ML19353B023

Insp Rept 50-382/89-39 on 891113-17.No Violations or Deviations Noted.Major Areas Inspected:Instrumentation Calibr Program,Implementation of Mods Designed to Provide Protection from ATWS & Followup on Previous Insp Findings

ML19353B023
Person / Time
Site:	Waterford
Issue date:	12/05/1989
From:	Paulk C, Stetka T, Wagner P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML19353B020	List: ML19353B019 ML19353B023
References
50-382-89-39, NUDOCS 8912110063
Download: ML19353B023 (15)

See also: IR 05000382/1989039

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APPENDIX

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U.S. NUCLEAR REGULATORY-COMMISSION

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REGION IV-

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NRC Inspection Report: 50-382/89-39

.0perating License: NPF-38

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Docket:

50-3821

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1.icensee:. Louisiana Power & Light Company (LP&L)

317'Baronne-Street

New Orleans, Louisiana 70160

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Facility Name: Waterford-SteamElectricStation, Unit 3(W-3)

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- Inspection At: .W-3, Taft, Louisiana

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Inspect 1on Conducted: -November 13-17, 1989

-Inspectors:

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P. CA Wagner, Reactor Inspector, Plant Systems

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Settion, Division of Reactor Safety

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C. JQaulk, Reactor Inspector, Plant Systems

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SectTon, Division of Reactor Safety

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Ap' roved:

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T.' stb'tka, Chief , Plant Systems Section

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Division of Reactor Safety

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Inspection Summary

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Inspection Conducted November 13-17, 1989 (Report 50-382/89-39)

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Areas Inspected:

Routine, unannounced inspection of the instrumentation

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calibration program . followup on previous inspection findings, and the-

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- implementation of rnodifications designed to provide protection from anticipated

transients without scram (ATWS).

8912110063 891205

PDR

ADOCK 05000382

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Results:.Withintheareas-ihsphted,noviolationsordeviation'swere

identified.

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The inspecto'rs were impressed with the technical effort'and cooperation from

licensee personnel in the instrumentation and ATWS modification: areas. When

problems were encountered during the testing of the ATWS-modifications, licensee

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personnel.promptly evaluated the situation and corrected the problems. .This is-

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. considered to be a strength in the engineering area.

The inspectors considered the licensee's self-initiated effort to provide a

detailed and easily auditable record of the basis for instrumentation

calibration scaling factors to be an improvement-that will further strengthen

.the calibration program. Although.some activities had been delayed in'the past,

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the newly implemented tracking and scheduling system should provide better

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control over these activities.

The cooperation received in the equipment qualification followup effort was

.less impressive. While plant , 'sonnel were cognizant of the requirements for

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equipment qualification as delineated in-10 CFR 50.49,,they did not receive

adequate management support to implement more than a marginal-environmental

qualification (EQ) program.' For example, licensee management opted to take a

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less conservative approach to the ongoing issue of; tape splices at W-3, although

recommendations _were made by the plant staff that, if accepted by management,

-would:have been more conservative. As a result, thezlicensee elected to restart ~

the plant with' splices whose qualification was inconclusive.

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There were some delays in receiving documentation to verify _ licensee positions.

These delays appeared to be excessive considering that official plant records

were requested. The problems with document filing and retrieval are considered

a weakness .that affects all plant groups (operations, maintenance, engineering,

etc. ).

An unresolved item related to taped electrical splices is discussed in

paragraph 3.p of the report.

