ML20055C782

Insp Rept 50-382/90-09 on 900501-31.No Violations or Deviations Noted.One Unresolved Item Noted.Major Areas Inspected:Plant Status,Onsite Followup of Events,Monthly Surveillance Observation & Operational Safety Verification

ML20055C782
Person / Time
Site:	Waterford
Issue date:	06/14/1990
From:	Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20055C779	List: ML20055C778 ML20055C782
References
50-382-90-09, 50-382-90-9, NUDOCS 9006250106
Download: ML20055C782 (16)

See also: IR 05000382/1990009

Text

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, , APPENDIX-

. _U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

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NRC Inspection Report: 50-382/90-09 Operating License: NPF-38

Docket: 50-382

Licensee: Entergy Operations, Inc. (Entergy Operations)

P.O. Box B

K111ona,- Louisiana 70066

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

Inspection At: Taft, Louisiana

Inspection Conducted: May 1-31, 1990

Inspectors: W. F. Smith, Senior Resident Inspector

Project Section A, Division of Reactor Projects

S. D. Butler, Resident Inspector

Project Section A, Division of Reactor Projects

Approved: - '

T. F. Westerman, Chief, Project Section A

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Inspection Summary

Inspection Conducted May 1-31, 1990 (Report 50-382/90-09)

Areas Inspected: Routine, unannounced inspection of plant status, onsite

followup of events, monthly maintenance observation, monthly surveillance

-observation, operational safety verification, followup of previously identified

items licensee event report followup, and engineered safety feature (ESF)

system walkdown.

Results: There were no violations or deviations identified during this

inspection. During the previous 2 months, the inspectors conducted a

comprehensive ESF walkdown and document review pertaining -to the containment

isolation system and found no significant safety problems. A question was

raised, however, as to the conditions under which certain containment isolation

valves were tested to assure compliance with Technical Specification (TS)

closure-time constraints. The licensee's surveillance procedures did not

appear to take into consideration the possible affect of flow on the closing

time for valves that were being tested under no-flow conditions. The licensee

is evaluating this question, and the NRC staff will review the issue further.

This was' presented as an unresolved item.

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While conducting maintenance observations during this inspection period, the '

inspectors noted overall-improvement in maintenance technician performance,

documentation, and assurance of-quality.

As a result of the Xenon-133 contamination of three of the licensee's '

demineralized water tanks (paragraph 3.a), the licensee implemented their root

cause analysis and corrective action programs, as well as their 10 CFR 50.59

safety evaluation process. The inspectors monitored the licensee's performance

throughout the related events and found the licensee's actions to be appropriate

and conservative.

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DETAILS

1. Persons Contacted

Principal Licensee Employees

R. P. Barkhurst, Vice President, Nuclear Operations

• J. R. McGaha, Plant Manager, Nuclear

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

• T. H. Smith, Jr., Plant Engineering Manager

D. F. Packer, Assistant Plant Manager, Operations and Maintenance

• A. S. Lockhart, Quality Assurance Manager

D. E. Baker, Manager of Nuclear Operations Support and Assessments

• J. B. Houghtaling, Operations Technical Manager

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

• T.- D. Brennan, Design Engineering Manager

W. T. Labonte, Radiation Protection Superintendent

• M. S. Ferri, Manager, Modification Control

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

• K. T. Walsh, Event Analysis and Reporting Engineer

L. W. Laughlin, Onsite Licensing Coordinator

• B. R. Loetzerich, Site Licensing Engineer

T. R. Leonard, Maintenance Superintendent

• D. A. Schultz, Assistant Operations Superintendent

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

• W. E. Day, Trending Compliance and Response Supervisor

R. S. Starkey, Operations Superintendent

A. G. Larsen, Assistant Maintenance Superintendent, Electrical

D. T. Dormady, Assistant Maintenance Superintendent, Mechanical

D. C. Matheny Assistant Maintenance Superintendent, Instrumentation-

and Controls

• Present at exit interview.

In addition to the above personnel, the inspectors held discussions with

various operations, engineering, technical support, maintenance, and

administrative members of the licensee's staff.

2. Plant Status (71707)

The plant was operated at full power for the entire inspection period

with two brief exceptions when power was reduced for repairs. On May 8,

1990, power was reduced to about 93 percent to plug leaking tubes in

Feedwater Heater 28. This took slightly more than 1 day. On May 22,

1990, the plant monitoring computer failed. Because this took the core

operating limit system (COLS) out of service, power had to be reduced to

82 percent as required by the TS. The plant computer was restored to

service after repairs within about 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />, but power was held at

82 percent until the next day due to low grid demand.

