ML20126A429

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Insp Rept 50-382/92-26 on 921018-1128.Violations Noted. Major Areas Inspected:Plant Status,Operational Safety Verification,Maint & Surveillance Observations & Followup on Corrective Actions for Violations
ML20126A429
Person / Time
Site: Waterford Entergy icon.png
Issue date: 12/11/1992
From: Johnson W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20126A415 List:
References
50-382-92-26, NUDOCS 9212210056
Download: ML20126A429 (18)


See also: IR 05000382/1992026

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APPENDIX B

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Inspection Report:

50-382/92-26

Operating 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: October 18 through November 28, 1992

Inspectors:

E. J. Ford, Senior Resident inspector

J. L. Dixon-Herrity, Resident inspector

Approved:

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Wi liam D

ohnson, Chief, Project Section A

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Inspection Summar_y

Areas inspected;

Routine, unannounced inspection of plant status, operational

safety verification, maintenance and surveillance observations, and followup

on corrective actions for violations.

Results:

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The following conservative practices were noted during containment

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closecut inspection (paragraph 2.1.1):

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the use of contamination controlled areas to reduce dose

accumulation;

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personnel utilizing low dose areas while not actually performing

work;

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engineering evaluations performed for equipment remaining in

containment; and

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the use of paper coveralls to limit the potential for

contamination of decontamination workers.

However, it was also noted that two of these practices were poorly

implemented in that a contamination controlled area sign and barrier

around a steam generator was not well maintained and the coveralls were

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not worn in a manner to fully protect the workers (paragraph 2.1.1).

llousekeeping in containment prior to closcout was very good

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(paragraph 2.1.1).

However, the main steam isolation valve rooms had

poor housekeeping (paragraph 2.1.7).

Allowing wood pallets which were not fire-retardant treated to

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accumulate in the turbine building could create a potential fire hazard

(paragraph 2.1.2).

failure of operations personnel to adequately communicate and unclear

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instructions in a procedure caused misalignment of a throttle valve

(paragraph 2.1.3).

lhe following actions within the operations department were notably

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conservative (paragraph 2.1.3):

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The depressurization of the reactor coolant system by the shift

supervisor prior to operating the misaligned throttle valve;

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The operations management decision to review all procedures

containing valve lineups for throttling instructions; and

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Entry into a 4-hour action statement when it appeared that-

unidentified leakage may have slightly exceeded the limit during a

surveillance (circumstances could have allowed for voiding the

results instead) (paragraph 2.1.10).

The following are observations regarding the~ licensee's chemistry

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control program (paragraph 2.1.4):

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A violation resulted from the failure to_have a procedure to

control consumable materials in the control room, allowing

16 switches on a' safety-related panel to be made inoperable by

cleaning the panel with an unapproved cleaner.

The licensee's initial corrective actions to the inoperable

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switches were marginally satisfactory. They were informal, did

not determine if switches outside the control room horseshoe area

had been affected, and did not assure a root cause determination

or good corrective actions.

A second example of the above violation resulted from the

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identification of nonapproved consumable materials located in the

consumable materials controlled area.-

A crane in_close proximity to safety-related equipment was determined to

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be secured accordin to security requirements (paragraph 2.1.5).

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The door to a temporary enclosure posted as a radiation controlled area

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was left open after decontamination, leaving the doorway temporarily

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unposted and creating a potential for inadvertent entry

(paragraph 2.1.8).-

Management action in response to discovery of an error in the

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calculation of the potential postaccident radiation levels in

the -4-foot level in the reactor auxiliary building wing areas was

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prompt (paragraph 2.2).

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Routine outage work on safety-related electrical busses by maintenance

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technicians was well-conducted and properly controlled,_using good

safety practices.

Operator error and insufficient control of ongoing activities caused

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loss of suction to a charging pump during surveillance activities,

however, the licensee's actions were prompt and sufficient to_ ensure no

damage to the pump (paragraph 4.1).

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Summar_y of Inspection findings:

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Violation 382/9226-01 was opened (paragraph 2.1.4).

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Violations 382/9117-01 and -02 were closed (paragraph 5.1).

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Attachments:

Attachment 1 - Persons Contacted and Exit Meeting

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DETAILS

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PLANT STATUS

At the beginning of this reporting period, the plant was in Mode 6 with Refuel

Outage 5 in progress,

lhe fuel shuffle was completed on October 12, 1992, and

the plant entered Mode 5 on October 22, 1992.

plant pressurization and heatup

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commenced on November 4, 1992, and proceeded smoothly. The plant reached

100 percent power on November 14, 1992, where it remained through the end of

the reporting period.

