ML20129D767
| ML20129D767 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 09/20/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20129D731 | List: |
| References | |
| 50-382-96-11, NUDOCS 9609300183 | |
| Download: ML20129D767 (20) | |
See also: IR 05000382/1996011
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ENCLOSURE 2
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.:
50 382
License No.:
Report No.:
50-382/96-11
Licensee:
Entergy Operations, Inc.
Facility:
Waterford Steam Electric Station, Unit 3
Location:
Hwy.18
Killona, Louisiana
Dates:
July 21 through August 31,1996
Inspectors:
L. A. Keller, Senior Resident inspector
T. W. Pruett, Resident inspector
D. L. Proulx, Resident inspector, River Bend Station
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Approved By:
P. H. Harrell, Chief, Project Branch D
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ATTACHMENTS-
Attachment 1:
Partial List of Persons Contacted
List of Inspection Procedures Used
List of items Opened, Closed, and Discussed
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List of Acronyms Used
9609300183 960920
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ADOCK 05000302
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EXECUTIVE SUMMARY
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Waterford Steam Electric Station, Unit 3
NRC Inspection Report 50-382/96-11
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This routine, announced inspection included aspects of licensee operations, maintenance,
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engineering, and plant support. The report covers a 6-week period of resident inspection.
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Operations
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All observed operations activities were conducted professionally and were
consistent with safe operation of the facility (Section 01.1).
A licensee audit revealed that the appropriate Limiting Conditions for Operation
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(LCO) was not entered for two Component Cooling Water (CCW) valves on the
Equipment out-of-service (EOS) List, due to the failure of operators to recognize that
the valves had a closed safety function. The inspectors determined that the valves
were always capable of performing their closed safety function, the valves'
condition did not require LCO entry and, therefore, this error was administrative in
nature (Section 04.1).
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A nuclear auxiliary operator's inadvertent addition of the wrong type of oil to the
CCW Pump A outboard bearing was a result of a lack of attention to details and is
considered a noncited violation (Section 04.2).
Maintenance
The licensee's maintenance scheduling process did not include provisions for
quantitative assessments of unscheduled maintenance. Additionally, the qualitative
assessments of maintenance on engineered safety features systems, concurrent
with switchyard maintenance, was not implemented by the on-shift operations staff
consistent with established practices. The adequacy of the licensee's risk
assessments for unscheduled maintenance is an unresolved item (Section M1.2).
As a result of not returning a manual / automatic station setpoint to its original state
following maintenance, Auxiliary Component Cooling Water (ACCW) Pump B
inadvertently started when power was returned to the pump. The unexpected start
of the ACCW pump caused a waterhammer in the system. The failure to provide
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written instructions appropriate to the circumstances for returning the
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manual / automatic station to service is a violation of Technical Specification (TS) 6.8.1.a (Section M4.1).
Enoineerino
A licensee self-assessment team questioned whether degraded CCW flows through
the containment fan coolers indicated the coolers were not in compliance with a TS
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surveillance requirement. The licensee concluded that there was adequate CCW
flow to meet all design basis requirements and that the coolers were in compliance
with TS. The issue of compliance with TS Surveillance Requirement 4.6.2.2.b.2
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and the adequacy of the 1325 gpm value is unresolved pending review by the
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NRC's Office of Nuclear Reactor Regulation (NRR) (Section E4.1).
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' .The engineering self-assessment finding that CCW flows experienced during
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full-flow conditions might indicate noncompliance with TS Surveillance
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Requirement 4.6.2.2 for the containment f an coolers was a positive example of
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questioning attitude. Overall, the self-assessment provided good findings and
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recommendations (Section E7).
Rosemount transmitter calibrotion errors were found to be of minor safety
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significance. The failure to appropriately calibrate certain Rosemount transmitters is
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identified as a noncited violation (Section E8).
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The licensee's corrective actions related to the latest Reactor Coolant Pump
(RCP) 2B baffle bolt failures were adequate (Section E8.4).
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Plant Suocort
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Allowing Emergency Operating Facility (EOF) diesel generator fuel oil storage tank
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level to decrease below 50 percent and not providing a user's guide for EOF plant
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monitoring computer terminals were identified as poor emergency planning practices
(Section P2.1).
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Reoort Details
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Summarv of Plant Status
The plant began this inspection period in mid-loop operations due to RCP 2B seal problems.
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On July 30,1996, RCP 2B seal replacement activities were completed and the plant was
placed in Mode 4. The plant reentered Mode 5 later that day due to RCP 2B exhibiting
similar seal problems that initiated the forced outage, on July 16, to replace the seal
package. The seal was replaced and the plant entered Mode 4 on August 3. Mode 1 was
entered on August 5 and the plant operated at or near full power throughout the rest of
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this inspection period.