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DETAILS

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Persons Contacted'

Principle Licensee Personnel

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• R. G. Azzarello, Manager of Nuclear Operations Engineering

• P. N. Backes, Programs Engineering Supervisor

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R. P. Barkhurst, Vice President Nuclear Operations

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• W. R. Brian, Systems Engineering' Supervisor

• R. F. Burski,- Manager of Nuclear Safety and Regulatory Affairs

V. Coy, Engineer III, Design Engineering, Electrical

• G. M. Davis, Manager of-Events Analysis Reporting & Responses

-*M. Ferri, Modification Control Manager

• J. E. Howard, Procurement / Programs Engineering Manager

• L. W. Laughlin, Onsite Licensing Coordinator

• A. S.'Lockhart, Ouality Assurance Manager

• D. C. Matheny, I&C Maintenance Assistant Superintendent

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• J. R. McGaha, Plant Manager, Nuclear

• T. Payne,-I&C Design Engineer

• R. W. Prados, Senior Licensing Specialist

• P. V. Prasankumar, Assistant Plant Manager, Technical Support

• M. L. Raines, Lead EO Engineer

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• T. H. Smith, Programs' Engineering Superintendent

• T. M. Yolladay', I&C Design Engineer-

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NRC Personnel

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S. Butler,= Resident Inspector, W-3

• C, Johnson, Reactor Inspector, Region IV

. W. Smith, Senior Resident Inspector, W-3-

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~*T. Stetka, Section Chief, Region'IV

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• Denotes personnel present at the November 17, 1989, exit interview.

The inspectors-contacted and interviewed other licensee operations,

engineering, and maintenance personnel during the course of the

inspection.

2.

Licensee Actions on Violation Corrective Actions

(92702)

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(0 pen) Violation-382/8911-01:

Failure to adequately control facility

design.

The NRC identified two examples where the licensee had failed to

adequately control the facility design. The licensee provided their

corrective actions in a letter dated June 9, 1989. The rear term

corrective actions involved:

(1) the removal of nonsafety-related

electrical loads from a safety-related power supply, and (2) the

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monitoring of instrument air system pressures required for certain safety

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-injsction-(SI)systemvalves operation. The long-term corrective actions

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involve an evaluation of modifications to the instrument air system for

the SI valve operation.

The. inspector verified that the near term actions had been completed.

0)erations Standing Instruction 89-04 was issuedito require monitoring of

t1e instrument air-system pressures and to describe the actions to be

.taken if the pressure decreased below the required values. The inspector

verified that the required pressure for each SI valve was listed on the-

shift supervisor's turnover checklist. This item will remain open pending

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completion'of.the licensee's long-term-corrective action evaluation and

the implementation of any required modifications.

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3.

. Licensee Actions on Previously Identified Inspection Findings (92701)

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-(0 pen)OpenItem 382/8632-08:

File Discrepancies for Conax

ElectricalPenetrationAssemblies(EPAs)

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During the first round Equipment Qualification (EQ) inspection, the

review of file EEQD 15.1 for Conax Model 7320, 10000 series

electrical penetrations identified three concerns.

First, an

analysis of main steam line break (MSLB) peak temperature was based

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on a Conax report that was not available for review. The report has

since been added to the file and supports the peak temperature

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analysis for MSLB conditions. The second and third parts of this

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open item are closely related, both dealing with the functional

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performance of Kulka terminal blocks used inside containment for core

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exit thermocouple. circuits.

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During this_-inspection, the licensee provided a response to IEB 84-47

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stating that the maximum core exittthermocouple temperature error

would be less than 2300 F and that this value was sufficient for.the

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application. The inspectors expressed a concern that the 300'F

appeared to be excessive and stated that an improved analysis based

on actual test data could reduce tne error level. The. licensee.

acknowledged the inspectors' concern and will reanalize the effect of

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this error on system operation. This item will remain open pending

. completion of the licensee's reanalysis,

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(0 pen)OpenItem382/8632-09: Damaged Conax EPA

During the first round EQ inspection plant walkdown, the NRC

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inspection team observed that the outside containment end of Conax

Penetrations CB-EPEN 316-117 and CB-EPEN 316-142 had the polysulfone

ends on the modules cracked with pieces of some ends missing and/or

damaged. The licensee indicated that an engineering analysis of the

problem had been performed, but no report was available during that

inspection.