2 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

licensee's responsibilities for continued safe operation.

2.1

plant Tours

2.1.1

Containment Closeout

On October 24, 1992, the inspector toured the containment building to observe

activities taking place in preparation for containment closure at the end of

the outage and to observe the general conditions inside containment.

Personnel in containment were waiting in low dose areas when not performing

some task.

The inspector observed that there was a great deal of activity and

containment was quite cluttered, but no more than would be expected during

preparations to remove excess material and equipment from containment.

However, two discrepancies were identified. A contamination controlled-area

sign and rope were found down at the top of a ladder that provided access from

the +46-foot level to a catwalk around Steam Generator 1.

Although this was

considered to be unsatisfactory, it was not a procedure violation, since

contamination controlled areas are not controlled by Administrative-

Procedure HP-001-219, " Radiological Posting Requirements." These areas were

conservatively posted by radiation protection personnel to limit the dose

accumulated during the outage.

The inspector also noted a_ used disposable

shoe cover in a nonsafety-related cable tray below a step-off pad at the east

end of the +35-foot level.

This was retrieved by the. licensee during

subsequent clean-up activities.

On November 4,1992, the inspector completed.a walkdown of containment after

management completed their initial walkdown and before the plant entered

Mode 4 _ Management's final walkdown was to take place prior to entering

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Mode 2.

Overall, containment looked very good from a housekeeping standpoint.

Closure preparations and cleanup were still ongoing, but there was marked

improvement compared to_ conditions observed on October 24.

Most of the-

scaffolding had been removed.

All of the contamination controlled area

postings had been removed.

Most of the trash that had been accumulating had

been removed with other trash and equipment staged near the personnel hatch

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for removal.

Equipment that was to remain in containment had been chained

down and secured. All of the plastic sheeting had been removed from the floor

gratings.

The only task that was observed during the tour was the decontamination of the

D-rings.

The inspector noted that the decontamination personnel were wearing

the health physics required paper coveralls and considered this a conservative

practice. However, several of the personnel doing this work had allowed their

disposable plastic shoe covers to bag at the ankle and the paper suit to ride

high, exposing their anticontamination clothing.

This reduction of the

offectiveness of the paper coveralls was discussed with the lead health

physics supervisor for operations.

In addition to this concern, the inspector

identified the following:

The drains in and near the Reactor Coolant Pump 18 cell were dismantled.

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No one was working in this cell.

A nitrogen bottle was chained on its side to the floor grating on the

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north end of the +21-foot level near the containment fan cooler adjacent

to Reactor Coolant Pump 2A,

it was labeled "Do Not Remove "

Other items labeled "Do Not Remove" included a 5-gallon bucket and a

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piece of paper taped to the wall on the +21-foot level.

Ladders and scaffolding were found unsecured in various places.

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Retest tags were on Valves MVAAA3098 and 310A, the sample line valves

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for Safety injection Tanks 18 and 2A.

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The inspector discussed these items with the licensee and received the

following explanations. The drains were properly installed during the-

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management tour on November 7, 1992.

The nitrogen bottle was not removed

prior to replacing the equipment-hatch and, in the-interest of personnel

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safety (carrying the bottle up the stairs to the personnel hatch, then back

down again), the licensee intended to leave the bottle in containment until

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Refuel.0utage 6,

An engineering evaluation had been completed, the valve'on

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the bottle opened, and the bottle secured.

Before this issue could be

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resolved, the containment coordinator independently had the bottle removed.

Any equipment that did remain (ladders and scaffolds,. for example) had to have

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engineering evaluations and had to be secured.

The retest on the sample line

valves could not be completed until the safety injection tanks were refilled.

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All of these items were verified removed or checked during the licensee's-

final walkdown.

The above items marked."Do Not Remove" had been removed. .The-

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only problem identified during the final walkdown was some trash in the

pressurizer cubicle.

This was removed prior to closure.

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2.1.2 Wood Pallets in Turbine Building

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On October 26, 1992, the inspector noted a number of wood pallets with

materials on them stored across from the spare low pressure turbine rotor in

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the northeast corner on the +15-foot level of the turbine building.

The

pallets did not appear to be treated with fire-retardant chemicals.

The

inspector noted that a similar finding in the reactor auxiliary building had

been identified as a violation during the 'ast report period (NRC Inspection

Report 50-382/92-23).

Subsequently, the inspector discussed the finding with

the operations and maintenance manager and the technical services manager.

They indicated that this was not a normal site practice and that untreated

wood should not be stored anywhere in the protected area.

