ML20141C073

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Insp Rept 50-382/86-05 on 860201-28.Violation Noted:Failure to Use Adequate Radiation Work Permits & Approved Test Procedure
ML20141C073
Person / Time
Site: Waterford Entergy icon.png
Issue date: 03/19/1986
From: Constable G, Luehman J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20141C036 List:
References
50-382-86-05, 50-382-86-5, NUDOCS 8604070175
Download: ML20141C073 (13)


See also: IR 05000382/1986005

Text

{{#Wiki_filter:_ . . , APPENDIX B U. S. NUCLEAR REGULATORY COMMISSION REGION IV NRC Inspection Report: 50-382/86-05 License: NPF-38 Docket: 50-382

Licensee: Louisiana Power & Light Company (LP&L) 142 Delaronde Street , ' New Orleans, Louisiana 70174 Facility Name: Waterford Steam Electric Station, Unit 3 (W3 SES) Inspection At: Taft, Louisiana Inspection Conducted: Februar - 8, 1986 f!ff Inspectors 4 _ y J. G. Luehma Resident Inspector D6te' Approved: 9 4 . L.~ Constable, Chief, Project Section C, Date Reactor Projects Branch Inspection Summary Inspection Conducted February 1-28, 1986 (Report 50-382/86-05) Areas Inspected: Routine, unannounced inspection of: (1) Licensee Action on Previous Inspection Findings; (2) Plant Status; (3) Licensee Event Report (LER) Followup; (4) Followup on Previously Identified Items; (5) Monthly Maintenance, (6) Monthly Surveillance; (7) Routine Inspection; (8) Inspection & Enforcement , (IE) Circulars and Bulletins; and (9) Allegation Followup. The inspection involved 93 inspector-hours onsite by one NRC inspector. Results: Within the areas inspected, one violation was identified (failure to use an adequate RWP and failure to use an approved test procedure, identified in paragraph 10). ? ? *!a W $ $8 0

. . -2- DETAILS 1. Persons Contacted Principal Licensee Employees R. S. Leddick, Senior Vice President, Nuclear Operations

  • R. P. Barkhurst, Plant Manager, Nuclear

T. F. Gerrets, Corporate QA Manager

  • S. A. Alleman, Assistant Plant Manager, Plant Technical Services

J. N. Woods, QC Manager A. S. Lockhart, Site Quality Manager R. F. Burski, Engineering and Nuclear Safety Manager K. L. Brewster, Onsite Licensing Engineer G. E. Wuller, Onsite Licensing Coordinator T. H. Smith, Maintenance Superintendent, Nuclear

  • N. S. Carns, Assistant Plant Manager, Nuclear, Operations and

Maintenance

  • Present at exit interviews.

In addition to the above personnel, the NRC inspector held discussions with various operations, engineering, technical support, maintenance, and administrative members of the licensee's staff. 2. Licensee Action on Previous Inspection Findings (Closed) Violation 382/8528-02 - The licensee's response to this violation, dated January 31, 1986, has been reviewed and the corrective actions outlined appear to be satisfactory. No violations or deviations were identified. 3. Unresolved Items Unresolved items were not identified during this inspection. 4. Plant Status The plant operated at or abc.e iuli power during this inspection period. 5. Licensee Event Report (LER) Followup The following LERs were reviewed and closed. The NRC inspector verified that reporting requirements had been met, that causes had been identified, that corrective actions appeared appropriate, that generic applicability had been considered, and that the LER forms were complete. Additionally, the NRC inspector confirmed that no unreviewed safety questions were involved and that violations of regulations or technical specificiations (TS) conditions had been identified. (Closed) 382/85-28 Automatic Actuation of Reactor Protective System

