ML20046A129

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Insp Rept 50-382/93-19 on 930516-0626. Violations Noted. Major Areas Inspected:Plant Status,Onsite Response to Events,Operational Safety Verification,Engineered Safety Features Walkdown & Maint & Surveillance Observations
ML20046A129
Person / Time
Site: Waterford Entergy icon.png
Issue date: 07/19/1993
From: Stetka T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20046A126 List:
References
50-382-93-19, NUDOCS 9307270004
Download: ML20046A129 (15)


See also: IR 05000382/1993019

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APPENDIX B

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Inspection Report:

50-382/93-19

Optrating License: NPF-38

Licensee:

Entergy Operations, Incorporated

P.O. Box B

Killona, Louisiana 70066

Facility Name: Waterford Steam Electric Station, Unit 3 (Waterford 3)

Inspection At: Taft, Louisiana

Inspection Conducted: May 16 through June 26, 1993

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Inspectors:

E. J. Ford, Senior Resident Inspector

J. L. Dixon-Herrity, Resident Inspector

K. M. Kennedy, Project Engineer

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Accompanying Personnel:

D. M. Garcia, NRC Intern

Approved

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JJhomas F. Stetka, Ejef, Project Section D

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Inspection Summar_y

Areas Inspected:

Routine, unannounced inspection of plant status, onsite-

response to events, operational safety verification, engineered safety

features walkdown, maintenance and surveillance observations, followup on

inspection items, and review of licensee event. reports.

Results:

The operators maintained an appropriate awareness of plant activities

and control board indications. Their response to the reactor trip, and

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the coordination of activities to recover plant equipment and an

emergency diesel generator (EDG) day tank level indication was vary good

(Sections 2.1 and 3.1.6).

However, a violation was identified fer 15e

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failure to adequately implement a plant status control requirement 4 r a

locked valve (Section 3.1.1).

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Appreciable improvement was noted in the area of housekeeping and the

centrol of radiological areas.

Recent painting activities have enhanced

several areas of the plant, including the EDG rooms.

Additional

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management attention to enhance radiological postings and restore ready

access to previously contaminated areas was evident (Section 3.1.3).

However, continued management attention was needed to assure transient

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materials were properly stored (Section 3.1.5).

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The licensee addressed plant activities and emerging issues with an

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appropriate safety awareness. The licensee's safety evaluation for the

increased radioactivity in the component cooling. water (CCW) system was

conservative (Section 2.1).

A heightened awareness of a potential

industrial hazard was noted (Section 3.1.4).

The EDG system engineer

demonstrated an excellent sense of system ownership (Section 3.1.3).

The CCW and auxiliary CCW systems were appropriately aligned to perform

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their safety functions. Several deficiencies were noted which were not

identified in the licensee's corrective action program. Additional

management attention was needed to ensure that plant personnel promptly

identify and document deficient equipment conditions (Section 4).

The maintenance and surveillance programs were appropriately implemented

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(Sections 5 and 6).

Summary of Inspection Findings:

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Violation 382/9319-01 was opened (Section 3.1.1).

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Inspection Followup Item 382/9208-03 was closed (Section 7 1).

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Licensee Event Report 382/92-008 was closed (Section 8.1).

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Licensee Event Report 382/92-010 was closed (Section 8.2).

Licensee Event Report 382/92-011 was closed (Section 8.3).

Licensee Event Report 382/92-012 was closed (Section 8.4).

. Licensee Event Report 382/92-019 was closed (Section 8.5).

Attachments:

Attachment - Persons Contacted and Exit Meeting

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DETAILS

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1 PLANT STATUS

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The plant was operating at full power at the beginning of this inspection

period until June 12, 1993, when power wcs reduced to 92 percent to allow'for

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surveillance testing of the main turbine steam inlet valves. On

June 15, 1993, the reactor tripped due to high level in Steam Generator 1

caused by a feedwater regulating valve failing open. The plant was restored

to full power operation on June 16, 1993, where it remained through the end of

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this inspection period.

2 ONSITE RESPONSE TO EVENTS (93702)

2.1 Reactor Trio Oue to Failure of Feedwater Regulatina Valve

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On June 15, 1993, at approximately 4:04 p.m., the reactor tripped from full

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power due to high water level in Steam Generator 1.

