ML20153D431
Jump to navigation
Jump to search
| ML20153D431 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/19/1988 |
| From: | Chamberlain D, Michaud P, Will Smith, Staker T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20153D424 | List: |
| References | |
| 50-382-88-19, IEB-88-005, IEB-88-5, NUDOCS 8809020201 | |
| Download: ML20153D431 (19) | |
See also: IR 05000382/1988019
Text
{{#Wiki_filter:* {{. ~
,
(,- ,
. . 4 ,
, ;
,, -
-.- ,
,
'
~,c
*
,t. j
h'; e ,:
e -, U. S. NUCLEAR REGULATORY COMISSION ' , .4 REGION IV
. .
b
,-
'
NRC Inspection Report: 50-382/88-19 License: 'NPF-38
I' 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
Inspection At: Taft: Louisiana
s
Inspection Conducted: June 18 through July 31, 1988 <
Inspectors: .- 8 &
W. F. Smith, Senior Resident Inspector Date
7-1-6s
T. R. St4ke?, lesident Inspector Date
We 7-2 2 -28
P. W. Michaud, Res'i ant Inspector, Region IV Date
'
Approved: C , &llT/00
D. D/LTainberlain, Chief, Project Section A Date !
Division of Reactor Projects
i
,
'
pg
O
+
- -
._
* J
, .
. .
2
Inspection Summary
Inspection Conducted June 18 through July 31, 1988 (Report 50-382/88-19)
Areas Inspected: Routine, unannounced inspection consisting of:
TI) enforcement followup on quality verification function inspection,
(2) monthly maintenance observation, (3) allegation followup, (4) operational
safety verification, (5) monthly surveillance observation, (6) followup of
previously identified items, (7) followup of NRC Bulletin 88-05, (8) licensee
event report followup (9) onsite followup of events, and (10) plant status.
Results:
Within the areas inspected, four violations were identified. The first
violation involved four failures to submit Licensee Event Reports within the I
30 days required by 10 CFR 50.73 (paragraph 2). The second and third
violations involved failures to follow operating and maintenance procedures
respectively (paragraphs 2 & 3). The fourth violation involved failure to .
perform s)ecial processes using appropriately qualified personnel
(paragrapi4). There is one new unresolved item in paragraph 3 regarding the
possibility of unacceptable delays in correcting undersized power cables.
.
I
;
i
l
m r ,. - - _ . . _ _ _ _ _ _ , _ - . _ . . , , . , _ _ _ . , _ . .._ .,_-__
__ - . _ _ _ - __ _ __ __ _ _
. - - _ -__ _ _ _ _ _ _ _ _ _ _ _ . _
'
. .
.. .
~3
DETAILS
1. Persons Contacted
Principal Licensee Employees
R. P. Barkhurst, Vice President. Nuclear Operations
*N. S. Carns., Plant Manager,' Nuclear
P. V. Prasankumar, Assistant Plant Manager, Technical Support
D. F. Packer, Assistant Plant Manager, Operations and Maintenance
J. J. Zabritski,flanager of Operations Quality Assurance
J. R. McGaha, Manager of Nuclear Operations Engineering
W. T. Labonte, Radiation Protection Superintendent
D. E. Baker, Manager of Nuclear Operations' Support and Assessments
*A. L. Holder, Fire Protection and Safety Department itead
*L. W. Laughlin, Site Licensing Support Supervisor
D. W. Vinci, Maintenance Superintendent
*N. E. Howard, Trending Compliance & Response Supervisor
A. F. Burski, Manager of Nuclear Safety and Regulatory Affairs
R. S. Starkey, Operations Superintendent
G. M. Woodard, Manager of Events Analysis Reporting & Responses
J. Sleger, Jr. , Nuclear Safety Review Manager
*Present at exit uterview.
In addition to the above personnel, the NRC inspectors held discussions
with various operations, engineering, technical su) port, maintenance,
quality assurance, and administrative members of t1e licensee's staff.
2. Enforcement Followup on Quality Verification Function Inspection (25578)
During the period of February 1 through February 12, 1988, the NRC staff
conducted NRC headquarters-directed quality verification function
inspections under the guidance of Temporary Instruction 2515/78. The
Inspection Report (50-382/88-200) was issued on June 2, 1988. Enclosure 1
of the report identified several potential enforcement findings. The NRC
Region IV staff has the responsibility to issue the appropriate Notices of
Violation for items requiring enforcement action. The items are listed
below:
a. Item 1.a: Failure to report a valid actuation of the broad range
toxicgasdetectionsystempursuantto10CFR50'3(a)(2)(iii),which
requires a 30-day report when an external condition poses a threat to
the safety of the nuclear power plant or significantly hampers site
personnel. Neither of these criteria were met when the actuation
occurred, therefore, the Region IV staff determined the item did not
have to be reported, There will be no enforcement action on this
item.
b. Item 1.b: Failure to report being outside of the design basis of the
plant due to nitrogen pressure indicator taps being located on the
. .
. .
4
Main Steam Isolation Valves (MSIVs) such that pressure could not be
monitored when the MSIVs were open. The Region IV staff considered
the licensee correct in not reporting this condition because the
design basis of the installation did not include being able to
monitor this parameter. This was further supported by the monitors
not being listed in the Technical Specifications. The staff noted
that LP&L did move the sensing line so that nitrogen pressure could
be checked, and that the information was provided to the licensee's
operational assessment group for dissemination to the nuclear
industry. There will be no enforcement action on this item.
c. Item 1.b: Nonreporting of a failure to meet safety to nonsafety
electr leal distribution separation criteria. The licensee
subsequently reported the event in LER 87-029, dated April 18, 1988.