.- ~ - . l " > . .. . '-' y. -_ C- s-3- , , (Closed) 382/85-47 Reactor Trip as a Result of Deluge System (Closed) 382/85-54 Loss of Offsite Power Due to Lightning Strike in Waterford Switchyard No violations or deviations were identified.- , 6. Followup cf Previously Identified Items ~(Closed) Open Item 382/8505-01 - In a letter dated December 2,1985, the . NRC Office of Nuclear Reactor Regulation (NRR) provided the licensee with ' the results of an audit done by NRR on the W3 SES safety parameter display system (SPDS) conducted September 25-27, 1985. In a letter dated February 14,-1985, the licensee outlined to NRR the SPDS changes that had been made and those that would be made in the future. Any further concerns with the SPDS will be covered by the licensee's internal task force addressing the audit report findings. (Closed)'OpenItem 382/8505-02 - The NRC inspector verified that the licensee has revised the shift turnover checklist to include minimum equipment lists (Attachments 6.5 and 6.6 of OP-100-007, Revision 3). (0 pen) Open Item 382/8528-03 - Based on the licensee's response dated January 31, 1986, this item has been changed from an unresolved to an open item. The item will be reinspected af ter the licensee has completed the revisions they committed to in the above referenced response. (Closed)OpenItems 382/8420-02 and 8420-07 - These items have been included in the plant's operating license and will be inspected as part.of License Condition 2.c.9. No violations or deviations were identified.- 7. Monthly Maintenance Station maintenance activities affecting safety-related systems and components were observed / reviewed to ascertain that the activities were conducted in accordance with approved procedures, regulatory guides and industry codes or standards, and in conformance with TS. During a tour of the turbine building the NRC inspector reviewed the calibration due dates of two pieces of measuring and test equipment (M&TE) , - 'that had been left near the main condenser circulating water discharge piping.- One of the pieces of M&TE was within the calibration due date while the other (MIPT 027.019) had gone out of calibration a day earlier (February 5,1986). Though the equipment was not in use, the failure to turn this piece of equipment in'for recalibration on or before the due date is another example of Violation 50-382/8533-02, which was issued in a recent report. The NRC inspector informed the control room of the out of calibration instrument and action was' taken to have the equipment removed from availability for use, i - . . . _ . - _ _ . . - . . .

. . , r-- , t f . . , a ' . . (, k No violations or deviations were identified. - 8. , . Monthly Surveillance . , , - The NRC inspector observed / reviewed TS required testing and verified that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that limiting conditions for . operation (LCO) were met, and that any deficiencies identified were ' s properly reviewed and resolved. ~ No violations or deviations were identified. 9. Routine Inspection - By observation during the inspection period, the NRC inspector verifie'd- that the control room manning requirements were being met. 'In addition, the NRC inspector observed shift turnover to verify that continuity of ' , system status was maintained. The NRC inspector periodically questioned shift personnel relative to their awareness of the plant conditions. ' - Through log review and plant tours, the NRC inspector verified compliance - with selected TS and limiting conditions for operations. ^ During the course of the inspection, observations relative to protected and vital area security were made including access controls, boundary _ integrity, search, escort, and badging. , On a regular basis, radiation work permits (RWPs) were reviewed and the specific work activity was monitored to assure the activities were being, conducted per the RWPs. Selected radiation protection instruments were . periodically checked and equipment operability and calibration frequency ' were verified. The NRC inspector kept informed on a daily basis of overall status of plant and of any significant safety matter related to plant operations. Discussions were held with plant management and various members of the - operations staff on a regular basis. Selected portions of operating logs , and data sheets were reviewed daily. - The NRC inspector conducted various plant tours and made frequent visits of the control room. Observations included: witnessing work activities . in progress; verifying the status of operating and standby safety systems ' and equipment; confirming valve positions, instrument and recorder readings, annunciator alarms; and housekeeping. , On February 12 and 13,1986, unplanned releases of radioactive gas through the plant stack occurred due to work being done under Station Modification (SM) 818 by instrument and control (I&C) personnel. The work was being conducted under RWP 86000101 dated February 5,1986, which should have been issued in accordance with Administrative Procedure HP-1-110, Revision 5, ' " Radiation Work Permits," and involved installation of a hydrogen and oxygen analyzing system for plant storage tanks. s . ~ - . _ , , - . , , , . ,_.

+w _ . . . -5- . - In the first instance, I&C personnel apparently courenced testing of the ' system without informing plant operations or health physics' personnel. Because of an improper valve lineup and system leakage, radioactive gas was directed up the plant stack as well as into the room in which the analyzer was located. When control room personnel received the high alarms on both plant stack gaseous radiation monitors, it took some time to identify the source because they were not aware that the system had been placed in operation. In the second instance, operations personnel were aware that I&C personnel were conducting some testing on the system; hcwever, when they again received high alarms on the plant stack monitors, an operator had to be dispatched to secure _the system because I&C: personnel had left the area. In both cases, the.RWP that was employed was inadequate to cover the work being done and, therefore, not in accordance_ with the provisions of - HP-1-110. EWP 86000101 appears to have been written to-cover only system installation and not testing. Without an approved testing procedure the personnel involved did not have the system aligned properly and failed to - consider that testing of a new system involving gaseous radioactivity _ might lead to airborne radioactivity problems. Consequently, neither - opt.ations nor. health physics personnel got involved to modify the RWP to monitor for. such probleins. The failure to use an adequate RWP and the failure to use an approved test procedure is an apparent violation and is identified as 50-382/8605-01. Additionally, it'is unclear _why, after the 'first~ release, I&C personnel- were again allowed to conduct testing without an updated RWP or health physics coverage, especially when the first release constituted not only a release to the environment but also a potential for radiation exposure at the Job site. ' - Subsequently, operations personnel did stop further testing by removing the existing RWP from the job site and then. modifying the control room ' copy of the RWP to require: '(a) notification.of the control room prior to - testing and-(b) health physics coverage. 0n February 14, 1986,"a meeting was held to discuss Radiological Occurrence Report 86-003 which dealt with the two releases. However, the neeting r- sunnary report does not explain why I&C personnel were allowed to conduct g' testing a second time or what the total radiological consequences of the events were. ' . During tours of various areas of the plant, the NRC inspector has noted a number of_ instances where scaffolding and the temporary structures had been erected around or adjacent to Seismic Category I systems / components. W3 SES Final' Safety Analysis Report (FSAR), paragraph 3.2.1 states, in part, that the occurrence of adverse interaction between safety and nonsafety-related components during safe shutdown earthquake (SSE) is eliminated in areas where adequate separation is not possible by providing -the nonsafety components with seismic supports or by providing a barrier.