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The licensee continued to operate at a reduced reactor coolant system

pressure of 2150 psia to help minimize leakage past the seat of a leaking

pressurizer code safety relief valve. The 1mkage rate appeared to be.

stable at less than 0.2 gpm.

3. 0nsite followup of Events (93702)

a. Radioactive Discharge to Waste Pond

• On May 7, 1990, the licensee drained approximately 330 gallons of-

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water from the auxiliary boiler to the low level metal waste pond.

The water was contaminated with Xenon-133 at a level of about 7.3 E-7

microcuries per milliliter. Although TS 3.11.1.1 allowed discharges

to unrestricted areas with liquids containing noble gases at

concentrations.of up to 2 E-4 microcuries per milliliter, this

discharge was unintentional and unmonitored.

The licensee calculated the level of radioactivity in the pond based

on the pond volume and on the concentration of contamination and

volume of the discharge. The result was 8.4 E-10 microcuries per

milliliter, which was below the licensee's lower limit of detection

by a factor of about 100. The licensee informed the resident

inspectors and stated that the discharge would be reported to the NRC

in the semiannual radioactive effluent release report.

The auxiliary boiler water contained Xenon-133 because, with the

review and approval of the licensee's health ph

was obtained from the condensate storage tank (ysics

CST). The group,

contentswaterof

the CST was contaminated with noble gas on or about May 3,1990, as

discussed below. Due to a miscommunication, the discharge from the

auxiliary boiler was not controlled and monitored by health physics

as-intended. The licensee investigated the cause of- the

miscomunication and -is taking appropriate corrective action.

The CST, demineralized water storage tank (DWST), and primary water

storage tank (PWST) all were discovered contaminated with Xenon-133

on May 3, 1990, to concentrations of 9 E-6, 4 E-5, and

7 E-5 microcuries per milliliter, respectively. This was caused

by cross-contaminttion of the nitrogen header from the radioactive

gas decay tanks (GDTs). On May 1, 1990, the operators had added

nitrogen to the GDT, which, by procedure, required failing o)en the

GDT nitrogen supply pressure regulator. This was necessary 3ecause

the-regulator was set at 5 psig and the GDTs are pressurized to at

least 10 psig-in order for the hydrogen / oxygen sampler to function

properly. While the regulator was open, the 60 psi nitrogen supply

header cqualized with the GDTs. A demand was then placed on the

nitrogen header, causing back flow from the GDTs to the nitrogen

header through the open regulator and a leaking check valve. This

contaminated the nitrogen header and, thus, the CST, DWST, and PWST

nitrogen blankets. By the time these tanks were sampled on May 3,

1990, the nitrogen header was no longer contaminated. Due to the

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short half-life of Xenon-133 (about 5 days) and the low activity '.

levels, the contamination will decay off in a few weeks. The check

valve was subsequently repaired, and instructions were provided to

the operators to prevent a recurrence until procedures could be

changed and any other corrective actions determined.

On May 16, 1990, the licensee completed a root cause analysis-using

Kepner-Tregn techniques. The root cause of the contamination was

detennined to be a deficient system design utilizing a single check

valve in conjunction with procedural controls to provide a

contamination barrier. The licensee generated a design change

request to correct this deficiency. Other contributing causes were

_ the check valve failure and no procedural controls to preclude the

_ operators from leaving the failed open pressure regulator for periods

long enough for the GDTs to equalize with the nitrogen header.

On May 21, 1990, the licensee informed the inspectors that it would

soon be necessary to operate the auxiliary component cooling

water (ACCW) system, which is an evaporative cooling tower arrangement

that supplements the dry cooling towers during warm weather. If this

became necessary before the Xenon-133 in the DWST . decayed off, two

problems would arise. The ACCW system evaporation makeup water would

come from the DWST at a rate of as much as 160 gallons per minute.

This would, in turn, contaminate the ACCW system, and the wet cooling

towers would strip the Xenon-133 from the coolant and release it to

the environment. In addition, when the DWST inventory decreased..the

contaminated nitrogen blanket in the DWST would be displaced to the

environment as the DWST was refilled. These are not the normal

monitored release paths described in the FSAR.