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The licensee has updated'the file to include the information from a-

telephone-call with Conax that was conducted on March 9, 1984.- Conax

indicated that the cracked seals do not affect the electrical. .

integrity or pressure boundary integrity of the penetration and that

the cracking is a normal occurrence of plastic and does not require

any corrective action. 'The licensee could not provide'information to

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demonstrate:'that the polysulfone seal is not required as a pressure

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boundary for the penetration. The licensee will review this-item and

provide information to support use of the EPA as a pressure boundary. .

This item remains open pending NRC review of this information.

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(Closed) Open Item 382/8632-11: Potential Submergence of Rosemount'

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. Resistance-Temperature Detectors (RTDs)

Examination of E0 file EE0D 39.3 during the first round E0 inspection-

identified a problem with submergence qualification of Rosemount

Model 104-1619-6 RTDs. The file indicated that submergence

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qualification was required, but documentation to support submergence

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qualification was not in the file. The licensee's followup activity.

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determined that none of these-RTDs would actually become submerged in

an accident. -The licensee provided a list of the subject RTDs and

their locations. All of the RTDs that are located inside containment-

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are at elevation +14 ft. (flood level is -0.8 ft.).

Other,RTDs,

outside containment in the auxiliary building, are not subject to=

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submergence.

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(Closed)OpenItem 382/8632-12:

BIW Coaxial, Cable Performance

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. Calculations

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Review of: file EEOD 6.6 during the first round E0 inspection for BIW

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coaxial: cable _-identified a concern that the cable test voltage and

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current levels were not in the same iange as that required during

plant operation.

In addition, no documentation was provided to

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justify this difference in terms of functional performance of the

cable. The cable is used for two applications at'W-3.

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Theffirst application is the high voltage supply line to the General-

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Atomics high range radiation monitor.

For this application, the

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licensee contacted General Atomics to find out the requirements for

cable insulation resistance, General Atomics indicated that the BIW

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. cable insulation resistance (IR) was sufficient for the high voltage

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cable application as confirmed by the results of past, Sandia National

Laboratories tests.

The second application at W-3 is for the cables in the Regulatory

Guide (RG) 1.97 neutron monitoring channels outside containment.

These cables run from'the preamplifiers in the field to the control

room. Because these cables are located outside containment, the

voltage / current differences between the test parameters and the plant

application are considered to be insignificant.

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(Closed)OpenItem 382/8632-13: Okonite 600v Cable Documentation.

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Review of file-EEQD 6.1 during the first round EQ; inspection

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identified three- problems with Okonite 600V cable;

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The first problem involved a thermal lag analysis included in the

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file that took credit for a cable jacket being present. The file did

not include any information to indicate that-the jacket would be

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intact after aging since the referenced testing used only unjacketed

cables. .As corrective action, the licensee made reference to

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EEQD 6.8., the file for Samuel Moore cable, which uses the same

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Ljacketing material as the'0konite cable. .A thermal aging analysis

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indicated the. Samuel Moore-jacket had been aged to an equivalent of;

73 years at plant ambient conditions prior to LOCA testing.

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In the second problem, the documentation for cable submergence was

not. adequately referenced in the qualification file. The revised

file was reviewed and found to contain appropriate documentation and

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references to. resolve this. item.

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In the third problem, a referenced Patel document to' support cable

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temperature rise as the result of the to self-heating was not included

in the file. Sections'of this Patel report;have since been added to

the file. Although the Patel report was. written for Okonite splices,

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.it is considered acceptable for cable because of a 30'F margin-between

the o)erating: temperature of the cable (including temperature rise)

and tie qualification temperature,

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(Closed)OpenItem 382/8632-15: 4ITT Barton Seal Requirements

Review of' file EEQD 8.2A-during 'the first'round_EQ inspection

identified a concern with replacement schedules for silicone seal

plugs.used for' conduit seals to-ITT Barton Model 763/764

transmitters. The licensee indicated that the Barton transmitters

have an in.tegral seal and require no further conduit seais. Since-

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this is reflected in-the file and is correct according to the test

reports, this issue is considered closed.