A few seconds after the

trip, an emergency feedwater actuation signal came in, as designed, due to low.

level in Steam Generator 2 as- a result of shrink following the trip. The A-1

6.9 KV bus failed to automatically fast transfer from the unit auxiliary

transformer (supplied by the main generator) to the~ start-up transformer,

causing Reactor Coohnt Pumps IA and 2A, Condensate Pumps A and C, and

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Circulating Water Pumps A and C to trip off line. After implementing

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Emergency Operating Procedure'OP-902-000, Revision 6, " Emergency Entry

Procedure," the operators initiated actions required by Emergency Operating

Procedure OP-902-005,' Revision 8, " Loss of Offsite Power / Station Blackout

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Recovery," minutes after the trip occurred. All other systems functioned.as

required, and the plant stabilized in Mode 3 (hot standby). After the plant

had stabilized and more was known'about what had caused the trip,'they exited

Procedure OP-902-005 and entered General Plant Operating Procedure OP-010-001,

Revision

'5, " General Plant Operations."

The operators had indications of problems with the feedwater regulating valve

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and auxiliary transfe"mer in the control room prior to the trip, but did not

have time to diagnose or react. The steam generator level increased due to

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feed regulating valve, FW-173A, going full open.

Instrument and

controls (I&C) technicians were called to the control room to observe

Valve FW-173A after operators noted that it was oscillating. The technicians

were taking readings from the feedwater cabinet in the control room when they

noted that the valve was going open at a very quick rate. They immediately

informed the control . room operators. The operators checked the steam

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generator levels, verified that they were high, and took the valve to manual,

but not in time to stop the transient.

Electrical maintenance personnel were calibrating the Unit A-1 auxiliary

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transformer -voltmeter, 7KVEM1A, earlier the same day.

After they removed it,

operators noted that the reading on the Unit A-1 bus megawatt-hour meter was

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considerably less than it had been.

The megawatt-hour meter was in the same

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circuit as the voltmeter that had been removed. When the trip occurred, the

technicians were about to inform the control room that the cause of the low

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meter reading was a fuse which had blown in the auto-transfer sync-check .

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circuitry. This prevented the circuit from verifying that the associated

startup transformer and bus were synchronized, thus preventing the bus from

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transferring. The reason that the fuse blew could not be determined, but the

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licensee suspected that it was a combination of age and added stress on the

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fuse due to work that was being done on the voltmeter.

Similar fuses in the

6.9 kV and 4.16 kV bus transfer circuits were replaced and these and the

failed fuse were sent offsite for analysis.

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The licensee determined that probable failure of the feedwater flow square-

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root extractor module and the adjustable feedback limiter module in the

feedwater control system caused Valve FW-173A to open. The apparent failure

of the modules caused the control system to react as if there was a loss of-

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feed flow, causing a large mismatch between feed flow and steam flow.

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caused the control system to demand that the feed regulating valve go full

open. The licensee replaced the two modules and sent them back to their

manufacturer to determine the cause of the failure. The manufacturer

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determined that only the square root extractor module had failed and that the

cause of failure was a failed transistor. They hypothesized a random

component failure due to a lack of prior history of.that transistor failing.

A records review by the licensee identified three possible square root

extractor module failures.

They were evaluating the need for periodic

replacement of square root extractor modules in both the feedwater and steam

bypass control systems. The issue will be resolved.when the resulting

licensee event report (LER 382/93-002) corrective actions are finalized.

2.2 Increase in CCW System Activity

As a result of the reactor trip on June 15, 1993,' activity levels increased in

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the reactor coolant system and, through a leak-in the letdown heat exchanger

(previously noted in NRC Inspection Report 50-382/93-07, Section 3.2), the

CCW system. The licensee performed a safety evaluation to address the

acceptability of low levels of radioactivity in the CCW system (less than

10" microcuries/gm) and low leakage rates in the letdown heat exchanger

(.30 gpm).

The licensee approved this safety evaluation on April 4,1992.