Failure to report this event within 30 days of the discovery date,
which
D CFRwas April 2,(1987,)is
50.73(a)(2) contrary
ii)(b which statestothat
the requirements of submit
the licensee shall
a 30-day report identifying any event or condition of the nuclear
power plant, including its principal safety barriers, being in a
condition that was outside the design basis of the plant. This is
the first example of where the licensee failed to submit a report
required by 10 CFR 50.73 and is an apparent violation (382/8819-01).
d. Item 1.c: Failure to report an event where sampling and analysis of
the gas decay tank was not performed in accordance with the action
requirements of Technical Specification (TS) Table 3.3-13. The
apparent basis for nonreporting was that the 25 percent surveillance
extension permitted by TS 4.0.2 was not exceeded. This assertion was
incorrect. TS Action Statements are not under the purview of
Surveillance Section 4.0.2. LP&L control room personnel appeared to
be aware of this limitation all along. The licensee published
LER 87-030 on April 18, 1988, in response to the NRC concern but
improperly identified the LER as "vcluntary" instead of pursuant to
10 CFR 50.73(a)(2)(1)(B), which requires a 30-day report of any
operation or condition prohibited by the plant's Technical
Specifications. It will be necessary for the licensee to revise the
LER cover sheet to indicate that it is not a voluntary report. Since
the event date was August 19, 1987, this is the second example of the
licensee's failure to submit a report required by 10 CFR 50.73 and is
part of apparent violation 382/8819-01.
e. Item 1.c: Failure to report a missed surveillance. The licensee
failed to perform stroke testing of Containment Atmosphere Purgr
Valve CAP-205 within the required interval in accordance with
TS 4.0.5. This was discovered on October 21, 1987. The licensee's
basis of nonreporting was that the action statements which ~rcquired
that the penetration be isolated was unwittingly satisfied by otM r
valves. Although this mitigated the safety significance of the
event, it did not eliminate the fact that TS surveillance
requireme.its were not met. The licensee published LER 87-031, dated
April 18, 1988, in response to the NRC concern but improperly
. .
. .
5
identified the LER as "voluntary" instead of pursuant to
10CFR50.73(a)(2)(1). It will be necessary for the licensee to
revise the LER cover sheet to indicate that it is not a voluntary
report. This is the third example of the licensee's failure to
submit a 30-day report as required by 10 CFR 50.73 and is part of
apparent violation 382/8819-01.
f. Item 1.d: Failure to report a wiring error that occurred during a
routine relay replacement. The relay was related to the automatic
start of a switchgear ventilation recirculation fan with an ESF
actuation. The fan had redundant controls as well as the other train
being available. The licensee did not consider that the errue alone
fu
could have
structures or prevented
systems asthe fulfillment
described in 10ofCFR
the 50.73
safety (a)nction
(2)(v). of safety
Therefore, the licensee did not report the incident. The Region IV
staff agrees and will take no enforcement action on this item.
g. Enforcement action related to reporting of emergency diesel generator
valid and nonvalid failures has been taken in NRC Inspection
Report 50-382/88-08,
h. While in the control room, the inspection team observed standing
signals, which had not been acknowledged at various times during the
inspection, including February 5 and 9, 1988. Further, the
inspectors observed signal actuations at about 1:00 p.m. on
February 8 (annunciator No. 6, Trains A and B - Containment
Isolation) and at about 3:20 p.m. on February 10 (annunciator No.1
Trains A, B, and AB - Emergency Feedwater). On neither occasion was
the signal acknowledged as specified by procedure. This is contrary
to Technical Specification 6.8.1.a which requires the implementation
of procedures covering activities recommended in Appendix A of
Regulatory Guide 1.33, Revision 2, including the procedures for
abnormal, off-normal, or alarm conditions. Operating
Procedure OP-4-020, Revision 0, "Bypassed and Inoperable Status
Indication System " requires the monitoring of safety equipment
status by way of computer and requires operator acknowledgement and
evaluation of systems that have been computed to be inoperable. This
is an apparent violation (382/8819-02).
3. Monthly Maintena_nce Observation (62703)
The below listed station maintenance activities affecting safety-related
systems and components were observed and documentation reviewed to
ascertcin that the activities were conducted in accordance with approved
procedures, technical specifications, and appropriate industry codes or
standards,
a. Work Authorization 99000212. The NRC ins)ector observed the
performance of hardness examinations on tie inlet and outlet flanges
for component cooling water system Valves CC-8083AB, CC-8085AB,
CC-8244AB, and CC-8246AB. These flanges were part of the recently
. .
.
6
installed piping used to connect a temporary chiller to the
containment coolers during long duration outages. The flanges were
examined in response to NRC Bulletin 88-05, "Nonconforming Materials
Supplied by Piping Supplies, Inc., at Folre , New Jersey, and West
Jersey Manufacturing Company at Williamst w.i, New Jersey." Testing
was performed with an Equotip hardness tuter. Two of the eight
flanges tested had satisfactory hardness measurements but six were
unsatisfactory. After consulting the NUMARC and the Equotip vendor,
the licensee decided the following:
(1) The acceptance criteria would be reduced from a hardness
corresponding to 70,000 pounds per square inch strength (70 KSI)
to that which corresponds to 66 KSI.
(2) The test surface would have to be prepared using 120 grit
flapper wheels only (60 grit was previously used) in order to
get accurate measurements.