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(Closed)OpenItem 382/8632-16: Walkdown Deficiencies on

Seimens-Allis High Pressure Safety Injection (HPSI) Motors

-During the plant walkdown portion of the first m und EQ inspection,

HPSI Motors SI-EMTR-3B-3A and SI-EMTR-3AB-3A w m inspected. The

walkdown identified discrepancies including tne 3B motor not having

the forward bearing oil reservoir fill hole plugged and missing-

screws on-the ventilation _ covers. The 3AB motor was missing some

ventilation cover mounting screws and had loose ventilation covers.

These items were considered to be more of a maintenance issue than an

EQ issue and were corrected as documented in an I.P&L interoffice

menorandum dated February 5,1987.

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During this inspection, the 3AB motor was once again inspected, and

-was found to have screws missing frnm the ventilation covers.

-Additionally, there was an apparent oil leak from the forward motor

bearing. _While it was determined that these conditions do not affect

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<the operability of the motor, they indicate a lack of attention to

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detail.and, in the case of the missing screws, poor maintenance

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• practices. The: licensee issued a Condition Identification Work

Authorization to. correct these discrepancies.

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(Closed) Open Item 382/8632-17: Walkdown Deficiencies on Allis

Chalmers Containment Spray (CS) Motor

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Duringlthe first round E0 inspection, CS Motor CS-EMTR-38-5 was

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inspected during the plant walkdown. Oil leakage was observed, and

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the air > intake filter was missing screws. These conditions were

reported-to be corrected in the licensee's interoffice memorandum of._

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February 5, 1987.

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This motor was reinspected and no discrepancies were noted.

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(Closed) Open Item 382/8632-18:

File-Discrepancy for the' General

Atomics' Radiation Detector

Review of file EEOD 8.3C during.the first round E0 inspection

disclosed a concern with the Rockbestos and BIW cables that supply

the General Atomics radiation detector. The BIW cable was previously

' discussed in paragraph 3.d.

The correct Rockbestos test report was

not included in the file at the time of the original inspection.

Since that inspection, General Atomics has issued a 10 CF_R Part 21

report to the NRC concerning Rockbestos cable performance in high

temperature environments. The licensee prepared an evaluation of the

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Part 21 report considering the thermal lag of the cable and using

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data from the latest Rockbestos test report. The licensee concluded-

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that only at very low ranges would the detector fail;to meet RG 1.97

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requirements. At these low levels, the. licensee stated that RG 1.97

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accuracy is not necessary. This response was considered satisfactory-

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to' address the concern.

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(Closed) Open Item 382/8632-19: V-Type Taped Electrical Splices

To resolve-this ongoing issue at W-3, the licensee obtained

additional test data to support the qualification of the V-type,

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taped electrical splices in power circuits.

The test report, PEI-TR-842900-1, was reviewed by the inspectors and

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found to be acceptable for power circuits, provided the tested

configuration was implemented. The tested configuration was a.V-type

splice that was fabricated as if it were an in-line splice and then

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bent into a "V.

The licensee revised Drawing LOU-1564-B-288,

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Sheet 40, to describe the procedure for fabricating such a splice and

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also added Sheet 39-A-2 to show the splice pictorially. These-

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revisions to the design specification for taped splices are

acceptable to resolve the issue of-V-type taped splices for power

_ circuit applications.

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(Closed) Open Item 382/8632-20: Potentially Damaged Tape Splice

During the fest round EQ inspection, V-type taped splices appeared

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to be in contact with the energized heater, in Motor Operator

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SI-HVAAA-331A. ConditionIdentification.WorkAuthorization(CIWA)

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-No. 031218 was prepared and performed on January 31, 1987. The wires

were inspected under the CIWA, were found not to be damaged, and were

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(Closed)OpenItem 382/8632-21: Qualified Life of Components

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Review of file EEQD 3.1 during the first round EQ inspection

indicated that energized space heaters in Limitorque motor operators-

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had not been considered when developing operator qualified life and

=specifically that components in the limit switch compartment had not-

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been considered. The licensee provided copies of updated EQ

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assessment forms for both inside and outside containment

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applications. These assessments considered the effects of;

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, temperature rise resulting from energized heaters and included the

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components in the 11m_it switch compartment.