Due to iodine spiking as a result of the trip, CCW activity increased to a

point where the licensee mticipated that the activity might surpass the

10-' microcuries/gm safet: evaluation limit. The licensee performed a second

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safety evaluation screening that expanded the acceptable range for. initial CCW

activity. The conclusion was that the presence of activity in the CCW system

of less than 10 microcuries/gm Dose Equivalent Iodine (DEIni) would have

only a negligible effect on the consequences of any accident, thus, operation

with a CCW system activity of 10 microcuries/gm was considered acceptable

provided the existing 0.30 gpm reactor coolant system to CCW leak rate limit

was not exceeded. The maximum activity for CCW during the event was 8.03 x.

10" microcuries/gm DEI n3

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The licensee established a task force to examine'the different options

available to the site to repair the leak.

The options discussed thus-far

included plant shutdown to repair the heat exchanger before Refuel ~0utage 6

and repairing the leak while operating.

A third safety evaluation was being .

prepared to address the possibility of increased leakage and/or-activity.

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2.3 Conclusions

Operator awareness of plant activities and main control board indications was

appropriate.

This resulted in their promptly observing the feedwater

regulating valve failure and anticipating the reactor trip.

Coordination

between the operation and maintenance organizations to recover plant equipment

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was very good.

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The licensee demonstrated appropriate safety awareness in response to the

increased radioactivity in the CCW system.

The. engineering safety evaluation

was conservative.

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3 OPERATIONAL SAFETY VERIFICATION (71707)

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The objectives of this inspection were to ensure that this facility was being.

operated safely and in conformance with regulatory requirements and to ensure

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that the licensee's management controls were effectively discharging the

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licensee's responsibilities for continued safe operation.

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3.1 Plant Tours

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3.1.1

Locked EDG Air Receiver B2 Outlet 1 solation Valve

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During a tour of EDG Room B on June 10, 1993, the inspector observed that the

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locking device for EDG B Air Receiver B2 Outlet Isolation Valve EGA-152B was

not threaded through the valve yoke or otherwise attached to prevent-

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repositioning of the valve. The locking device was attached to the valve

handwheel and draped over the valve yoke such that it; appeared to.be-locked.

The valve appeared to the inspector to be in the open position.

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Administrative Procedure OP-100-009, Revision 11, " Control of Valves and

Breakers," required that this valve-be locked in the open position with a lock

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or positive locking device.

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The shift supervisor, after learning of this condition from the inspector,

dispatched an operator to determine the valve position and lock the valve.

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The operator verified that the valve was in the open position and locked the

valve.

A second operator was dispatched to independently verify that the

valve was in the open position and locked.

In addition, the shift supervisor

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dispatched an operator to verify that other EDG starting air va'1ves required

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to be locked by Administrative Procedure OP-100-009 were correctly locked.

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an attempt to determine when the valve was last manipulated, the shift

supervisor identified that, while portions of the starting air system were-

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tagged out on June 9, 1993, Valve EGA-152B was not one of the valves tagged

out.

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Administrative Procedure OP-100-009 required that the position of valves and

breakers listed on the locked valve and breaker list be verified at least

quarterly.

The shift supervisor determined that Valve EGA-152B was verified

to be in the locked open position during a quarterly verification conducted on

May 7, 1993.

The inspector identified the failure to lock Valve EGA-1528 as a violation of

Technical Specification 6.8.1.a. and Administrative Procedure OP-100-009

(VIO 382/9319-01).

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3.1.2 CCW Heat Exchanger Fire D,or

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On June 18, 1993, while touring the reactor auxiliary building, the inspector.

found that Door 41 to CCW Heat Exchanger A could not be fully closed.

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latch on the door appeared to be sticking inside of the lockset. The door was

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posted as a fire door and was required to fully close. The inspector notified

security. The door had been verified as functional on June 17, 1993, in

accordance with Security Procedure PS-015-lll, Revision 4, " Fire Door

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Surveillance"; however, the inspector identified the hardware deficiency prior

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to the next scheduled surveillance.

Condition Identification 286358 was

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generated to assess what additional corrective actions may be needed.

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addition, a fire impairment tag was posted on the door and the door was added

to the hourly fire watch patrol. The licensee's response to this condition

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was appropriate.

