ML20028E738
| ML20028E738 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 01/05/1983 |
| From: | Constable G, Crossman W, Cummins J, Flippo T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20028E733 | List: |
| References | |
| 50-382-83-28, NUDOCS 8301280161 | |
| Download: ML20028E738 (10) | |
See also: IR 05000382/1982028
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APPENDIX
U. S. NUCLEAR REGULATORY COMISSION
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REGION IV
NRC Inspection Report:
50-382/82-28
License: CPPR-103
Docket:
50-382
Licensee: Louisiana Power and Light Company
142 Delaronde Street
New Orleans, Louisiana 70174
Facility: Waterford Steam Electric Station, Unit 3
Inspectica At: Taft, Louisiana
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Inspectiori Conducted: November 1,1982, through November 30, 1982
Inspectors-
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G. L. Tohstable, Senior Resident Inspector
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J. E. Cummins, Resident Inspector
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n/u/ex
T. A. Flippo, Rbsident Inspector
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Yb'Y//JM!w 3
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Approved:
A. C Crossma
Chief ~
Da(e/
Reactor Pr ect Section B
Inspection Summary
Areas Inspected: Routine, announced inspection of: _(1) Independent
Design Review; (2) Management Meeting; (3) Control Room Design Review;
(4) Preoperational Testing; and (5) Instrumentation and Control. This
inspection involved 130 inspector-hours by three NRC inspectors.
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Results: Within the areas inspected, no violations or deviations were
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identified.
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8301280161 830110
PDR ADOCK 05000382
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DETAILS
1.
Persons Contacted
- D. Lester, Plant Manager
L. Arnold, Unit Coordinator Operations Testing
B. Toups, QA Engineering Technician
G. Pittman, QA Engineer
- J. Woods, Plant QC Engineer
T. K. Armington, Lead Startup Engineer
- B. Morgan, QA Engineer
T. Gerrets, QA Manager
- G. Rogers, Site Director
C. Wells, Advisor to Vice President Nuclear Operations
- Present at exit interviews.
In addition to the above personnel, the NRC inspectors . held discussions
with various operations, construction, engineering, technical support,
and administrative members of the licensee's staff.
2.
Plant Status
The Waterford 3 site is presently in the preoperational testing phase.
The licensee completed the RCS and SG hydrostatic tests during October.
Pre core hot functional testing is scheduled to begin in January. The
current, published fuel load date is May 1983. Construction is
indicated as approximately 94% complete.
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3.
Independent Design Review
During this inspection period, NRC inspectors visited Torrey Pines
Technology to review the ongoing independent design review of the
emergency feedwater system. The NRC inspectors reviewed the " Program
Plan," Revision B, dated September 13, 1982, and discussed the review
activities with engineers and managers associated with the independent
review. Persons contacted during this review are listed below:
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Torrey Pines Technology
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L. Johnson
Manager - Projects'
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F. Carpenter
Project Manager
M. Dunlap
Senior Quality Assurance' Engineer-
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A. Schwartz
Engineering Task Leader
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M. Verdugo
Staff Engineer
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A. Chuang
Staff Engineer
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F. Lin
Senior Engineer
M. Gitternan
Senior Technical Coordinator
V. Flanagan'
Staff Engineer
J. Graves
Offsite Field Engineering Supervisor
NRC
G. L. Constable
Senior Resident Inspector - Waterford 3
L. E. Martin
Reactor Inspector - NRC Region IV
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a.
Independence
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The NRC inspector had discussions with the project'managerLfor
the Waterford Unit 3 design review to determine any contractural
obligations between General Atomics (Torrey Pines) and Louisiana
Power and Light Company (LP&L), Ebasco. Services, Inc. (Ebasco),
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or Combustion Engineering, Inc. (C-E). Since .the cancellation
of the St. Rosalie Station for LP&L, there did not appear to-
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be any areas of significant conflict.
The NRC inspector reviewed Project Directive 3, dated September 23,
1982, " Technical Independence," which pertains to signed statements
by all General Atomic employees that are.providing significant
input into the Waterford 3 design review. Twenty-one of the
signed statements and 20 professional resumes were reviewed
to determine if possible conflicts of interest might exist and
the qualification of: involved personnel. All'of the personnel
appeared to be highly qualified and the experience levels ranged
from 10 to 25 years. There were no areas identified that appeared
to be of concern regarding personal conflict of interest.
b.
Training
The I4RC inspector had reviewed the training requirements for the
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Waterford 3 design review and the designated' training records.
The training requirements were adequate and the material. covered
was appropriate.
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c.
