ML20129K236

Insp Rept 50-382/96-12 on 960901-1012.Violations Noted.Major Areas Insp:Operations,Maint,Engineering & Plant Support

ML20129K236
Person / Time
Site:	Waterford
Issue date:	11/04/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20129K233	List: ML20129K231 ML20129K234 ML20129K236
References
50-382-96-12, NUDOCS 9611130075
Download: ML20129K236 (18)

See also: IR 05000382/1996012

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ENCLOSURE 2

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U.S. NUCLEAR REGULATORY COMMISSION

REGION IV l

Docket No.: , 50-382  ;

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l- License No.: NPF-38

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Report No.: 50 382/96-12

Licensee: Entergy Operations, Inc.

Facility: Waterford Steam Electric Station, Unit 3

! Lccat'on: Hwy.18

Killona, Louisiana

Dates: September 1 through October 12,1996

Inspectors: L. A. Keller, Senior Resident inspector

T. W. Pruett, Resident inspector .

G. A. Pick, Project Engineer l

C. A. Clark, Reactor inspector l

Approved By: P. H. Harrell, Chief, Project Branch D

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ATTACHMENT: Supplemental Information

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961113007'5 961104

, PDR ADOCK 05000382

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EXECUTIVE SUMMARY

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Waterford Steam Electric Station, Unit 3

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NRC Inspection Report 50-382/96-12

This routine, announced inspection included aspects of licensee operations, maintenance,

engineering, and plant support. This report covers a 6-week period of resident inspection.  ;

Ooerations

• All observed activities were conducted professionally and were consistent with safe

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operation of the facility (Section 01.1),

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Maintenance

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• The f ailure of personnel to use measuring and test equipment (M&TE), as required

l by procedures, indicated that the licensee had not resolved previously-identified

l compliance deficiencies associated with the use of M&TE and is a violation of

Technical Specification (TS) 6.8.1.a (Section M1.2).

• The licensee-identified conditions related to the emergency feedwater (EFW) system

were appropriately addressed. A noncited violation was identified for not

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performing a test before adjustment of the EFW pump turbine governor

(Section M1.3).

• The fasteners for the limit switch covers on four safety-related, motor-operated

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valves (MOV) were of questionable material. The fastener discrepancies did not

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affect valve operability for these particular valves. The licensee identified suspect

or missing fasteners on several safety-related MOVs applications that potentially

affected operability. This issue remains unresolved pending additional NRC review

of the fastener assessments (Section M2.1).

• The painting and preservation program failed to identify unacceptable corrosion on

! the seismic supports for Valve CC-134B (Dry Cooling Tower B bypass valve) air

accumulator. The failure to properly maintain the seismic supports for the

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! Valve CC-1348 air accumulator is a noncited violation (Section M2.2).

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Encineerina

a Engineering provided good technical support and good teamwork was exhibited

among the various disciplines in effectively resolving the Valve CC-1348 air

accumulator. seismic support issue in the short time period available (Section M2.2).

j * The inspectors concluded that the use of wet cooling tower (WCT) basins as a

source of EFW, in lieu of the condensate storage pool, would be inappropriate due

to the inability to meet the EFW design bases in terms of minimum temperature and

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inventory. The failure to ensure that the WCT basins met all EFW design bases

requirements is a violation of 10 CFR Part 50, Appendix B, Criterion lif

(Section E8.4).

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Plant Succort

• All plant support activities observed were satisfactory (Section R1.1).

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l Reoort Details l

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l Summarv of Plant Status

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l The plant operated at essentially 100 percent power during this inspection period.

l. Operations

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01 Conduct of Operations

01.1 General Comments (71707)

i The inspectors conducted frequent reviews of ongoing plant operations, control

l room board walkdowns, and plant tours. All observed activities were conducted i

professional!y and were consistent with safe operation of the facility. Operators j

displayed good knowledge of plant status and understood the reason why control l

room annunciators were lit.

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O2.2 Review of Ooerations Combined Deficiency List (71707) l

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l The inspectors evaluated whether the licensee had implemented appropriate I

measures and administrative controls for the following components on the

operations combined deficiency list:

• Pressurizer Normal Spray Valve B

• Steam Generator 1 Outside Containment Blowdown Isolation Valve  !