I. Operations
01
Conduct of Operations
01.1 General Comments (71707)
Using Inspection Procedure 71707, the inspectors conducted frequent reviews of
ongoing plant operations, control room board walkdowns, and plant tours. All
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observed activities were conducted professionally and were consistent with safe
operation of the facility. Operators displayed good knowledge of plant status and
understood the reason why control room annunciators were in alarm.
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04
Operator Knowledge and Performance
04.1 Failure to Recoanize Closed Safetv Function of CCW Valves
a.
Inspection Scoce (71707)
On July 3,1996, the inspectors were informed that two CCW valves with closed
safety functions had been previously declared out of service without closing the
valves or entering the appropriate LCO. The inspectors reviewed the background
and circumstances associated with the valves being out of service and reviewed the
EOS list to determine if there were generic problems in this area. The EOS list is
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maintained by the licensee to track the status of equipment that has been removed
from service. This list is used by the operations crews to ensure that any system
affected by the equipment out of service will be declared inoperable and the
appropriate TS LCO entered.
b.
Observations and Findinas
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During a review of the EOS list on July 3, the licensee noted that Valves CC-620
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(spent fuel pool heat exchanger temperature control valve) and CC-636 (letdown
heat exchanger temperature control valve) have a closed safety function per the
inservice testing program design basis documentation. Although these valves were
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on the EOS list, they were in service and operating appropriately to throttle CCW
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through the respective heat exchangers. The personnel performing the EOS list
review noted that if Valves CC-620 and -636 were truly out of service then the
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valves should either be closed or the appropriate TS LCO entered. Upon discovery
of this problem on July 3, the licensee entered 1S 3.7.3 for CCW Train A.
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Valve CC-620 was placed on the EOS list on February 6,1996, for replacement of
the manual handwheel stem actuator coupling key. The valve was tagged out, but
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the work was never performed and the clearance was restored. Although the valve
was returned to service, it remained on the EOS list as a result of the limit switch
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being inoperable. The licensee determined that the limit switch problem did not
prevent Valve CC-620 from fulfilling its safety function and removed Valve CC-620
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from the EOS list on July 3.
Valve CC-636 was placed in the EOS list on October 9,1995, in order to perform a
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modification to the valve in accordance with Design Change 3430. The
modification involved replacing the existing butterfly valve with a smaller globe
valve. The clearance tags were subsequently removed and the valve was returned
to service; however, since a portion of this modification was not completed, the
valve remained on the EOS list. The licensee determined that the unfinished portion
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of the modification did not prevent Valve CC-636 from fulfilling its safety function
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and removed it from the EOS list on July 3. TS 3.7.3 was exited, on July 3, after
Valves CC-620 and -636 were removed from the EOS list.
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The inspectors determined that Valves CC-620 and -636 were returned to service,
but left on the EOS list, due to the failure of operators to recognize that these
valves had a closed safety function. The inspectors independently confirmed that
Valves CC-620 and -636 were always capable of performir.g their closed safety
function, and would not have required LCO entry. Therefore, this error was
administrative in nature. The inspectors reviewed the other items on the EOS list
and determined that there were no other items that would require the licensee to
enter a TS LCO action statement. The inspectors noted that the Procedure
OP-100-10, " Equipment Out Of service," Revision 7, was in the process of being
revised to assist the operators in determining if entry into a TS LCO was appropriate
after taking a component out of service.
c.
Conclusions
The inspectors determined that Valves CC-620 and -636 were always capable of
performing their closed safety function, the valves' condition did not require LCO
entry and, therefore, this error was strictly administrative in nature.
04.2 Addition of incomoatible Oil to CCW Pumo
a.
Insoection Scoce (71707)
The inspectors reviewed the licensee's response to their identification that a nuclear
auxiliary operator added incompatible oil to the CCW Pump A outboard bearing,
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b.
Observations and Findinos
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On August 23,1996, while investigating a CCW Pump A outboard bearing oil leak,
the licen'see noted from the lube oil addition records that a nuclear auxiliary operator
added 215 milliliters of SHC 626 (motor bearing oil) instead of DTE-MED (pump
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bearing oil) to the CCW Pump A outboard bearing on August 19. The licensee
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determined the cause to oe human error in that the individual misread the type of oil
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to be used from the computerized equipment database.