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Buna-N gaskets','a_11 m_aterials still have a qualified' life of 40 years.

The Buna-H gaskets are not required for qualification because the

switch' compartment was exposed to the harsh environment during testing.

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These actions are sufficient to-close this open item.

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(Closed) Open Item 382/8632-22: Documentation to Qualify High

' Pressure Safety Injection (HPSI) Motors

During the first round EQ inspection, the licensee,did not have

adequate documentation _in files EEQD 4.12 and 4.13-for the

Seimens-Allis HPSI motors. The licensee incorporated Report

No.:NQ'890339-1, Revision 0, dated June 26, 1981, " Equipment

Qualification for Class.1E Safety-Related Service in Power Generation

Station Outside Containment," into the files. The inspectors

reviewed the document and determined that the requirements for

qualification of the motors have been met.

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(Closed) Open Item 382/8632-23: Unidentified Terminal Blocks in

Conax Electrical Penetration Assemblies (EPAs)

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During the plant walkdown conducted during the first round EQ

inspection a concern with Penetration BC-EPEN316-142 was identified.

Two terminal blocks located near the penetration were unidentified,

but were used as termination points.

No mention of these blocks was

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included in-the EQ file. The licensee provided documentation.to

demonstrate that these terminal blocks do not require EQ since they

are only used for penetration temperature. monitoring.-

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(Closed)Openitem 382/8825-03:. Replacement Program for Expired EQ

Splices

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During the previous inspection,-the inspector'noted that the-

qualificationsfile for Okonite tape splices indicated a 15-year life.

'The inspector requested information' pertaining.to a: replacement,

program for the splicesiand found'that the licensee did.not-have such

a program established for the splices.

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Subsequent to that inspection,.the licensee obtained infornation that

qualified the taped splices for.40 years, thereby eliminating the

need to replace them after 15 years. This information was: reviewed

and found to be acceptable. .

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(Closed)OpenItem 382/8827-03:

Nylon Crimped Chnnectors in Dual

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Voltage Limitorque Operators.

This iteu was downgraded to an open item in NRC Inspection

Report 382/88-27.because of.the NRC's position that the licensee

should not have known of the qualification problems associated with

the crimp connections. After further evaluation, the licensee removed

the nylon connectors during October 1989 and replaced them with another

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type of splicing mechanism.

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While reviewing this item, the licensee initially informed the

inspector that Okonite tape splices were used. Subsequently, the

licensee' informed the inspector that all of the connectors had been

replaced with heat shrinkable tubing (HST) splices and supplied the

inspector with three work authorization (WA) packages to substantiate

' this claim. ; The' inspector requested additional documentation to

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verify that HST had been used for all these applications and made a

request to physically inspect one of the motor operators.

The licensee was-unable to provide the additional documentation or to

arrange for the physical valve inspection by the time of the exit.

'The licensee did-provide the necessary documentation to the senior

resident inspector who forwarded the information to the regional

office. The material was reviewed and found to be acceptable.

During the. followup of this item, the inspector became aware of the

licensee's use of taped splices in instrument circuits inside the

containment. The licensee was informed that the NRC had not

previously accepted the use of taped splices in instrument circuits

in areas subject to a loss of coolant accident /high energy line

break (LOCA/HELB) environment.

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The licensee provided test reports that.they asserted provided

qualification of the splices for use in the subject applications.

The reports were reviewed by the inspectors and judged to be

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inadequate to demonstrate qualifications for taped splices used in-

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instrumentation circuits subject to LOCA/HELB environments.