The licensee perfonned calculations which indicated that if all

of the Xenon-133 in the DWST water was released at the maximum makeup

rate to the ACCW, the offsite whole body gamma dose would be only

.1.6 E-5 percent of the TS limit for_the quarter. If all of the

Xenon-133 in the DWST nitrogen blanket was released at the maximum

displacement ~ rate (tank refill rate), the offsite whole body gamma

dose would be only 6.0 E-5 percent of the TS limit for the quarter.

The licensee also perfonned a 10 CFR 50.59 safety evaluation and '

-detennined that a TS change would not be required, and an unreviewed

safety question would not arise, by running the ACCW system and

refilling the DWST at the present Xenon-133 contamination levels.

The inspectors reviewed the above documentation and found no safety

problems. ~The licensee minimized operation of the ACCW system to

just those times when it was needed, or anticipated to be needed, but

frequent starts and stops of the pumps were avoided.

The inspectors will continue to monitor licensee controls over the

contaminated water until there is no detectable activity and will

monitor corrective actions to prevent future cross-contamination

between the nitrogen header and the GDT.

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. b. Reactor Operator Random-Tested Positive for Drugs

On May 15, 1990, the licensee informed the inspectors that'a licensed

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reactor operator was random tested and confirmed positive for. drugs.

Pursuant to the licensee's 10 CFR 26 fitness-for-duty program, the

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individual was denied access to the protected area and suspended from

employment for 14 days. He was'placed in the licensee's Employee

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Assistance Program. The inspectors were informed that the operator

was reinstated.

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He will be subjected to the accelerated follow-up testing requirements

" of the licensee's 10 CFR 26 program. The licensee's actions were

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observed by the inspector to be appropriate to the circumstances of

the individual and in compliance with 10 CFR 26,

c. Fault on Startup Transformer B

On Hay 30,,1990, the licensee experienced a fault on Startup

Transformer (SVT) B. The unit was at 100 percent power at the time

of the fault, but no significant transient was experienced since

plant loads were supplied from the unit auxiliary transformers, which

is normal when the unit is on line. The only problems noted during -

the event was the spurious closure of a letdown isolation valve,

CVC-101, and the loss of indication in the control room for two-

radiation monitors required by TS.

The fire protection deluge system for SVT B had been inadvertently

actuated prior'to the fault, and the water-spray was believed to have

caused the failure. The fault burned a 2-inch hole through the

bottom of the oil expansion bowl on top of one of the high voltage

bushings of the SUT. The' inspector was in the vicinity of the

. control room when the fault occurred and observed the licensee's

response to the event. The' licensee ensured that the plant was,

stable, verified the. transformer was isolated,'and complied with the

action requirements for TS 3.8.1.1 since the failure of the

transformer resulted in the loss of one of the two required sources of

offsite power for the plant's Class 1E electrical distribution system.

The-licensee's transformer maintenance group patched the hole in

the oil expansion bowl using an epoxy method typically used for

such repairs. The porcelain busing was not damaged. After several

tests, such as high potential, megge'r, oil samples, and transformer

ratio tests, the SVT was placed back in service within the 72-hour

time constraint of the TS limiting condition for operation.

The licensee determined that, although it was not desirable to spray

down a unit transformer while it was in service, the deluge system

should not have caused the fault. It appeared that the spray nozzles

were directing too much water at the busings on top of the SUT rather

than down'the sides as designed. The licensee is reviewing the

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' signed off. Additional engineering input was contained in the work \ '

, package because, in the course of the work, it was noted that metal'

particles were found in the bottom of the gear box. Engineering had

determined that the metal particles were a result of normal wear of

the gears, but that the gear box would be periodically inspected' to

ensure that there were no other problems developing.

,~ A quality control (QC) inspection was: conducted on the housing before '

final closure and was documented in the package, while preparations. -l

to install the cover and retaining plates were in progress. Fastener

4 torque verification sheets were prepared:and ready for use in that'

the work package required final torque verification by QC when it..was

done. Radiation control measures were observed and were adequate.

