ML20132G077

Insp Rept 50-382/96-13 on 961013-1130.Violations Noted.Major Areas Inspected:Operations,Maint,Engineering & Plant Support

ML20132G077
Person / Time
Site:	Waterford
Issue date:	12/19/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20132G036	List: ML20132G034 ML20132G055 ML20132G077
References
50-382-96-13, NUDOCS 9612260175
Download: ML20132G077 (20)

See also: IR 05000382/1996013

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ENCLOSURE 2

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-382

License No.: NPF-38

Report No.: 50-382/96-13

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Licensee: Entergy Operations, Inc.

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Facility: Waterford Steam Electric Station, Unit 3

Location: Hwy.18

Killona, Louisiana l

Dates: October 13 through November 30,1996 l

Inspectors: L. A. Keller, Senior Resident inspector

T. W. Pruett, Resident inspector  :

D. Proulx, Resident inspector, River Bend Station

G. A. Pick, Project Engineer )

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

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9612260175 961219

PDR ADOCK 05000382

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EXECUTIVE SUMMARY J

Waterford Steam Electric Station, Unit 3

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NRC Inspection Report 50-382/96-13  ;

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

engineering, and plant support. The report covers a 7-week period of resident inspection.

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Operations

-* The licensee identified three examples of f ailure to maintain configuration control.

These failures were identified as examples of a violation of Technical

Specification (TS) 6.8.1.a. For all three examples, there were control room panel

indications of the abnormal configuration which were readily available to the control

room operatcrs. This is of particular concern since several shift turnovers occurred

before the abnormal operating configurations were identified. The direct safety

significance of each of these incidents was minor; however, poor configuration

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control discipline and poor control room panel walkdowns represent generic

concems for the conduct of operations (Section 02.1).

• The inspectors identified one poor operations work practice involving the

determination of the gagged-closed position of Containment Fan Cooler Isolation

' Valves CC-807A and CC-823A. This revealed an operator knowledge deficiency

and. willingness to proceed in the face of uncertainty (Section 04.1).

l * Operations' peer check process for reactivity manipulations and the control board

operator's verification of control switches prior to operation were good during a

i boration activity (Section 04.2).

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e The operators' failure to recognize the effect of the curtains on the operability of the

WCT fans represented an operator knowledge deficiency and was contributed to by

a lack of thorough engineering, evaluation. The failure to enter the TS limiting

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conditions for operation for the inoperable wet cooling tower (WCT) fans is a

l violation of TS 3.7.4.f (Section 08.1).

Maintenance

• The inspectors identified a violation for the failure to perform inservice testing which

i verified the operational readiness of the dry cooling tower manual inlet and outlet  !

isolation valves. The inspectors determined that the review of IST requirements for

the CCW system did not identify all of the requirements for testing due to the poor

documentation of the design-basis tornado event (Section M1.2).

Enaineerina

• Engineering's review of inservice testing requirements for the component cooling i

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water system did not identify all of the components requiring testing due to the '

poor documentation of operator actions required for the design basis tornado event

(Section M1.2).

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• The inspectors determined that the licensee was slow in evaluating safety-related

pump potential operability concerns; however, the completed evaluations were

found to be thorough and assumptions appropriate (Section M1.3).

• Engineering's identification that the broad range gas monitors did not have

independent power supplies is considered a noncited violation (Section E2.1).

Plant Sucocrt

• The inspectors identified an area for improvement involving the failure to source

check survey meters upon activation of the Technical Support Center (TSC) during

the October 23,1996, emergency drill. Emergency preparedness personnel

adequately maintained the operational readiness of the TSC (Section P1.1).

• The inspectors noted good command and control in the control room simulator

during the emergency preparedness drill of October 23,1996. The crew diagnosed

plant conditions properly and responded in a timely manner (Section P4.1).

• The TSC did not consistently communicate actions to the control room, and

Procedure OP-921-521, " Severe Weather and Flooding," did not provide guidance

on structures, systems, and components that needed to be inspected on a priority

basis following the dispatch of personnel to assess damage (Section P4.1).

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Report Details  !

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i Summarv of Plant Status  !

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I The plant operated at 60 percent power between November 21-24 to perform maintenance

. on the Main Feedwater Pump B inboard journal bearing. The plant operated at essentially i

l 100 percent power during the remainder of the inspection period. ,

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) 1. Operations i

j O1 Conduct of Operations ,

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01.1 General Comments (71707) i

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Using Inspection Procedure 71707, the inspectors performed frequent reviews of

i ongoing plant operations, control room board walkdowns, and plant tours.