3.1.3 General Site lour

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During site tours on June 14 and 15, 1993, the inspector noted many

improvements made in the area of housekeeping around the site.

In addition to

the painting mentioned in previous reports, different areas of the plant have

been upgraded in appearance due to the painting program. The two most notable

were the +15-foot level of the turbine building and the EDG rooms.

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noted that the EDG system engineer was cognizant of a recent industry event

where an EDG was rendered inoparable because of painting activities.

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individual demonstrated a heightened awareness of the activities in the EDG

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rooms and periodically assured himself that the EDGs had not been

inadvertently painted.

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Other programs, like the labeling program, have made good progress. The

changes to the radiation posting practices were noted throughout the site and

were definitely a positive improvement in both housekeeping and safety

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most noted improvement was the condition of the safety injection pump rooms.

These areas had been decontaminated and the hot particle protection barrier

removed from around the low pressure safety injection pumps, allowing the

pumps to be viewed freely.

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3.1.4

Addition of Chenicals' to Wet Cooling Tower

On June 22, 1993, the inspector observed the addition of chemicals by the

licensee to the west wet cooling tower.

The towers were operating at the

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time. The technicians were adding Calgosil, a corrosion prohibitor, directly

into the basin from the second level up.

A large aarrel of the chemical, a

dry powder, was poured into the basin from a plast.: bag. While the chemical

was being added, the inspector noted a plastic cup floating on the surface of

the basin. The cup.had sunk when the inspector went a level lower to check

after the addition of the chemical. The inspector discussed the addition of

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chemicals and the cup with the shift supervisor. The technicians had already

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reported the cup. The shift supervisor spoke with systems engineering to see

if it would cause a problem in the system.

The system engineer cited a

licensee probabilistic risk assessment report that was done on the impact of

debris in the west cooling tower basin on December 8, 1992, and stated it

would not be a problem.

The inspector questioned the practice of adding the chemical from the second

level up from the basin's edge. Although most of the chemical went into the

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basin, a small amount was blown out. The chemistry supervisor explained that

this was the accepted practice when the tower was operating during_the summer

because the draft caused by the falling water caused the chemicals to blow

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back into the technicians faces. During the rest of the year, chemicals were

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added at the next level down at the basin's edge. Neither practice was

considered desirable,

in the first instance, not all of the chemical made it.

into the basin, depending on the wind or drafts.

In the second,_the

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technicians had to lean out over the guardrail or get on the edge of the-basin

to pour in the chemical.

In both practices, the large barrel containing the

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chemical had to be lowered down several stairways to get to the basin.

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inspectors have identified previous similar concerns with adding chemicals to

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the wet tower basins to the licensee. The licensee subsequently identified

that the chemistry department had initiated a design change request to install

a chute above the basins to allow easy addition of chemicals without

endangering personnel.

3.1.5 Tour of Cooling Towers

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On June 22, 1993, while touring the east cooling tower, the inspector noted

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that a raincoat had been draped over a pipe next to the basin edge, and a

large cover from the control room breathing air compressor was leaning on the

breathing air tanks.

The raincoat had been noted on an earlier date, but was secured around the

pipe at the time so that it would not be inadvertently blown into the basin.

The shift supervisor had it removed from the area immediately.

The shift

supervisor also investigated the missing compressor cover.

It was determined

that a condition identification had been written to identify that the cover

hinges were broken. The licensee indicated that the breathing air compressor

was operable without the cover installed.

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3.1.6

Loss of EDG Day Tank A Level Indication

On June 25, 1993, during the night shift, operators noted a slight burnt smell

in the back of the control room.

I&C technicians on duty were notified. They

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identified a burnt card in the Train A balance-of-plant process analog control

cabinet.

In addition, they found that the primary power supply for that

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cabinet had failed and that power to the cabinet was being supplied from the

backup power supply. The card provided level indication for the EDG A day

tank. The operators entered Technical-Specification 3.8.1.1.1 Actions b

and d, declaring EDG A inoperable. The inspector observed from the control

room as the operators reacted and gained control of the situation. The level'

in the day tank was raised until the high level alarm was activated in the

control room to provide a means of monitoring the day tank level.