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Maintenance engineering determined that the oils were incompatible in that mixing
of the different oils in the pump bearing could result in sludge formation. The
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licensee's immedime corrective actions included draining, flushing, and placing the
correct oil in the bearing; performing a satisfactory inservice test; and counseling
the individual. The licensee estimated that there was not enough incompatible oil
added to result in bearing failure under any accident scenario. The licensee
performed checks to verify that the proper oil had been added to other pumps and
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motors and identified no additional problems.
Procedure UNT-005-007, " Plant Lubrication Program," Section 5.4.2, stated that
only lubricants specified on the information sheet in the Station Information
Management System shall be used in lubrication tasks. The f ailure to ensure the
correct oil was added to the CCW Pump A outboard bearing is a violation of
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TS 6.8.1.a. This licensee-identified and corrected violation is being treated as a
noncited violation, consistent with Section Vll.B.1 of the Enforcement Policy.
Specifically, the violation was identified by the licensee, was not willful, actions
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taken as a result of a previous violation should not have corrected this problem, and
appropriate corrective actions were completed by the licensee (50-382/9611-01).
c.
Conclusions
A nuclear auxiliary operator inadvertently read the wrong line item off a
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computerized database which resulted in the addition of the wrong type of oil to the
CCW Pump A outboard bearing. This error was a result of a lack of attention to
details and is considered a noncited violation.
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II. Maintenance
M1
Conduct of Maintenance
M1.1 General Comments
a.
Inspection Scope (61726,62707)
The inspectors observed all or portions of the following activities:
- WA01149811:
Replace RCP 2B mechanical seal
- WA01149346:
Troubleshoot / check calibration of Valve ACC-126B
- WA01147321:
VOTES testing of Valve SI-125B in accordance with
ME-007-047
- PE-005-004:
Control room envelope integrity test
- OP-903-068:
Emergency Diesel Generator A monthly surveillance
- STP-115-0154: Special test procedure - CCW system flow balance
b.
Observations and Findinas
in general, the inspectors found the work performed to be adequate. All work
observed was performed with the work authorization (WA) package and/or test
procedure present and in active use. Technicians were experienced and
knowledgeable of their assigned tasks. When applicable, appropriate radiation
control measures were implemented. However, certain maintenance activities
appeared to be in violation of NRC requirements or indicate problem areas, as
discussed below in Sections M1.2 and M4.1.
M1.2 On-Line Maintenance Risk Assessment for Unscheduled Work
a.
Inspection Scoce (62707)
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The inspectors performed a review of the licensee's process for ensuring that the
assessment of equipment removed from service considered the impact on the
performance of safety functions.
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b.
Observations and Findinos
During a review of scheduled maintenance activities performed on August 12-14,
1996, the inspectors noted that the licensee removed portions of the low-pressure
safety injection (LPSI), high-pressure safety injection (HPSI) and containment spray
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(CS) Train B systems from service in conjunction with the performance of
switchyard maintenance affecting batteries and a phase comparison relay.
Scheduling personnel performed a quantitative analysis of the on-line maintenance
using the risk monitor and determined that the activities involving LPSI, HPSI, and
CS constituted an ac'ceptable risk (plant safety index of 8.8 and a core damage
frequency increase of 2.79E-5). The inspectors noted that the analysis did not
include the impact of performing concurrent switchyard maintencnce. The risk
inonitor is a computer tool maintained by safety and engineering analysis and
utilized by planning and scheduling to quantitatively determine core damage
frequencies for on-line maintenance.
The switchyard battery maintenance involved installing and parallelling a temporary
battery, disconnecting the normal battery, performing activities on the normal
battery, and reconnecting the normal battery. The maintenance on the phase
comparison relay was performed in response to a failure causing one of the two
main transformer output breakers to open. The licensee stated that the shift
supervisor was aware of the switchyard maintenance activities and that based on
his understanding, no significant increase in risk occurred as a result of these
activities.
The inspectors noted that switchyard maintenance was not identified on the
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maintenance schedule, that scheduling was unaware of the switchyard maintenance
activities, and that the switchyard maintenance activities had not been factored into
the quantitative risk assessment. In response to the inspectors' concern,
scheduling f actored in the unplanned switchyard work in conjunction with the
planned LPSI, HPSI, and CS maintenance and determined that the resulting plant
safety index (6.1) and a core damage frequency increase (7.04E-4) were in the
"high risk" category. Scheduling stated that they would not have allowed the
performance of the maintenance activities associated with LPSI, HPSI, and CS had
they been aware of the switchyard maintenance activities.
The inspectors noted that the risk monitor enabled the user to select one of four
options for a potential loss of offsite power and that the licensee had not
established specific criteria associated with each of the four options. As of
August 14, scheduling arbitrarily assigned the worst case loss of offsite power
penalty into the risk monitor for any switchyard maintenance activity. The licensee
subsequently determined that the performance of the switchyard maintenance did
increase the risk of a potential loss of offsite power, but not to the degree in which
the scheduling department originally calculated.
