ML20057F035

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Insp Rept 50-382/93-27 on 930808-0918.Noncited Violation Identified.Major Areas Inspected:Plant Status,Onsite Response to Events,Operational Safety Verification,Maint & Surveillance Observations & Employee Concern Program Review
ML20057F035
Person / Time
Site: Waterford 
Issue date: 10/07/1993
From: Stetka T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20057F034 List:
References
50-382-93-27, NUDOCS 9310140036
Download: ML20057F035 (16)


See also: IR 05000382/1993027

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APPENDIX

U.S. NUCLEAR REGULATORY COMMISSION

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REGION IV

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Inspection Report:

50-382/93-27

License:

NPF-38

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Licensee:

Entergy Operations, Inc.

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P.O. Box B

Killona, Louisiana

Facility Name: Waterford Steam Electric Station, Unit 3

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Inspection At:

Taft, Louisiana

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Inspection Conducted:

August 8 through September 18, 1993

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Inspectors:

E. J. Ford, Senior Resident Inspector

J. L. Dixon-Herrity, Resident Inspector

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C. E. Johnson, Reactor Inspector

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Approved:

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Thorhas F. Stetka, Chief, Project Section D

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Inspection Summary

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

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response to events, operational safety verification, maintenance and

surveillance observations, employee concerns program review, followup on

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corrective actions for violations and licensee action on other followup items,

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and review of licensee event reports.

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Results:

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Operations personnel reacted swiftly to the unexpected loss of a

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480V bus. Maintenance and engineering personnel involved in the

diagnosis of the problem were found to be knowledgeable of the

system and its capabilities (Section 2.1).

A lack of lighting was noted in several areas of the plant that were not

often accessed (Section 3.1).

Security officers were properly touring radiation controlled areas

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outside the vital areas in accordance with procedures. Central alarm

station personnel were alert and engaged in appropriate activities.

Barrier effectiveness was questionable at one protected area gate

(Section 3.1).

9310140036 931007

PDR

ADOCK 05000382

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Involvement of the lubrication engineer in preventive maintenance

involving oil samples was a goed practice (Section 4.1).

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Maintenance management and supervision were observrJ to be actively

performing their oversight responsibilities at a job site.

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response by the maintenance organization precluded further unnecessary

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outage time for High Pressure Safety Injection Pump B (Section 4.2).

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A routine surveillance procedure was found to be properly performed in

accordance with procedures; the health physics technician was very

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knowledgeable of impending changes to requirements (Section 5.1).

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The licensee appears to have been proactive in structuring a

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procedurally-driven Employee Concerns Program with a staff,

organizational reporting requirements, and confidentiality. An exit

interview process is in place as is an 800 nationwide telephone line

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(Section 6.1).

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Summary of Inspection Findings:

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Inspection Followup Item 382/9327-01 was opened (Section 2.1).

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Violation 382/9022-02 was closed (Section 7.1).

Violation 382/9223-03 was closed (Section 7.2).

A noncited violation was identified (Section 8.1).

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Unresolved Item 382/9323-01 was closed (Section 8.1).

Licensee Event Report 382/92-17 was closed (Section 9.1).

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Attachments:

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Attachment 1 - Persons Contacted and Exit Meeting

Attachment 2 - Tl 2500/028, Employees Concerns Program Questionnaire

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DETAILS

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1 PLANT STATUS

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The plant operated at full power from the beginning of the inspection period

until August 21, 1993, when power was reduced for routine turbine valve

testing. On August 25, 1993, power was reduced to 99.4 percent due to loss of

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extraction steam to Feedwater Heater 1 as a result of the incorrect actuation

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of a high water level switch. The plant returned to full power and operated

there until the end of the inspection report period.

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2 ONSITE RESPONSE TO EVENTS (93702)

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2.1

Loss of Vital Bus

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On August 31, 1993, 480V Bus 31B inadvertently deenergized while preventive

maintenance was being performed on one of it's circuits. The bus was restored

approximately 10 minutes later. The inspectors observed operations in the

control room to ensure the plant had stabilized following the bus loss, then

monitored the event followup meeting. Maintenance, operations, and

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engineering personnel met to review events which led to the loss of the bus to

determine the cause.

Personnel in attendance were knowledgeable of the

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system.

Circuit drawings and records of previous surveillances were reviewed

to gain additional information.

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The bus loss occurred when an electrical technician lifted a lead on a 74/hr

relay in the primary electrical protection circuit for Control Element Drive

Mechanism Cooling Fan D.