(3) The hardness test sample size for each flange would be increased
from four to five with the highest and lowest readings discarded
before averaging the readings.
(4) Acceptance criteria for the variation in readings was provided
by the hardness tester vendor. If all readings in a sample did
not meet this criteria, testing would be performed at a new
location.
After the appropriate procedure changes, all eight flanges were
retested satisfactorily.
The NRC inspectors also observed the hardness testing of Essential
Service Chilled Water Flanges 3AC-2208, 3AC-2218, and 3AC-2228. The
flanges did not meet the specified minimum hardness corresponding to
66 KSI. The lowest reading corresponded to 63.3 KSI. The licensee
promptly performed an analysis which determined that the flanges were
suitable for their present application. This is a low pressure, low
energy system. The inspector reviewed the completed work package,
including the analysis and a justification for continued operation,
and no problems were noted.
b. Work Authorization WA-01020904. The NRC inspector witnessed portions
of the overhaul of the motor-driven firewater pump during the week of
July 18, 1988. The inspector reviewed the work authorization to
determine if it contained adequate instructions, references, and hold
points. The inspector also verified that Quality Assurance,
Maintenance Administrative Supervisor, and Shift Supervisor reviews
and approvals were received prior to starting work. The inspector
verified the materials to be used met the appropriate specifications
and had the proper documentation. Some packing material was upgraded
3 for use in this application in accordance with licensee
Procedure UNT-07-021, Revision 6, "Spare Parts Equivalency Evaluation
._ - _ _ .
_ _____ _________ ._ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _
. .
. .
7
Report / Parts Quality Level Determination." The NRC inspector
reviewed this procedure and the evaluation for the packing material
in this application and found this acceptable.
Three instances of procedural noncompliance were observed during the
pump reassembly. Work Authorization 01020904 referenced Technical
Manual 457000514 Volume 2, "Type A Centrifugal Pumps," for
instructions for pump reassembly. The manual contained FMC
Corporation, Peerless Pump Division, Bulletin No. 2880551, "Repair
Instructions, Type A Centrifugal Pumps." Step 3-2.f of this document
provided instructions which stated, "Cover the top side of the casing
gasket with a mixture of graphite and oil." The NRC inspector noted
that this step was not performed prior to the pump casing assembly.
Steps 3-2.f and 3-2.h provided instructions which stated, "Rotate
shaft by hand to check that it runs free," after the casing
reassembly and after the packing gland reassembly. These rotational
checks were not performed. Step 3-2.g provides instructions which
state, "Insert the glands and set the nuts finger tight-00 NOT USE A
WRENCH." The NRC inspector observed the packing rings inserted with
the use of a wrench.
The instances above did not represent a significant degradation of
the work product but rather indicated a lack of sensitivity to
procedural compliance. This lack of adherence to procedural
requirements is an apparent violation of NRC regulations
(382/8819-03).
c. Work Authorization 01022087. The NRC inspectors monitored the
licensee's efforts to repair the AB Essential Services Chilled Water
System Chiller. This chiller is a "swing" unit which can serve as a
backup to either the A or B chiller. The AB chiller is not normally
in operation and does not corre under the purview of the technical
specifications, unless it is being used in place of the A or B
chiller in that respective essential services chilled water loop.
The problems with the AB chiller may have been caused or aided by the
fact that it was not run on a routine basis. This indicates that its
availability may be questionable if lef t out of service for extended
time periods. The licensee is evaluating the preventive maintenance
and reliability aspects of the AB chiller and intends to do more work
during the next inspection period. The inspectors will continue to
mor.itor licensee activity on this unit.
d. Work Authorization 01005480. The NRC inspector observed the
replacement of the wiring and conduit in an auxiliary control panel
to the "A" Shield Building Ventilation System Heater Control
- Panel (EHC-51(3A-5A)). The installed wire was observed to be brittle
'
and discolored. No problems were noted during the installation.
During work package documentation review, the NRC inspector observed
that the wire and conduit were being replaced in response to
i Nonconformance Condition Identification Work '
Authorization (CIWA) 016612, dated March 24, 1985. The
. .
O S
8
nonconformance was written after determining that the installed wire
(No.12 AWG) was not adequate for the load requirements and No. 8 AWG
wire was the minimum required size. In March 1985, licensee
personnel observed that this undersized wiring was discolored and
brittle. It was also noted that a backup contactor in the "B" Train
Heater Control Panel (EHC(3B-5B)) was overheating during operation.
This indicated that proper contact was not being made and/or a high
contact resistance condition existed. The engineering evaluation in
CIWA 016612 required immediate action to replace the backup contactor
to avoid further damage and immediate expediting of replacement power
cables. The backup contactor was replaced in January 1986
(approximately nine months later). The power cables for the "A"
Train Heater were not replaced until July 1988, almost two and one
half years later. The NRC inspector requested that the licensee
provide additional information on the basis for the delays in
correcting these nonconformances. Determination of the causes for
the delays and of the safety significance of this issue shall be the
'
subject of an Unresolved Item (382/8819-04).
4. Allegation Followup (92701)
The NRC inspector performed a review to determine the safety significance
of the following concerns and to ensure that appropriate corrective action
was taken.
a. (Closed) Concern 4-87-A-0030
The following issues on fire wrap of cable installations were
identified by a concerned individual:
been
(1) The individual
adequately did not consider
addressed his concerns
by the licensee's QualityasTeam.
having(The
Quality Team is a licensee organization that provides a
confidential means by which employee safety and quality concerns -
can bs. received, investigated, and acted upon as appropriate.
