ML20153E309

Insp Rept 50-382/88-09 on 880404-08.No Violations or Deviations Noted.Major Areas Inspected:Licensee Surveillance Procedures & Records & Verification of RCS Leak Rates

ML20153E309
Person / Time
Site:	Waterford
Issue date:	04/26/1988
From:	Bundy H, Mckernon T, Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20153E295	List: ML20153E292 ML20153E309
References
50-382-88-09, 50-382-88-9, NUDOCS 8805090454
Download: ML20153E309 (8)

See also: IR 05000382/1988009

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APPENDIX

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,- U.S. NUCLEAR REGULATORY COMMISSION ..

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REGION IV-

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. NRC Inspection Report: 50-382/88-09 Operating' License: NPF-38

Docket: 50-3f12 l

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' Licensee': -Louisiana Po'wer & Light Company (LP&L) -

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N-80

317~Baronne Street

New Orlean's, Louisiana 70160

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' Facility Name: Waterford Steam Electric Station, Unit 3 (W3)

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Inspection At: W3, Taft, Louisiana ,  ;

Inspection Conducted: ' April 4-8, 1988

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Inspectors: [@ ~'

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f 7 T. O. McKernon, Reatitor Inspector, Test

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Programs Section, Division of Reactor Safety _

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H FT Eundy, Reactor Inspector, Test Programs

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Section, Division of Reactor Safety ,

Accompanied ,

By: W. C. Seidle, Chief, Test Programs Section  ;

Division of Reactor Safety on April 7-8, 1988

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Approved: -

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7.~C. SeidT % Chief, Test Programs Section Date

Division of Keactor Safety ,

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Inspection Summa _ry

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Inspection Conducted April 4-8, 1988 (Report 50-382/88-09) i

Areas Inspected: Routine, unannounced inspection of the licensee's

surveillance procedures and records and verification of reactor coolant

system (RCS) leak rates. l

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8805090454 880505

PDR ADOCK 05000382

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Results: The procedures and records reviewed in the areas of inservice

inspection of components and inservice testing of pumps and valves pursuant to

10 CFR 50.55a(g) and ASME Section XI appeared to satisfy all requirements. -The

procedures and records related to Technical Specifications required .

surveillances appeared to satisfy ~ all requirements. However, an area of

confusion relating to anomalies in calibration and control of measuring and

test equipment was identified (paragraph 2). The NRC inspectors verified the

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adequacy of the licensee's calculating technique 3 for determining RCS leak

rates,

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DETAILS

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1. Persons'Contactjd

.. LP&L

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R. Barkhurst, ' lice President, Nuclear / Site Director

• N. Carns, Plant Manager

• P. Backes, Special Assistant to Vice President

• P. Prasankumar, Plant Technical Services Manager j

• S. Allenan, Quality Assurance Manager ,

R. Starkey, Operations Superintendent

• T. Smith, Plant Engineering Superintendent

• G. Wuller, Operational Licensing S_upervisor

+0. Schultr, Operations Shift Technical Aovisor Supervisor

G. Koehler, Operations Quality Assurance Supervisor

• D. Baker, Event Analysis and Response Supervisor

L. Bass, Technical Support Supervisor

• G. Robin, Inservice Inspection Coordinator

• A. Harris, Shift Technical Advisor

C. DeDeaux. Technical Specifications Coordinstor

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NRC ,

y~ ' *W. Smith, Senior Resident Inspector

T. Staker, Resident Inspector

• E. Tomlinson, Nuclear Reactor Regulation .

• W. C. Seidle, Chief, Test Programs Section, Division of Reactor Safety

The NRC-inspectors also interviewed other licensee personnel during the

inspection.

• Denotes those attending the exit interview on April 8, 1988.

2. e

Surveillanc_efroceduresandRecords (61700)

The purpose of this part of the inspection was to ascertain whether the

surveillance of safety-related systems and components was being conducted

in accordance with approved procedures as required by the licensee's

Technical Specifications (TS) Inservice Inspection (ISI) Plan, and

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InserviceTesting(IST) Plan. Pursuant to this ob.iective, the NRC

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inspectors reviewed the following licensee documents:

• 10 Year Inservice Inspection Program, Revision 3 (ISI Plan)

• W3 LP&L Pump and Valve Inservice Test Plan, Revision 5 (IST Plan)

The NRC inspectors then selected certain TS surveillance requirements and

components listed in the ISI and IST Plans and reviewed the associated

licentea test procec'ures and an appropriate number of test results records

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for each procedure. The TS surveillance requirements of ISI or IST

components together with the associated test procedures reviewed by the

NRC inspectors are tabulated in the attachment.

The NRC inspectors determined that the required tests were being scheduled

and performed as required in accordance with approved procedures.