Fire Protection

Procedure FP-001-017, Revision 8, " Transient combustibles and Designated

Storage Areas," establishes controls for the handling, storage, and use of

transient combustibles in safety-related areas and recommended practices for

other areas of the site.

The fire protection and safety supervisor and the inspector discussed the

concern and the supervisor indicated that he had found 24 pallets stored ir.

the area the inspector identified.

In addition, he pointed out that

Procedure FP-001-017 was ap)licable to safety-related areas, which excluded

the turbine building, and taat it was only a recommended practice for other

areas of the site.

After additional discussion with the inspector, he stated

that construction personnel had been instructed to remove the pallets but that

this was not required by the procedure.

The inspector stated that allowing

the untreated wood to be kept there, even if allowed by the procedure, but

contrary to the recommended practice, was noncon.ervative and could create a

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potential fire hazard.

The inspector noted that, due to the short period of

time that passed since plant management became anare of the violation, full

corrective actions had not been put into effect 'or the previous incident.

Concerns in this area should be alleviated when this happens.

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2.1.3

Inadequate Communication During Line-up

The operations superintendent indicated, at the plan-of-the day. meeting on

October 27, 1992, that operations had found a valve out of alignment in the

chemical and volume control system after a valve-alignment and verification

had taken place.

In discussions with the operations superintendent, the

inspector learned that the valve was closed when it was supposed to be

throttled and that the situation was discovered-by control room operators when-

the reactor coolant pump seals all went to the same pressure (350 psi) while

they were pressurizing-the reactor coolant system.

The shift supervisor's

immediate response was_ to depressurize the reactor ' coolant system until the

misalignment was corrected. . This was a conservative and safety-minded action

asiall of the seals are rated at full reactor coolant system pressure.

Personnel responsible for the lineup and verification stated that the cause of

the problem was the use of the term " throttled" in the procedure.

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immediate corrective action taken was to change the procedure that was used

and to fill out a precursor trending program card.

The licensee also

committed to check additional procedures to verify that the term " throttled"

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was not used without additional instruction to better identify the correct

valve position.

The licensee checked all 260 procedures that contained valve

lineups within 2 days of the incident, identified 14 procedures (2 safety and

12 nonsafety) that contained the same wording, and committed to correct these

items.

Both the shift suaervisor and the operations management displayed

notcble conservatism in t1eir corrective actions.

A second concern in this incident was the action taken by the personnel

performing the lineup. The operations superintendent stated that they

questioned the word " throttled" but did not query control room personnel

during the lineup, and a request to improve the procedure was not completed

after the lineup.

Had the question been asked, the incident might have been

prevented.

The operations superintendent said that he had stressed asking

questions and maintaining a questioning attitude in talks with his personnel

in the past and would continue to do so.

He also planned to address this

particular incident in the lessons learned for Refuel Outage 5.

The shift

supervisor indicated that the operations superintendent holds discussions with

shift personnel regularly, either on shift or during time set aside in the

training week. He also said that maintaining a questioning attitude and the

requirement to self-check were common topics for these discussions.

2.1.4 Control Board Switches Made Inoperable by cleaner

The inspector attended the operators' morning shift meeting on October 28.

During this meeting, a lessons-learned briefing was given on the use of

cleaning materials in the control room. An operator had used a commercial

contact cleaner for coin machines and electronic equipment to clean Engineered

Safeguards Control Panel CP-8 on October 25, 1992.- Within approximately

2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, the solvent caused the plastic parts of 16 safety-related control

switches to glue or bond together making the switches inoperable.

The

affected switches included:

the engineered safety feature Trains A and

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B pumps' suction valves from the refueling water storage pool; the control for

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High Pressure Safety injection Pump B; and the flow controls for the Low

Pressure Safety injection Pump A into Cold leg 2A and Low Pressure Safety-

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Injection Pump B into Cold Legs IA and-18. With the unit in cold shutdown,

the inoperable handswitches did not impact operability of equipment required

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by Technical Specifications. Under different plant conditions, the safety

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impact could have been much more significant. The licensee's immediate

corrective action was to complete an operational experience report, write a-

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condition identification (No. 283138) to cause the switches to be replaced,

inform the operating shifts on duty of what had happened to prevent a

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recurrence of the incident, and inspect the panels in the control room

horseshoe area for additional damage.

The operational experience report is an

informal internal operations tool used to pass information to the other

shifts. There was no requirement for any action to take place as a result of

this report other than to suggest that operators review the reports.

The main

point made during the training was that the labels on any material: should be

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r'ead prior to using it in the control room.