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The licensee's procedure for the construction of scaffolding, Mii-12-013, " Erection of Scaffolding," does not consider the potential impact of scaffolding on seismic system / components during SSE. The NRC inspector questioned licensee management on the type of analysis that was done for temporary structures, directing particular concern to those cases where the scaffolding would remain in place for extended periods of time. The licensee is reviewing their controls and the potential impact _of 10 CFR Part 50.59. No other violations or deviations were identified. 10. - Inspection & Enforcement (IE) Circulars and Bulletins - The licensee's actions on the following IE Circulars have been reviewed and the IE Circulars are considered closed. (Closed) IEC 77-05 - Liquid Entrapment in Gate Valve Bonnets (Closed) IEC 77-06 - Effects of Hydraulic Fluid on Electrical Cables (Closed) IEC 77-10 - Vacuum Conditions Resulting in Damage to Liquid , , Process Plants - This concern was readdressed in IEB 80-05 which has already been reviewed and~ ' , closed. , ^ '(Closed) IEC 77-13 - Safety Signals Negated During Testing (Closed) IEC 77-15 - Degradation of Fuel Oil Flow to the Emergency , ~ ' ' Diesel Generator , (Closed) IEC 77-16 - Emergency Diesel Generator Electrical Trip Lock-out Features (Closed) IEC 78-03 - Packaging Greater Than Type A Quantities of Low , Specific Activity Radioactive Material for Transport , (Closed) IEC 78-15-- Tilting Disc Check Valves Fail to Close with Gravity in Vertical Position (Closed) IEC 78-18 - Underwriters Laboratory Fire Test (Closed) IEC 78-19 - Manual Override (Bypass) of Safety System Actuation- Signals (Closed) IEC 79-17 - Contact Problem in SB-12 Switches on General Electric Metalclad Circuit Breakers (Closed) IEC 79-25 - Shock Arrestor Strut Assembly Interference and Supplement A ~ f

m. - -- - p7; '; ? . . , , , , - - 'n . , ' -7- - , . , (Closed) IEC 80-04 - Securing-Threaded Locking Devices on. Safety-Related Equipment (Closed) IEC 80-05 - Emergency Diesel Generator (ubricating 0111 Addition _ Addition and Onsite Supply - -(Closed) IEC'80-07 - Problems with HPCI Turbine Oil System - Though this 3 was identified as a problem at BWR facilities, a Terry turbine is used for an emergency feedwater pump at W3 SES'so the problem was pursued. (Closed) IEC 80-09 - Problems.with Plant Internal Communications Systems (Closed) IEC 80-14 - Radioactive Contamination of Plant Demineralized . Water System and Pesultant' Internal Contamination . of Personnel. , (Closed) IEC'80-15 - Loss of Reactor Coolant Pumps and Natural Circulation Cooldown- (Closed). IEC 80-16 - Operational Deficiencies in Rosemount Model 510D0 ' Trip Units and.Model 1152 Pressure Transmitter (Closed) IEC 80-18 - 10 CFR 50.59 Safety Evaluation for Changes to Radioactive Waste Treatment Systems (Closed) IEC 81-02 ~ Performance of NRC-Licensed-Individuals While on Duty (Closed) IEC 81-13 - Torque Switch Electrical Bypass Circuit for Safeguards Service Valve Motors (Closed) IEC 81-15 - Unnecessary Radiation Exposures to the Public and Workers During Events Involving Thickness and Level Measuring Devices ThefollowingIECircularshavebeeninspectedandhavebeenclosed because they are not applicable to Waterford 3. (Closed) IEC 77-12 - Dropped Fuel Assemblies at BWR Facilities (Closed) IEC 78-01 - Loss of Well Logging Source (Closed) IEC 78-10 '- Control of Sealed Sources Used in Radiation Therapy (Closed) IEC 78-11 - Recirculation of M-G Set Overspeed Stops , (Closed) IEC 78-12 - HPCI Turbine Control Valve Lift Rod Bending j (Closed) IEC 78-13 - Inoperability of Service Water Pumps i I L