This activity was in accordance with an approved

work authorization which had been authorized by the control room.

Review of

the alarm sequence, the circuit involved, and a work bench mock-up test of the

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relay in the circuit provided information to allow the team to determine the

most probable cause for the failure. The work bench mock-up indicated that

the protective circuit was subjected to sufficient voltage to cause the relay

to trip the feeder breaker to Bus 318. Condition Report 93-133 was written to

document the incident; the inspectors reviewed the initial report and will

review the final report for root cause determination and appropriate

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corrective actions.

This is Inspection Followup Item 382/9327-01.

2.2 Conclusions

Operations personnel "eacted swiftly to the unexpected loss of the 480V bus.

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Maintenance and engineering personnel involved in the diagnosis of the problem

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were found to be knowledgeable of the system and its capabilities,

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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

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

Interior Lighting

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On August 19, 1993, while touring the reactor auxiliary building, the

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inspectors noted a need for relamping several areas including the ion

exchanger gallery and gas decay tank Room B on the -4-foot level of the

building. This was discussed with the electrical maintenance supervisor who

had responsibilities in this area. On a subsequent tour, the inspector noted

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that the problem had been partially remedied in that areas which were not

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posted as high radiation areas were relamped. The remaining areas, which are

seldom accessed, will be addressed when as low as reasonably

achievable (ALARA) conditions allow.

3.1.2 Outside Tours of Radiation Controlled Areas

On September 1, 1993, the inspectors questioned the security manager regarding

whether or not an outside plant area bounded on three sides by buildings and

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on the fourth side by a radiological barrier could be properly observed by

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patrolling security guards.

During the on-the-scene discussion with the

manager, who asserted that entry into the area was required, a guard

approached and was questioned by the inspectors as to whether or not entry was

routinely made into the controlled area. The guard stated that entries were

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made (under the required RWP) at least every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> as required by procedure.

This was affirmed by a subsequent observation.

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3.1 3 Security Observations

On September 9, 1993, the inspectors conducted interviews and discussions with

security force personnel inside the central alarm station regarding their

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duties, responsibilities, and equipment.

The inspectors noted upon entry into

the station that the officers were alert and engaged in required activities.

The inspectors also performed a walkdown of the protected area fence line to

assure the integrity of the fence fabric and to assess the effectiveness of

that barrier to provide delay. During this inspection the inspectors queried

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several security guards and other security personnel at a protected area gate

regarding their duties and the status of equipment. During the conversation,

the inspectors were informed that the gate was awaiting maintenance. The

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inspectors assessed the physical situation at the gate and questioned the

licensee regarding barrier effectiveness.

Inspection of this item will be

further addressed by an NRC security inspector in NRC Inspection

Report 50-382/93-31.

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3.2 Conclusions

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Several of the less travelled areas of the plant were noted to be in need of

rel amping.

Security was properly touring radiation controlled areas outside

the vital areas in accordance with procedures.

Central alarm station

personnel were alert and pursuing their required duties.

Barrier

effectiveness was questionable at one protected area gate.

4 MONTHLY MAINTENANCE OBSERVATION (62703)

The station maintenance activities affecting safety-related systems and

components listed below were observed and documentation reviewed to ascertain

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that the activities were conducted in accordance with approved work

authorizations (WAs), procedures, Technical Specifications, oi.d appropriate

industry codes or standards.

4.1

Preventive Maintenance on Emergency Feedwater Pump B

On September 15, 1993, the inspectors observed a portion of the preve,;tive

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maintenance completed on Emergency Feedwater Pump B.

The maintenanco

technicians changed the lubricating oil in the pump and motor in accardance

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with WA 01111250 and Maintenance Procedure UNT-005-007, Revision 4, " Plant

Lubrication Program." The plant lubrication engineer assisted in the

maintenance and collected samples of the oils for test as required by

WA 01112308. The inspectors noted that the technicians had verified the oil

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type and compared the label on the can to the oil specified in the procedure

to ensure the correct oil was being used. After completing the job, the

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technicians ensured that all spills were cleaned up and that the area was left

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in good condition.

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Several maintenance technicians were working on the room air handling unit in

the overhead at the same time that the job discussed above was taking place.