Observed activities were generally performed in a manner consistent with safe

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operation of the facility, Operators were f amiliar with causes for control room

annunciators. Caution and danger tags accurately identified out-of-service

equipment. However, certain activities appeared to be in violation of NRC

requirements or indicate problem areas, as discussed below.

02 Operational Status of Facilities and Equipment

O2.1 Failure to Maintain Confiouration Control

a. Insoection Scooe (71707)

The inspectors reviewed the licensee response to identifying that the containment

airborne radioactivity removal unit had been left running for 19 days, dry cooling

tower (DCT) Fan 13 B had been left in the off position for 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, and

Valve SI-1398 was mispositioned for 62 hours7.175926e-4 days <br />0.0172 hours <br />1.025132e-4 weeks <br />2.3591e-5 months <br />,

b.1 Containment Airborne Radioactivity Removal Unit Left Runnina for 19 Davs

On October 1,1996, the reactor' building airborne radioactivity removal system was

started in preparation of a containment purge and entry. The airborne radioactivity

removal system is a nonsafety system inside containment that is used to reduce

airborne radioactivity below the limits of 10 CFR Part 20 to permit access for

operation, maintenance, inspection, and testing inside containment. After exiting

containment and completing the containment purge, operations failed to secure the .

airborne radioactivity removal system. Consequently, the system remained in

_ operation until the abnormal operating configuration was detected on October 20, a

period of 19 days.

Procedure OP-002-010, " Reactor Auxiliary Building HVAC and Containment Purge,"

Revision 11, Section 6.6, required that the system be secured when stopping

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containment purge. The inspectors determined that the failure to maintain

configuration control for the airborne radioactivity removal system is the first

example of a violation of TS 6.8.1.a (50-382/9613-01).

b.2 DCT FAN 13-B in Off Position for 36 Hours

On October 19,1996, the licensee placed selected DCT fans in the manual-f ast

position to maintain wet cooling tower (WCT) basin temperatures above 70 F.

While returning the f ans to the automatic mode, a licensed operator inadvertently

placed the control switch for DCT Fan 13-B in the off position at 3:37 a.m. on

October 19. DCT Fan 13-B remained in the off position until an operator detected

the abnormal switch configuration at 4:40 p.m. on October 20, a period of

36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The inspectors noted that operations failed to observe the abnormal

switch configuration during three shift turnovers.

Procedure OP-002-003, " System Operating Procedure - Component Cooling Water

System," Revision 10, Section 6.0, " Normal Operations," required the DCT fan

control switches be in the AUTO position. The inspectors determined that the

failure to maintain configuration control for DCT Fan 13-B is a second example of a

violation of TS 6.8.1.a (50-382/9613-01).

b.3 Valve SI-1398 Left Open for 62 Hours

On November 21 at 4 p.m., control room operators identified that Low-Pressure

Safety injection to Reactor Coolant Loop 1 A Flow Control Valve SI-139B was in the

open position instead of the required closed position. Based on a review of plant

monitoring computer records and station logs, the operators determined that the

valve was last opened during surveillance testing on November 19 at 1:42 a.m., a

period of 62 hours7.175926e-4 days <br />0.0172 hours <br />1.025132e-4 weeks <br />2.3591e-5 months <br />. The inspectors noted that the abnormal configuration occurred

despite immediate corrective actions being implemented to remedy inadequate

walkdowns of control room panels.

Procedure OP-903-121, " Safety Systems Quarterly IST Valves Tests," Section 7.2,

" Safety injection Train B," required that Valve SI-1398 be closed and independently

verified closed. The inspectors determined that the failure to close Valve SI-1398

following completion of inservice testing (IST) is a third example of a violation of

TS 6.8.1.a (50-382/9613-01).

c. General Observations

At of the end of the inspection period, the licensee was stillinvestigating the cause

of the three examples of configuration control problems and inadequate control

room panel walkdowns. The inspectors noted that for all three incidents there were

control room panel indications of the abnormal configuration which were readily

available to the control room operators. In response to the deficiencies, operations

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initiated corrective actions which included, in part, counseling of the affected

individuals, performance of at least two control panel walkdowns per shift, and a

review of the operations turnover process.

d. Conclusions

The inspectors concluded that inconsistent use of Stop-Think-Act-Review

techniques, inattention to detail, and lack of procedure discipline contributed to

these incidents. The inspectors concluded that the direct safety significance of

each of these incidents was minor; however, poor configuration control discipline

and poor control room panel walkdowns represent generic concerns for the conduct

of operations.

