.
This inconsistency was referred to licensee
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management for correction.
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g.
The minimum flow stop check valves for the HPSI pumps were not locked
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in the open position.
This was previously identified in Inspection
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Report 50-382/89-01 as an example of a valve that should be locked
open for pump protection.
This was discussed with licensee personnel
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and these valves are now required to be locked open by procedure.
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The licensee also stated that they e ould review other safety systens
to determine if other minimum flow valves should be locked open for
pump protection.
Correction of all of the above deficiencies shall be tracked under
Inspector followup Item 382/8926 03.
10.
Exit Interview
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The inspection scope and findings were summarized on October 4.1989, with
those persons indicated in paragraph 1 above. The licensee acknowledged
the inspectors' findings. The licensee did not identify as proprietary
any of the material provided to or reviewed by the inspectors during this
inspection.
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