Acceptance criteria were specified in the procedures, and the records

st0ted satisfaction of acceptance criteria. Appropriate instructions for

returning equipment to service following testing were given. Also,

selected test personnel were verified to have appropriate certifications.

All requiren nts appeared to have been satisfied. However, anomalies in

calibration tnd control of measuring and test equipment (M&TE) discovered

in one test record are discussed below.

During a review of records pertaining to Surveillance Procedure MI-3-305,

Revision 3. "Instrumentation Loop Check," dated October 24, 1986, for

Bistable SG-IL 1113C, it was noted that Task Card No. 1, Note 1 indicated

that one of the test equipment maters was out of tolerance. In particular,

the record stated, ". . . as found data for SG-ILEI-1113C, TBB 19 and 20

is out of tolerance due to bad (out of tolerance) test equipment. No

adjustments were made. As left data was taken with good test equipment."

The NRC inspectors noted that five M&TE items were listed on the test

record; Decade Bcx, MIET 124.006; Transmation 1040, MIET 76.022; Keithley,

MIET 41.010; Fluka 8600. MIET 20.100; and Transmatien 1040, MIET 76.028.

' During subsequent inspection, the NRC inspectors found that only two of

the five test meters could have been suspect; these were Keithley MIET 41.010

and the Fluke 8600, MIET 20.100 meters. Through discussions with the M&TE

supervisor, it was determined that no records of Condition Identified (CIs)

or Nonconformance E(aluation Reports had been generated. The licensee's

administrative procedures required the M&TE user to report suspect "out of

tolerance" test equipment to the facility meter issue personnel.

When a suspect "out cf tolerance" test equipi.,ent item is identified, a CI

and a Nonconformance rvaluation Report are generated. In this manner a

formal review of other test data taken with the suspect test equipment can

be performed and an evaluation for safety-related concerns made. Since

none of the M&TE equipment listed on the test record had CIs or

Nonconfonnance Evaluation Reports generated during or af ter the usage

period, it appeared M&TE calibration was in-tolerance. Further, although

the as-found data were recorded using the suspect M&TE, the suspect M&TE

was not identified on the test record.

Through discussions with the licensee, it was postulated that the involved

technician recorded the "as-found" data with an out-of-tolerance test

meter and then turned the suspect meter into the facility meter issue

personnel. Upon receiving a good meter from the issue facility, the

technician took and recorded the "6s-left" data and the instrument identity

on the task card. The technician did not record the identity of the test

instrument with which the "as-found" data was measured. The licensee's

Administrative Procedure MD-1-021. Revision 1, "M&TE Accountability,"

required the MATE user to record the M&TE identity on the task card.

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However, Adminsitrative Procedure MD-1-021 Revision 0, the procedure in

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effect during the surveillance, did not specifically require the recording ,

of M&TE identity on the task card. The licensee stated that the general

practice used by the 18C technicians is to record the identity of the M&TE

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upon completion of the procedure. If during the procedure, a suspect

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instrument is identified, the instrument is returned to the issue

i facility, and a good meter checked out. The procedure is then reperformed,

in toto, using the in-tolerance instrument and the M&TE identity is

recorded on the task card. t

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From the above discussion, there appears to be no safety significence in

that the licensee took and recorded the as-left data with an in-tolerance

meter. No adjustments were made to system instrumentation and the

identity of the good M&TE was recorded on the task card.

However, it is significant to note that the licensee's procedures for M&TE

accountability do not relate with the same specificity, in writing, as

fenerally practiced. Revision 1 of the M&TE accountability procedure

specifies that the identity of M&TE be recorded on the task card.

However, the implementation of this procedure is left to the

inttepretation of the M&TE user. M&TE traceability is vital to a

comprahensive M&TE program. If a general work practice is acceptable and

has shown success in its effectuation, then confusion and errors can be

avoided by incorporating the practice into the licensee's procedure. The

NRC inspectors concluded that the licensee should consider a revision to

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the existing procedure to include more delineated guidance,

f Within tha scope of this inspection, no violations or deviations were

identified.

3. Verification of Reactor Coolant System (RCS) Leak Rates (61728)

During this inspection, the NRC inspectors reviewed the licensee's

procedure for RCS inventory leakage calculation. The following records

for RCS inventory accountability were reviewed:

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• OP-903-024, Revision 6, dated March 30, 1988, 0445 hours0.00515 days <br />0.124 hours <br />7.357804e-4 weeks <br />1.693225e-4 months <br />

OP-903-024, Revision 6, dated March 30, 1988, 0710 hours0.00822 days <br />0.197 hours <br />0.00117 weeks <br />2.70155e-4 months <br />

• OP-903-024, Revision 6, dated March 30, 1988, 1640 hours0.019 days <br />0.456 hours <br />0.00271 weeks <br />6.2402e-4 months <br />