Considerable effort had.been expended to-cover adjacent surfaces in. ,

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the area to aid in cleanup and decontamination after the work.was

completed. No problems were identified. 3

b. WA-01057946. On May 22, 1990, the inspector observed work on the

! jacket circulating water pump for- Emergency Diesel Generator (EDG) A.  :

LThe shaft seal on the pump was being re) laced dueLto excessive

leakage. The inspector. verified that tie equipment was properly

removed-from service and tagged, and that maintenance personnel had- ,

received authorization from the shift supervisor to commence work. j

The inspector reviewed the WA to verify that it was properly prepared

and appropriate for the circumstances. The work was discussed with-

the mechanics. involved as it progressed. The inspector noted they

were very knowledgeable of what was required for the. job. During the - ,

work, a problem was identified with the impeller keyway on the pump.  !

shaft. The keyway was worn and did not provide'a proper fit for the

key. The mechanics notified the appropriate engineering personnel

i. and requested an evaluation prior to reassembly of the pump.

l The EDG system engineer determined that the condition of the keyway : y

wds due to normal Wear and that the pump could be returned to service-

until spare parts were obtained. Spare parts were ordered, and-a

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condition identification report was written to install them when

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available. The jacket circulating water pump only sees-intermittent >

service and is not required for EDG operability as-long as the proper -

temperature of the machine is maintained. Since the pump would be ,

l monitored periodically by operators and is covered under the ,

licensee's predictive maintenance program, the inspector had no -

further questions on the work. No other problems were identified,

c. WA 01059090. On May 30, 1990, the inspector observed preventive

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maintenance being performed on control room emergency ventilation 3

L system Train B. Periodic calibration of the heater temperature

control switches and themocouples was being performed using

Procedures MI-005-204, " Calibration of Temperature Instruments,"

and MI-005-219, " Calibration Check and Verificatie of Thermistors, l

Thermocouples and RTDs." The inspector reviewed the work package and

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verified that the work had been properly approved for performance.

Test equipment was verified to be properly calibrated. Lifted lead

sheets and calibration data sheets were reviewed and found to be

complete. The work was discussed with the maintenance personnel

involved and they were very knowledgeable of the work to be done. l

Two of the four. switches were found to be' faulty and had to be ,

replaced. One switch was found to be out of adjustment and would not- I

remain at setpoint when set to the desired value. The other switch

had a broken setpoint potentiometer. The lead technician wrote a . -

condition identification-report so that another work package could be -l

prepared to replace the switches. The two faulty switches were

replaced and calibrated using WA 01059205. No problems were

identified.

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d. WA 01056487. On May 30, 1990, the inspector observed preventive  !

maintenance being performed on control room normal ventilation system

Train B. Inspection, cleaning, and functional testing were being

perfonned using Procedure ME-004-401, " Heating and Ventilation

Equipment." The inspector reviewed the work package and found it

prowrly prepared and approved for work. The inspector discussed the '

wor ( with the personnel involved. No problems were identified.

No violations or deviations were identified.

5. Monthly Surveillance Observation (61726)

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 Technical Specifications. The applicable

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procedures were reviewed

to be in calibration, for b@ data was reviewed for accuracy andquacy, test

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completeness. The inspectors. ascertained that deficiencies identified were

properly reviewed and resolved. ,

a. Procedure PE-005-004, Revision 4, " Control Roca Air Conditioning

System Surveillance." On May 2,1990, the inspector observed the

performance of Sections 8.1, " Pretest Visual Inspection," 8.6,

b " Airflow Capacity and dEPA/HECA D/P Check." and 8.8, "In Place Leak

Test-Adsorbent," of PE-005-004 which was done after the replacement

of charcoal in control ~ room emergency filtration Unit B. The charcoal -

was replaced after required laboratory analysis showed reduced

capability to absorb radioactive iodine. Other sections of the

procedure were previously completed satisfactorily as part of the <

required surveillance testing of the system.

The testing was being done by an independent contractor under the

supervision of the licensee's system engineer responsible for the

control room air conditioning system. The inspector reviewed and

discussed the procedure with the system engineer and observed the >

test setup. The test equipment was verified to be in calibration

and certification of the independent tester was reviewed. Air flow ,

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measurements and leak testing of the charcoal bed was observed and

the calculations required by the procedure were verified-to_ be

Correct.