Exiting employees and contractors are encouraged to check out
through the Quality Team. If they do not, a fonn letter is sent
to their forwarding address thus
mail or by telephone "hot line.")providing the opportunity by
(2) At the time these concerns were received by the NRC, the
individual stated that he had been unjustly terminated because
of his previous concerns. (It is understood by the staff from
discussions with the individual that this is no longer an issue
and thus will not be addressed in this report.)
(3) The LP&L insulation inspector is not doing a correct or adequate
job.
The NRC inspectors reviewed the practices and policies of the LP&L
Quality Team on July 29, 1988. It appeared that the Quality Team was
_
.
. ,
,
9
carrying out their charter as required by company policies and
procedures. The inspector noted, however, that the followup closure
letters sent to the individuals are very short and somewhat cryptic.
Comparison of sample letters with the activity files indicated that
disposition letters sent to individuals do not fully represent what
action was taken and to what extent. The licensee's representative
stated that it is LP&L's policy to avoid detailed technical
discussion in the responses. The inspector acknowledged this as
LP&L's prerogative. The brief notifications may be the cause for
some individuals concluding that little or no action was taken on
their concerns. Their only recourse is to take the concerns to the
NRC. This appears to resolve Item (1) above. The staff intends to
take no further action on this.
The inspector reviewed Quality Team files related to fire wrap and
,
fire seals in 1987 and 1988. The concerns appeared to have been
'
adequately addressed with the exception of one area. In one file,
there was concern that fire wrap was not being properly installed;
that people were leaving trash and debris in cable trays and wrapping
trash along with the cables. A letter to the Assistant Plant
Manager, Technical Services, dated March 5, 1987, was in the Quality :
Team file requesting action in response to the concern. No response
was in the file nor could the Quality Team Supervisor produce an
appropriate disposition. The Quality Team Supervisor comitted to
provide an answer for the inspector. On August 2, 1988, the
inspector was provided with the response, which was dated August 1,
1988. The letter stat?d that there was a delay in the response
because a 100 percent surveillance of fire wrap was underway. On
January 12, 1988, the surveillance was completed, and any
deficiencies discovered were repaired and reinspected.
The inspectors reviewed documentation of completed fire wrap and fire
seals. There was no indication that the LP&L insulation inspectors
were failing to follow the procedural requirements of inspection and
verifying correct work in these areas. The inspectors also reviewed
a sampling of completed fire seal surveillances. It appeared that
roughly five percent of the results were unsatisfactory and thus
requiring repairs due to expected wear and tear from people working
in the areas. There was not a preponderance of evidence that would
lead the inspectors to the conclusion that improper inspection
activities existed, thus Item (3) could not be substantiated,
b. (Clused) Concern 4-88-A-0032
The following issues on fire seal installation / rework were identified
by a concerned individual.
(1) Ropes were left protruding from fire barrier seals after rework.
I i
-_ ____ _ _ .,_- ____.. _._ . _ _ _ . _ _ _ - _ _ - _ _ _ - _ . _ _ __
=
.
.
10
(2) Quality Assurance inspectors did not always verify the required
dimensions (two inches around the periphery) of the void before
it was filled with repair material and sealed during fire seal
rework operations.
(3) Fire seal installation / rework was being performed by t.nqualified
individuals.
(4) Quality Control inspectors were completing signoffs in the fire
seal installation procedure accepting fire seals that were not
installed.
The NRC inspector observed a fire seal and found a cable pull rope
protruding from the seal. The licensee later stated during
discussions that there is no degradation due to cable pull ropes
protruding from fire seals. Additionally, the licensee provided
copies of Southwest Research Institute Reports 01-8305-058A and
01-8305-058B which supported this. The inspector concluded that
Item (1) above was not a valid cor.cern.
The NRC inspector reviewed Procedure ME-13-100, Revision 6 "Fire
Barrier Installation and Rework," and observed that a quality hold
point to verify the removal of two inches (minimum) of material
around repair areas was sequenced before the void was filled. The
inspector also noted that a recent change was incorporated into the
procedure to change the sequence of this hold point from after
filling the void to prior to filling. Licensee personnel stated that
this procedure change was issued after a concern nad been raised by
an individual performing fire seal repair work. -1 NRC inspector
discussed the sequence of perfomance of this verilication with a
Quality Assurance inspector who had been responsible for performing
these inspections. The Quality Assurance inspector stated that
verification of removal of two inches of material was always
performed prior to filling the void. The results of thw NRC
inspector's review of documentation indicated that although the hold
point in ME-13-100 had been listed out of sequence, it would have to
have been performed prior to installation of the seal material
otherwise the Quality Assurance inspector could not have accomplished
the action. The inspector found no reason to pursue the matter
further short of removing seals to see if the two-inch requirement
was met. There was insufficient evidence to require such action.
The licensee's corrective action to change ME-13-100 to the proper
sequence appeared adequate to preclude future questions in this area.
Item (2) above is therefore resolved.
The NRC inspector discussed training requirements for fire seal
repair personnel with the licensee. Tra1oing records were then
reviewed to ascertain the qualifications of individuals involved in
fire seal repair. The inspector noted thet the licensee has not
implemented a training course on fire seal installation /rewt,rk.
Personnel performing these repairs were contractors, and
~
.
. .
