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

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                                         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
   Inspectors           4
                  J. G. Luehma
                                   _
                                           Resident Inspector
                                                                       y  f!ff
                                                                      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).
              ?0 ? *!a W $ $8

. .

                                      -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
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                    (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,

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                            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.
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            In the first instance, I&C personnel apparently courenced testing of the
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            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
           ~
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                                                  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
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                 (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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  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 -
 s                                                           two oils as discussed in the IE Circular.

                                   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-

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                                                   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.          "

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                                        -"                   the requirements of these documents. Most of them
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   s                          ,                             were covered under the licensee's response to NUREG 0737.
       .                                                                                                            .
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                                    (Closed) IEB 79-23 - Potential Failure of Emergency Diesel Generator-
                                                                 Field Exciter Transformer
                                    (Closed) IEB 79-24 - Frozen Lines                                                                ,
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                                         (Closed),IEB 80-03 - Loss of Ch'a rcoal from Standard Type II' 2-inch Tray   '
                        ,              ,           .                 Absorber Cells
                                         (Close'd )?IEB 80-09        Hydramotor Actuator. Deficiencies :
                                         (Closed) -IEB 82-02 and. Revision 1 - Degradation of Threaded Fasteners in
        ,
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                                                                  the Reactor Coolant Pressure Boundary PWR-Plants
                                                                                                    3
                                         No violations or dev'iations were identified.
                                                                                                  '
               .             110 Allegation Followup

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                                         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..
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                                                Finding
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                                                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. >
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                                   ,     b.   '(Closed) Concern 4b5-A-120                    .
                                                                                                .
                     n                          The NRC Region IV staff was advised.by the Region II A11e'gations
                                              " 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
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       , ,                                      documented.
                                         No violations or deviations were identified.
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                   12. Exit Interview
                            The inspection scope and findings were sunsnarized on March 4,1986, with
    ,
                            those persons indicated in paragraph I above. The licensee acknowledged
                            the NRC inspector findings. The licensee did not identify as proprietary
    _.-                    .any o -f the material provided to or reviewed by the NRC inspector during

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                            this inspection.
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                     Technical Specification (TS) 6.8.1 requires in part that written                                                                                                      -
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