Prior to the end of this inspection, the licensee provided additica ,

documentation that they considered necessary to substantiate

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qualification of the splices. This information will be reviewed and

. evaluated by the NRC to determine tape splice qualification. The

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issue of taped splices on instrumentation circuits is considered to

be unresolved.

UnresolvedItem(382/8939-01): Determine the EQ of Okonite T95/35

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tape splices used in instrument circuits subject to harsh

environments.

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(Closed)FollowupIten 382/8915-01: Wire Markers Under Heat

Shrinkable Tubing (HST) and Nicks in Kapton Insulation

During the previous inspection, wire markers were noted as apparently

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being under the HST on three wires in Penetration CB-EPEN-316-142.

In' addition, nicks were noted in the Kapton insulation of several

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wires.

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The licensee initiated condition Identification (CI) 263318 to

address the wire markers under the HST. The inspector reviewed the

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CI and determined that the one marker that was actually under the HST

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did not affect the qualification of the splice.

'The licensee also presented information to indicate that the nicks in

the Kapton insulation were only in the Teflon coating and not in the

insulation. The inspector performed a visual inspection:of the

subject wires and concurred with the licensee's determination.

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4.

Instrument Calibration (56700)

The purpose of this portion of the inspection was to ascertain whether the

licensee had. developed and implemented an instrumentation calibration

program in conformance with regulatory requirements, commitments, and

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industry standards. The inspector reviewed the testing requirements

containedintheTechnicalSpecification(TS),.selectedimplementing

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procedures, and selected test records. Since the plant was in the process

of restarting following.the refueling. outage, all of the required

instrument calibratinn work had been completed prior to the inspection;-

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therefore, no work in progress was witnessed.

The inspector reviewed the procedures to verify that they had been

properly. reviewed and approved as required by TS, that the measuring and

test equipment utilized for the calibration of installed instruments were

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in calibration, that independent verification was required for critical

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evaluations-(e.g., lifting / landing electrical leads and opening / closing of.

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. valves), and that instructions were provided for actions to be taken if an

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out-of-tolerance condition was noted. The licensee had revised most of

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the reviewed procedures to aimore easily followed and understood format

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-during~the past 18-month period. The inspector found all of-the

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procedures to be acceptable. 'A listing of the procedures that were.

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reviewed is contained in Attachment 1.-

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' During the review of-the steam generator (SG) level instrument calibration

procedure (MI-003-306) and; procedures for other pressure and level

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instruments, the inspector noted that the required pressure inputs to the

trancmitters were included in an instrument data package that was separate

from, but referenced in, the procedure. The inspector reviewed the

instrument data package for the SG level instruments and questioned how-

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the transmitter pressure inputs for various output level indications were

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determined. The inspector then reviewed the instrumentation calculation'

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sheet for the transmitter. This document presented the accuracy and

offset calculations but did not contain the.information'needed to derive

the proper pressure inputs for representation of SG levels. The inspector

discussed this subject with licensee personnel and was informed that a

program was underway to_ upgrade the instrumentation calculation sheets.

The inspector reviewed the instructions for this u) grading effort and some

- of the completed work. The inspector determined t1at this self-initiated

- licensee effort should produce accurate and easily auditable records of

the derivation of the scaling factors being used to calibrate the

- instruments.

The inspector's-specific questions on the appropriateness of the scaling

factors used for the SG leve1' transmitters were answered by reviewing the

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calibration data for those transmitters. The inspector found this

information to contain a good deal more data than normally available in

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scaling factor determinations._ The data included not only height offsets

and fluid density corrections, but also-fluid velocity corrections. The

inspector found this aspect of the instrument calibration program to be

quite good.

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The inspector also reviewed the records for the past 3 years of selected ,

calibrations in order to ensure that the tests had been performed within

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the allotted time period with acceptable results. All records were found

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to be' acceptable, but the inspector noted that the retrieval of these

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records took considerably longer than anticipated. The inspector also

noted that. in the past, some calibration activities had been delayed for

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considerable periods of tine. Since none of the overdue calibration

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periods were contrary to TS requirements and since the newly implemented

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tracking and scheduling system was maintaining better control over these

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activities, the inspector had no further questions in this area.