The label.on.this particular

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material was slightly misleading and one could not tell that it was harmful

until reading the bottom of the label on the back of the can.

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The inspector contacted an engineer in the chemistry department to determine

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whether there was a procedure in place to prevent the incident.

The engineer

identified Adreinistrative Procedure UNT-007-003, Revhion 8, " Control of

Consumable Materials," as the procedure that controlled consumable materials

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in some areas of the plant, but indicated that the control room was exempted

from this procedure.

The procedure's original and primary purpose was to

establish controls for the use of consumable materials at Waterford 3 in order

to regulate consumable materials that are not compatible with plant mechanical

systems or equipment.

The product was not en the list of approved consumables

for use in the consumable materials controlled a,eas.

These areas included

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all of the turbine building and the nuclear island with the exception of labs,

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of fice areas, and the control room.

The switchgear rooms in both tha nuclear

island and the turbine building were included.

10 CFR Part 50, Appendix B,

Criterion V, " Instruction, Procedures, and Draw mgs," requires that activities

affecting quality be prescribed by documented procedures.

The failure of the

existing procedure to control the use of this chemical on the controls for

safety-related equipment in the control room is an example of a violation of

10 CFR Part 50, Appendix B, Criterion V (VIO 9226-01).

The inspector was concerned with the adequacy of the licensee's initial

corrective actions in response to this incident.

The controls for a number of

safety-related components were made inoperable in

manner that could not be

detected on the control panel until one tried to use them.

No action was

taken procedurally to prevent a recurrence of the incident.

Af^er questions

were raised by the inspector concerning tn~ e potential for commoi mode failure,

the licensee inspected a 50 percent samp e of control panels in the plant

(including the diesel panels and the remt te shutdown panel) to ensure that the

chemical had not been used elsewhere.

S,gnificant Occurrence Report 92-019

was completed to document that the inc' dent had occurred, investigate the

incident, and identify the root cause and corrective actions necessary to

prevent recurrence.

Standing Instruetion 92-11 was written to identify the

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only approved cleaner for th( contro' panels.

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2.1.5 Security Observation

On November 6, 1992, the inspector notet a mobile crane located in close

proximity to the Train A cooling tower. Closer investigation revealed that

the vehicle was unlocked and that no key was readily evident.

The vehicle was

up on stabilizers, so it could not move, but the crane could be moved over the

vital area if it were operable.

The inspector contacted the security and

general support manager and explained the concern. Through discussion with

him and the individual responsible for the crane, it was determined that the

vehicle and the crane were both rendered immobile and inoperable without the

key.

2.1.6 Control Room Observation

The inspector observed control room operations on November 9, 1992. The

operators were rolling the turbine :n preparation for synchronizing to the

grid.

The operators performed well and followed procedures.

The only concern

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noted was the number of personrel in the control room during this time. The

inspector noted that there were a large number of people in the horseshoe area

around the operator performing the r ocedure.

Further review of the situation

revealed that the additional personnel were on hand in response to problems

the operator was having with throttle valve leakage while rolling the turbine.

2.1.7 Main Steam Isolation Valve Rooms

On November 11, 1992, the inspector completed a tour of the east and west main

steam isolation valve rooms where work appeared to be in progress.

Tarpaulins

had been draped to cover scaffolding to provide a prote W work area (the

room is open to the elements).

Both rooms were in pe

n "Jition with respect

to housekeeping.

Equipment and hoses had been left on tne catwalk around

Main Steam Isolation Valve 1.

These, and the cover plates and trash bags on

the catwalk around the feedwater isolation valve actuator, made walking on the

catwalks hazardous.

The floor under the main steam isolation valve hydraulic

actuator was covered with a pool of water and what appeared to be hydraulic

fluid. This made climbing ladders in the vicinity hazardous.

The rest of the

space was also covered with puddles of water. This could be expected for_a

space exposed to the weather, but the only drain sighted by the inspector had

its cover removed and was full of trash.

There was used plastic sheeting and

trash on the floor, along with several parts and-tools.

The space also

appeared to be a storage location for scaffolding.

This was stored

haphazardly, some in areas marked for storage, some not. The general

condition of the rooms was discussed with the shift supervisor. He initiated-

immediate corrective actions.

2.1.8 Radiation Barrier Posting

On November 11, 1992, the inspector identified one t;ncern in Switchgear

Room B.

The door to the temporary enclosure instalied in the room over the

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access plug to the letdown containment isolation valve'was ope.

Further

investigation revealed that it was still posted as a radiation controlled

This posting was on the door and could not be seen when the door was

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open.