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02.2 Failure to implement Technical Specification (TS) for Containment Isolation Valves

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a. Insocction Scone (717071

The inspectors reviewed licensee actions in response to Condition

Report (CR) 96-1726, which documented the failure to totally isolate Containment

Penetration 20 as required by TS 3.6.3 from October 23-25.

b. Observations and Findinas

After NRC questioned operability of containment isolation valves in the component

cooling water (CCW) system supply and return to the containment fan coolers (refer

to NRC Inspection Report 50-382/96 24), the license,e initiated testing to ensure '

that the air-operated valve accumulators would maintain the containment isolation

valves closed on a loss of instrument air. On November 1, testing personnel

identified internal leakage in the air-operator for Valve CC-807A, a containment fan

cooler CCW inlet isolation valve.

During development of work procedures for Valve CC-807A, operators cot ld not

isolate the containment penetration since only a check valve existed between the

penetration and the temporary chiller system. After learning this information, the

inspectors questioned operators as to why containment penetration isolation was

not a problem during a similar maintenance activity performed from October 23-25 l

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for Valve CC-808A, a containment fan cooler CCW inlet isolation valve, which

isolated Containment Penetration 20. Subsequently, the licensee initiated

CR 96-1726 to review and evaluate the circumstances related to isolating the

containment penetration. Tne licensee determined operators had not isolated all

flow paths by use of a deactivated automatic valve, a manual valve, or a blind

flange as specified in the actions for TS 3.6.3. Instead, operators had used a check I

valve as a containment isolation valve barrier for the penetration.

Region IV Task Interface Agreement 96TIA017, dated November 13,1996,

requested that the Office of Nuclear Reactor Regulation review the regulatory

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requirements for isolation and closure capability for the containment fan cooler CCW

isolation valves. The inspectors determined that the answer to Task interface  ;

Agreement 96TIA017 will have a direct bearing on the safety significance of the i

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failure to properly isolate Containment Penetration 20 during maintenance activities.

The failure to maintain appropriate isolation valves for Containment Penetration 20 ,

is an unresolved item pending resolution of Task Interface Agreement 96TIA017 '

(50-382/9613-02).

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c. Conclusions  :

The inspectors identified an unresc!ved item for failure to properly isolate a

containment penetration. This condition reflected mixed operator performance in

that one crew recognized that a penetration was unisolable; however, a previous  ;

crew failed to recognize the same situation.

03 Operations Procedures and Documentation l

03.1 Emeraency Ooeratina Procedures (EOP) Uoarade (71707)

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The inspectors noted that the licensee is upgrading their EOPs to take fewer .

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deviations from the owner's group and to be in a two column format. These new

EOPs were being verified and validated by crews in the simulator. The inspectors

considered this to be a positive initiative to improve the EOPs.

Operator Knowledge and Performance

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04.1 Installation of Gaoaino Device on Valves CC-807A and CC-823A

a. Insoection Scope (71707) j

The inspectors observed operations personnel verify the placement of danger tags

on the temporary gagging device for Containment Fan Cooler isolation

Valves CC-807A and CC-823A. .1

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b. Observations and Findinos

During the observation of maintenance activities associated with the removal of the

air actuator for Valves CC-807A and CC-823A, mechanical maintenance decoupled

the valve stem and installed a temporary gagging device. Prior to the removal of

the actuator, an operator placed danger tags on the gagging device.

The inspectors observed the independent verifier, for the danger tag, check that the

gagging device was installed on Valve CC-807A. Prior to the independent verifier

signing the tag sheet, the inspectors questioned the operator to determine how he

verified the gagged-closed position. The verifier rechecked the gagging device but

could not determine if the valve was in the closed position. The verifier stated that

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the valve actuator position indicating limit switches would provide an indication of  :

the open or closed position of the valve. The verifier observed the limit switches on

the actuator and determined that the valve was in the open position. The

inspectors noted that the verifier was not aware that the valve actuator had been

placed.to the full open position after decoupling the stem in order to install the

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Because the verifier could not determine if the valve was gagged closed, he

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questioned the individual hanging the danger tag to determine how the l

gagged-closed position could be verified. The individual could not demonstrate that

the valve was gagged closed.  !