The inspectors observed that the scaffolding had been surveyed by health

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physics the day before. Health physics surveyed the area again and completed

the measurements necessary for the confined space permit to allow work inside

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the unit while the inspectors were present. During the equipment outage, the

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mechanical maintenance superintendent and the job supervisor checked on the

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status of both jobs.

4.2 in Pressure Safety injection Pump Breaker Maintenance

On September 16, 1993, the inspectors observed as the 74/hr breaker relay for

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Low Pressure Safety Injection Pcmp B was tested and calibrated. The work was

performed in accordance with WA 01112769 and Testing Procedure ME-007-036,

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Revision 5,

"G. E. Auxiliary Relay's 12HFA51A and 12HFA518." The technicians

completing the work were cautious and followed the procedure verbatim.

Independ2nt verification of the wires removed and replaced was found to be

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performed correctly.

The interior of the breaker cubicle was clean and free

of debris or infestation.

All visible wires were labeled.

Both the job

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supervisor and the electrical maintenance superintendent stopped at the job

site and reviewed. work progress.

After observing this task, the inspectors noted that several technicians were

preparing to work on the High Pressure Safety Injection Pump B breaker.

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Train B pumps had been declared inoperable for the performance of preventive

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maintenance. While doing other maintenance earlier that morning,.the

technicians had noted that the upper reset spring in the breaker was not

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attached. This spring was used to reset the breaker following an overload

condition and did not affect breaker operation. They prepared a condition

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identification and WA 01113403 was prepared to allow the job to be done that

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day during the component outage. The job proceeded without incident and in

accordance with procedural requirements. The inspector noted that the

maintenance organization responded swiftly to the discovered problem and

affected repairs in a manner which prevented another outage for the component

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and precluded prolonging the outage in progress.

4.3 Conclusions

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Maintenance was found to be properly performed in accordance with the

procedures. The involvement of the lubrication engineer in collecting oil

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samples and char.ging the oil in rotating equipment was a good practice.

Maintenance management and supervision were observed to be actively performing

their oversight responsibilities at a job site. Swift response by the

maintenance organization precluded further unnecessary outage time for High

Pressure Safety Injection Pump B.

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5 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

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

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5.1 Monthly Test of Self-Contained Breathing Apparatus

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On September 8,1993, the inspectors observed while a health physics

technician performed a monthly inspection on several self-contained breathing

apparatus (SCBA) kits staged outside the control room. The inspection was

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performed in accordance with Technical Procedure HP-002-602, Revision 8,

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" Respiratory Protection Equipment Quality Control." The technician was

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knowledgeable on the procedure and the equipment he was testing. The SCBAs

tested appeared to be in good condition. The technician indicated that he had

replaced all the SCBAs, including those outside the control room and those

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staged throughout the plant, since he assumed the function 3 years ago. The

inspector made inquiries to determine if working-level health physics

technicians were aware of impending 10 CFR Part 20 changes. The technician

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discussed the changes and stated that they would probably become effective or.

January 1, 1994.

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5.2 Conclusions

A routine surveillance was found to be properly performed in accordance with

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the procedure; the health physics technician performing the surveillance was

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also very knowledgeable of impending changes to the federal regulations in the

health physics area.

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6 EMPLOYEES CONCERNS PROGRAM (TI 2500\\028 - ATTACHMENT 2)

6.1 Quality Team Program Review

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On August 31, 1993, the inspectors completed a review of the Waterford-3

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Employee Concerns Program (ECP) with the licensee's technical support

coordinator and a member of his staff. The coordinator was in charge of the

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program and normally reported directly to the Director of Nuclear Safety.

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coordinator had two other full-time people working in this function who had

received QA auditor training (approximately I week), engineering support

training (approximately 3 months) and administrative controls training

(approximately 1 month).

The licensee stated that the ECP staff's collateral

pitnt duties enhance staff effectiveness through exposure to the plant staff.

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The program was prescribed by the procedures for Quality Reporting, Site

Policy W1.501 and the Employee Concerns Program, Site Directive W5.606. The

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resolution of all concerns, which typically are at the coordinator level, are

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disseminated to management in a quarterly report.

The program applied to

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safety as well as nonsafety issues and was designed for nuclear as well as

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personnel issues (excluding union grievances); technical issues were reviewed

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by the appropriate discipline.

The program applied to all licensee personnel

as well as most contractors. These personnel were made aware of the Quality

Tear " ogram through GET-1 training and followup refresher training, posted

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signs, and general information meetings prior to outages. There was no

licensee requirement that contractors or their subcontractors have similar

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programs.