The inspector noted that the testing " guidelines" for performance;

of the halide leak testing (per ANSI H510-1975) contained in the.

plant procedure limited the upstream concentration'of the halide

U tracer gas to 20 ppm to ensury that the detector. was operating within

its linear response range. ine test data indicated that the upstream

concentration of the tracer gas was as high as 36-37 ppm. When the

system engineer was questioned about this by the inspector, he

contacted the contractor for an explanation. The contractor it dicated

that their detectors had a linear response ranca in concentratians as

high as .50 ppm of tracer gas and that the upstream concentratior, of

the tracer gas only had to be limited to prevent filter break-thcough.

The fact that the filter downstream concentration remained at zera-

throughout the test indicated that filter break-through did not

. occur. The contracter provided supporting documentation of this

~ fact. -The liccnsee consitted to improve the procedure with definiti <e

instructions in lieu of ' guidelines" and to take into consideration

the additional informatiot, provided by the centractor. The inspectors

will review the revised prccedure at a later date under Inspector

FollowupItem(IFI) 382/9005-01. No other problems were identified.

No violations or deviations were identified.

6.1 - Operational Safety Verification (71707)

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

being operated safely and in conformance with regulatory requirements, to

ensure that the licensee's management controls were effectively discharging

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the licensee's responsibilities for continued safe operation, to assure

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that selected activities of the licensee's radiological protection programs

are implemented in conformance with plant policies and procedures and in

, compliance with regulatory requirements, and to inspect the licensee's

compliance with the' approved physical security plan.

The inspectors conducted control room observations and plant inspection

tours and reviewed logs and licensee documentation of equipment problems.

Through in-plant observations and attendance of the licensee's

- plan-of-the-day meetings, the inspectors maintained cognizance over plant

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status and TS action statements in effect.

. The inspectors reviewed the status of fire impairments in the plant.

The licensee has had an extensive effort in place since 1988 to identify

and correct all fire seal deficiencies at Waterford 3. This process has

been documented in LER 382/88-030, dated December 12, 1988, and was last

addressed by the resident inspectors in NRC Inspection Report 50-382/89-38,

dated Gecember 18, 1989,

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Over the past 6 months,'.the licensee has made considerable progress .in

correcting deficiencies' that'could be corrected without extensive'

engineering design _ change effort. As of May 21, 1990, there were a total

- of 93 fire impairments. Of-the 93, 82 were corrected with the program.

About 100 seals were the wrong type, an untested design having fire seals

where radiation seals should have been, or no seal at all. These all

required engineering design action. About 25 seals were oversized and'

thus needed to be tested to determine how much material, if any, must be

removed. . About 70 fire dampers remain in neted of engineering design 1

action. Ten of the impairments involved fire wrap which had to be removed

to gain access to the seals. Thirteen of the impairments involved holes

in walls or floors which require some design effort.

The licensee is currently planning for completion of this project by

July 1, 1991. In the meantime, the licensee is maintaining the fire

watches required by. their fire protection program pursuant to 10 CFR 50,

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Appendix R. The resident inspectors will continue to monitor the

licensee's actions to complete this program.  ;

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No violations or deviations were identified.

7. Followup of Previously Identified-Items (92701,92702) i

(Closed) Violation 382/8813-05: This violation involved a failure to

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identify and correct deficiencies involving equipment marking. The

licensee's corrective action for the violation was previously reviewed

by the inspector and discussed in_ NRC Inspection Report 50-382/90-01. <

' After discussion with the Plant Engineering' Superintendent, it was

determined that walkdowns had been completed by system engineers as

committed in their-response to the Notice of Violation. Identified i

discrepancies were being evaluated for correction and plans formulated

to provide an_ ongoing program of system walkdowns for identification

of problems, including component labeling. This violation is closed. 1

b. (Closed) Open Items 382/8903-04 and 382/8912-01. These open items-

were both related to the problem of overheating of the leads on the

dry cooling tower (DCT) fan motors. The inspector reviewed the ,

licensee's root cause analysis for the problem which concluded that

.the overheating was. caused by inadequate sealing of the leads during 1

installation. Moisture intrusion and corrosion caused increased

4 , resistance and overheating during operation. In'some' cases, the

woven jacket on the insulation provided a moisture . intrusion path,

o In response'to the problem, the licensee took several steps.

Thermography was performed during fast speed fan operation and leads

with higher than normal temperatures were relugged and taped to

correct the problem. Subsequently, all DCT fan motor leads were

retaped, ensuring that the insulation woven jtcket was removed to

prevent moisture intrusion. Maintenance procedures were revised to

routinely inspect the DCT fan motor leads for tvidence of overheating.