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The two operators questioned mechanical maintenance personnel to determine what

l indications were available to verify that the valve was gagged closed. Mechanical  ;

I maintenance informed the operators that a separate valve position indicator existed J

between the valve stem and the packing gland. After verifying the alternate valve l

l position indicator, the operators were able to demonstrate that the valves were j

gagged closed. 1

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The inspectors noted that the operators' determination of the gagged-closed

position was poor in that when questioned by the inspectors they were unable to

demonstrate the position of the valves.

c. Conclusions

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One poor operations work practice involving the inadequate determination of the

gagged closed position of Valves CC-807A and CC-823A was identified. This

revealed an operator knowledge deficiency and a willingness to proceed in the face

of uncertainty.

04.2 Control Room Peer Checks Durino Reactivity Maniouf ations

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a. Insoection Scope (71707) '

The inspectors performed observations of personnel during reactivity manipulations.

b. Observations and Findinos

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On November 21, the inspectors observed two operating shifts add approximately

40 gallons of boric acid to the reactor coolant system. The inspectors noted that

both operating shifts used a peer check process to aid in preventing an abnormal

reactivity manipulation. The addition of the boric acid required the control board

operator to manipulate the control switches with the procedure in hand. The peer i

check operator observed the control board operator perform the evolution.

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The inspectors observed the control board operator point to each control switch to

verify the correct valve was being operated. Additionally, the inspectors observed

that the peer check operator did not reference the procedure during the evolution

and that the control board operator did not state the actions he was performing

during the evolution. The inspectors determined that the peer check process has a

potential weakness in that the peer check operator did not reference the procedure

to verify correct control board manipulations. The operations manager stated that

he would evaluate the inspectors' observations and make changes if necessary.

c. Conclusions

The inspectors determined that the peer check process for reactivity manipulations

and the control board operator's verification of control switches prior to operation

were good during a boration activity. It was noted, however, that the potential for

ineffective peer check existed because the peer check operator had not referenced

the procedure during the evolution.

08 Miscellaneous Operations issues (92901)

08.1 (Closed) Unresolved item 50-382/9605-03: Failure to enter TS limiting conditions

for operation (LCOs).

This item initiated the corrective actions implemented in response to the root cause

analysis documented in CR 96-0497. The licensee performed the root cause

' analysis to determine why operators failed to understand conditions requiring entry

into TS LCOs. The inspectors reviewed the root cause analysis and completed '

corrective actions identified in the root cause analysis. The inspectors determined

that the short-term and intermediate-term corrective actions implemented in

response to the root cause analysis have not been fully effective; however,

improvement was noted. The corrective actions included procedure guidance that

required operators to enter TS LCOs under any condition of uncertainty. On

November 7,1996,in response to a number of recent errors related to improper

entry into TS LCOs, the Operations Manager issued a memorandum to all operations

personnel that reiterated his expectations for entry into TS LCOs.

Many of the long-term corrective actions related to process improvements to aide

control room operators will not be completed until the second quarter of 1997. The

inspectors will evaluate the completed long-term conective actions during the

closecut of Licensee Event Report 50-382/96-005.

The other aspect of this unresolved item related to the specific failure to perform

the actions required by TS 3.7.4.f. As documented in NRC Inspection

Report 50-382/96-05, Section 3.1, operators failed to recognize that placing

curtains around the WCT basin on three separate occasions from May 5-9,1996,

rendered the affected cell inoperable. TS 3.7.4.f requires, in part, that, with more

than one fan inoperable and the outside air temperature greater than 70 F, the dry

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bulb temperature must be determined at least once every 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. On May 5-9,

1996, various WCT fans were inoperable, because curtains were placed over the

WCT air flow path, while outside air temperature exceeded 70*F; however,

operators did not measure the dry bulb temperature every 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The failure to

determine the dry bulb temperature with a WCT fan inoperable is a violation of

TS 3.7.4.f (50-382/9613-03). The operators' failure to recognize the effect of the

curtains on the operability on the WCT fans represented an operator knowledge

deficiency and was contributed to by the lack of a thorough engineering evaluation.

II. Maintenance

M1 Conduct of Maintenance .

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M1.1 General Comments

a. Insoection Scope (62707.61726)

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The inspectors observed all or portions of the following maintenance and

surveillance activities: )

• WA 01151881 Adjust Regulator for Valve CC-807A )

• WA 01152104 Replace Solenoid Valve for Valve CC-807A (

• WA 01152141 Rework Valve CC-823A Actuator

• WA 01152142 Rework Valve CC-807A Actuator

• WA-01151879 Leak Test of Valve CC-181 A

• STA-001-005 Leak Testing of Air and Nitrogen Accumulators l

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b. Observations and Findinas

The inspectors found that maintenance and surveillance activities listed above were

conducted in accordance with the applicable procedures. TS LCOs were met and

the systems were restored properly. Measuring and test equipment was verified to

have been in current calibration. The inspectors reviewed the completed test

documentation and noted that acceptance criteria were met.

c. Conclusions

Maintenance and surveillance activities observed were performed properly and in

accordance with the applicable procedures.