If an alleger requested confidentiality it was maintained within

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the ECP staff to the greatest extent possible. An anonymous allegation could

also have been made; a 24-hour per day recorder and a nationwide 800 number is

available.

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6.2 Conclusion

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While there are no specific NRC requirements for an employees concerns

program, the licensee appears to have been proactive in structuring a

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procedurally-driven program with a staff, organizational reporting

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requirements, and confidentiality. An exit interview process is in place,

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reinforced by providing a postinterview form and an 800 number telephone line.

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7 FOLLOWP DN CORRECTIVE ACTIONS FOR VIOLATIONS. (92702)

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7.1

(Closed) Violation 382/9022-02:

Failure to Provide Complete and Accurate

Information to the NRC

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This violation identified that the basis for Inservice Test Program Relief

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Request 3.1.27 to not cycle the valves on a quarterly basis failed to consider

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that Main Steam Atmospheric Dump Valves MS-Il6A and MS-Il6B could have been

isolated to perform such quarterly cycling. This item was previously reviewed

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and documented in NRC Inspection Reports 50-382/91-25 and 50-382/92-27. The

licensee has revised the Inservice Testing Plan - Pumps and Valves with

Change 4 of Revision 7-on August 19, 1993. The inspectors reviewed

Surveillance Procedure OP-903-120, Revision 0, " Containment and Miscellaneous

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Systems Quarterly IST Valve Tests," and found that it contained a requirement

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to test these valves quarterly.

7.2 (Closed) Violation 38'</9223-03:

Failure to Post Radiologically

Controlled Areas

The inspectors reviewed the corrective actions taken by the licensee-in

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response to the violation.

The violation pertained to a deficient

radiological posting that did not clearly indicate radiologically controlled

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areas. Review of the licensee's corrective actions indicated that

Procedure UNT-005-022, "RCA Access Control," had been enhanced to include

instructions to radiation workers relative to maintaining radiological

boundaries and postings; Procedure HP-001-219, " Radiological Posting

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Requirements," was revised to include additional guidance on what constitutes

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appropriate posting; General Employee Training was revised to provide

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additional information on the importance of maintaining radiological

boundaries and postings; and this event was discussed with the health physics

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technicians during their department meeting. Based on records reviewed and

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discussions with licensee personnel, the inspectors determined that the

corrective actions taken were satisfactory.

8 FOLLOWP (92701)

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(Closed) Unresolved item 382/9323-01:

Failure to Re-engage letdown Heat

Exchanger Temperature Control Valve Following Calibration

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This item was opened to review the effectiveness of the licensee's root cause

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and corrective actions to identify and resolve the practices that resulted in

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a failure to properly reset the limiter following maintenance. The inspectors

interviewed supervisors in the instrument and controls department and the

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acting operations and maintenance manager, reviewed the technical manual on

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the valve, and examined the valve in the plant. The limiter on that

particular pneumatic valve (CC-636) was the manual operator, a hand wheel on

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the top of the actuator. The valve was normally open and would close as air

was applied. The procedure to set the valve to limit flow was to turn the

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manual operator until the indicator on the valve showed 34 percent, the

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percent'open that would prevent the flow from going above 1200 gpm. This

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value was determined during preoperational testing. Due to this known valve

setting, postmaintenance testing to verify proper flow through the heat

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exchanger was not normally required.

Calibration Procedure MI-005-211, Revision 4, " Calibration of Control Valves

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and Accessories," and work package WA 01095230, required the valve's manual

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operator to be disengaged. This was done by an operator at the request of the

instrument and controls technician prior to starting work.

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The licensee determined that the work package and procedures were lacking in

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that they did not require the return of the limiter to it's initial 34 percent

setting. The operations lineup following the maintenance only required that

the valve be verified as operable and not that the limiter position be

verified. The instructions for verifying a valve's operability, delineated in

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

Breakers," did not address limiters.

The inspectors determined that the corrective actions identified by the

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licensee to review and modify Procedure OP-100-009 and the maintenance

procedures used in the job appeared adequate to prevent repetition of the

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incident. The inspectors determined that the lack of a requirement in the

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procedures to replace the limiter was a licensee identified violation of

Technical Specification 6.8.1.

Therefore, the violation would not be cited

because the criteria specified in Section VII.B.(2) of Appendix C to

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10 CFR Part 2 were satisfied.