Design Procedure Review - Task A
Review of the design procedures utilized in'the Waterford 3
emergency feedwater system is complete. The review'was done
to the requirements of Amendment 44 of the Waterford 3 Preliminary
Safety Analysis Report. No potential findings were identified
in Task A.
d.
Design Procedure Implementation - Task B
This task is in process and approximately 50% complete. ' The
master checklist is complete; however, no individual checklist
has been completed yet. The master checklist was comprehensive
and adequately detailed.
e.
Technical Review - Task C
The NRC inspectors interviewed staff engineers involved in the
following portions of the independent design review:
Emergency Feedwater System Performance
Instrumentation and Controls
Piping
Piping Supports
Cable Raceway Supports
The NRC inspectors concluded that the individuals involved in the
review were highly qualified for the work they were doing.
Early potential findings were discussed in terms of how they were'
identified and how they are to be evaluated. The review system
(Task E) appears to be adequate.
f.
Physical Verification Walkdown - Task D
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The scope of the physical verification does not reflect a complete
evaluation of the system. The sample size of what is looked at
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in depth is limited.
It appears that-the purpose of the overall
review is to ascertain that controls are sufficient to result in
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an adequately designed and installed system; however,-ther
review does not appear to be broad enough to give complete
confidence . hat the system will ultimately operate as intended.
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As an example, only 1 hanger out of 14 is inspected in
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detail to verify that it was constructed as designed. The
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other hangers were looked at to determine if the location and
crientation were correct, but no attempt will be made to
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determine if the other hangers will support their intended '
loads. Also, the scope of the review does not include anchor -
bolts or embed plates to which the hangers are attached to
the plant structure.
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The selection of items reviewed does appear to meet specific
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program and procedt al requirements and should-give a good
understanding of types of problems; however, it is not clearf
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what kind of conclusion can be drawn on the adequacy of the
installed system.
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Conclusion
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Individuals involved in the design review were very impressive
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in their areas of expertise.
It was not. clear if the scope
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of the physical verification walkdownLis appropriate to meet
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the objectives of the overall design review. .This will be
discussed during subsequent meetings on this subject. The.
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final report (Task F) and potential findings-(Task.E) will be
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reviewed when they become available.
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No violations or deviations were identified.
4.
Management Meeting
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A meeti.ng was held with representatives of LP&L on November 23,1982,
to discuss NRC Inspection Report 82-14 which identified significant'
quality assurance (QA) problems at the Waterford 3 facility. : The
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QA problems had been identified in two areas of construction activity.
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NRC management specifically requested that LP&L include in their
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reply to NRC Inspection Report 82-14 what actions they have taken.or-
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will take to assure that similar QA problems do not exist in other-
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areas.
The following individuals attended the meeting:
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NRC Representatives.
J. E. Gagliardo, Director, Division of Resident, Reactor Project
& Engineering Program, RIV
P. Keshishian,. Senior Reactor Construction Engineer
J. W. Craig, Enforcement Specialist'
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J. H. Sniezek, Deputy Director IE
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G. L. Constable, Senior Resident Inspector
J. E. Cummins, Resident Inspector
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T. A. Flippo, Resident Inspector
W. A. Crossman, Chief, Reactor Project Section B
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LP&L Reoresentatives
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G. D. McLendon, Senior Vice President
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L. V. Maurin, Vice President, Nuclear Operations
T. F. Gerrets, QA Manager
G. B. Rogers, Site Director
R. W. Prados, Licensing Engineering Supervisor
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S. A. Alleman, Assistant Plant Manager
C. A. Wells, Advisor to Vice President Nuclear Operations
J. Woods, QC Engineer
L. L. Bass, Project QA Engineer
W. M. Morgan, QA Engineer
B. Toups, QA Engineering Technician
5.
Control Room Design Review
During the course of this inspection period, the NRC inspectors
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reviewed the ongoing human engineering modifications being made
to the control panels. Specific discussions were held between
NRC and LP&L staff regarding the scheduled completion of 'open
humanengineeringdeficiencies(HED's)(0penItem 8228-01).
Completion of the individual commit:nents will be reviewed during
future NRC inspections.
6.
Preoperational Test
NRC Regulatory Guide 1.68, Revision 2, August 1978 states that
approved test procedures for staisfying ' final safety analysis
report (FSAR) testing commitments should be made available to the
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NRC staff approximately 60 days prior to their intended use. On
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November 30, 1932, the Senior Resident Inspector was notified that-
certain startup preoperational test procedures (SP0's) would be late.