11
qualifications were determined by a licensee department head based on
previous training and work experience. Some of the people installing
fire seals, however, had no record of prior work experience nor any
formal training in fire seal installation, thus they should not have
been considered qualified. Failure to perfonn this special process
with appropriately qualified personnel is contrary to the
requireaents of 10 CFR 50, Appendix B, Criterion IX, which states (in
part) that measures shall be established to assure that special
ersonnel. This is an
processes
apparent are accomplished
violation by qualified
(382/8819-05). Item p(3) above is apparently
substantiated.
ME-13-100, Paragraph 3.2, states, "Maintenance personnel directly
supervising installation or rework activities in accordance with this
rocedure shall have su::cessfully completed the training program
p(either B&B Training Program or LP&L Training Program or applicable
instruments) covering Cable Wrap Protective System or Penetration
Seals, Fire Barriers, and Water Seals." The wording does not appear
to implement adequate measures to ensure people who are supervising,
inspecting, and performing fire seal work will be properly qualified.
'
The licensee identified this in LP&L Quality Assurance
Audit SA-88-010.1, "Control of Special Processes," dated April 28,
1988. The audit was performed during the period February 19 thrcugh
March 18, 1C88. Quality Notice QA-88-036, of March 9, 1988,
identified the deficiency for processing under the licensee's
corrective action program.
The licensee's fire seal installation / rework program did require
acceptance by Quality Control (QC) inspectors after work completion.
In addition, third-party inspections were performed prior to
returning the seals to an operable status in accordance with
surveillance procedures. These inspections were performed by
experienced parsonnel in the electrical maintenance department. The
NRC inspector reviewed inspection documentation and discussed the
inspection results with the department supervisor responsible for the
third party inspections. No significant problems were identified to
indicate a lack of QC inspections during fire seal installations.
Item (4) above does not appear to be a valid concern.
Specific actions taken pursuant to apparent violation 382/8819-05 will be
documented in a future inspection report.
5. Operational Safety Verification (71707, 71709, & 71881) _
The objectives of this inspect'on are (1) to ensure that this facility is
being operated sately and in conformance with regulatory requirements,
(2) to ensure that the licensee's management controls are effectively
discharging the licensee's responsibilities for continued safe operation,
(3) to assure that selected activities of the licensee's radiological
protection programs are implemented in conformance with plant policies and
. .
. .
12
procedures and in compliance with regulatory requirements, and (4) to
inspect the licensee's compliance with the approved physical security
plan.
The NRC inspector attended the quarterly ALARA committee meeting held on
June 27, 1988, and noted that the licensee's ALARA program appears to be
effective in reducing Man-Rem expenditure as evidenced by the following:
a. The licensee estimates that 5-10 Man-Rem were saved by use of
improved reactor head shielding during the recent refueling
operation,
b. New aluminum foreign material exclusion covers versus steam generator
nozzle dams for a cleanliness boundary during tube inspections
reduced installation / removal time by a factor of ten. This resulted
in significant Man-Rem savings. In addition, when nozzle dam
installation was required, mockup training appeared to be effective
because exposure rates were reduced by a factor of four from the
previous refueling outage.
c. The licensee's contaminated area reduction program has been effective
resulting in a contaminated area reductior. from 13 percent to
2.4 percent of plant area (outside of containment).
The inspectors visited the control room on a daily basis when onsite and
verified that control room staffing, operator behavior, shift turnover,
adherence to technical specification limiting conditions for operation,
and overall control room decorum were being conducted in accordance with
NRC requirements. No prnblems were identified.
Tours were conducted in various locations of the plant to observe work and
operations in progress. Radiological work practices, posting of barriers,
and proper use of personnel dosimetry were observed. The inspectors noted
considerable effort underway to reduce areas containing surface
contamination in the Reactor Auxiliary Building.
General housekeeping, condition of fire protection equipment, and physical
condition of safety related equipment were inspected with particular
emphasis on engineered safety feature systems.
The inspectors verified, on a Sr.n.pling basis, that the licensee's security
force was functioning in compliance with the approved physical security
plan. Search equipment such as X-ray machines, metal detectors, and
explosive detectors were observed to te operational. The inspectors noted
that the protected area was we.Il maintained and not compromised by erosion
or unauthorized openings in the area barrier.
No violations or deviations were idercified.
,
1
. ,
13
6. Monthly Surveillance Observation (61726)
The NRC inspectors observed the below listed surveillance testing of
safety-related systems and components to verify that the activities were
being performed in accordance with the technical specifications. The
applicable procedures were reviewed for adequacy, test instrumentation was
verified to be in calibration, and test data was reviewed for accuracy and
completeness. The inspectors ascertained that any deficiencies identified
were properly reviewed and resolved,
a. Procedure OP-903-032, Revision 6, "Quarterly ISI Valve Tests." On
July 19, 1988, the NRC inspector observed the performance of
Quarterly ISI Valve Tests on the component cooling water system by
the licensee's control room operators. These surveillance tests were
perfomed in accordance with Section 8.7 of Procedure OP-903-032.
The NRC inspector reviewed the procedure to verify the appropriate
administrative reviews and approvals were obtained prior to
performing the test. The control room operators were observed using
the procedure to perfom these tests in a step-by-step manner.
Communications between operations personnel in the control room and
operators out in the plant were observed to be accurate and clear.