The inspector closed the enclosure door to prevent inadvertent entry by

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other personnel.

Before leaving the area, the inspector discussed the finding

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with the health physics technician who had just entered the area. 'h

indicated that decontamination personnel had just finished decontaminating the

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area and that he had been assigned to verify that'it was decontaminated and to

depost the area so that the temporary. enclosure could be disassembled and

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removed. The inspector contacted the radiation protection superintendent,

informed him of the situation, and verified that the explanation given_was

correct. This appeared to be an isolated incident.

2.1.9 Unapproved Consumable Materials

On November 17, 1992, while touring the reactor auxiliary building, the

inspector noted two consumables without labels identifying them as approved

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items for use in the consumable materials controlled area.

The items were a

spray can of odor counteractant and a tube of glue.

The inspector also noted

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numerous items with labels in areas where work was not in progress.

The

inspector asked the shift supervisor about the two items without labels.

The

shift supervisor did not know if they were approved for the area but had them

removed and requested that the list of approved materials, the Plant

Consumable Materials Report, be provided to the control room for future

reference.

In addition, he stated that oc9rators would be watching for

unapproved consumables in the consumable materials controlled areas.

On November 19, 1992, the inspector identified a can of insecticide without a

label on a scaffold next to Main Steam Isolation Valve 1.

The inspector

discussed the three products with the engineer in the chemistry department

responsible for the consumable materials control program the next day.

He

found that the three products were not on the Plant Consumable Materials

Report.

The procedure (UNT-007-003) requires that only approved consumable

materials be used in the consumable materials controlled area.

This is a

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second example of failure to follow procedures as required by 10 CFR Part 50,

Appendix B, Criterion V (VIO 9226-01).

The engineer stated that leaving the labeled products at the work site after

work was complete was a poor housekeeping practice.

The current procedure

(UNT-007-003) had been revised in March 1992 to incbde 01 of the nuclear

block (with some exceptions, including the control room), t'e turbine

building, and other spaces on site. All the doors on the c.fected buildings

had postings that stated that the space was a con,unble materials controlled

The procedure placed the responsibility for ensuring that unapproved

area.

consumables are not brought into these areas on the workers. . Personnel have

been educated on consumable materials through general cmployee training. The

key point made in the training was that products must be labeled with blue or

orange labels for use in the consumable materials controlled areas.

The chemistry department had recognized the deficiency in the program and was

making an effort to improve it prior to the inspector's finding.

Their

corrective action was a request that the different maintenance departments

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review a list of unapproved consumables in the warehouse and identify those

products used in areas outside the consumable materials controlled areas. The

goal was to remove products which were unapproved and not used from the

warehouse to make them unavailable.

2.1.10 Unidentified Leakage

On November 23, 1992, the shift supervisor informed the inspector'that they

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had entered Technical Specification 3.4 5.2. due to unidentified leak rate

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greater than 1 gpm (1.0577 gpm).

The inspector went to the control room to

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gain additional information and observe activitit s. . The control room

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operators had secured the chemical and volume cortrol system gior to starting

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the surveillance to allow operators to make a containment entry.

Removing

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this system from service, coupled with problems with the pressur !zer heaters,

caused a pressure transient which lasted approximately four times as long as

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normal.

Charging Pump B, which was running and had beeti previously identified

that day as having a slightly degraded seal, provided a possible leak path.

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The operators conservatively elected to enter the 4-hour action statement in

lieu of voiding that run and repeating it due to the known transient.

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addition, two auxiliary operators were dispatched to enter containment and

look for possible leaks.

The control room operators allowed the plant to

stabilize and isolated Charging Pump B, then repeated Surveillance

Procedure OP-903-024, Revis;on-8, " Reactor Coolant System Water Inventory

Salance," and found that the unidentified leak rate had been reduced to

0.32 gpm.

Charging Pump B was left out of service until the seal was

repaired.

This was another example of electing a conservative option by an

operating crew.

2.2 Radiation Level Calculations Following_a Loss of Coolant Accident

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Valve CC-710 is the containment isolation valve inside containment for

Component Cooling Water Train AB to the reactor coolant pumps.

It fails in

the open position and closes upon receipt of a containment spray actuation

signal using instrument air.

Upon failure of instrument air, a 10-hour

accumulator is used to ensure the valve remains closed. With the most

recantly measured accumulator leakage rate (5.48 psi /hr), it was estimated

that Valve CC-710 would drift open 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after a postulated loss of

instrument air.

The scenario of concern was a -large break loss of coolant accident with the

assumption of loss of offsite power.