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Technica' Specification action statement was exited once Surveillance

Procedure OP-903-066, Revision 6, " Electrical Breaker Alignment Check," was

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completed. Condition identifications were written to replace the card and

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troubleshoot the failed primary power supply.

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3.2 Conclusions

Operator performance was generally very good as demonstrated by their

cognizance of plant activities and response to the loss of EDG day tank level

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indication. However, a violation was identified for the failure to lock _ an

EDG starting air valve in accordance with the procedure requirement.

The licensee's housekeeping activities exhibited notable improvement as

reflected in its painting program,'and improved health physics postings and

decontamination practices.

It was noted though, that continued management

attention was needed in this area as indicated by the improper staging of a

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raincoat in an area where it could adversely affect equipment operation.

The licensee's action to initiate a design change for adding chemicals to the

wet cooling tower basins indicated a heightened awareness to reduce potential

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industrial hazards.

4 ENGINEERED SAFETY FEATURE (ESF) SYSTEM WALKDOWN (71710)

During this inspection period, the inspectors performed a detailed procedure

and drawing review and walkdown of the systems below to determine their

overall system condition and operational readiness. Although not ESF systems,

they are essential- support systems to a majority of the ESF systems.

4.1 CCW and Auxiliar_y CCW Systems (ACCW)

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The CCW system is a closed cooling water system serving all reactor

auxiliaries requiring cooling water.

Heat is removed from the system by dry

cooling towers and by the CCW heat exchangers, if required. The ACCW is a

separate system that cools the CCW after the dry cooling towers via the CCW

heat exchangers and then dissipates that heat to the atmosphere through the

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wet cooling towers. The ultimate heat sink consists of 9 of the 15 fans in

the dry cooling tower, the wet cooling tower, and the water stored in the wet

cooling tower basins.

The inspectors reviewed Procedures OP-002-001 and OP-002-003 and the Design

Basis Document, W3-DBD-004, Revision 0, " Component Cooling Water Auxiliary

Component Cooling Water Design Basis Document."

ihe inspectors conducted a physical walkdown of the safety-related portions of

the CCW and ACCW systems. Housekeeping was considered good'in most areas.

The west cooling tower was not as well kept as the east cooling tower due to

the continuing problem with pigeons, 'although the conditions had improved _ from

the observations discussed in NRC Inspection Report 50-382/92-27. The lowest

level of the towers was roped off as a radiological controlled area due to the

radiological contamination in the system.

(Paragraph 2.2 of the report

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provides a discussion for the cause of the system contamination.) The

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inspectors found the area radiological posting to be appropriate as this was

the only portion of the tower easily accessible to the CCW valves and piping.

The rest of the system was located in the reactor auxiliary building, a

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designated radiological controlled area.

Several lights were out in the

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expansion tank room. This room was a locked room on the roof of the reactor .

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auxiliary building. A technician replaced the bulbs as the inspectcrs walked

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down that portion of the system.

A comparison of samples of the physical plant to Flow Diagram G-160,

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" Component Cooling Water System," and the valve lineups from System Operating

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Procedures OP-002-001, Revision 8, " Auxiliary Component Cooling Water," and.

OP-002-003, Revision 9, " Component Cooling Water System," revealed several

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concerns.

The inspector noted a capped valve in the chemical feed portion of the system

that did not have a label and could not be identified on the drawing and two

valves, CC-505 and CC-508, the chemical feed tank inlet and outlet isolation

valves, that were open, but were required to be closed by the normal lineup.

The shift supervisor explained that these had been left open, as specified in

the applicable procedure, f ' lowing the addition of nitrates.

The inspectors also identified 12 or more unlabeled valves in the vicinity of

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the CCW and chilled water expansion tanks.

Some of these -valves were part of-

the CCW expansion tank, while the rest were part of essential chilled water

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system expansion Tank B.

Similar valves on essential chilled water expansion

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Tank AB, next to Tank B, were labeled. The valves were instrument valves and

were not on the drawing. One of these valves was missing its packing gland

nuts.

In addition, the CCW surge tank outlet Header B drain valve, CC-110B,

was badly corroded. These concerns were brought to the attention of the shift

supervisor.