The Assistant Maintenance Superintendent, Elec;rical informed the

inspector that he was not aware of any subsequint problems with

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leads overheating on the DCT fan motors. The inspector had no- .

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further. questions on this problem and considered these items closed,

c. (Closed) Violation 382/8906-01. This violation involv'ed three

examples of failure to adhere to procedures. The'first example

was a repeat _ instance where mechanical maintenance-(MM) personnel .

were not in compliance with fastener torquing requirements; prescribed-

- by the licensee's torquing procedure, MM-006-011,'" General Torquing

and Detensioning."' In a supplemental response to the NRC's concerns

about repeated noncompliances in this area, the licensee committed to

~ departmental meetings and training'to elevate maintenance department

personnel awareness: of the torquing program. . In! addition, HM-006-011

was revised to improve the human factors aspects of the procedure,

and a review of all MM procedures was conducted to identify and

correct deficiencies related to the torquing program. The inspectors)

verified the above actions and noted that 41 MM procedures were

identified as having a torque program-related problem. They were in

the process of being revised during this; inspection. As of.May 23,

1990', 7. of the 41 had been revised. 27 were in various stages.of-

revision, I had yet to be corrected, and.6 were deleted.= There is'no

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need to track these actions any further.=

The second example involved the' February 15, 1989, operation.of a-

red danger-tagged valve. This was the second instance in-1 month.

Even though the-individuals were counselled, a letter was issued

1 emphasizilg the'importance of not disturbing red l danger-tagged

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valves, and the subject was discussed at safety meetings.. Another.

such insident occurred on August 23, 1989. LThis became~the subject

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of an enforcement conference held on October 24,:1989. Acuun;

taken, including disciplinary action and' emphasis in general employee

training'as described'in NRC Inspection Report 50-382/90-01, appeared

te solve the~ problem in that no further red danger-tag violations

have been noted.

The third example involved failure to follow an operations

surveillance procedure, resulting in an inadvertent actuation of

a low pressure safety injection pump. The individual was counselled,

and a letter was issued from licensee management to operations ~

personnel emphasizing the importance of a cautious and thorough

appyoach when following procedures. These actions, combined with the

licensee's various incentive programs to achieve excellence in

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procedure compliance, have been effective in reducing such errors in

recent months. This violation is closed.

d. (Closed) Violation 382/8907-02. This violation involved examples

of where the Plant Operations Review Committee (PORC) did not meet in

quorum. Instead, the PORC members were contacted sequentially for

review and approval purposes, as permitted by the licensee's

Administrative Procedure, UNT-1-004, Revision 8, " Plant Operations

Review Committee." The licensee denied the violation on the basis

that they were in compliance with UNT-1-004, and that such a practice l

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was-acceptable. The NRC disagreed, and the licensee changed UNT-1-004

to discontinue the option of sequential reviews. The inspectors

reviewed Revision 12 of UNT-1-004 and verified the actions as having

-been satisfactorily completed. The second item in this violation

involved failure of the PORC to review the details of radioactive

releases that occurred-on April 3 and May 23,1988, >iuring PORC

Meetings88-107 and -112. The licensee responded that they were

discussed during the PORC meetings and that, subsequently, the

required PORC actions were taken during PORC Meeting 89-02 on

January 5, 1989. The inspectors reviewed all of the PORC meeting

minutes above, verified that the radioactive release reports in

question had been reviewed by the PORC and appropriate. actions taken,.

as detailed in the licensee's response of August 21, 1989. This

violation is closed,

e. (Cicsed)InspectorFollowupItem 382/8908-02. During an inspection

conducted in April 1989, the licensee committed to modify the

atmospheric dump valves (MS-116A & B) in accordance with the vendor's

recommendations for prevention of problems experienced at other

plants. Similar valves at other plants were failing to open upon

demand for a number of reasons, not all of which were applicable to

Waterford 3. This modification was to have been completed by the end

of Refueling Outage 3. The inspectors observed the modification in

progress in November 1989 and reviewed the documentation for closed

Design Change 3215. The modified valves were turned over to, and

accepted by, Operations on November 22, 1989, in support of the

startup following refueling. The design change documentation pa6 le

was closed out on January 17, 1990. This item is closed,

f. (Closed) Open Item 382/8908-03. This item was opened to follow

, up on the licensee's corrective action for a problem associated

with the containment recirculation sump outlet valves (SI-602. A & B).