The NRC inspector discussed this subject with licensee. personnel
and explained that,the 60 days gave the NRC inspectors adequate time
to review the startup preoperational procedures before the actual.
test is conducted. The NRC inspector infonned the licensee that:
any substantial delays in receiving these procedures could result
in a delay in starting the test or a violation of NRC requirements.
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No violations or deviations were noted.
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7.
Instrumentation and Control
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The licensee, during the past few months, has been reviewing NRC.
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concerns regarding the installation and testing.of various flow and
level instruments in safety-related systems. ~ 0n November 23, 1982,-
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the NRC inspectors met with the site director and selected engineers
from the LP&L and Ebasco organizations, In previous inspections
(see NRC Inspection Reports 82-10 and 82-14) NRC inspectors have
noted that instruments and the associated impulse r' ping were not
being installed in accordance with the instrument manufacturer's
recommendations. The manufacturer recommends the following
installation practices be followed in order to ensure proper
operation and to minimize the possibility of errors:
a.
For liquid flow or pressure measurements, the transmitter
should be mounted beside or below the process connection
taps so that gases will vent into the process line.
b.
For gas flow or pressure measurements, the transmitter should
be mounted beside or above the taps so that liquid will drain
into the process line,
c.
Slope piping between the process connection and the transmitter
at least 1" per foot toward the process connection.
d.
Avoid high points in liquid lines and low points in gas lines.
Ebasco Installation Instruction IC-1, " Instruction for Erection of
Instrumentation Systems," Revision 1, and Drawing LOU 1564-430,
" Instrument Installation Details," do not distinguish between an
installation for the measurement of liquid as opposed to the
measurement of gas. High points are allowed and minimum required
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slope, where slope is required, is 1/4" per foot from these high
points.
Industry standards allow instrument installation contrary to
manufacturer's recommendations on a case-by-case basis; however,
the instruments should still respond as designed. The startup
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testing program should identify whether instrument installations
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operate correctly.
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The purpose of this meeting was for LP&L to discuss their review of
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the instrument installations and to provide comments on the adequacy
of the installations.
LP&L identified 60 flow and level instrument installations that might
be susceptible to installation problems of the type discussed above.
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During their review thus far, they looked at 47 installations. Of
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these,13 had high points ranging from 1.5' to 26'.
In general, LP&L
believes that all of the 13 installations will operate correctly as
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designed for the following reasons:
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a.
All impulse taps come off the horizontal plane. . Air bubbles
are not likely to get into the impulse lines unless the process
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pipe is drained.
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Impulse lines are run in parallel. .If one line gets air-in.it',
they both should over about equal lengths of the lines.-
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Significant air in an impulse line of a nonoperating system
should cause the instrument to drift off zero.
In such a
condition, operators should notice the drift and request that
maintenance evaluate the problem.
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d.
In systems that operate under significant pressure, air ~in the-
impulse lines would be compressed, minimizing any errors.-
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Air that might come out of solution due to a'depressurization is
not significant.
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During the course of the meeting,' the NRC inspector made the following
observations:
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The review did not include differential pressure instrumentsion.thei
various emergency ventilation systems.
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Time response of instruments is based on speed of sound in water.
No one in the meeting could'say whether air in the impulse lines
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would cause a problem with time response.
c.
No guidelines were available to operators to help them determine
when an instrument should have its calibration checked.
d.
System operating procedures had not been reviewed _to determine
if any modes of operation might cause improper instrument
indications,
e.
Startup testing should identify if systems need rework because
of unforseen problems; however, it is'not clear how the systems-
are to be tested.
The NRC inspector observed that there appears to be a strong underlying-
belief on the part of LP&L representatives that air in' liquid instrument
lines is not a significant problem.
In certain cases, it may not be a
problem; however, this appears to be contrary to manufacturers guidance -
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on the subject. ~ During the course of the startup test program, the
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NRC inspectors will continue to monitor testing to verify ~the above
assumptions, the adequacy of instrument installations, and that the
testing program adequately tests instrument systems that have been
installed in a questionable manner. A concern remains that some of
these instrument systems at the Waterford 3 plant may not properly
indicate system parameters under all expected system operating
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conditions.
Thisissueremainsopen(8214-03).'
8.
Exit Interviews
The NRC inspectors met with the licensee representatives (denoted in
paragraph 1) at various times during the course of the inspection.
The scope and findings of the inspection were discussed.
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wic FORM 7es
U.S. NUCLEAR REGULATORY COMMISSION
PRINOPALINSPECTOR(Name est. 4rst Jnammeaw)
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G. L. Constable
INSPECiOR'S REPORT
R,y,E
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Office of Inspection and Enforcement
W. A. Crossman
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G. L. Constable
T. A. Flioco
J. E. Cummins
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