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The inspectors questioned the licensee to determine if assessments of emergent or
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unscheduled maintenance activities on the overall effect on performance of safety
functions were being performed. Based on discussions with scheduling,
maintenance, and operations, the inspectors determined that the licensee routinely
did not quantitatively assess the impact of unscheduled maintenance on the
performance of safety functions. However, the licensee did perform a limited
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qualitative assessment in that the on-line maintenance philosophy only allowed
work on selected components within a single safety train and that maintenance on
components in separate safety trains or in conjunction with electrical power source
maintenance would not be performed.
The inspectors noted that the qualitative assessments, which were frequently
performed by the operations shift supervisor, were informal and relied primarily
upon the knowledge level of each individual (i.e., no checklist, matrix, or other tool).
The inspectors questioned several senior reactor operators to determine what
function the switchyard batteries performed. Based on these discussions, the
inspectors determined that the knowledge level of operations personnel regarding
the function of the switchyard batteries varied widely. Specifically, the range o'
responses provided to the inspector was from no knowledge of the battery fur;ction,
to back-up power supply to annunciators, to back-up power supply for protective
relays, to a full understanding of the purpose of switchyard batteries.
The inspectors noted that the shift supervisor's assessment of the qualitative risk
was not consistent with current on-line maintenance practices in that maintensnce
on one train of LPSI, HPSI, and CS were performed concurrently with mainteni nee
on an electric power source.
In response to the inspectors' observations, the lionsee commenced a review of
on-line maintenance controc. Interim corrective actions taken by the licensee
included, in part: (1) operations personnel ncofying scheduling of unscheduled
maintenance activities, (2) providing the operations shift support center with the
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risk monitor capability, and (3) providing personnel with a consistent methodology
to assess the risk of performing switchyard maintenance on a loss of offsite power.
The inspectors questioned the adequacy of the quantitative and qualitative
assessments for maintenance activities involving switchyard maintenance in
conjunction with LPSI, HPSI, and CS maintenance on August 12-14. The
inspectors concluded that the licensee's maintenance scheduling process did not
provide provisions for quantitative assessment of risk of unscheduled maintenance
activities. This issue will be tracked as an unresolved item pending an evaluation of
the licensee's risk assessment process by the NRC maintenance rule review
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committee (50-382/9611-02).
c.
Conclusions
The licensee's maintenance scheduling process did not include provisions for
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quantitative assessments of risk of unscheduled maintenance. Additionally, the
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qualitative assessments of maintenance on engineered safety features systems,
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concurrent with switchyard maintenance, was not implemented by the on-shift
operations staff consistent with established practices. The adequa.:y of the
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licensee's risk assessments for unscheduled maintenance is an unresolved item.
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M4
Maintenance Staff Knowledge and Performance
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M4.1 Inadvertent ACCW Pumo Start and System Waterhammer
a.
Insoection Scoce (62707)
The inspectors reviewed the circumstances surrounding an inadvertent automatic
start of ACCW Pump B and coincident waterhammer of the ACCW system following
maintenance on a CCW temperature control instrument loop.
b.
Observations and Findinas
On July 29,1996, ACCW Pump B automatically started when control power was
restored to the 4160-volt feeder breaker following maintenance on a CCW
temperature control instrument loop. The unexpected start of the ACCW pump
caused a waterhammer in the system. The susceptibility of the ACCW system to
waterhammer during an ACCW pump start due to void formation in the ACCW
system is discussed in NRC Inspection Report 50 382/95-23. Due to the potential
to damage ACCW system components from waterhammer, the licensee, by
procedure, shuts the pump discharge valve prior to starting the pump. Since this
was an inadvertent start, the discharge valve was open, and as a result, the system
experienced a waterhammer. The licensee walked down the system and
determined that the waterhammer event did not damage the system.
The licensee determined the cause of the inadvertent pump start was the failure to
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restore the CCW temperature control loop manual / automatic Station CC ITIC70708
setpoint to its original setting following maintenance. Manual / automatic Station
CC ITIC7070B provides control signals to Valve ACC-1268 (CCW heat exchanger
outlet temperature control valve), which in turn throttles CCW flow through the
CCW heat exchanger in order to maintain CCW temperature at a predetermined
setpoint. An automatic start signal is sent to the respective ACCW pump when the
CCW train temperature exceeds the manual / automatic setpoint by more than 10 F.