The licensee had previously identified that the air accumulators for

the valve operators for SI-602 A & B were not adequately. sized to

ensure valve operation for a small break loss of coolant' accident, if

instrument air (IA) was not available. The inspector reviewed Design

Change DCP-3195 which installed, as Phase I, tubing from the

accumulators to a 'relatively low radiation area (postaccident) to

allow operators to repressurize the accumulators with nitrogen in the

event IA became unavailable. Phase II of the DCP will evaluate

whether it is necessary to replace the air operators with electric

motor operators or if the Phase I design change is adequate. The

licensee is tracking their long-range plan on their commitment

tracking system. This item is closed.

g.- (Closed) Inspector Followup Item 382/8917-02. During an inspection

in June 1989, the inspectors noted during an emergency diesel

generator surveillance test that cylinder pressures were being

obtained with no procedure. The licensee relied on the apparent

expertise of the individuals performing the test. The licensee

had already recognized the need for such a procedure and committed to

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i publish a procedure by November 30, 1989. The inspectors verified

that MM-003-040, Revision 0, "EN-SPEC 1000 Diesel- Generator Analyzer," ~

was published on November 28, 1989. This item is closed,

h. - (Closed)OpenItem 382/8917-05: The inspector followed up on the

licensee's evaluation of the proper sealing of the DCT fan motor lead

access covers. The licensee determined that the gasket' material under

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the access covers for the DCT fan motor. leads needed replacement. The

1 inspector reviewed the WA used to perform the replacement and observed

the new gaskets during routine tours of the DCT areas. This-item 1s- 1

closed.

1. (Closed)InspectorFollowu'pItem 382/8922-01. This item was initiated

to track the licensee's final resolution of the need to stroke test

the valves that cross-connect ACCW with the emergency feedwater

system, as required by ASME Code Section XI. The concern was that

cycling these valves with the respective systems in service would

degrade the purity of emergency feedwater due to the elevation of the

ACCW basins. The licensee performed an evaluation and, on October 31,

1989, submitted Change 2 to Revision.6 of the licensee's inservice

test (IST) program. They requested NRC approval to test the valves

during each refueling when the associated piping was drained, in lieu

of quarterlyrelief

granted-the as required

pursuantbytothe 10 CFR Code. 'On January)4,1990,

50.55a(g)(6 theis!<RC

(1). This item

closed.

No violations or deviations were identified.

8. Licensee Event Report (LER) Followup (90712)

The following LERs were reviewed and closed. The inspectors verified

that rcoorting requirements had been met, causes had been identified,

correctie actions appeared appropriate, generic applicability had been

considered, and the LER forms were complete. The inspectors confirmed

that unreviewed safety questions and violations of TS, license conditions,

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or other regulatory requirements had been adequately described.

a. (Closed)LEr, 382/90-002, " Reactor Trip Caused by Dropped Control

Element Assemblies."

b. (Closed)LER 382/90-004, " Inadvertent Emergency Feedwater System

Actuation due to Test Circuit Malfunction."

No violations or deviations were identified.

9. Engineered Safety Feature (ESF) System Walkdown (71710)

During the previous reporting period, the inspectors perfonned an indepth

review and walkdown of accessible portions of the containment isolation

system (CIS) (see NRC Inspection Report 50-382/90-07). Deficiencies and

questions were identified to the licensee at the end of the previous

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s inspection report period. The items were discussed with t'ie licensee and

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received further review by the inspectors during this rep 9rting period.

The items that required correction or terther resolution are' listed below:

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a. Surveillance Test Procedure OP-903-03c', Revisior. 7. " Quarterly IST ,

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Valve Tests," listed a maximum stroke tin = cf 10 seconds as the 4

acceptance criterion when stroke timing the steam generator blowdown

containment isolation valves (BD-102A & B and BD-103A & B). This was-

consistent with the value listed in TS Table 3.6-2. However, the

test procedure secured blowdown flow prior to stroke timing the

valves, thus placing the valves in a no-flow condition. A flow

condition would normally exist when an isolation occurs. The

inspector questioned why the valves should not be tested under at

least normal blowdown flow conditions. The acceptance criterion in

the surveillance test procedure did not account for the no-flow

conditions. A similar situation was previously identified by the

licensee on the main feedwater isolation valves, and the no-flow

acceptance criterion was reduced. Current data indicated that the

slowest valve had closed in 4 seconds or less with no flow, so there.