• Containment Sump Level Indicators )

• Accumulators for Valves CC-641 and CC-713 i

• Component Cooling Water (CCW) and Auxiliary Component Cooling Water

(ACCW) Crossconnect Valves

The inspectors determined that the licensee appropriately addressed the hardware

deficiencies listed above. No concerns were identified with respect to system

operability and/or the capability to respond to an emergency.

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08 Miscellaneous Operations issues

08.1 Review of institute of Nuclear Power Ooerations Report (71707)

The inspectors reviewed the Institute of Nuclear Power Operations report titled,

"WAT-3 SES 3/96 Evaluation." The inspectors concluded that the report did not

l identify any operational or safety concerns that were not previously known by the  ;

j NRC and, as a result, no additional followup is planned. '

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II. Maintenance

M1 Conduct of Maintenance

M1.1 General Comments

a. Insoection Scope (61726,62707)

The inspectors observed all or portions of the following activities:

• WA 01151150: Calibrate CCW Header B Flow Loop

• OP-903-004: Boric Acid Pump Operability Check

• OP-903-904: Engineered Safety Features Actuation Systems (ESFAS)

Subgroup Relay Test

• WA 01151341: Rework Rusted Accumulator Legs For Valve CC-134B

b. Observations and Findinas

in general, the inspectors found the conduct of maintenance and surveillance to be

adequate. All activities observed were performed with the work authorization (WA)

package and/or test procedures present. Technicians were experienced and

knowledgeable of their assigned tasks. When applicable, appropriate radiation

control measures were implemented. However, certain activities violated NRC

requirements or indicated performance problems, as discussed below.

M1.2 Failure To Comotv With Procedural Reauirements For M&TE

a. Insoection Scone (61726)

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The inspectors reviewed completed inservice testing documents for Boric Acid

Makeup (BAM) Pump A performed in accordance with Procedure OP-903-004,

" Boric Acid Pump Operability Check," and Blowdown isolation Valves BD-102 A(B)

i and BD 103 A(B) performed in accordance with Procedure OP-903-094, "ESFAS

I Subgroup Relay Test - Operating," to determinc if testing of the components was

consistent with regulatory requirements.

b. Observations and Findinas

Procedure OP-903-004, Section 3.2, " Limitations," indicated that the full-scale

range of pressure and fluid flow instruments shall be three times the reference value

or less and that the reference value shall not exceed 70 percent of the range for

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digitalinstruments. The inspectors noted that the range of digital test Pressure

Gauge ODPT 353.013 (0-50 psig) exceeded three times the reference suction

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l pressure of BAM Pump A (10.8 psig). The inspectors also noted that the

documented suction pressure was consistent with past surveillance tests and that

the pressure reading did not affect the test results.

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Subsequently, the licensee acknowledged that the procedural requirements were not

followed and initiated a condition report (CR) to document the inconsistency

between pressure test gauges described in surveillance procedures and

NUREG 1482, " Guidelines for Inservice Testing at Nuclear Power Plants."

NUREG 1482 recommended that the requirements in Operations and Maintenance [

Standards Part 6 for digital instruments apply during inservice testing. Specifically, l

digital instruments should be selected such that the reference value does not

exceed 70 percent of the calibrated range of the instrument and the accuracy must

be within 2 percent over the calibrated range. If these requirements for digital

instruments are met, the licensee need not request relief from Subsection IWP of

ASME Code,Section XI. The inspectors noted that the requirements for digital

instruments as described in the Operations and Maintenance Standards were met

during the BAM Pump A surveillance test.

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The inspectors noted that NRC Violation 50-382/9508-01 (November 1995) t

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resulted from failure to use the correct M&TE described in procedures for testing of

main steam safety valves and electrical relays. NRC Violation 50-382/9509-01

(December 1995) resulted from failure to remove suspect M&TE from service.

Because of the recent similar failures of personnel to follow procedures with respect

to use of M&TE, the inspectors determined that failure to use the correct p' essure

gauge is a vsolation of TS 6.8.1.a (50-382/9612-01).

c. Conclusions

The implementation of surveillance requirements for BAM Pump A and

Valves BD-102A(B) and BD-103A(B) were adequate. The inspectors identified one

violation in which personnel used M&TE that did not meet the limitations described

in the surveillance procedure. The failure to ensure that the correct M&TE is used

by personnel indicated that the licensee had not fully resolved deficiencies

associated with the use of M&TE.