This particular pump start occurred because the manual / automatic station setpoint
was set at 50*F (minimum) when it was returned to service, while CCW water
temperature was 86*F.
As of the end of this inspection period, the licensee had not completed their root
cause assessment for this incident. The inspectors performed an independent
assessment and determined that the written instructions included in the WA
package for the maintenance on the CCW temperature control loop
manual / automatic station were not appropriate to the circumstances. Specifically,
WA01149346 did not address restoring the manual / automatic Station
CC ITIC70708 setpoint to its original setting following maintenance. The inspectors
observed that this activity did not appear to be within the skill of the craft. The
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failure to provide written instructions appropriate to the circumstances for CCW
temperature control loop maintenance is a violation of TS 6.8.1 (50-382/9611-03).
c.
Conclusions
The inspectors concluded that the WA did not provide instructions appropriate to
the circumstances for restoring the CCW temperature control loop to service
following maintenance.
M8
Miscellaneous Maintenance issues (92902)
M8.1 (Closed) Insoection Followuo item 50-382/9604-01: Review of the licensee's
evaluation on extending replacement scheduie for safety-related relays. The
licensee extended the replacement schedule for numerous safety-related Agastat
relays from 10 to 40 years, despite vendor guidance that the qualified life of the
relays was 10 years. The inspectors reviewed the licensee's evaluation for
extending the replacement schedule and determined that it followed acceptable
practices for determining the life of electric / electronic components; however, it did
not address the vendor's rationale for establishing 10 years as the replacement
interval. The inspectors were unable to clearly establish the relay vendor's basis for
selecting 10 years as the qualified life. However, the inspectors determined that
the vendor had not identified an anticipated failure mechanism for these relays that
would occur after some specific period of operation in excess of 10 years. The
inspector noted that these relays were included in the licensee's maintenance
program and are routinely tested. The inspectors noted that, per the licensee's
testing and corrective action programs, any relay failures that were the result of
age-related phenomenon would require evaluation of the replacement schedule. The
inspectors determined that the licensee's extension of the replacement schedule for
these relays was acceptable.
Ill. Enaineerina
E2
Engineering Support of Facilities and Equipment
E.2.1 Review of Facility and Eouloment Conformr,nce to Uodated Final Safety Analysis
Report (UFSAR) Descrirtion
A recent discovery of a licensee operating a facility in a manner contrary to the
UFSAR description highlighted the need for a special focused review that compares
plant prcctices, procedures and/or parameters to the UFSAR descriptions. While
performing the inspections discussed in this report, the inspectors reviewed the
applicable portions of the UFSAR that related to the areas inspected. The following
inconsistency was noted between the wording of the UFSAR and the plant
practices, procedures and/or parameters observed by the inspectors.
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containment fan coolers and shutdown cooling heat exchangers that were not
consistent with those demonstrated during a special test conducted in
, October 1995 and August 1996. This issue is discussed in Section E4.1.
E4
Engineering Staff Knowledge ind Performance
E4.1
CCW Flow issues
a.
Insoection Scoce (37551)
On August 12,1996, during the ultimate heat sink design basis self-assessment, a
question was identified by the self-assessment team regarding the low flow results
obtained during a CCW flow balance test performed during the last refueling outage
(RFO 7) and the impact on the TS flow requirements. The inspectors reviewed the
flow balance test results, CCW startup testing results, the licensee's operability
analysis, and the applicable UFSAR and TS sections.
b.
Observations and Findinas
TS Surveillance Requirement 4.6.2.2.b.2 requires verifying that, following a safety
injection actuati:.n signal, CCW flow to each containment fan cooler is greater than
or equal to 1325 gpm. The licensee's test to verify flow greater than 1325 gpm is
typically conducted with CCW in its normal alignment and, therefore, flows through
the containment f an coolers are greater than would be expected during a design
basis accident. Tests conducted with CCW in its normal lineup have always
resulted in flows through the coolers greater than 1500 gpm.
On August 12, a licensee self-assessment team noted that a special test, conducted
during RFO 7, with CCW in its accident lineup, demonstrated flows less than
1325 gpm to each containment fan cooler. The licensee generated Condition
Report (CR) 95-0955 to document and evaluate that CCW flow through the
containment fan coolers was less than the value specified in the UFSAR, which was
1350 gpm. The flow through the coolers was:
Train A
Containment Fan Cooler A 1300 gpm
Containment Fan Cooler C 1320 gpm
Train B
Containment Fan Cooler B 1200 gpm
Containment Fan Cooler D 1290 gpm
CR 95-0955 and its attached engineering analysis concluded that the containment
fan coolers remained operable as long as CCW flow was greater than 1100 gpm.