The surveillance tests were completed satisfactorily, and no problems
were identified,
b. Procedure OP-903-056, Revision 6, "Fire Protection Systems Functional
Test." During the period July 26 through July 29, 1988, the
inspectors witnessed portions of the annual flow capacity testing of
the motor-driven and both diesel-driven fire pumps. The operators
appeared to follow the procedure satisfactorily in a step-by-step
manner. The motor-driven pump performed well within the acceptance
criteria, which was expected because the pump had just been
overhauled during the week of July 18, 1988. The diesel pumps
performed marginally. The raw data indicated that the
have been delivering at least 2000 gallons per minute (pumps
GPM) while at may not
a pump head of 100 pounds per square inch differential (psid).
Technical Specification (TS) 4.7.10.1.1.f.1 requires each of the
pumps to deliver at least 2000 GPM at a total head of 100 psid by
verifying at least three points on the pump performance curve during
performance testing. Acceptance Criterion 7.2 of OP-903-056 appears
to have the same requirements. The operator brought this to the
attention of the system engineer who then evaluated the data using
correction factors. The operator explained to the inspector that the
pumps were perfoming satisfactorily based upon the engineer's
calculations. The test was completed with what appeared to be
marginal results. The NRC inspector decided that further review was
necessary.
On July 30, 1988, the inspector reviewed the completed fire pump flow
data that had been presented to the Shift Supervisor. Diesel Fire
Pump No. 1, although it only delivered 1966.6 GPM, was running below
rated speed. By applying correction factors for speed in accordance
.
. ,
14
with OP-903-056, the pump would deliver at least 2000 GPM at 100 asid
if running at or above rated speed. The TS was silent as to whetler
the pump should deliver at least 2000 GPM at 100 psid when called
upon during testing or actual need or just be proved capable of the
same by applying correction factors. By taking a liberal
interpretation of the TS and by applying cc,rrection factors for
speed, the three Joint pump curve established by this test places the
pump just above t1e 2000 GPM point at 100 psid.
Diesel Fire Pump No. 2 was running slightly above rated speed but
delivered only 1991.5 GPH. Application of correction factors in
accordance with OP-903-056 placed the pump below the 2000 GPM point
at 100 psid. Although this was well within the acceptable -ange set
up by ASME, Section XI, Table IWP-3100-2, which i +3 percent and
-10 percent, it did not comply with the TS as written. When the
inspector brought this to the attention of the Shift Supervisor, he
agreed and declared the pump inoperable. Since only two of the three
fire pumps must be operable at all times, this did not place the
plant in a TS L niting Condition for Operation (LCO). By the strict
interpretation of the acceptance criteria in 0P-903-056, the operator
(assisted by the system engineer) failed to follow the procedure
acceptance Section 8.8 which requires the operator to identify
unsatisfactory test results and to inform the Shift Supervisor.
Instead, the procedure was signed off as satisfactory. In light of
the arrbiguities associated with the TS and the procedure,
particularly when the ASME Code allows a negative tolerance of
10 percent, the staff will not issue a Notice of Violation. The
licensee has comitted to obtain a TS change and clarify 0P-903-056
acceptance criteria such that the intended operability requirements
of the fire pumps will be met. The Waterford 3 FSAR,
Section 9.5.1.2, calls for a maximum demand of 1844 GPM. As such,
the TS value could be lowered to accommodate normal pump wear and
still be within the safety analysis. This shall be tracked under
Open Item 382/8819-06.
No violations or deviations were identified.
7. Followup of Previously Identified items (92701)
a. (Closed) Unresolved Item 382/8615-03: Conflicts and inconsistencies
between the Technical Specifications, FSAR, and Operating
Procedure OP-10-001, Revision 6. "Cooldown to Hot Shutdown (Mode 3 to
Mode 4)." These inconsista cies were related to Reactor Coolant
System (RCS) Low Temperature Overpre"urization Protection (LTOP).
Appendix 5.2B.3 of the FSAR state 5 that administrative controls
necessary to provide LTOP are limited to those controls that open the
shutdown cooling system isolation valves, which in turn place the
shutdown cooling system relief alvr in service. The NRC inspector
was concerned that there were idi ' administrative controls
addressed in Section 6.3.2.5
3 \R. The language of
licensee to be poorly worded
Section 6.3.2.5.1 was dett
_ _ _ - - - -
. ___
-_ _ _____-.-
_____ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .___ ____
, .
. ,
f
15
and subject to misinterpretation. This section of the FSAR has since
been rewritten and will be included in the 1988 revision of the FSAR.
The other inconsistencies identified by the NRC inspector were also
addressed and corrected by the revision to Section 6.3.2.5.1 of the
FSAR. This item is closed,
b. (Closed)OpenItem 382/8710-01: Followup on the basis for
modification to core protection calculator auxiliary cabinet fans.
The licensee provided a copy of Field Action Request 9270-422, dated
February 24, 1984, which documented Combustion Engineering's approval
of modifications to the fans. The modifications included rerouting
of the power cord and bypassing of the "high/ low" switch. In
addition, the licensee added a precaution to the SIMS - Instrument
Information Sheet for the applicable control panel (CP-22) addressing
fan modifications. This item is closed.
c. (0 pen) Open Item 382/8710-03: Followup on the licensee's actions to
, install and ensure adequate control of seismic restraining bolts on
480 volt switchgear breaker cabinet hoists during maintenance
activities. The NRC inspector verified that the seismic restraining
bolts were installed. The NRC inspector also verified that
instructions to reinstall these bolts after maintenance had been
incorporated into the applicable breaker maintenance procedures, t
However, the instructions referenced Drawing 506760500. This drawing
could not be obtained by the NRC inspector from the document control
center at the Waterford-3 site, which places its existence or perhaps
the drawing number in question. As of the end of this inspection
period, about a week had passed and the licensee had not yet provided
the drawing. Consequently, this item could not be closed,
d. (Closed) Open Item 382/8717-03: Followup on the licensee's '
3
implementation of corrective actions taken because a containment '
pressure instrument was lef t isolated durin" maintenance. The NRC
inspector verified that Procedure OP-903-02), Revision 2, "Inspection
4
of Containment," has been changed to require and provide instructions '
!