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M1.3 Review of Conditions identified with the EFW System

a. Inspection Scope (92903)

The inspectors reviewed CRs 96-0841, -0819, -0877, -0919, -1321 to

independently verify that the licensee had adequately resolved these documented

EFW system deficiencies. The inspectors Jiscussed the detaile of each CR with the

i system engineer.

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b. Observations and Findinas

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The licensee had :xperienced problems with the governor for the EFW

turbine-driven pump since startup from the last outage in December 1995. The l

governor had difficulty maintaining the turbine speed at a predetermined setpoint '

and, as a result, the speed remained slightly elevated. The increased turbine speed

resulted in a pump discharge pressure of approximately 1440 psig, which exceeded  :

the 1400 psig rating of the system discharge piping. The licensee completed an  !

evaluation to establish that the greater pressure did not affect the operability of the

system. This evaluation was reviewed, and no concerns were identified.

In an effort to reduce the pump discharge pressure below the operating pressure

limit for the piping and return the system to its normal operating limits, the system

engineer performed periodic turbine governor adjustments to reduce the turbine

speed. Prior to adjustment of the governor, the pump is required to be operated to

verify that the pump is still performing satisfactorily based on the previous baseline

data. This verification test ensures that no equipment degradation occurred

between tests and that readjustment of the governor would not mask a potential

operational concern.

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A test was not performed prior to adjusting the turbine governor to reduce the

turbine speed on August 25,1996. Subsequent to the performance of the test, it

was noted that a test should have been conducted. Upon discovery of this error,

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the system eagineer compared the data obtained after the governor was adjusted

and previous test data. The engineer determined that no degradation concerns

existed and that the pump remained fully operable. The inspectors reviewed the

data and did not identify any concerns.

Section IWP-3110 in Section XI of the ASME Code allows a change to reference  !

values, as long as an inservice test at the conditions of an existing set of reference

values is performed and the results analyzed. When the results are verified as being

satisfactory, then a second test is to be performed at the new reference cc.iditions j

and these results are then used to establish the new set of reference values. The j

licensee failed to perform these actions, which is a violation of TS 4.0.3.

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This licensee identified and corrected violation is being treated as a noncited

violation, consistent with Section Vll.B.1 of the Enforcement Policy. Specifically, l

the violation was identified by the licensee, was not willful, actions taken as a result i

of a previous violation should not.have corrected this problem, and appropriate l

corrective actions were completed by the licensee (50-382/9612-02).

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c. Conclusions i

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The system engineer adequately addressed the technical issues associated with  !

each CR, except for CR 96-1321. A noncited violation resulted because engineers

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changed the operating conditions for the turbine-driven EFW pump without verifying

no degradation existed, as specified by Section XI of the ASME.

M2 Maintenance and Material Condition of Facilities and Equipment

M2.1 Fastener issues

a. Inspection Scope (62707,92903)

The inspectors performed a plant walkdown to verify the effectiveness of corrective

actions implemented to improve the material condition of the plant. Because of

problems identified by the inspectors, and subsequently by the licensee, related to  ;

the use of questionable and/or missing fasteners, the inspectors reviewed the j

specific applications in terms of the impact on component operability. l

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b. Observations and Findinas  !

On September 18,1996, the inspectors noted that some of the fasteners installed

on the limit switch cover for Valve SI-139B (Iow pressure safety injection header to

Reactor Coolant Loop 1 A flow control) appeared to be nonconforming. The valve

operator manufacturer, Limitorque, specified that the hex head cap screw fasteners  ;

for the operator limit switch cover should be Grade 5 or better. Some of the cap

screws (and associated lockwashers) installed on Valve SI-139B appeared to be ,

manufactured from a brass or bronze material and were not magnetic, which l

indicated that these cap screws were probably not Grade 5 or better. Subsequent

inspections noted that similar fasteners were installed on Valves SI-138A (Iow

pressure safety injection to Reactor Coolant Loop 2B flow control), Valve SI-138B

(Iow pressure safety injection to Reactor Coolant Loop 18 flow control) and l

Valve SI-139A (Iow pressure safety injection header to Reactor Coolant Loop 2A

flow control) and that all four valves were missing at least one lockwacher.