However, the CR did not address the applicability of TS Surveillance Requirement 4.6.2.2.b.2.
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in response to the self-assessment team's concern, the licensee performed an
assessment of the CCW flows through the coolers under accident conditions and
determined that the coolers remained operable and were in compliance with the TS
, operability requirements. The basis for the licensee's position was that the value of
1325 gpm, as specified in the TS, was a design assumption for analysis and not
intended as a minimum flow requirement through the containment fan coolers. The
licensee stated that the intent of TS Surveillance Requirement 4.6.2.2.b.2 was to
verify that the flow control valve for the cooler was fully open and not to verify
minimum accident flow rates would be achieved. The inspectors acknowledged the
licensee's position and the information was forwarded to NRR for a determination of
compliance with the TS.
The inspectors questioned the difference between the UFSAR value of 1350 gpm
and the TS value of 1325 gpm. It was determined by engineering that there is a
25 gpm tolerance for error for instruments used to measure CCW flow through the
coolers. The licensee stated that this tolerance was apparently applied in the wrong
direction to ensure 1350 gpm to each cooler. The inspectors noted that if the
instrument uncertainty had been applied appropriately, the TS value would be
1375 gpm.
CR 95-0955 documented degraded CCW through the shutdown cooling heat
exchangers (2900 gpm vice UFSAR value of 3000 gpm) in addition to the
containment fan coolers. The CR determined the apparent cause of the degraded
CCW flows was increased flow resistance through the dry cooling towers as a
result of fouling. The CR concluded that as long as flow through the containment
fan coolers exceeded 1100 gpm and flow through the shutdown cooling heat
exchangers exceeded 2600 gpm, no operability concern existed. Therefore, the
plant was started up with the expectation that the dry cooling tower tubes would
be cleaned during system outages and the CCW full-flow test would be reperformed
during the next refueling outage, scheduled for the spring of 1997. The dry cooling
tower cleaning was completed in February 1996.
On August 23, the licensee performed a CCW full-flow test after the dry cooling
towers were cleaned. The results of the August 23 test were:
Train A
Containment Fan Cooler A 1340 gpm
Containment Fan Cooler C .1310 gpm
Train B
Containment Fan Cooler B 1250 gpm
Containment Fan Cooler D 1370 gpm
These results indicated that at least one cooler in each train has CCW flow greater
than the TS required a minimum of 1325 gpm. These flowrates satisfied the
requirements for system operability as specified in TS 3.6.2.2.
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The issue of compliance with TS Surveillance Requirement 4.6.2.2.b.2 and the
1325 gpm flow requirement specified in the TS is unresolved pending review by
NRR (50-382/9611-04).
c.
Conclusions
The inspectors acknowledged the licensee's position that they were in compliance
with the TS requirements for CCW flow through the containment fan coolers
following a safety injection actuation signal. The inspectors determined that the TS
value of 1325 gpm through the coolers was the result of applying instrument error
in the wrong direction. The issue of compliance with TS Surveillance
Requirement 4.6.2.2.b.2 and the adequacy of the 1325 gpm value is unresolved
pending review by NRR.
E7
Quality Assurance in Engineering Activities (37551)
From August 12-16,1996, the licensee performed an engineering self-assessment
of the ultimate heat sink (CCW and ACCW systems). The self-assessment team
was composed of offsite engineering personnel (both Entergy and contractors)
knowledgeable in the subject areas. On August 12, the self-assessment team
questioned whether degraded CCW flows through the containment fan coolers
during previous full-flow testing indicated the coolers were not in compliance with
the TS surveillance requirement. The inspectors considered the self-assessment
team's identification of this issue to be a positive example of questioning attitude.
The technical aspects of this issue are discussed in Section E4.1. The issue of
compliance with TS Surveillance Requirement 4.6.2.2.b.2 is unresolved pending
review by NRR.
The inspectors attended the exit meeting for the licensee's ultimate heat sink
self-assessment team and noted the team provided valuable insights into the
ultimate heat sink deign basis, material condition, and operating practices.
E8
Miscellaneous Engineering issues (92700,92903)
E8.1
(Closed) Unresolved item 50-382/9510-03: Rosemount instrument transmitter
calibration errors. On November 2,1995, while reviewing main steam flow
calculations, the licensee discovered that the static pressure correction for some
safety- and nonsafety-related Rosemount differential pressure flow and level
transmitters was in error. The misapplication of the static pressure correction and
subsequent instrument calibrations resulted in safety injection tank (SIT) and steam
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generator indicated levels being higher than the actuallevel. Records indicated that
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the SIT actual levels were below the minimum level allowed by TS 3.5.1 for periods
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longer than the allowed outage time. The licensee submitted Licensee Event Report
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(LER)95-005 to address this issue. The inspectors left this item unresolved until
the licensee reviewed all other calculations associated with Rosemount transmitters
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to determine the extent of the problem and to review the licensee's corrective
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actions.