4
for containment pressure detector operability checks when
<
establishing containtent integrity. These enecks are now performed +
4
bv measuring the pressure difference with the containment purge .
system operating and secured. The NRC inspector reviewed the results
of the check as performed after the recent refueling outage. No
.
l
problems were noted. The licensee has issued a letter, W3M87-0244, ;
dated September 15, 1987, to clarify policy requiring "in-hand"
- procedure use in radiological controlled areas. This position is
also addressed in Procedures MD-1-014. Revision 2. "Conduct of f
Maintenance," and UNT-4-009, Revision 7. "Control, Distribution, :'
;
Handling, and Use of POM Procedures." This item is closed.
e. (Closed) Open Item 382/8804-03: Followup of licensee actions on
items identified during controlled area ventilation system walkdown,
The NRC inspector verified that the licensee had corrected the
,
l
identified items. This item is closed,
i
,_. -
_ _ _ _ _ _ _ _ _ _ _ _
. .
. .
16
f. (Closed)OpenItem 382/8731-02: Followup on final outcome of
licensee staff reviews of vendor information packages. During the
period of December 7 through December 18, 1987, the NRC conducted a
Procurement / Vendor Information Audit at Waterford 3 The NRC
inspectors identified cases where service bulletins issued by the
emergency diesel generator vendor, Cooper-Bessemer, were not acted
upon by the licensee. The specifics were corrected as reported in
NRC Inspection Report 50-382/87-31, however, the licensee committed
to conduct a two-phase review of a population of 769 items which had
presumably been processed through the licensee's Vendor Equipment
Technical Information Program (VETIP). The first phase consisted of
345 VETIP packages which the licensee determined to have a potential
for significant impact on plant equipment. This was completed on a
priority basis by January 5, 1988. The second phase was a review of
the remaining 424 VETIP packages which was completed by March 1,
1988. A total of 208 packages required additional plant staff
review, and as a result, 20 required procedure changes. Quality
Notice 88-01 was written to document the failure to ensure that
proper reviews of vendor infonnation packages are performed. With
the exception of the Cooper-Bessemer service bulletins already
identified, no significant program or procedure changes resulted from
the rescreening effort. Details on the licensee's actions were
documented and transmitted from LP&L to the NRC on March 19, 1988, by
cover letter serial number W3P88-0040. This item is closed.
No violations or deviations were identified.
8. Followup On NRC Bulletin 88-05 (92703)
The inspectors conducted followup inspections on NRC Bulletin 88-05,
"Nonconforming Materials Supplied by Piping Supplies, Inc., at Folsom, New
l
Jersey, and West Jersey Manufacturing Company at Williamstown, New
l
Jersey." The licensee promptly initiated a program to carry out the
i instructions in the bulletin. They determined the number of affected
flanges onsite, and then initiated actions to locate and test the flanges.
By review of procurement documents, the licensee determined that 534 of
the affected flanges were potentially onsite. Records were traced to
locate each flange. The licensee determined that 259 flanges were
currently installed in safety-related systems,138 flanges vere in the
warehouse, and the remaining 137 flanges were not installed in
safety-related systems.
As flange locations were determined, the licensee perfonned hardness
testing using an Equotip hardness tester to detennine whether material
design strength requirements were met. Several flanges were tested onsite
and then at an independent testing laboratory to verify results of the
onsite testing. In addition, several flanges were destructively tested
offsite to verify onsite test results. The material strength determined
offsite were found to correspond with onsite measurements. At the end of
this inspection period,16 flanges (in safety-related systems) were found
l
_. m
. .
. ,
17
to have lower than acceptable strength of 66 KSI. Seven of these flanges
(HeatNumberG631889) were installed on the inlet to main steam relief
valves ~The licensee performed an analysis, based on the lowest strength
flange (58 KSI) and the highest calculated loading, and determined that
these flanges met the ASME, Section III NC-3658.1, requirements and were
acceptable for their intended use.
Five essential service chilled water system flanges and four containment
atmosphere release system fbges (the lowest were at 60 KSI) were found
to have lower thtn required strength of 66 KSI. These flanges were
detemined to be acceptable after an analysis was performed and
conformance with ASME, Section III, was verified.
The licensee has identified three flanges which are located in the
l containment. Two of these flanges are in the containment atmosphere
i release system and one on the component cooling water return to Reactor
J Coolant Pump 2A cooler. Because these flanges are in a high radiation and
i
high temperature area, the licensee has published a justification for
'
continued operation, which states that testing can be delayed until the
next forced outage without introducing a significant hazard. These are
low pressure, low energy systems.
4
No violations or deviations were identfied.
9. Licensee Event Report (LER) Followup (92700)
In early June 1988, the inspector conducted a review of Potentially
Reportable Event (PRE) Report 88-055 which was the licensee's internal
identification that a snubber had been discovered missing from the
shutdown cooling system (Safety Injection System) during maintenance.