On September 19, in response to the inspectors' observations and questions, the

licensee issued CR 96-1455. CR 96-1455 noted that the limit switch cover

fasteners of the subject valves did not appear to be Grade 5 material, but the

fastener material for these particular applications was not an apparent operability

concern. The inspectors agreed that no operability concern existed for these

specific fastener applications but expressed concern over the generic implications

for control of fasteners.

! On October 1, licensee personnel initiated a walkdown of safety-related MOVs to

! inspect critical components for the presence of the correct-fastener material. The

licensee identified numerous MOV fastener deficiencies, including discrepancies

associated with eight different valves, which potentially affected operability.

Subsequently, the licensee either declared the valve out of service or performed an

operability evaluation. As a result of Valves BAM-133A (boric acid tanks to

charging pump suction), SI-120B (Si recirculating header to RWSP upstream

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isolation), and SI-1218 (Si recirculating header to RWSP downstream isolation)

being declared out of service, the licensee entered TS Limiting Conditions for

Operation (LCO) 3.1.2.2, _"Boration Flowpath," and 3.5.2, " Emergency Core Cooling

System," respectively. The questionable fasteners on Valves BAM-133A, SI-1208,

and SI-121B were replaced with qualified fasteners, the TS LCOs exited on

October 3, and the questionable fasteners sent offsite for laboratory analysis,

ihcause of the identified MOV fastener discrepancies, the licensee formed a root

cause analysis team to determine the root cause and identify the corrective actions

fnr the specific issue of fastener controls with respect to MOVs, as well as

determining any generic implications to ensure the issue was fully bounded. Since

the root cause analysis team continued to evaluate this issue, review of licensee

actions to resolve the use of fasteners in safety-related applications is an unresolved

item (50-382/9612-03).

c. Conclusions

The inspectors reviewed the MOV inspection results and the completed operability

evaluations and concluded that the licensee had entered all the appropriate TS

LCOs. Additional NRC inspections / reviews are needed to determine the scope and

implications of the use of fasteners in safety-related applications.

M2.2 External Corrosion Problems With a Safetv-Related Air Accumulator

a. Insoection Scone (62707)

The inspectors reviewed the circumstances associated with Valve CC-1348 being

declared inoperable because of significant corrosion of the associated air

accumulator.

b. Observations and Findinas

On October 3, because of control of fastener issues (Section M2.1), the licensee

inspected various fasteners throughout the plant. While attempting to remove paint

from the supports for the Valve CC-134B air accumulator tank to inspect the

fasteners, the licensee discovered that two of the four supports were completely

corroded away and a third support had only a small percentage of metal remaining.

The licensee declared Valve CC-134B out of service, which required entry into the

TS LCO 3.7.3 for CCW Train B. Entering TS LCO 3.7.3 required declaring the

Train B Emergency Core Cooling System inoperable and entering TS LCO 3.5.2,

which has an allowed outage time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. However, since this LCO had

already been entered because of fastener problems with Valves SI-1208 and

SI-1218, only 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> remained to resolve the Valve CC 134B air accumulator

issue before a plant shutdown would be required.

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The licensee restored the Valve CC-134B accumulator to operable before the TS

LCO expired by utilizing the supports from another nonsafety-related accumulator.

The inspectors noted that engineering provided good technical support for this issue

and that the various disciplines exhibited good teamwork in effectively resolving this

issue in the short time period available.

Valve CC-134B bypasses sections of Dry Cooling Tower B following postulated

damage from a tornado. The accumulator provides a 2-hour air supply for

Valve CC-134B following the loss of instrument air and is bolted to the concrete

basemat in the Dry Cooling Tower B area. This location is open to the atmosphere,

is subject to rain water, and is subject to spray from the WCT basin. The licensee

walked down both dry cooling tower areas to determine if any other components

had significant corrosion. Several components had evidence of external corrosion

but were not considered to be operability concerns. The inspectors conducted an

independent walkdown and did not identify any operability concerns. As part of

their corrective actions, the licensee was reviewing their inspection and preservation

program for components exposed to the atmosphere.