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M1.2 IST of DCT Manual isolation Valves

a. Inspection Scooe (62707)

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The inspectors performed a review of manually operated DCT bundle isolation  !

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valves to determine if IST requirements were being implemented. l

b. Observations and Findinas j

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D;' dated Final Safety Analysis Report (UFSAR) Section 9.2.5.3.3, " Site Related

j Phenomena," states that damage by tornado missiles to the DCT coils is detected i

. by decreasing CCW surge tank level and automatic bypassing of the DCTs. The  !

j licensee must maintain the DCTs bypassed for approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to enable

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sufficient time to isolate the damaged DCT bundles and place the operable bundles  ;

back into service.

! Restoration of the DCT requires that unprotected DCT bundles damaged in the

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design-basis tornado event be isolated by closing the inlet and outlet manual l

isolation valves. Closure of the DCT isolation valves following the tornado accident  ;

represents an active safety function, j

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10 CFR 50.55a(g) requires that IST to verify operational readiness of pumps and

i valves whose function is required for safety be accomplished in accordance with

Section XI of the ASME Boiler and Pressure Vessel Code.Section XI, " Rules for

' ~lnservice inspection of Nuclear Power Plant Components," Subsection IWV-3400,

" Inservice Tests, Category A and B Valves," requires that valves be exercised to the

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position required to fulfill their function. The inspectors reviewed the IST program

i and noted that the DCT bundle inlet and outlet isolation valves were not included in

the IST program and were not periodically exercised. The failure to exercise the

DCT bundle manualisolation valves is a violation of 10 CFR 50.55a(g)

f (50-382/0613-04).

j The failure of the licensee to identify the need for IST of the DCT isolation valves is

of particular concern because personnel failed to identify the active safety function

i during a 100 percent review of IST requirements associated with the CCW system

s in August 1996. Engineering personnel stated that the DCT bundle isolation valves

were not identified during the review because of the poorly documented design

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basis for the tornado event.

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c. Conclusions

The inspectors identified a violation for the failure to perform IST which verified the

operational readiness of the DCT manualinlet and outlet isolation valves. The

inspectors determined that the review of IST requirements for the CCW syst m did

not identify all of the requirements for testing due to the poor documentation of the ,

design-basis tornado event.

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M1.3 Review IST of Pumos

a. Insoection Scoce (73756)

The inspectors evaluated, in part, the basis for the selection of the IST " alert" and

" action" limits for several safety-related pumps. The inspectors compared the IST

flow and differential pressure limits to the design basis limits. Further, the

inspectors verified, in part, the ability of the safety-related pumps to meet design

basis flows.

b. Observations and Findinos

in March 1996, the licensee initiated CR 96-0414 that documented that the IST

acceptance criteria for the CCW pumps had allowed pump operation to be less than

the 6554 gpm flow specified in UFSAR Table 9.2-3, " Heat Removal and Water

Requirements for the CCWS." Immediate actions included documenting that a

previous operability analysis demonstrated that a CCW system flow of 6000 gpm

provided the required design basis flow and heat removal requirements.

The licensee initiated a root cause analysis for the deficiency identified in

CR 96-0414. The root cause evaluation identified several contributing causes. The

major cause involved inadequate margins for the' CCW system as originally

designed. Another significant contributor was the failure to take advantage of prior

opportunities upon receipt of industry information. Generic Letter 89-04, "Guidanca

on Developing Acceptable Inservice Testing Programs," indicated that testing

" . . . assessed whether adequate margins are maintained" and specified that, ,

tonether with the TS, IST programs are intended to ensure the operational rr,adiness

of safety-related pumps and valves.

As indicated in CR 96-0414, the licensee first knew about this issue in 1994 when

Arkansas Nuclear One described that the high pressure injection pumps could be

consideied operable in the " alert" range and have flow and differential pressure

conditions lower than allowed in the design basis. This item was assigned a low

priority because engineering personnel wrongly assumed that all safety-related

pumps had sufficient design margin.