• * OP-903-024, Revision 6, dated March 30, 1988, 1758 hours0.0203 days <br />0.488 hours <br />0.00291 weeks <br />6.68919e-4 months <br />

• OP-903-024, Revision 6, dated March 31, 1988, 0005 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />

The NRC inspectors verified that the licensee's calculating technique for

determining RCS leak rates was satisfactory. By utilizing the licensee's

RCS data und inputting this data into the NRC's RCSLK9 program, the NRC

inspectors verified the correctness of the licensee's calculated

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identified and unidentified leak rates. For those leak rate results

outside the limiting conditions for operation, the NRC inspectors reviewed

.l the licensee's response and timeliness in identifying, isolating, and

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I reporting the incident to the NRC. In addition, the NRC inspectors

verified that post-event leak rates were within the acceptable limits of  ;

the Technical Specifications.

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Within the scope of this inspection, no violations or deviations were i

identified.

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4. Exit Interview

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The NRC inspectors met with licenseo representatives denoted in Saction 1

on April 8, 1988, and summarized the scope and findings of the insoection.

The licensee did not identify as proprietary any of the materials trovided

to or reviewed by the inspectors during the inspection.

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ATTACHMENT

PROCEDURES AND RECORDS REVIEWED

Requirement /

, Component Description -Test Procedures

TS 4.1.2.2C Verify correct actuation of auto valves OP-903-029 R4

in boron injection flow path on SIAS

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TS 4.1.3.4C Verify drop times-for full-length CEAs NE-02-020. R0

TS 4.3.2.1, Containment. spray (CSAS) containment MI-3-201, R4

Table 4.3-2, pressure high-high channel calibration OP-903-107, R3

Item 2.b

TS 4.3.2.1, SG level low and delta P high emergency MI-3-305,.R3

Table 4.3-2, feedwater(EFAS)tripchannel MI-3-306, R4

Item 7.b calibration MI-3-201, R4

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TS 4.4.3.1.3a Verify pressurizer heaters are OP-903-028. R2

and b automatically shed from emergency power

sources on SIAS and verify heaters can

be energized from control room

TS 4.4.6 Verify dissolved oxygen, chlorine, and CE-2-006, R5

fluorine are within limits

TS 4.5.1d Verify SI tank isolation valves open OP-903-025, R1

when RCS pressure exceeds 535 psia and OP-903-029, R3 '

upon receipt of SI test signal  ;

TS 4.5.2e1 Verify each auto valve in ECCS subsystem OP-903-029, R3 i

actuates to correct position on SIAS and OP-903-091, R2

RAS

TS 4.6.1.3c Verify only one door in each containment PE-5-024. R2 ' ,

air lock can be opened at a time OP-903-113, R0

TS 4.6.2.2b Verify that each containment cooling fan OP-903-029, R3 -

group starts automatically on SIAS and

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verify cooling water flow g,1325 gpm

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TS 4.7.3b Verify each CCW/ACCW valve servicing OP-903-029, R3

' safety-related equipment actuates to OP-903-036, R4

correct position on SIAS and CSAS test ,

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Requirement /

Component Description Test Procedures

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TS 4.8.2.1d -Verify 125 VDC battery capacity is '

ME-3-230. R5

adequate

TS 4.7.10.1.1f Perform functional test of fire OPa903-056, R5 *

sup3ression water system by verifying OP-903-077 R2

eac1 pump delivers 2000 gpm at 100 psid, '

cycling each valve in flow path not

testable during plant operation, and ,

sequential pump start to maintain system

pressure at 96.5 psig-

TS 4.7.10.1.3c Inspection of diesel fire pumps 12 V ME-3-100, R2

starting batteries

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IST/ Charging Test CVCS charging pump 00-903-003, R6

Pump A -

IST/ Valve Test valve in safety injection system OP-903-032, R5

SI-138A

ISI Mministrative procedure for controlling N0EP-251, RO

ISI

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ISI/ Class 1 RCS Perform RCS leak check prior to startup QI-009-003,R1-

Pressure Boundary

IS7/ Weld 04-012 Perform UT inspection of weld WTR-ISI-47, R0

(RC)

ISI/ Weld 17-039 Perform UT inspection of weld WTR-ISI-206, R0

(SI) .

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ISI/ Weld 42-022 Perform UT inspection of weld WTR-ISI-E06, R0,

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(MS)

Perform UT inspection of weld WTR-ISI-206, RO,

ISI/ Weld 48-001

FCI

(FW)

Perform PT inspection of weld WTR-ISI-11, R0

ISI/ Weld 58-002

(CS)

Perform visual inspection of restraint WTR-IST4, R0

ISI/ Restraint

ACR-462 (AC) ,

ISI/ Spring Hanger Perform visual checks of spring hanger WTR-ISI-8, R0

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FWSH-348(FW)

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