This would cause a loss of instrument

air.

The component cooling water piping to the. reactor coolant pumps is not

protected from jet impingement and pipe whip and wac assumed to break. A

failure of the outside containment isolation valve (CC-713) to close was also

assumed, causing containment isolation to be provided solely by Valve CC-710.

The licensee determined that the probability of this sequence of events was

less than lx10" per. year.

The solution would have been .to have an operator enter the -4-foot . level

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reactor auxiliary building wing area and manual?y close Valves CC-713 and

CC-641 (Valve CC-641 is the containment isuiation valve on the inlet of the AB-

-component cooling water train into containment).

After finding that the

accumulator for Valve CC-710 failed to meet the 10-hour l requirement, design

engineering discovered that the radiation-levels in the wing areas-following a

recirculation actuation ,ignal would be significantly higher than originally

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calculated.

This was caused by the failure of the original calculations to

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take into account the recirculation of highly contaminated' coolant from the

sump through the containment spray and high pressure safety injection-systems.

There is a 10-inch containment spray line and two 3-inch high pressure safety

injection lines in the wing area. The exposure rate calculations, based on

final safety analysis report source terms, showed exposure rates too high to

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allow valve operation-while maintaining operator exposure to less than 5 rem;

The licensee installed temporary shielding on the referenced lines so that an

operator could enter the wing area and receive less than 5 rem (approximately

4.1 rem) using preliminary calculations generated on site. Other strategies

identified included the possibility of restoring instrument air to service or

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of closing the referenced valves prior to receipt of a recirculation actuation

signal.

The accumulators for Valves CC-713 and CC-641.had leakage rates which

would allow them to remain closed for greater than the required 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />.

The

licensee intends to repair the accumulator during Refuel Outage 6 or during

the next forced outage when in Mode 5.

The planned long-term corrective-

action was to install permanent shielding in place of the temporary shielding.

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2.3

Surveillance of the Turbine-Driven Emergency Feedwater Pump

On November 24, 1992, the licensee declared Emergency Feedwater Pump AB out of

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service after failing to meet the initial conditions for steam pressure

required as part of the acceptance criteria in Surveillance

Procedure OP-903-046, Revision 9, " Emergency Feed Pump Operability Check."

Technical Specification 3.7.1.2 required pump restoration within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

The acceptance criteria could not be met due to the new practice of operating

at a lower hot leg temperature in the steam generators to reduce corrosion.

This had been implemented after Refuel Outage 5.

The lower temperature

resulted in a steam pressure less than required for testing.

The. problem with

this Technical Specification had been identified and a change request had been

submitted to the Nuclear Regulatory Commission, but the review had not been

completed.

The licensee had scheduled this test to coincide with a power reduction

associated with turbine valve and control element assembly testing.

For some

reason, yet to be identified by the licensee, the test was run at . full power

when the required steam pressure could not be achieved. After

licensee-initiated discussions, a representative of the Office lof Nuclear

Reactor Regelation agreed that the test was invalid and did not indicate pump

inoperability.

The licensee stathd that the surveillance test would be

performed under the proper conditions prior to expiration of the surveillance

interval.

2.4 Conclusians

Workers were observed waiting in low dose areas when not directly

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performing a task.

Areas near the top of the steam generators were_ conservatively posted as

o

a contaminated controlled area to limit' outage-related dose.

Poor implementation of a conservative practice was noted in containment

o

with regard to control of a contamination controlled area' sign and

barrier rope.

Housek!eping in containment was very good,

o

Health pnysics exhibited a good practice by requiring decontamination

o

personnel inside containment to wear paper overalls over their

protective clothing.

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Decontamination personnel failed to wear paper coveralls in a manner to

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minimize potential for contamination.

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Although corrective actions in response to a violation regarding

o

transient combustibles in the safety-related switchgear area were not

yet fully implemented, allowing a large number of untreated wood pallets

to accumulate in the turbine building was not conservative,

Failure of operations personnel to adequately communicate and unclear

o

instructions in a procedure caused misalignment of a throttle _ valve.

The depressurization of the reactor coolant system by the shift

o

supervisor, prior to operating the misaligned throttle valve, was

notably conservative, as was the management decision to review all

procedures containing valve lineups,

The licensee did not have a procedure to control consumable materials in

o

the control room.

Switches on a safety-related panel were damaged by

cleaning the panel with an unapproved cleaner.

A second example of improper consumable material control was the

o

identification of nonapproved consumable materials located in the

consumable materials controlled area.

The licensee's initial corrective actions after identifying the-

o

inoperable switches were marginally satisfactory.