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Condition identifications were written to replace the packing nuts and to

resolve the corroded valve. The inspectors determined that the instrument

valves were not required to be depicted on Drawing G-160. The system

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engineering group developed an action plan to resolve. the concerns with the

. unlabeled valves, which included a field walkdown to identify discrepancies.

between the drawings and field conditions. Condition identifications will be

initiated to resolve discrepancies.

4.2 Conclusions

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The CCW and ACCW systems were properly aligned to perform their safety

function.

Equipment deficiencies were generally identified by condition

identifications. However, it was noted that a number of deficiencies,

including unlabeled instrument valves and a badly corroded' valve had not been.

properly identified. This indicated that additional management attention was

needed to ensure that plant personnel promptly identify deficient equipment

conditions.

5 MONTHLY MAINTENANCE OBSERVATION (62703)

The station maintenance activities affecting safety-related systems and

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components listed below were observed and documentation reviewed to ascertain

that the activities were conducted in accordance with approved work

authorizations (WAs), procedures, Technical Specifications, and appropriate

industry codes or standards.

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5.1 High Pressure Safety Injection Pump (HPSI) Preventive Maintenance

On June 15, 1993, the inspector observed portions of work done by mechanical

maintenance technicians under WAs 01106856 and 01101579. The work consisted

of lubricating the HPSI A pump coupling and replacing the HPSI CCW inlet

header vent valve downstream flange gasket. The technicians were working to

Rework Procedure MM-006-Oll, Revision 5, " General Torquing and Detensioning,"

while reassembling the coupling. The crew supervisor observed the work,

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provided guidance, and assisted as necessary. The work package.was complete

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and all required signatures had been obtained. No concerns were identified.

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5.2 Troubler. hooting of Feed Regulatina Valve 1

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On June 15, 1993, the inspector observed portions of the troubleshooting of

feedwater regulating Valve 1 following the plant trip that occurred _ on the

same day.

The package was a basic troubleshooting package that had been

initialed by the shift supervisor, as required by Administrative

Procedure UNT-005-015, Revision 3, " Work Authorization Preparation."

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allowed the technicians to take readings and do tests that would not affect

plant operations to determine what the cause of the failure was before trying

to make repairs.

The technicians, job supervisor, and system engineer were

very knowledgeable of the system. No concerns were identified.

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5.3 Control Room Emergency Filtration Unit B

On June 22, 1993, the inspector observed a portion of the preventive

maintenance done on Control Room Emergency Filtration Unit B.

The unit was

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completely opened up when the inspector arrived at the work site.

The filters

had already been changed out and the technicians were completing some

maintenance on the heater coils. The compartments in the unit were fairly

clean. Much of the dust from the filter change out had been cleaned up.

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There appeared to be no interior or exterior corrosion or deterioration. The

technicians completing the work were knowledgeable of both the equipment and

the procedere (ME-004-401, Revision 7, " Heating and Ventilation Equipment")

they were working to. A confined space permit had been obtained to allow them

to work in the unit. The inspector was present for the final inspection and

while the doors were secured and locks replaced.

No concerns were identified.

5.4 Essential Chiller AB

On June 23, 1993, the inspector observed the filling of Essential Chiller AB

with freon.

The system had lost all of its freon through leaks on the packing

motor terminal and by three valves.

The leaks had been detected and repaired

and the system was being re-filled with freon as directed by WA 01109883. The

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paperwork in this package was complete and the technicians were knowledgeable

on the task they were performing. No concerns were identified.

5.5 Conclusions

The maintenance personnel were cognizant of the WAs instructions and

limitations. The I&C technicians, job supervisor, and system engineer were'

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very knowledgeable of the feedwater regulating valve control system. Other

routine maintenance activities were properly performed utilizing appropriate

procedural controls.

6 BIMONTHLY SURVEILLANCE OBSERVATION (61726)

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The inspectors observed the surveillance testing of safety-related systems and

components listed below to verify that the activities were being performed in

accordance with the licensee's programs and the Technical Specifications.