The interim corrective actions required determining the minimum design pump head

required at the tested flow rate for all pumps in the IST program and reviewing the

baseline IST data against the design minimum data. A long-term corrective action

required updating the UFSAR and the IST program to list the CCW system design

flow at 6000 gpm. Actions to prevent recurrence included: periodically testing the

CCW system in the accident lineup; continuing actions to improve the questioning

attitude and self-critical nature of site personnel; evaluating the need to revise the

review process for industry information; reviewing outstanding action items for

operability concerns; and evaluating site compliance with the UFSAR.

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The engineers determined the minimum acceptable pressures at design basis flow  :

requirements and translated this information to the required differential pressure at  !

the IST flow values. Design engineering completed the evaluation (Engineering l

Report on Minimum Acceptable Pump Differential Pressure at The Inservice Test  !

Flow Rate)in June 1996 and issued the report in October 1996. [

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in October 1996, the Inservice Test Group adjusted the reference values and the

low " action" and low " alert" limits for Trains A and B auxiliary CCW and Trains A

and A(B) high pressure safety injection to ensure that the pumps would be declared l

inoperable at a point before or when the IST values indicated that the pumps could  !

not meet the minimum design basis values. Prior to adjusting the low " alert" and

I low " action" limits, the pumps could have been considered operable in accordance -

with the IST program yet unable to meet design basis flow requirements. The f

inspectors reviewed historicalIST data for the affected pumps and determined that

l the pumps had remained operable.

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c. Conclusions i

The inspectors determined that the licensee was slow to evaluate whether the high l

pressure injection pumps were subject to the same operability concerns as at

another facility. The delay in performing the evaluation was particularly poor since

there was regulatory guidance available related to the issue. Once the licensee had

addressed the issue, licensee evaluations were found to be thorough and

assumptions appropriate. The licensee implemented appropriate actions to ensure

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that Trains A and B auxiliary CCW and Trains A and A/B high pressure safety

injection would be declared inoperable during IST prior to exceeding the design

basis values.

M8 Miscellaneous Maintenance issues (92902)

M8.1 (Open) Insoection Followuo item 50-382/94402-02: Unacceptable weld-joint

configuration identified during inspection of flow accelerated corrosion replacement

piping. When Field Weld FW-20A was installed between the high-pressure turbine

and the first-stage feedwater heaters, the drawing detail for the weld was not

followed. This resulted in a condition that conflicted with the drawing.

The inspectors reviewed CR 94-337 and noted that the licensee had identified the

following actions to prevent recurrence: (1) training of craft to stress the

importance of installing the half-coupling correctly, and (2) revising applicable

procedures to require verification that the inside diameter of the half coupling and

sockolet matched the hole cut in the pipe. The inspectors noted CR 94-337 was

closed May 19,1994.

While reviewing the corrective actions, the inspectors noted the following: (1) there  ;

was no documentation that the training recommended by CR 94-337 had been

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performed, and (2) procedures had not been revised to require weld-joint verification

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by quality control personnel. The inspectors noted that the applicable section '

(Document E-GWS-1, Revision 1) of the current Welding Program Manual did not

require quality control verification of half-coupling sockolet welds.

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When the licensee was notif;ed that CR 94-337 actions to prevent recurrence had I

not all been adrninistratively completed or could not be verified as completed, they

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issued CR 961452 to implement corrective actions to resolve the inspectors' l

concerns. This item remains open pending review of the corrective actions  ;

implemented for CR 96-1452.  ;

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111. Enaineerino l

E2 Engineering Support of Facilities and Equipment  ;

E2.1 Broad Ranae Gas Monitor (BRGM1 Power Sucofv

a. Insoection Scope (375511

The inspectors reviewed the corrective actions associated with identifying that

BRGMs A and B were both powered from Distribution Panel 396AB.

b. Observations and Findinas ,

On October 23,1996, engineering initiated CR 96-1656 to document that BRGMs A

"and B shared the'same power supply. UFSAR Section 6.4.4.2.b specified that -

, redundant BRGMs were powered from independent nonsafety-related uninterruptible

power supplies.

TS 3.3.3.7.3 states that two independent broad range gas detection systems shall

be operable. With one broad range gas detection system inoperable, restore the

inoperable detection system to operable status within 7 days or within the next

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> initiate and maintain operation of the control room ventilation system in the

isolate mode of operation. In response to CR 96-1656, the shift supervisor declared

BRGM B inoperable due to not having an independent power supply and

implemented the required TS action statement.

On October 30, the licensee placed the control room ventilation system in the

isolate mode of operation, minimized the number of personnel in the control room

envelope to less than 16, and implemented provisions to ensure TSC personnel

responded to the emergency operations facility in the event of emergency plan

activation.