The failure to properly maintain the seismic supports for the accumulator for

Valve CC-1348 in accordance with Procedure NOCP-210 " Maintenance and

Construction Painting," is a violation of TS 6.8.1.a. Procedure NOCP-210 requires

that oil, rust, grease, dirt, dust, and other foreign materials be removed prior to I

painting. 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

taken as a result of a previous violation should not have corrected this problem, and

appropriate corrective actions were completed by the licensee (50-382/9612-04).

c. Conclusions

The painting and preservation program failed to prevent unacceptable corrosion on

the seismic supports for the Valve CC-134B air accumulator. Engineering provided

good technical support for this issue and the various disciplines exhibited good

teamwork by effectively resolving this issue in the short time period available. The

failure to properly maintain the seismic supports for the Valve CC-1348 accumulator

is considered a noncited violation.

M8 Miscellaneous Maintenance issues (92902)

M8.1 (Closed) Insoection Followuo item 50-382/9403-04: Review licensee corrective

actions for hoist drive failure. On March 9,1994, during Refueling Outage 7, the

refueling machine control element assembly (CEA) hoist box dropped unexpectedly

and struck the fuel transfer system drive column. The licensee determined that the

CEA hoist bearing retainer plate had failed causing the hoist reel to freewheel and

drop the hoist box. The licensee determined that the existing CEA hoist would not

be used for future CEA movement. Instead, a new design hoist would be installed

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in accordance with Design Change 3435 prior to Refueling Outage 8. The l

inspectors determined that the licensee had implemented appropriate corrective

actions to address this item.

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M8.2 (Closed) Inspection Followuo item 50-382/94402-01: Lack of formal

documentation of quality process surveys. This item noted that during Refueling

Outage 6, the quality assurance nondestructive examination survey observations j

were not formally documented at the time they were performed in the field. The  !

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inspectors were concerned that this practice would result in the audits not

thoroughly describing the process surveys performed. The licensee noted that while

observing activities in the field, quality assurance personnel used audit checklists l

and took notes, as required, to assist them later in preparing audit reports. The j

licensee also noted that when conditions requiring corrective action were observed

during the process surveys, the conditions were promptly documented in

accordance with the corrective action program. The inspectors determined that the )

current practice in this area was adequate.

M8.3 (Closed) Violation 50-382/9513-03: Plant material condition deficiencies. This item

noted examples of plant material condition deficiencies that had not been identified

by licensee personnel. The licensee initiated various actions via various condition i

identification documents and CRs to address and correct the identified deficiencies. I

The inspectors reviewed the corrective actions implemented for the identified '

examples and toured various areas of the plant. The inspectors determined that

adequate corrective actions were taken for the identified examples.

Ili. Enaineerina

E2 Engineering Support of Facilities and Equipment

E.2.1 Review of Facility and Eauioment Conformance to Updated Final Safety Analysis

Report (UFSAR) Descriotion

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 practices, 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

inconsistencies were noted between the wording of the UFSAR and the plant

practices, procedures and/or procedures observed by the inspectors.

The inspectors reviewed the applicable sections of the UFSAR and Design Basis

Document W3-DBD-007, " Chemical and Volume Control System," and noted that

the normal operating temperature for BAM Pump A(B) in UFSAR Table 9.3-9 and

W3-DBD-007 was 70 F and 150 F, respectively. The actual normal operating

temperature of BAM Pump A(B) is approximately 100-110 F. The licensee stated

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l that the discrepancies would be corrected in the next revision of UFSAR Table 9.3-9

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and W3-DBD-007. This identified discrepancy did not affect system operability.

l E8 Miscellaneous Engineering issues (92903)

E8.1 (Ocen) Inspection Followuo item 50-382/9325-03: Evaluation of the results of the

CCW heat exchanger corrosion monitoring program. This item involved a review of

l the CCW heat exchanger corrosion monitoring program. The licensee reviewed the

CCW heat exchanger corrosion monitoring program from December 11-15,1995.

The inspectors reviewed the results of this latest self-assessment, as documented in

an inter-office correspondence dated February 3,1996. The self-assessment

identified areas for improvement in the CCW heat exchanger corrosion monitoring

program. The licensee continued to implement corrective actions to improve the

evaluative information provided by this program. This item will rernain open

pending review of the implementation of the latest corrective actions for the

corrosion monitoring program.

E8.2 (Closed) Violation 50-382/9403-02: Failure to control approved design basis. This

issue involved the failure of the licensee to ensure the design basis was maintained.