6.1

Plant Protection System Channel D Functional Test

On June 16, 1993, the inspector observed the high logarithmic power level and

the reactor protection system matrix test portions of the functional test on

Plant Protection System Channel D that was required prior to escalating power

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following the plant trip on June 15. The operators were properly using

Surveillance Procedure OP-903-107, Revision 11, " Plant Protection System

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Channel D Functional Test." The work package, which included WA 01110239, was

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in order. The operators were careful to' ensure that the reactor trip breaker

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phase current lights were energized while going through>the procedure as

required by the most recent procedure change. This procedure change was made

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as a result of a recent event during which an observant operator noted that

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the phase current lights associated with two trip breakers were deenergized,

while the multiple indications listed in the procedure all indicated closed.

The operator challenged the procedure and suspended testing while maintenance

checked the trip breakers.

It was found that one breaker was not completely

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closed due to a loose spring.

Had testing continued, a reactor trip would

have occurred.

In addition to the procedure change, an Operator Experience

Report was written up for this event and was required reading for operators.

No concerns were identified while observing this surveillance.

6.2 Conclusions

The surveillance test was performed in accordance with the procedure

requirements. The operators' performance during the test was very good and

they were fully cognizant of expected indications and potential system

failures.

7 FOLLOWUP (92701)

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7.1

(Closed) Inspection Followup Item 382/9208-03:

Loss of Shutdown Margin

This inspection followup item addressed a licensee identified failure to

maintain shutdown margin requirements following a plant shutdown due to

weaknesses in operator training as well as a weakness in the shutdown margin

determination procedure.

This event was reported to the NRC in Licensee Event

Report 382/92-19.

This licensee event report is closed in Section 8.5.

The

procedure did not require the operators to project changes in shutdown margin

due to Xenon decay.

Because of this, the operators did not anticipate the

effect that Xenon decay would have on shutdown margin following a reactor

shutdown.

The inspector reviewed Surveillance Procedure OP-903-090, Revision 6,

" Shutdown Margin," which added steps to verify that the required shutdown

margin would be maintained during the 24-hour interval of the Technical Specification 3.1.1.2 surveillance requirement.

In addition, the event was

discussed with all operations personnel, reviewed in continuing training for

plant staff personnel, and added to the requalification training curriculum

for reactivity management.

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8 ONSITE REVIEW OF LICENSEE EVENT REPORTS (92700)

8.1

(Closed)

Licensee Event Report 382/92-008P?E

khtESFActuation

due to Plant Protection System

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This event, which occurred on July 26, 1992, resE NEP N [ a failure of

circuitry provided for testing the ESF matrix relays (Channel C). The root

cause determination and corrective action were submitted in a supplemental

report, Licensee Event Report 92-008-01, on January 29, 1993.

wo

A Kepner Tregoe analysis revealed that the problem were related to the matrix

test circuit for Matrix AC. Additional testing and inspections did not

identify the exact component (s) which caused the inadvertent actuation, thus,

the root cause remained indeterminate. Corrective measures specific to the

root cause could not be applied.

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.During Refuel Outage 5, a station modification (Design Change 3371) was

performed on the matrix test circuit. The modification replaced the-matrix

hold push-button with a three-position selector switch, provided test power

channelization, and eliminated the terminal block for.all six matrices.

It'

was expected that the design change would address the problem.

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The inspector reviewed the documentation of the root cause and the design

change and determined that the licensee had taken the necessary corrective

action to close this item.

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event Report 382/92-010: Noncompliance with Boron

8.2 (Closed) Licensee

Dilution Technical Specification

This report addressed the licensee entering Mode 4 during a plant shutdown

while in an operating configuration prohibited by Technical

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Specification 3.1.2.9, " Boron Dilution." The plant had three charging pumps

running in an effort to maximize the removal of cobalt-60 from the reactor-

coolant system to reduce radiation exposure to personnel during the shutdown

ps.'od.

The Technical Specification required that one of.the charging pumps

be secured and the breaker racked out to prevent inadvertent boron dilution in

the reactor coolant system. The root cause for this event was. determined to

be an inadequate step in the procedure, with inadequate attention to detail by-

the operating crew as a contributing cause. The inspector reviewed the

revision of the procedure that was approved by the Plant Operations Review

Committee on November 11, 1992. The revision _added precaution and caution

statements and clearly identified that Technical Specification 3.1.2.9 must be

met before entering Mode 4.