appeared to be plenty of margin to allow for the possible slowing

effects of full flow. The licensee committed to evaluate the issue.

taking into consideration such factors as the basis of the TS limits

and design requirements. This item will require further review

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by the staff to determine whether or not NRC requirements have been

met. This item is considered to be an Unresolved Item 382/9009-02.

b. During procedure and drawing reviews and system walkdowns, the

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inspectors found that certain valves on the component cooling

water (CCW) system did not meet the requirements for valves that

form part of the containment isolation barrier. . Final Safety

Analysis Report Section 6.2.4.1.4.b stated that all manual valves

which serve as containment isolation barriets-shall be under

administrative control and secured in the clased position. Vent and

drain valves inside containment on the CCW supply and return headers

for the containment fan coolers are not. requirad by procedure to

,be locked nor caps. installed (as shown on the s,< stem drawing).

Valves CC-642, -643, -711, and -712 outside the containment are

not required to be locked by 0P-903-031, Revisit n 5, " Containment

Integrity Check."

. Resolution: The licensee contended that a capped vent or drain

valve is not considered part of the containment isolation barrier

and, therefore, is not required to be locked. As a matter of

practice,-they have locked capped vents and drains outside containment

but'not inside containment. They committed to revise their normal

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operation valve lineup for CCW to include a " cap installed" for the

vent and drain valves located inside containment to the improve

administrative controls. They also committed to revise OP-903-031 to

ensure that it requires that capped vents and drains in the CCW

isolation barrier outside containment are locked as well. j

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n c. Surveillance Procedure OP-903-031 did not list Valves MS-1051A and -B1

onthemonthlychecklist(Attachment 10.1),andYalveCAR-2012Bwas

listed on the cold shutdown checklist (Attachment 10.2) when it i

should have been on the monthly checklist. These valves were vent i

and drain valves.

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Resolution: The licensee committed to revise OP-903-031 to include  ;!

CAR-2012B'on the monthly checklist. Valves MS-1051A and -B were not '

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containment isolation ~ valves and, therefore, were not required to be

checked per OP-903-031. They were included on the normal system .,

. valve checklist in OP-005-004, Revision 6 " Main Steam System." j

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d. Operating Procedure OP_-003-016, Revision 4. " Instrument Air."

Attachment 8.2 breaker lineup listed "BKR for IA-908." IA-908 was a

manual valve. The procedure should have read, "...IA-909." At,

Distribution Panel PDP-390-5A, the breaker for power to' IA-909 was-

incorrectly labeled as power to IA-908.

Resolution: The licensee committed to revise OP-003-016 to correct j

the error and to install a correct label plate on the breaker. '

Items b, c, and d will be_followed up by the inspector as IFI 382/9009-03.  !

e. Surveillance Test Procedure OP-903-032 listed the steam generator

blowdown sample line' containment isolation valves as "SSL-8004A & B-

and SSL-8006A & B." Drawing LOV-1564-G-162, Revision 22, Sheet 2 of'

5, identified them with the same numbers. However, TS-Table 3.6-2 ,

identified them as "PSL404A & B and PSL406A & B." .;

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L f. In TS Table 3.6-2, Valve PMU-152 on penetration No. 7-was identified

as PMU-162 and Valve 2CA-E606E on penetration No. 49 should _have been

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L g._ In TS Table 3.6-1, Valve 2SA-V601A/B (SA908) on penetration No. 8 H

was incorrectly designated 2SA-V610A/B, Valve 2HV-V180A (CVR 202)

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on penetration.No. 13 was incorrectly designated 2HV-V1818, and on 1

l penetration No. 12 Valve 2HV-V181B (CVR 102) was incorrectly 3

designated 2HV-B1818. .i

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Resolution for items e, f and g: Discrepancies in TS Tables 3.6-1 and -2

were identified to the licensee's licensing group who was maintaining a

i number of administrative changes pending for their TS. They indicated t

that they would include the changes as part rf the TS upgrade program

currently in progress awaiting the outcome '.,f a pilot program at a plant

of a similar reactor type. The inspector plars no futher followup of

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No violations or deviations were identified. -

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M  :- 10. Exit Interview

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The inspection scope and findings were sumarized on June 6,1990, with

those persons indicated in paragraph I 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

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this inspection.

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