Subsequently, the licensee submitted LER 96-001, which again concerned
out-of-specification SIT levels. Due to the previous error corrections associated
with LER 95-005, two SIT levels were out-of-specification high, requiring entry into
TS 3.0.3 for 14 minutes. The licensee demonstrated that although the SIT levels
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were outside TS limits, they did not exceed the levels assumed in the safety
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analysis. Therefore, this event was of minor safety consequence.
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The inspectors evaluated the licensee's results of the calculation reviews. The
licensee identified a number of other errors in applying correction factors to
Rosemount transmitter outputs. These errors did not affect operability of any
safety-related Rosemount transmitters and were not safety significant. These items
were corrected upon discovery.
The two examples of f ailure to control SIT levels within the.TS limits is a violation
of TS 3.5.1. This licensee-identified and corrected violation is being treated as a
noncited violation, consistent with Section Vll of the NRC Enforcement Policy.
Specifically, the violation was identified by the licensee, was not willful, actions
taken as a result of a previous violation should not have corrected this problem, and
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appropriate corrective actions were completed by the licensee (50-382/9611-05).
E8.2 (Closed) LER 50-382/95-005: Rosemount instrument transmitter errors. This item
was addressed in Section E8.1 of this report.
E8.3 (Closed) LER 50-382/96-001: Entering TS 3.0.3 due to safety injection tank levels
reading high. This item was addressed in Section E8.1 of this report.
E8.4 (Closed) Insoection Followuo item (IFI) 50-382/9610-02: Review root cause and
corrective actions for RCP baffle bolt f ailures. On July 16,1996, the plant was
shut down when flow through the RCP 2B mechanical seal was lost. The licensee
removed the mechanical seal cartridge and found that all six bolts on the rotating
baffle, located immediately below the seal cartridge, were broken. The bolts are
used to retain the baffle to the RCP shaft. The baffle itself fits over and directs
controlled bleed-off flow through the seal heat exchanger to cool the water prior to
entering the seal cartridge.
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Examination of the mechanical seal found metallic particles within the pressure
breakdown device and between the seal faces. The licensee concluded that these
metallic particles were wear products that resulted from the baffle bolt f ailures. The
cause of the failure of the baffle bolts was determined to be loss of bolt preload.
Loss of preload reduces the clamping force of the joint between the baffle and the
RCP shaft and can result in relative motion between the baffle and bolts, which can
result in fatigue failure of the bolting. The most likely cause of loss of preload was
identified by the licensee as inadequate thread engagement. To prevent future bolt
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failures, the baffle bolts were modified to add 1/2 inch to their length. Additionally,
proper preload was ensured by measuring the elongation of the baffle bolts during
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installation.
- " On July 29-30, following the initial RCP 2B seal failure outage, the licensee again
experienced seal f ailure shortly after placing RCP 2B in service. The licensee
determined that the cause of this failure was blockage of the mechanical seal from
existing debris. The mechanical seal was again replaced and all potential sources of
debris were thoroughly cleaned and inspected. The pump was returned to service
on August 3 with no further seal problems experienced to date.
IV. Plant Support
P2
Status of Emergency Planning (EP) Facilities, Equipment, and Resources
P2.1
Tour of EOF
a.
Insoection Scooe (71750)
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On July 29,1996, the licensee distributed Inter-Office Correspondence
W3D3-96-0146, "Waterford 3 Technical Support Center (TSC) Staffing." The
correspondence indicated that when access to the control room envelope is limited
to a specified number of persons and an emergency occurs requiring staffing and
activation of the TSC, responders shall report to the EOF. The correspondence was
initiated in response to deficiencies involving leakage of the normal air intake
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Valves HVC-101 and -102 (See NRC Inspection Report 50-382/9621).
On August 14, the inspectors performed a walk through and inventory of the EOF
to ensure that the licensee would be able to accommodate inclusion of TSC
personnel in the EOF.
b.
Observations and Findinas
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The inspector observed that the EOF diesel generator fuel oil storage tank capacity
was 500 gallons and that the level was 225 gallons. EP personnel stated that the
diesel generator operated for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> every Tuesday which resulted in an
approximate 4 gallon decrease in fuel oil storage tank level. EP personnel also
stated that a task existed that required the fuel oil storage tank be drained and
refilled every year and that the task may not be performed frequently enough to
maintain a desirable quantity of fuel oilin the storage tank. Following the
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inspectors observation, EP personnel initiated a new task to verify the fuel oil
storage tank level once per month and to refill the tank if the level decreased to
300 gallons.