On November 13, the licensee completed plant modifications to provide

independent uninterruptible power supplies to the BRGMs. This licensee-identified

and corrected violation is being treated as a noncited violation, consistent with

Section Vll.B.1 of the NRC Enforcement Policy. Specifically, the violation was

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identified by the licensee and 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 (50-382/9613-05).

c. Conclusions

The inspectors identified a noncited violation involving engineering's identification  ;

that BRGMs A and B did not have independent power supplies.  ;

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E2.2 Review of Facility and Eauioment Conformance to UFSAR Description l

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A recent discovery of a licensee operating a facility in a manner contrary to the i

UFSAR description highlighted the need for a special focused review that compares i

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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.

UFSAR Section 6.4.4.2.b specified that redundant BRGMs were powered from

independent, nonsafety-related, uninterruptible power supplies. However, the

BRGMs were powered from the same distribution panel (See Section E2.1).

UFSAR Section 12.3A specified that the original shielding study dose rates were

obtained though the use of Computer Code SPAN-4. During a review of

Calculation OSA-RC-CALC-91001, " Dose Rates at the CS-117A and CS-117B Valve

Operators Six Hours into a Small Break Loss of Coolant Accident," the inspectors

noted that MICROSHIELD, a computer code not specified in the UFSAR was used to

perform the shielding study dose calculations.

UFSAR Section 3.9 specified that ICES STRUDL was used to perform safety-related

structural analysis and design calculations, in response to the inspectors' concern

regarding the use of MICROSHIELD, the licensee determined that the GTSTRUDL

computer code had been used instead of the UFSAR described ICES STRUDL  !

computer code. The licensee stated that a review of the MICROSHIELD and

GTSTRUDL computer codes would be performed and the necessary UFSAR changes

would be submitted to the NRC.

E8 Miscellaneous Engineering issues (92903) q

E8.1 LC_losed) Insnection Followuo item 50-382/9306-10: This item involved licensee

efforts to complete reviews of its Generic Letter 89-10 motor-operated valve

population for susceptibility to pressure locking and thermal binding and to take  ;

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corrective actions to ensure valve operability. Subsequently, the NRC issued

Generic Letter 95-07, " Pressure Locking and Thermal Binding of Safety-Related

Power-Operated Gate Valves." The response to this generic letter is currently under

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review by the NRC Office of Nuclear Reactor Regulation. This issue will be fully

resolved under Generic Letter 95-07; therefore, this item has been closed.

IV. Plant Suocort j

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P1 Conduct of EP Activities

! P1.1 Failure to Source Check Technical Succort Center (TSC) Survey Meters  ;

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a. Insoection Scoce 71750

The inspectors toured the TSC on November 3,1996, to determine if the facility

was readily available and maintained for emergency operations.

b. Observations and Findinas

The inspectors noted that the licensee maintained the operational readiness of the 1

TSC. During the tour, the inspectors noted that Ludlum 12 Survey

Meters HP-CR-091 and HP-CR-025 were last source-checked on l

September 4,1996, and June 28,1996, respectively. The inspectors noted that i

these survey r.:dters were in use during the site emergency drill on l

October 23,1996, and that they should have been source checked as part of the 'I

initial activation of the TSC.

' Procedure EP-002-100, " Technical Support Center Activation,- Operation and

Deactivation," did not provide guidance on source checking the facility survey

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meters. The inspectors determined that the failure to ensure that survey meters are

source-checked during activation of the TSC during the October 23 site drillis an

area for improvement.

The corrective actions included planned revisions to the activation procedures to

include additional requirements for source checking survey meters and adding

survey meter source checking to'the lessons learned section of emergency

preparedness training program. The inspectors determined that the planned

corrective actions for the failure to ensure survey meters were source checked

should be sufficient to prevent recurrence.

c. Conclusions

The inspectors identified an area for improvement involving the failure to  ;

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source-check survey meters during activation of the TSC during the

October 23,1996, emergency drill.

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P4 Staff Knowledge and Performance in EP

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l P4.1 October 23.1996. EP Drill

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j a. insoection Scope (71750)

The inspectors obse'ved and waluated the control room simulator staff during the

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EP drill conducted on October 23,1996. The tasks evaluated included detection

and classification of events, analysis of conditions, and notification of onsite

personnel and offsite authorities.