9 ONSITE REVIEW 0F LICENSEE EVENT REPORTS (92700)

9.1

(Closed) Licensee Event Report 382/92-17:

Failure to Track Repair Causes

Technical Specifications Action Reauirement Time Limit to Be Exceeded

On December 15, 1992, the Waterford-3 control room supervisor gave mechanical

maintenance personnel permission to adjust the packing on Valve PSL-204 in

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accordance with WA 01104103. Work commenced, however, the valve was not

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entered in the equipment out-of-service log as required by Administrative

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Procedure OP-100-010, " Equipment-Out-of-Service."

Because the valve was not entered in the equipment out-of-service log, it was

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not entered in the station log as inoperable, Technical Specification 3.6.3

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Limiting Condition for Operation was not entered, and the control room staff

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(other than the control room supervisor) was not aware of the status of the

valve.

As a result, the progress of the work on the valve was not being

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tracked to ensure continued compliance with Technical Specification

requirements.

The root cause of this event was inappropriate action by the

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control room supervisor because he failed to utilize available administrative

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controls to ensure that the maintenance completed complied with Technical

Specification requirements.

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The licensee's immediate corrective action was to perform the stroke time test

in accordance with procedures.

Secondly, the control room supervisor involved

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with this event was debriefed in accordance with the Improving Human

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Performance Program. To prevent recurrence, this event was added to the

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operations department required reading program. Also, discussion of this

event and the administrative requirements associated with maintenance on

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Technical Specification components was added to the operators' requalification

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program.

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The inspectors reviewed the licensee's corrective action and determined that

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the licensee has satisfactorily completed the corrective actions as stated in

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the licensee event report.

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-ATTACHMENT 1

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1 PERSONS CONTACTED

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1.1 Licensee Personnel

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  • R. E. Allen, Security and General Support Manager
  • R. G. Azzarello, Director, Design Engineering

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  • R. G. Bennett, QA Inspection Supervisor
  • R. F. Burski, Director, Nuclear Safety
  • T. J. Gaudet, Operational Licensing Supervisor

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  • J. B. Houghtaling, Technical Services Manager

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  • L. W. Laughlin, Licensing Manager
  • D. F. Packer, General Manager, Plant Operations

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  • W. H. Pendergrass, Shift Supervisor
  • R. D. Peters, Electrical Maintenance Superintendent

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  • D. L. Shipman, Planning and Scheduling Manager
  • D. W. Vinci, Operations Superintendent

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  • Denotes personnel that attended the exit meeting.

In addition to the above

personnel, the inspectors contacted other personnel during this inspection

period.

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2 EXIT MEETING

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An exit meeting was conducted on September 24, 1993. During this meeting, the

inspectors reviewed the scope and findings of the report. The licensee did

not identify as proprietary any information provided to, or reviewed by, the

inspectors.

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ATTACHMENT 2

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EMPLOYEE CONCERNS PROGRAMS

PLANT NAME: Waterford-3 LICENSEE:

Entergy DOCKET 50-382

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NOTE: Please circle yes or no if applicable and add comments in the space

provided.

A.

PROGRAM:

1.

Does the licensee, have an employee concerns program?

(Yes or No/Coments) YES

2.

Has NRC inspected the program? Report #

Not in the past 3 years

B.

SCOPE: (Circle all that apply)

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1.

Is it for:

a.

Technical? (Yes, No/Coments) YES, farmed out to appropriate

discipline for review and then back for closcout.

b.

Administrative? (Yes, No/Coments) YES

c.

Personnel issues? (Yes, No/Coments) YES

2.

Does it cover safety-as well as non-safety issues?

(Yes or No/Coments) YES

3.

Is it designed for:

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Nuclear safety? (Yes, No/Coments) YES

b.

Personal safety? (Yes, No/Coments) YES

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c.

Personnel issues - including union grievances?

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(Yes or No/Coments) N0 for union, yes for all else.

4.

Does the program apply to all licensee employees?

(Yes or No/Coments) YES

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5.

Contractors?

(Yes or No/Coments)

YES, all contractors exposed to GET-1 would be aware of Quality

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Team Program (except certain specialized contractors such as

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intake structure divers).

6.

Does the licensee require its contractors and their subs to have a

similar program?

(Yes or No/Coments)

NO - Other than a statement in general contracts, regarding the

law and whistle blower employee protection

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7.

Does the licensee conduct an exit interview upon terminating

employees asking if they have any safety concerns?