On May 17, 1988, maintenance personnel were reinstalling the shutdown
cooling relief Valve SI-404A after maintenance when they noted
Snubber SISR-1352 missing. The Shift Supervisor was appropriately
notified, and a work authorization was initiated to promptly replace the
snubber. In accordance with Technical Specification (TS) 3.7.8, the
, !
absence (and thus the inoperability) of this snubber placed the shutdown
- cooling system in an inoperable status for an indeterminate amount of
'
time, a condition prohibited by technical specifications. The plant was
in a refueling outage, and there were times when TS 3.9.8.2 required
shutdown cooling Train A to be operable. The PRE indicated that this
event was not reportable because subsequent evaluation determined that the
snubber could be removed permanently. The subsequent evaluation which
showed the snubber was not required mitigated the consequences of the
event but it did not affect the reportability of the event.
During an exit meeting on June 17, 1988, the inspector expressed concern
to plant management regarding implementation of the reporting requirements
of 10 CFR 50.73. On July 11, 1988, LER 88-017 was published describing
,
the above event. This is a fourth example (see paragraph 2 of this
I L .
, _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
. .
18
report) of failure to comply with the reporting requirements of
10 CFR 50.73. This is part of apparent violation 382/8819-01.
Since the issues are already identified in apparent violation 382/8819-01,
the staff will not issue a second Notice of Violation citing the failure
of the licensee to maintain shutdown cooling Train A operable when it was
required by TS 3.9.8.2. It appears that issues and corrective actions
that would normally be discussed in the response to such a violation were
addressed in LER 88-017, thus no purpose would be served in the issuance
of another Notice of Violation. Although the LER stated that a root cause
of this event could not be detennined because it could not be ascertained
when or why the snubber was disconnected, the event implies that someone
removed the snubber without authority after April 8,1988, (when it was
surveillance inspected in place). The inspector expressed concern that
on-going licensee efforts to eliminate procedure violations (which
includes doing work affecting quality without procedural controls) are not
achieving satisfactory results to date. The licensee acknowledged the
inspector's concerns in the procedure compliance area and discussed
additional plans and programs being implemented to achieve procedure
compliance. The resident inspectors will continue to monitor this area.
LER 88-017 is closed.
10. Onsite Followup of Events (93702)
a. Failure of Main Feed Pump "A"
During the week of July 18, 1988, the licensee noted increasing
vibration on the Main Feed Pump (MFP) "A". The plant was at full
power with both MFPs in service. By the end of the week, the
vibration had approached approximately 8 mils displacement, which was
the licensee's decision point for reducing power and securing MFP "A"
for investigation and repairs. By 3:00 p.m. on July 22, 1988, power
was reduced to about 65 percent. The pump was disconnected from the
turbine, and the turbine was tested for vibration, with satisfactory
results. The pump was then disassembled to repair an already leaking
inboard seal. The licensee found the inboard pump bearing badly
damaged with melted babbit, and two of the 26 socket head bolts that
secured the diffuser were missing. One of the bolts was found jauned
in the impeller. The bolt and the impeller were both damaged. This
seemed to point toward the cause of vibration. Attempts to find the
second boltimposed
restrictions were unsuccessful due to
by minor steam access
(hot and
flashing visibility ) leakage
feedwater
into the suction piping. Although the remaining 24 diffuser bolts
were tack welded in place, two other bolts were found with the bolt
heads broken off. The licensee connented that earlier revisions of
the MFP technical manual did not specify a torque value for these
bolts, but the current revision did, thus the bolts may have been
over torqued during initial installation. The licensee replaced all
, 26 diffuser bolts, the pump bearings, the impeller, and the pump
seals.
r
. .
. .
19
On July 26, 1988, MFP "A" was started up after completion of repairs.
At about half speed, a metallic sound was heard in the pump, and
again severe vibration of 8 to 10 mils was observed. On July 27,
1988, MFP "A" was again disassembled to determine the cause of
vibration. The inboard seal was opened to look in the impeller for
the bolt that could not be found. The feedwater isolation valves
seated better this time allowing removal of a short section of the
suction piping, and the bolt was found. The pump was reassembled,
and by 6:00 a.m. on July 29, the plant was restored to full power.
No violations or deviations were identified.
11. Plant Status (71707)
The plant was at full power from the beginning of the reporting period
until about 3:00 p.m. on July 22, 1988. Then power was reduced to
65 percent for Main Feedwater Pump "A" repairs, and stroke testing of the
main turbine throttle, governor and intercept valves. Also, while at
reduced power, the monthly reactor control element assembly movement test
was done.
On July 22, 1988,
at about
on low electro-hydraulic 9:25 p(.m.
control EHC), pressure.
the plant experienced a turbine trip
Maintenance mechanics
were replacing a test solencia valve while at reduced power. A check
valve used for isolation leaked due to a missing "0" ring when they
attempted to remove the solenoid valve. This depressurized the EHC and
the turbine tripped. The Steam Bypass Control System responded properly,
and the reactor remained at power. Minimum power was about 30 percent
until the plant was restored to the grid at about 9:30 a.m. on July 23,
1988, and then power was increased back to 60 to 65 percent.
As discussed in paragraph 10 above, by 6:00 a.m. on July 29, 1988, full
power was restored and remained such as of the end of this inspection
period.
No violations or deviations were identified.
12. Exit Interview
The inspection scope and findings were sunnarized on August 1,1988, with
those persons indicated in paragraph 1. The licensee acknowledged the NRC
inspectors' findings. The licensee did not identify as proprietary any of
the material provided to or reviewed by the NRC inspectors during this
inspection.
1
}}