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z 'As , . I -8- . ,. i (Closed) IEC 79-01'- Adminfetration of Unauthorized By-Product Materials O Huu.ans .(Closed) IEC 79-06 - Failure to Use Syringe .and Bottle Shields in Nuclear Medicine (Closed) IEC 79-07 - Unexpected Speed Increase of Reactor' Recirculation - MG Set Resulted in Reactor Power Increase (Closed) IEC 79-08 - Attempted Extortion - Low Enriched Uranium (Closed) IEC 79-24 - Proper Installation and Calibration of Core Spray. Pipe Break Detection Equip *nent on BWR's The licensee's actions on the following IE Circular has been reviewed and 7 the IE Circular is 5till considered to be open. (0 pen) IEC 78-02 - Proper Lubricating 011 for Terry Turbines - The use of Mobil DTE-797 in the lube oil systems for Terry Turbines was found to.be unacceptable.because that oil does not contain the corrosion inhibitors found in the recomended lubricants. In reviewing the IEC- LP&L discovered that, though they were not using DTE-797, neither-.were they using one of the two recommended lubricants (Mobil RL-851 or Shell VSI-827 , " Code 65249). Consequently, the licensee decided to switch to Mobil RL-851 and this was to be accomplished by August 1984, A review of the licensee's approved lubricant list shows they are presently using DTE-797 - which was the oil originally identified as. - unacceptable. The NRC inspector verified that the Terry. Turbine Technical Manual presently recomends the same - '. two oils as discussed in the IE Circular. s The licensee's responses to the following IE Bulletins have been reviewed and the Bulletins are considered closed. - , (Closed) IEB 79-05 and Supplements A, B, and C- 7, - , , 4 . IEB 79-06 and Supplements A, B, and B, Revisiori ' ' Three Mile Island Incident - In a response dated j. ' + November 3, 1983, the licensee outlined how they met. " the requirements of these documents. Most of them . -" ' t were covered under the licensee's response to NUREG 0737. s , . . ' (Closed) IEB 79-23 - Potential Failure of Emergency Diesel Generator- ~ Field Exciter Transformer (Closed) IEB 79-24 - Frozen Lines , , w g _A. A__ I' p

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(Closed),IEB 80-03 - Loss of Ch' rcoal from Standard Type II' 2-inch Tray a ' Absorber Cells , , . (Close' )?IEB 80-09 Hydramotor Actuator. Deficiencies : d (Closed) -IEB 82-02 and. Revision 1 - Degradation of Threaded Fasteners in the Reactor Coolant Pressure Boundary PWR-Plants ' , 3 No violations or dev'iations were identified. ' . 110 Allegation Followup 's " ' The NRC inspector performed inspections to determine the validity and, if a- verified, the safety' significance of the following. concerns: a a. (Closed) Concern 4-84-A-077 -It was alleged that a certain individual, who was working as a sealer for an.. insulation contractor onsite, was engaged in the. sale and use , of' drugs. The alleger was concerned about the ability of the individual to perform his-job.. ' - ' , , Finding s a It was7found that the individual worked onsite for the stated ' contractor.as a pumper, not a sealer, from September 9,1983, to . January 3,1984. There is no evidence of further site employment. A, background check ~ had been performed by LP&L resulting in no adverse information. This individual's work as a. pumper would not adversely - affect final product quality. Therefore, even if he was involved in- + . the sale and use .of drugs, there is..no safety significance. >

~ b. '(Closed) Concern 4b5-A-120 . . , n The NRC Region IV staff was advised.by the Region II A11e' ations g " Coordinator that a fonner employee at=W3 SES was obsdrved forging a n . . supervisor's signature on a work order at a Region Il plant; Finding The licansee determined that the' individual in question had~ worked ~ for LP&L during the period: September 24, 1984, through April 24,

1985, as an electrical supervisor. He was predominately involved with preventive-maintenance and TS surveillance task cards. Licensee H ' supervisors who are familiar with all ' authorized signatures reviewed ' all. task cards signed by the individual during his last 2 weeks of employment 'and a sample of '23 previous cards which he signed.. 'No irregularities'were' identified. This provides reasonable assurance that no work in.which this individual was involved was fraudulently documented. , , , No violations or deviations were identified. . rw ,

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