The NRC-approved burnup for the specified acceptable fuel design limits was

exceeded in Cycles 4 and 5 reactor core designs, as well as in the operational

cycles. The licensee identified that the root cause as miscommunication between

Waterford 3 and the NRC and a failure to follow procedures. The inspectors

determined that the licensee had implemented adequate instructions to personnel on

when specific license amendments would be required to be submitted to the NRC

regarding approval of new higher fuel burnups.

E8.3 LClosed) Miolation 50-382/9522-04: Failure to perform integrated leak test. This

issue involved the failure to perform a surveillance test required by TS 6.8.4.a at

each refueling cycle interval or less (i.e., less than 18 months). The licensee

identified the root cause as the misapplication of the TS 4.0.2 interval extension to

the Administrative Controls section of TS. The licensee noted repetitive tasks / tests

scheduled in the System Information Management System had a 25 percent

extension automatically added to the task interval, which established " late dates"

for these tasks. The licensee performed a review of all repetitive surveillance tasks

and revised the task intervals, as required, to ensure the TS surveillance " late date"

did not exceed the interval specified in TS Section 6.0. The licensee also reviewed

the Commitment Management System and verified no 25 percent interval extension

had been added to the due dates in that system. A caution was also added to the

procedure used for implementation of TS changes to ensure that a surveillance

interval extension was not added to any TS surveillance other than those addressed

by TS 4.0. The inspectors determined that the corrective actions were adequate.

E8.4 (Closed) Unresolved item 50-382/9605-08: Review of the adequacy of the WCT

basin as a source of water for the EFW system. The inspectors identified a concern

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related to use of the water in the WCT basins as a source of EFW because of the

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l potential for the basin water to decrease below the 70*F minimum assumed in the

steam generator technical manual and the Waterford 3 Chapter 15 safety analyses.

The' inspectors noted that TS 3.7.1.3 allowed the condensate storage pool to be

l inoperable for up to 7 days provided the WCT basins were available as a backup

l supply to the EFW pumps. Additionally, UFSAR Section 10.4.9, " Emergency

Feedwater System," stated, in part, that the suction to EFW pumps is capable of

being provided from two WCT basins, following emergency shutdown caused by

the design-basis tornado. This event requires EFW exceeding the amount stored in

! the condensate storage pool due to postulated tornado generated missile damage to

the wet cooling towers.

The inspectors noted that there were no temperature controls on the WCT basin;

therefore, water potentially colder than that assumed in the accident analyses could

be used by the EFW system. The inspectors also noted that the Combustion

Engineering Technical Manual for the steam generators stated, in part, that cold

feedwater at not less than 70 F may be introduced into the unit. The licensee

stated that WCT basin temperature had been as low as 57*F. The licensee also

indicated that the WCT basins had never been aligned to the EFW system.

Combustion Engineering confirmed that a minimum EFW temperature of 70*F was a

design basis assumption and that a reduction in the minimum temperature would

require reanalysis regarding steam generator structural integrity and the impact on

the Chapter 15 safety analyses. Combustion Engineering anticipated being able to

reduce,the minimum assumed temperature to 40 F since this temperature was used

for another plant of a similar design and found to be an acceptable condition. As of

the end of this inspection period, Combustion Engineering had not completed the

Waterford 3 plant specific analyses in order to reduce the minimum assumed EFW

temperature to 40*F.

On September 17,1996, the licensee identified in CR 96-1441 that the basis for

allowing the WCT basins to be used as the EFW supply, in lieu of the condensate

storage pool, was also unsupported from an inventory standpoint. Following a loss

of cooling accident, the WCT can consume as much as 168,000 gallons of basin

water to dissipate the heat required by the ultimate boat sink. Since the total

capacity of each WCT basin is approximately 174,000 gallons, the requirement of

170,000 gallons of water for EFW would not be met following a loss of cooling

accident, if the WCT basins were the primary source of EFW, assuming a single

failure (i.e., ACCW pump) and the evaporative losses that would occur.

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On September 26, licensing issued Interoffice Letter W3F1-96-0169 to operations

which stated, in part, that during a design basis loss of cooling accident, a WCT

basin does not contain enough water to supply EFW and perform its heat removal

requirements for the ultimate heat sink. The letter indicated that if the WCT basins

were aligned to EFW, there would not be enough water for EFW or the ultimate heat

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sink and that both trains of ACCW (ultimate heat sink) would be inoperable, which  !

is prohibited by TS. The letter went on to recommend that entry into TS 3.7.1.3  ;

Action (b) be prohibited.