The shift supervisor on duty the day of the event

reviewed Operating Instruction 01-030-000, " Improving.0perator Performance,"

with his shift. All other operations personnel reviewed the event via

required reading. The revision of the procedure.and. training of personnel

were found to be adequate to prevent repetition'of the event and allow closure

of this item.

8.3 (Closed) Licensee Event Report 382/92-011:

Technical Specification

'

Required Sample Obtained Late as a Result of Personnel Error

On September 24, 1992, while in Mode 5 (cold shutdown) the licensee discovered

that a CCW system grab sample required by the Technical Specifications had not

been taken within the required frequency.

The root cause was determined to be personnel error by the contractor

technician. The technician appeared to simply overlook the sample

requirement. A contributing factor was inadequate oversight responsibility

for count room activity by permanent plant staff personnel.

.

Corrective actions included assignment of clear oversight responsibility to

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specific individuals and temporary removal of contract personnel from

Technical Specification related sampling requirements until the existing

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training and qualification requirements for contract personnel were evaluated.

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Procedure NTC-230, Revision 4, " Health Physics Contract Technicians ' Training,"

was revised and became effective April 7, 1993. The revision separated the

current count room _ technician qualification card into two cards; H100-042-04,

" Senior Contractor Count Room Technician Qualification Card" and H100-043-00,

" Junior Contractor Count Room Technician Qualification Card." Personnel

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qualified to the basic level will be somewhat limited in the tasks that they

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may be assigned.

Based on the inspector's review of this documentation, it was determined that

the licensee has implemented appropriate corrective actions to address the

identified event.

8.4 (Closed) License Event Report 92-012: Jumper Error Results in Partial

Engineered Safety Features Component Actuation

On October 2, 1992, during the licensee's fifth refueling outage, while

performing maintenance to replace a relay in the engineered safety features

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actuation systems, an improperly placed electrical jumper caused a limited

number of ESF actuation relays to deenergize, resulting in an invalid-

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actuation. The root cause was determined to be an improperly positioned

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alligator clip, which, while on the correct terminal point, did not establish.

electrical continuity.

The immediate corrective actions for this event were to properly land the-

jumper and restore actuated components to their normal conditions.

Photographs were taken of the temporary jumper installation for review by the

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personnel responsible in the relay replacement work.

The inspector determined

that this review had been completed and that the licensee event report had

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been reviewed with electrical and I&C maintenance personnel during a shop

meeting to prevent recurrence of the event.

8.5 (Closed) Licensee Event Report 382/92-019: Loss of Shutdown Marqin

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This licensee event report addressed a loss of shutdown margin, caused by

,

xenon decay, due to inadequate procedural guidance and the failure of shift

,

operating crews to anticipate changes in xenon concentration and its effect on

shutdown margin. The licensee's corrective actions for this event were

reviewed by the inspector during closecut of Inspection Followup

Item 382/9208-03 and found to be satisfactory (Section 7.1).

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ATTACHMENT'

1 PERSONS CONTACTED

1.1

Licensee Personnel

R. E. Allen, Security and General Support Manager

  • L. W. Laughlin, Licensing Manager

T. R. Leonard, Technical Services Manager

D. E. Marpe, Mechanical Maintenance Superintendent

  • D. F. Packer, General Manager, Plant Operations

R. D. Peters, Electrical Maintenance Superintendent

R. G. Pittman, I&C Maintenance Superintendent

J. A. Ridgel, Radiation Protection Superintendent

  • R. S. Starkey, Operations and Maintenance Manager

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D. W. Vinci, Operations Superintendent

1.2 Other NRC Personnel

T. F. Westerman, Chief, Engineering Section, DRS, Region IV

D. L. Wigginton, Project Manager, NRR

  • Denotes personnel that attended the exit meeting.

In addition to the above

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personnel, the inspectors contacted other personnel during this inspection

period.

2 EXIT MEETING

The inspection scope and findings were summarized on June 30, 1993, 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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