No violations or deviations were identified.

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Compliance with 10 CFR 50.62 (25020)

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The NRC published 10 CFR 50.62, " Requirements for Reduction' of Risk from

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AnticipatedTransientsWithoutScram(ATWS)Eventsfor. Light-WaterCooled

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Nuclear Power Plants," in June'1984. This regulation provided the

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technical and scheduler requirement to be implemented by the;1icensees to

provide protection from ATWS events. Further guidance was provided in NRC Generic Letter 85-06, "QA Guidance for ATWS Equipment That is not Safety

Related," dated April 16, 1985.JThe LP&L request for partia1 exemption

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from the requirements of 10 CFR 50.62 for W-3'was denied by the NRC-in a

letter dated March 8, 1989. Ascheduleextensiontothethird(ongoing)

refueling outage following: publication of 10 CFR 50.62 was, however,

approved by the NRC. By letter dated September 8,1989, the NRC provided

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a safety. evaluation'of the ATWS protection being implemented during this

refueling outage.

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The three systems being implemented for compliance with 10 CFR 50.62 at

W-3 consist of a diverse reactor trip system (DRTS), a diverse ~ initiation

of a turbine trip (DTT), and a diverse actuation of the emergency

feedwater system (DEFAS). The inspectors reviewed the safety. evaluation

andthelicensee'simplementingDesignChangePackage(DCP)3080. This

DCP contained _ documents and drawings related to the specific design

characteristics of DRTS and DEFAS. The ins)ectors also reviewed the

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installation instructions for the-involved 1ardware contained in Work

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Authorization-(WA) 99000286.- A listing of the more pertinent drawings is

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included in Attachment 1.

'The DRT'S being implemented at W-3 contained two pressurizer pressure

signals if the pressure increased above

transmitters, which provide trip (RTS) setpoint.

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the regular reactor trip system

The transmitter outputs

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were isolated from the RTS by utilizing isoletion relays and-the

instrument output signals were configured in a 2 out of 2 logic < trip. The

output trip signals are sent to the electrical contactors on the output of

each of the control element drive mechanism (CEDM) motor generator sets.'

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Since these motor generator sets provide the CEDM power, opening of the

contactors;would deenergize the CEDM buses, thereby causing a reactor

scram. Since the DRTS components are independent of the RTS, an

independent means of causing a reactor scram is being provided. The

inspectors noted, however, that the system is not safety-related nor

single failure' protected; these provisions ere not required by the

regulation.

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The DTT function was being provided at W-3 by utilizing existing-

equipment. The CEDM busses have undcrvoltage relays, which provide a trip

signal to the main turbine generator trip circuitry.

Since the DRTS

provides a diverse means of deenergizing the CEDM busses and causing the

attached undervoltage relays to trip, the licensee reasoned that a diverse

means of turbine trip was inherently provided. NRC acceptance of this

LP&L position was provided in the September 8, 1989, safety evaluation.

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The DEFAS portion of the ATWS protection was considerably more complicated

than the other two portions. A DEFAS initiation si

low level is sensed in both steam generators (SGs) gnal is produced when a.

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provided:

(1)anormal

emergency feedwater actuation signal'(EFAS) has,not been generated,

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(2)'thepressureineachSGisabovethesetpointthatwouldbeindicative

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of a possible steam line break or steam generator fault, and (3) a DRTS

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signal has been initiated. The DEFAS provides signals to close the motor

driven emergency feedwater (EFW) pumps' circuit breakers, open the steam

inlet valves to start the turbine driven EFW pump, and position the

appropriate.EFW valves. These operations result in a flow of EFW to.the

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.SGs.