They were informal,

did not determine if switches outside the control- room horseshoe area

had been affected, and did not assure a root cause determination or good

corrective actions.

A crane in close proximity to safety-related equipment was determined to

o

be secured according.to security requirements.

The main steam isolation valve rooms had poor housekeeping.

o

The door'to a temporary enclosure posted ~as a radiation controlled area

o

was left open after decontamination, leaving the doorway temporarily

unposted and creating a potential for inadvertent entry,

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A-second example of operator conservatism occurred when-the shift

o

supervisor entered a 4-hour action statement when it appeared that

unidentified leakage may have slightly exceeded the limit during a

surveillance (circumstances would have allowed for voiding the results).

Management action in response to discovery of an error in the calcula-

o

tion of the potential postaccident radiation levels in the -4-foot level

irtthe reactor auxiliary building wing areas was prompt.

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3 MONTHLY KAINTENANCE OBSERVATION (62703)

The station maintenance activities affecting safety-related systems and

components listed below were observed and documentation reviewed to ascertain

that the activities were conducted in accordance with approved work

authorizations, procedures, Technical Specifications, and appropriate industry

codes or standards.

3.1 Maintenance on 480V Motor Control Center

On October 29, 1992, the inspector observed portions of ongoing work on the

Train A safety bus. Motor Control Centers 312A and 313A were opened, cleaned,

and inspected. Contacts and fuses were checked. The applicable work

authorization numbers were 01095995 and 01095996.

The electricians appeared

knowledgeable and were following the procedures.

The cabinet interiors were

clean and contained no trash. Appropriate safety practices were observed

during the work. The buses are taken out for maintenance every other outage.

Both Busses A and AB were completed during Refuel Outage 5.

No concerns were

identified.

3.2 Troubleshootina Feedwater Pump Turbine Speed Controller

The inspector observed the completion of the work authorization which included

troubleshoot:ng the controller for feedwater pump turbine speed on

November 10, 1992. This problem had been identified by an operator while the

inspector was observing the rolling of the turbine on November 9,1992. The

instrument and controls technician had identified a loose pin in the

connector. While observing the replacement of the controller, the inspector

e

noted that the interior of the panel was neat with no trash present.

It was

noted that cables and devices were labeled on the interior of the panel. The

personnel completing the task were knowledgeable in their trade and-did not -

handle the controller after reinstallation. They had the operator test to see

that it was installed correctly and operable.

No concerns were identified.

3.3 Conclusions

Routine outage work on safety-related electrical busses by maintenance-

technicians was well-conducted and properly 1 controlled and good safety

practices were observed.

4 BIMONTHLY 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 licensee's programs and the Technical Specifications.

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4.1

Enaineered Safety Feature Actuation System Subaroup Relay Test

On November 4, 1992, the inspector observed a portion of Surveillance

Procedure OP-903-094, Revision 7, "ESFAS Subgroup Relay Test - Operating."

The operators performing this task were versed in what they were doing and

were following the procedure.

The surveillance was to be completed before the

plant could proceed from Mode 4 to Mode 3.

The operators were doing portions

of the procedure as the opportunity arose.

When a window opened to do Train B

Position 4, Relay K108, the operators approached the operator on the

associated board to see if the surveillance could be completed. That operator

was concerned about tripping the charging pump he was running while restoring _

the volume control tank hydrogen blanket.

The operators completing the surveillance verified that Charging Pump AB would

not be tripped. The operator assigned to the board agreed to allow the

surveillance to be performed.

He switched the selector switch from A-B to

B-AB, according to the first step in the surveillance procedure. At this

point, the indicator lit up to show that the Charging Pump B was tripped.

As

this was not the desired response, the operator then positioned the switch to

A-B and proceeded to determir.e what was wrong. The shift supervisor was

called over to look into the problem.

The operator then instructed a nuclear

plant operator to go and check on Pump AB, which was still operating.

Further

review of the board revealed that the suction path for the charging pumps had

been closed. The operator at the pump indicated that the pump was still

running but seemed to be vibrating more than normal and that the seals looked

abnormal.

The shift supervisor's interpretation of the situation was that the operator

had been in the process of switching from draining to filling the volume

control tank for the hydrogen restoration (burping) process when the operators

doing the surveillance approached him.

In attempting both procedures, he had

missed opening the valve _from the refueling water storage pool to provide a

suction path before assisting with the surveillance.

The shift supervisor

quickly determined that the cause was that too rauch was geing on and said that

the surveillance would have to wait until after the higher priority equipment-

line-ups were complete.