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b. Observations and Findinas )

The inspectors noted good formality and command and control in the control room

simulator. The operators consistently employed three-way communications and j

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repeat-backs in accordance with operations instructions, in addition, the control

room supervisor conducted frequent crew briefings throughout the drill. The crew .

used good teamwork in diagnosing plant conditions and planning for recovery I

actions. Notifications to offsite agencies were appropriate. .l

The inspectors also noted that, although the control room simulator crew

communicated frequently to the TSC, the prioritization and strategies of the TSC

were not consistently communicated back to the control room simulator crew. On

two occasions in which safety-related pumps had failed, the control room simulator

- ~ crew was unaware that the TSC had directed personnel in the operations support

center to investigate. This resulted in the shift supervisor directing auxiliary ' ,

operators to locally investigate the pump failures.

The drill scenario also included a tornado strike. The control room simulator crew

responded appropriately. However, the inspectors noted that the abnormal j

operating procedure for tornado response did not have sufficient detail for timely

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response. Procedure OP-921521, " Severe Weather and Flooding," Revision 2,

Section E2.12, which discussed' tornado strike response, stated "when weather

conditions are safe dispatch personnel to assess damage." Procedure OP-921-521

did not provide direction on what to inspect or the priority in which to inspect  ;

systems, despite several safety systems (e.g., DCTs, emergency feedwater) having

portions exposed to the outside. The inspectors discussed these observations with ,

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the operations manager who stated that these concerns would be evaluated for

corrective actions. g

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c. Conclusions

The inspectors noted good command and control in the control room simulator  ;

during the EP drill of October 23,1996. The crew diagnosed plant conditions l

properly and responded in a timely manner. The TSC did not communicate their  ;

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actions to the control room on two occasions. The procedure for response to a

tornado strike required improvement in that it did not provide direction of what

inspections were necessary on a priority basis. ,

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i V. Manecement Meetinas

X1 Exit Meeting Summary

The inspectors presented the inspection results to members of licensee management

at the conclusion of the inspection on December 3,1996. The licensee

acknowledged the findings presented. j

The inspectors asked the licensee whether any materials examined during the

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inspection should be considered proprietary. No proprietary information was

identified.

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ATTACHMENT

SUPPLEMENTAL INFORMATION

PARTIAL LIST OF PERSONS CONTACTED

Licensee

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R. G. Azzarello, Manager, Maintenance i

T. P. Brennan, Design Engineering

C. M. Dugger, General Manager, Plant Operations  ;

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J. J. Fisicaro, Director, Nuclear Safety

T. J. Gaudet, Acting Manager, Licensing ,

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P. M. Melancon, inservice Testing Engineer

D. C. Matheny, Manager, Operations

M. B. Sellman, Vice-President, Operations

D. W. Vinci, Superintendent, System Engineering

A. J. Wrape, Director, Design Engineering

INSPECTION PROCEDURES USED

37551 Onsite Engineering

61726 Surveillance Observations

62707 Maintenance Observations

71707 Plant Operations

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71750 Plant Support Activities

92901 Followup - Plant Operations

92903 Followup - Engineering  ;

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ITEMS OPENED. CLOSED, AND DISCUSSED

Ooened i

50-382/9613-01 VIO Failure to follow procedure regarding configuration control -

three examples (Section 02.1)

50-382/9613-02 URI Review safety significance of using a check valve as

containment isolation for CCW to containment fan coolers

(Section 02.2) -

50-382/9613-03 VIO Failure to enter appropriate TS for inoperable WCT fans

(Section 08.1)

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50-382/9613-04 VIO Failure to exercise the DCT bundle manual isolation valves

(Section M1.2)

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50-382/9613-05 NCV BRGM B inoperable due to not having an independent l

power supply (Section E2.1) l

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Closed i

50 382/9613-05 NCV BRGM B inoperable due to not having an independent

i power supply (Section E2.1)

50-382/9306 10 IFl Evaluation of calculational methodology (Section E8.1) l

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50-382/9605-03 URI Review results of the licensee LCO entry assessment ,

(Section 08.1)  !

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Discussed  ;

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50-382/9613-05 NCV BRGM B inoperable due to not having an independent

power supply (Section E2.1)

'50-38?]94402-02 IFl Review corrective actions for unacceptable weld joint - '

configuration (Section M8.1)

LIST OF ACRONYMS USED

ASME American Society of Mechanical Engineers

BRGM broad range gas monitor .

CCW component cooling water

CFR Code of Federal Regulations

CR condition report

DCT dry cooling tower ,

EP emergency preparedness ,

IST inservice testing

LCO limiting conditions for Operation

NRC U.S. Nuclear Regulatory Commission i

TS- Technical Specification

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TSC Technical Support Center

UFSAR Updated Final Safety Analysis Report  ;

WCT wet cooling tower

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