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The inspector observed that a plent monitoring computer user's guide was not
located at each operating station. in October 1995, the licensee replaced the old
plant monitoring computer with a new model. Because the user's guide had not
been approved by the licensee, EP personnel did not provide user instructions for
the ne.w plan't monitoring computer stations in the EOF. Following the inspectors'
observation, emergency planning provided copies of selected attachments from
Procedure OP-004-012, " Plant Computer System," at each operating station.
Emergency planning stated that the user's guide would be placed at each operating
station once the procedure was revised.
The inspectors observed that the licensee had the 1993 version of
NUREG/BR 0150, " Response Technical Manual," instead of the 1996 version. In
response to the inspectors' observation, the licensee obtained several copies of the
1996 NUREG/BR 0150 version. EP personnel stated that updated copies of
NUREG/BR 0150 were normally provided by the NRC when new revisions were
issued and that there had been a delay in the licensee's receipt of the updated
revision.
c.
Conclusions
The inspectors determined that allowing the EOF fuel oil storage tank level to
decrease below 50 percent and not providing a user's guide for the plant monitoring
computer were poor emergency planning practices.
V. Manaaement Meetinas
X1
Exit Meeting Summary
The inspectors presented the inspection results to members of licensee management
at the conclusion of the inspection on September 9,1996. The licensee
acknowledged the findings presented.
The inspectors asked the licensee whether any materials examined during the
inspection should be considered proprietary. No proprietary information was
identified.
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ATTACHMENT 1
PARTIAL LIST OF PERSONS CONTACTED
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Licensee
R. G. Azzarello, Manager, Maintenance
C. M. Dugger, General Manager, Plant Operations
J. J. Fisicaro, Director, Nuclear Safety
T. J. Gaudet, Acting Manager, Licensing
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D. C. Matheny, Manager, Operations
M. B. Sellman, Vice-President, Operations
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D. W. Vinci, Superintendent, System Engineering
A. J. Wrape, Director, Design Engineering
INSPECTION PROCEDURES USED
37551
Onsite Engineering
61726
Surveillance Observations
62707
Maintenance Observations
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71707
Plant Operations
71750
Plant Support Activities
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92901
Followup - Plant Operations
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92902
Followup - Maintenance
92903
Followup - Engineering
ITEMS OPENED. CLOSED, AND DISCUSSED
Opened
50-382/9611-01
Failure to follow procedures for oil addition to CCW pump
(Section 04.2)
50-382/9611-02
Adequacy of quantitative and qualitative assessments for
risk of switchyard work in conjunction with other work
(Section M1.2)
50 382/9611-03
Inadequate written instructions for CCW temperature
control loop work (Section M4.1)
50-382/9611-04
Compliance with TS Surveillance Requirement 4.6.2.2.b.2
and adequacy of 1325 gpm value (Section E4.1)
50-382/9611-05
Rosemount transmitter calibration errors (Section E8.1)
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Closed
50-382/9510-03
Rosemount instrument transmitter calibration errors
(Section E8.1)
50 382/9604-01
IFl
Review licensee's evaluation on extending replacement
schedule for safety-related relays (Section M8.1)
50-382/9611-01
Failure to follow procedures for oil addition to CCW pump
(Section 04.2)
50-382/9611-05
Rosemount transmitter calibration errors (Section E8)
50-382/9610-02
IFl
Review root cause and corrective actions for RCP baffle
bolt failures (Section E8.4)
50-382/95-005
LER
Rosemount instrument transmitter errors (Section E8.2)
50-382/96-001
LER
Entering TS 3.0.3 due to safety injection tank levels
reading high (Section E8.3)
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LIST OF ACRONYMS USED
Auxiliary Component Cooling Water.
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Component Cooling Water
CR
Condition Report
EO'F
Emergency Operating Facility
EOS
Equipment Out-of Service
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Emergency Planning
gpm
Gallons Per Minute
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High Pressure Safety injection
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IFl
Inspection Followup item
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LCO
Limiting Conditions for Operation
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LER
Licensee Event Report
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LPSI-
Low Pressure Safety injection
NRC
- Nuclear Regulatory Commission
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Office of Nuclear Reactor Regulation
Public Document Room
P
Reactor Coolant Pump
Refueling Outage
Safety injection Tank
TS
Technical Specifications
Updated Final Safety Analysis Report
WA
Work Authorization
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