In addition to this immediate action, a condition identification was generated

to diagnose and repair the suspected low pressure switch that failed on

Charging Pump AB (which should have tripped it upon loss of a suction source).

The inspector noted that Pump B correctly tripped and Pump A was out of

service.

The shift supervisor also determined that poor communications and

the number of ongoing activities (the plant had just gone to Mode 4 and was

heating up for Mode 3), contributed to the problem.

A mechanic who had worked on the pump in the past and was in the vicinity of

-the pump at the time was asked to check the pump while it was running.

Operators also ensured that the flow and other parameters were normal.

The

mechanic determined qualitatively that vibration was acceptable and seals were

in good condition.

The shift supervisor talked to the operator to ensure that

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he did not repeat his mistake.

The operator filled out an operational

experience report on November 7, 1992.

A precursor trending program card was

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also completed.

Subsequently, vibration tests were completed on the pump and

found to be normal.

No other concerns were identified.

4.2 Operability Check of Charging Pumo AB

On November 10, 1992, the inspector observed a portion of the operability

check on Charging Pump AB per Surveillance Procedure OP-903-003, Revision 8,

" Charging Pump Operability Check." The auxiliary operator had Charging Pump A

secured several minutes prior to the vibration test on the Charging Pump AB.

The calibration date was verified and recorded for both the vibration

7

instrument and its probe.

After the Pump AB had run for 5 minutes by itself,

the personnel completing the test took readings from several marked points on

the motor and the pump.

Review of the results later in the control room

indicated that the readings were well within the acceptable range for the

pump.

No concerns were identified.

4.3 Conclusions

Operator error and insufficient control of ongoing activities caused

o

loss of suction to a charging pump.

The licensee's actions were prompt and sufficient to ensure no damage to

o

the pump.

5 FOLLOWUP ON CORRECTIVE ACTIONS FOR VIOLATIONS (92702)

5.1

(Closed) Violation 382/9117-01 and -02:

Failure to Ensure Proper

Isolation Boundaries for Maintenance and Changed Scope of Work

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Authorization Without Proper Authorization

The inspector reviewed the corrective actions taken by the licensee in

response to the violations.

The event involved the failure of the shift

supervisor or control room supervisor to ensure the establishment of proper

isolation boundaries for maintenance on High Pressure Safety Iniection

Valve SI-512A being worked under Work Authorization 01065402 and the failure

of the mechanical maintenance supervisor to obtain proper authorization prior

to initiating a change to the scope of the subject work authorization. The

result of the incident was a loss of shutdown cooling for 19 minutes when the

low pressure safety injection pump became air bound upon the removal of the

bonnet for Valve SI-512A. This caused a 10*F increase in the core

temperature. The corrective actions taken included: developing and

implementing training for appropriato operations, maintenance, and planning

and scheduling personnel prior to refueling outages; revising administrative

and work controls; revising Maintenance Procedure MD-001-026, " Maintenance

Department Work Center Planning;" instituting requirements to maintain a

reactor coolant system perturbation log; and developing a composite isometric

drawing of the shutdown cooling system.

Based on records review and

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discussions with licensee personnel, the inspector determined that the

corrective actions were satisfactorily completed prior to entering shutdown

cooling during Refuel Outage 5, as specified in the response to the violation.

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ATTACMMENT 1

1

PERSONS CONTACTED

1.1

Licensee Personnel

R. E. Allen, Security and. General Support Manager

  • R. G. Azzarello, Director, Design Engineering

R. F. Burski, Director, Nuclear Safety

T. J. Gaudet, Operational Licensing Supervisor

J. G. Hoffpauir, Maintenance Superintendent

  • A. L. Holder, Supervisor, Fire Protection and Safety
  • J. B. Houghtaling, Director, Plant Modification and Construction
  • B. R. Loetzerich, Engineer, Licensing
  • L. W. Laughlin, Licensing Manager
  • T. R. Leonard, Technical Services Manager
  • A. S. Lockhart, Quality Assurance Manager

D. E. Harpe, Mechanical Maintenance Superintendent

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

R. D. Peters, Electrical Maintenance Superintendent

R. G. Pittman, Instrumentation & Controls Maintenance Superintendent

J. A. Ridgel, Radiation Protection Superintendent

  • R. S, Starkey, Operations and Maintenance Manager
  • D. W. Vinci, Operations Superintendent
  • Denotes personnel that attended the exit meeting.

In addition to the above

personnel, the inspectors contacted other personnel during this inspection

period.

2 EXIT MEETlHG

-The inspection scope and findings were summarized on December 1, 1992, 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-this inspection.

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