The inspectors concluded that the use of WCT basins as a source of EFW, in lieu of

the condensate storage pool, would be inappropriate because of the inability to

meet the EFW design bases in terms of minimum temperature and inventory. The

failure to assure that the WCT basins were capable of meeting all EFW design bases

requirements is a violation of 10 CFR Part 50, Appendix B, Criterion 111

(382/9612 05).  !

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IV. Plant SuDDOrt

R1 Radiological Protection and Chemistry Controls j

R1.1 General Comments (71750) ,

The inspectors made frequent tours of the radiologically protected area and noted

good radiological housekeeping and worker awareness of radiological hazards. The

inspectors also noted adequate radiological work practices during the jobs observed. '

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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 October 15,1996. The licensee

acknowledged the findings presented. l

The inspectors asked the licensee whether any materials examined during the I

inspection should be considered proprietary. No proprietary information was l

identified.

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ATTACHMENT

SUPPLEMENTAL INFORMATION

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PARTIAL LIST OF PERSONS CONTACTED 4

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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

K. V. Le, Engineer, Maintenance Engineering

D. C. Matheny, Manager, Operations l

M. B. Sellman, Vice-President, Operations

D. W. Vinci, Superintendent, System Engineering

A. J. Wrape, Director, Design Engineering

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INSPECTION PROCEDURES USED

37551 Onsite Engineering

61726 Surveillance Observations

62707 Maintenance Observations

71707 Plant Operations

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71750 Plant Support Activities

92902- Followup-Maintenance

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92903 Followup-Engineering

ITEMS OPENED, CLOSED, AND DISCUSSED .

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I- Ooened

50-382/9612-01 VIO Failure to follow procedure for M&TE requirements

(Section M1.2)

50-382/9612-02 NCV Failure to perform a test before adjustment of the turbine

(Section M1.3)

50-382/9612-03 URI Review the licensee's actions regarding the use of

fasteners in safety-related applications

(Section M2.1)

50 382/9612-04 NCV Failure to maintain seismic supports for the Valve CC-1348

air accumulator (Section M2.2)

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1 50-382/9612-05 VIO Inadequate analysis for WCT basin water as a source of

EFW (Section E8.4) j

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Closed

l 50 382/9612 02 NCV Failure to perform e test before adjustment of the turbine ,

(Section M1.3)

50-382/9612-04 NCV Failure to maintain seismic supports for the Valve CC-1348 ,

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air accumulator (Section M2.2)

50-382/9403 04 IFl Review licensee corrective actions for. hoist drive failure

(Section M8.1)

50-382/94402-01 IFl Lack of formal documentation of quality process surveys

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(Section M8.2)

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l 50-382/9513-03 VIO Plant material condition deficiencies (Section M8.4) l

50-382/9403 02 VIO Failure to control approved design basis (Section E8.2)

50-382/9522-04 VIO Failure to perform integrated leak test (Section E8.3)

50-382/9605-08 URI Review of the adequacy of the WCT basin as a source of

water for the EFW system (Section E8.4)

Discussed

50-382/9325 03 IFl Evaluation of the results of the CCW heat exchanger

corrosion monitoring program (Section E8.1)  !

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LIST OF ACRONYMS USED

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ACCW . Auxiliary Component Cooling Water i

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ASME American Society of Mechanical Engineers

! BAM Boric Acid Makeup

CCW Component Cooling Water

l CEA Control Element Assembly

l CFR Code of Federal Regulations j

CR Condition Report

Emergency Feedwater I

! EFW 1

ESFAS Engineered Safety Features Actuation Systems j

LCO Limiting Condition for Operation  !

LOCA Loss-of-Coolant Accident

l M&TE Measuring and Test Equipment j

MOV Motor-Operated Valve

! NRC Nuclear Regulatory Commission

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PDR Public Document Room

psig pounds per square inch gauge

OC ~ Quality Control

! RFO Refueling Outage

TS Technical Specifications

UFSAR Updated Final Safety Analysis Report

WA Work Authorization

WCT Wet Cooling Tower

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