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The DEFAS modifications involved the installation of a number of isolation

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relays to provide separation from the safety-related portions of the EFW

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system and the RTS. While this system is also not single failure

protected, the NRC found it to be in accordance with 10 CFR 50.62

requirements.

The inspector witnessed the acceptance testing for the DEFAS portion of

the ATWS modification. The acceptance testing was performed in accordance

with Special Test Procedure (STP).99000286, " Diverse Reactor Trip and EFW

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Actuation System. During this testing, a number of problems occurred:

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minor equipment problems with readouts, incorrect procedure instructions,

one wiring problem, and one design error. The significant problems were

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corrected by rewiring a relay contact arrangement to agree with the

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instructions (the drawing was misleading and caused the problem) and by

installing a spare contact from the DEFAS actuation relay in parallel-with

EFW flow control valves (this. bypassed an overlooked interloc().- The.

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corrective actions were documented in DCP Changes 9 and 10. The inspector

reviewed these documents and found them acceptable. The retest of the

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corrected design problem was performed in accordance with STP-01048977,

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.which the inspector witnessed and found acceptable.

The~ inspector'also evaluated the installed hardware to verify that<the

components had been installed in accordance with the DCP. The inspector

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considered both.the design engineering effort and the installation / testing

' effort lfor the ATHS modifications to be quite good. The modifications

were fairly involved and, with the exception of the few problems discussed

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with the DEFAS testing, the installation and testing proceeded smoothly.

The inspector was informed that the necessary'in-service testing

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procedures would be developed and implemented prior to the time required

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to fulfill the licensee's commitments.

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.InspectorFollowupItem(382/8939-02): Evaluate the in-service procedures

for operating, testing, and calibrating the DRTS, DEFAS, and DTT systems.

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6.

Unresolved Items

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Unresolved items are matters for which more information is necessary for

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the . inspectors to ascertain if the matter is acceptable, a deviation, or a

violation. An unresolved item related to the environmental qualification

of taped electrical splices is identified in paragraph 3.p of this report.

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Exit interview

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The inspectors summarized the scope and findings of the inspection during

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the exit interview on November. 17, 1989, with the personnel identified in

paragraph 1, above. Although some proprietary documents were reviewed by

the inspectors, no proprietary documents were removed from the facility,

.and no proprietary information-is contained in this report.

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ATTACHMENT

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LIST OF PROCEDURES REVIEWED

A

Number

. Revision

Title

.f",

- MI-003-114:

02

Core Exit Thermocouple Channel Calibration

t

MI-003-201'

05-

Plant Protection System Calibration

MI-003-209

05

Resistance Temperature Detector Loop Current Step

Response Time Test.

-

MI-003-306

05

Steam Generator No. 2 Level Loop Check and

Calibration

">

~ MI-003-334

02

Reactor Coolant System Saturation Margin Monitor

Loop Checks and Calibration

'

M1-005-203

06

Calibration of Differential Pressure Instruments

'

MI-005-219

03

Calibration Checks and Verification of

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Thermistors, Thermocouples and RTDs.

1

..MI-013-523

02

Control Element Assembly and Incore Nuclear

Instrumentation Connection and Verification;

OP-901-004

03~

Evacuation of Control Room and Subsequent Plant-

-

Shutdown

,

' 0P-902-005

03

Loss of Offsite Power / Station Blockout Recovery

Procedure

' 0P-903-032

07

Quarterly IST Valve Tests-

LIST OF DRAWINGS REVIEWED

DCP-3080

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PDD B-424

Sheet 2976

DRTS Wiring D'iagram

2977

DRTS Alarms and Computer Inputs

2978

DEFAS-Wiring Diagram, Sheet 1

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~2979

DEFAS Wiring Diagram, Sheet 2

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2980

DEFAS Wiring Diagram, Sheet 3

2981

DEFAS Computer Inputs

.

SG Level Instruments

5817-5668, Revision 1

Calibration Data documentation for SG Level-

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Transmitters, Sheets 1-4 and Appendices A and B

,