(Yes or

No/ Comments)

YES, and a form is provided for after the interview.

C.

INDEPENDENCE:

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1.

What is the title of the person in charge?

Technical Support Coordinator (George Wilson)

2.

Who do they report to?

Director of Nuclear Safety (Ray Burski)

3.

Are they independent of line management?

Yes - with access to VP if necessary.

4.

Does the ECP use third party consultants?

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No, they do not hire outside assistance

5.

How is a concern about a manager or vice president followed up?

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For manager - we go to level above him and start there.

For VP - would go to immediate boss (if possible) and escalate to

corporate if necessary. Actions would depend on the

circumstances.

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D.

RESOURCES:

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What is the size of the staff devoted to this program?

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Two full time plus the coordinator

2.

What are ECP staff qualifications (technical training,

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interviewing training, investigator training, other)?

QA auditor training (approximately one week)

Informal training by corporate security

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Engineering support training (i.e. Technical (approximately three

months) and Administrative Controls (approximately one month)

training)

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E.

REFERRALS:

1.

Who has followup on concerns (ECP staff, line management, other)?

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.

G

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-3-

!

!

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!

i

ECP staff

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F.

CONFIDENTIALITY:

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l.

Are the reports confidential? (Yes or No/ Comments) YES

2.

Who is the identity of the alleger made known to (senior

management, ECP staff, line management, other)?

(Circle, if other

i

explain)

ECP staff - Procedurally, if confidentiality requested it is

maintained to greatest extent possible.

5

3.

Can employees be:

a.

Anonymous? (Yes, No/ Comments) YES

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b.

Report by phone? (Yes, No/ Comments) YES

+24 hr/ day recorder

"

  • Nation-wide 800 number

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G.

FEEDBACK:

1.

Is feedback given to the alleger upon completion of the followup?

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(Yes or_No - If so, how?)

YES, unless anonymous. Would inquire how alleger wished to be

,

informed and, following resolution of the allegation, a letter

j

would be sent to the alleger.

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.

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2.

Does program reward good ideas?

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NO - not addressed in directives.

Good suggestions would be

redirected to other appropriate programs.

3.

Who, or at what level, makes the final decision of resolution?

Majority are at coordinator level, but could be escalated

depending on circumstances.

4.

Are the resolutions of anonymous concerns disseminated?

Resolution of all concerns are disseminated to management via

quarterly report.

.

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-4-

1

5.

Are resolutions of valid concerns publicized (newsletter, bulletin

board, all hands meeting, other)?

Generally, no. Occasionally items such as industrial safety

issues are publicized to appropriate audience.

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H.

EFFECTIVENESS:

1.

How does the licensee measure the effectiveness of the program?

No official measurement tool but lack of repetition of items of

concern and allegations is an indicator (e.g. see Q 2.b).

2.

Are concerns:

,

a.

Trended? (Yes or No/ Comments) YES - Trended by type of

concerns.

b.

Used? (Yes or No/ Comments)

YES - See item G.5 with regard to industrial safety items.

Following outage showed a decrease in this area.

Scaffolding concerns also showed similar decrease.

,

3.

in the last three years how many concerns were raised?

182 Of

the concerns raised, how may were closed? 179 What percentage

were substantiated? (27 substantiated) 14%

4.

How are followup techniques used to measure effectiveness (random

r

survey, interviews, other)?

Other than replying to concernee with regard to the disposition of

the concern (substantiated or not, corrective actions) there would

.

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normally not be further contact unless initiated by the

individual.

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S.

How frequently are internal audits of the ECP conducted and by

whom?

Other than normal supervisory oversight, audits are not

procedurally required.

I.

ADMINISTRATION / TRAINING:

1.

Is ECP prescribed by a procedure? (Yes or No/ Comments) YES

Site Policy W1.501 " Quality Reporting"

Site Directive W5.606 " Employee Concern Program"

2.

How are employees, as well as contractors, made aware of this

program (training, newsletter, bulletin board, other).?

.

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-5-

GET-1 training (and GET refresher)

Posted signs

General information meetings prior to outages

ADDITIONAL COMMENTS: (Including characteristics which make the program

especially effective, if any.)

Independence of program enhances the effectiveness of the program.

Plus, the ECP staff has collateral duties in plant which through

exposure to the plant staff increases the ECP staff effectiveness.

NAME:

E. J. Ford

TITLE: SRI

PHONE:

783-6253

DATE COMPLETED: August 31, 1993