Text

Ack Receipt of 860501 Response to 860320 SALP Board Rept 50-382/85-30,per 860401 Mgt Meeting.Problem W/Airborne Radioactivity in Reactor Auxiliary Bldg Deserves Continued Involvement of Mgt Task Force Until Problem Resolved
	ML20203E180
Person / Time
Site:	Waterford
Issue date:	07/21/1986
From:	Martin R; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Muench G; LOUISIANA POWER & LIGHT CO.
References
	NUDOCS 8607240077
	Download: ML20203E180 (4)
	v • d • e

, ,

o *

In Reply Refer To: U

Docket: 50-382/85-30_

Louisiana Power & Light Company

ATTN: G. W. Muench, Director

Nuclear Operations

317 Baronne Street

i P.O. Box 60340

New Orleans, Louisiana 70160

'

Gentlemen: ,

Thank you for your letter of May 1,1986, in response to our letter and

Systematic Assessment of Licensee Performance (SALP) Board Report of March 20,

1986, which was discussed with you at a management meeting held at your

Waterford Steam Electric Station, Unit 3 (W3 SES), on April 1, 1986. Your

letter with its attachment and a list of meeting attendees are enclosed. This

letter with enclosures is considered an appendix to SALP Board Report

50-382/85-30.

We have reviewed your responses and find that they appear to adequately

address the concerns and recommendations contained in the SALP Board Report.

We encourage you to continue emphasis on your reactor trip reduction program.

The problem with excessive airborne radioactivity in the reactor auxiliary

building deserves the continued active involvement of your management task

force until it is eliminated. Timel

Information Management System (SIMS)y implementation

and completion of efforts of

to your

incorporate Station

mechanical equipment environmental qualification requirements into your

maintenance procedures and practices should be given high priorities to enhance

your maintenance program. Because your responses require implementation of a

variety of improvement programs, we suggest that they be closely monitored and

evaluated for achieving the desired performance improvements. We request that

you keep us infomed of your progress in these areas. We understand that some

of your programs already appear to be showing positive results. Implementation

of your stated actions will be monitored concurrent with our routine inspection

program and considered in our next SALP assessment.

~ -

- .-

L _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _

a

PB/c

R)h:indy;dg

EYt

Rh/

G 4sfistable

C:RPB]

JEGag do

D:DRSP D:D

J EHJohnwf R BanGart

A/[

D arti

7/ p/f6 e/p/86

~

86

1/ } /86

q/ 3 /86 7 /) / -]

,h

D'

8607240077 860721 d\

PDR ADOCK 00000382 %

0 PDR

_ _ _ _ _ _ _

.- F

,

-. \

l

Louisiana Power & Light Company -2- l

l

-

This concludes our SALP assessment process for this. period; however, should you

have further questions, please let us know and we will be pleased to discuss

them with you. 4

Sincerely, - $ , i

'l

f ;

ORIGINAL $?GNED BY . ,

'

ROBERT D. MARTN

Robert D. Martin *

Regional Administrator ' -

.

Enclosures:

1. List of W3 SES SALP Meeting -

Attendees on April 1, 1986

2. LP&L SALP response dated

May 1, 1986

cc:

Louisiana Power & Light Company

ATTN: G. E. Wuller, Onsite

Licensing Coordinator

P.O. Box B

Killona, Louisiana 70066

Louisiana Power & Light Company

ATTN: R. P. Barkhurst, Plant Manager

P.O. Box B

Killona, Louisiana 70066

Middle South Services

ATTN: Mr. R. T. Lally

P.O. Box 61000

New Orleans, Louisiana 70161

Louisiana Power & Light Company

ATTN: K. W. Cook, Nuclear Support

and Licensing Manager

317 Baronne Street

P.O. Box 60340

New Orleans, Louisiana 70160

Louisiana Radiation Control Program Director

'

.. '

Louisiana Power & Light Company -3-

bcc to DM8 (IE40)

bcc distrib. by RIV:

RPB D. Weiss, LFMB (AR-2015)

-Resident Inspector R. D. Martin, RA

Section Chief (RPB/c) DRSP

R&SPB RSB

MIS SYSTEM RRIs

RSTS Operator Records Center, INPO

RIV File J. Taylor, D/IE

Chmn. L. W. Zeck (MS: H-1149)

Comm. T. M. Roberts (MS: H1149)

Comm. J. K. Asselstine (MS: H-1149)

Comm. F. M. Bernthal (MS: H-1149)

E. J. Reis, OELD

D. Crutchfield, NRR

. f

Louisiana Power & Light Company (LP&L)

W3 SES SALP MEETING ATTENDEES

April 1, 1986

NAME ORGANIZATION / TITLE

J. G. Luehman NRC, Senior Resident Inspector

J. H. Wilson NRC, Project Manager, NRR

J. E. Gagliardo NRC/RIV, Chief, Reactor Projects Branch

D. Crutchfield NRC/NRR/PWR-B

P. S. Check Deputy Administrator, NRC/RIV

E. H. Johnson NRC/RIV, Director, Division of Reactor Safety and

Projects

G. L. Constable Chief, Reactor Project Section C, NRC

P. F. McKee Chief, ORPB, NRC/IE

T. F. Gerrets LP&L, Corporate QA Manager

R. F. Burski LP&L, Engineering Nuclear Safety Manager

K. W. Cook LP&L, Nuclear Support & Licensing Manager

R. P. Barkhurst LP&L, Plant Manager

J. M. Cain LP&L, President

G. W. Muench LP&L, Acting Diractor of Nuclea, Operations

J. E. Fort LP&L, Public Informati:n Manager

T. P. Brennan LP&L, Projects Control Manager

E. J. Senac LP&L, Special Projects Manager

P. N. Backes LP&L, Operations QA Manager

W. M. Morgan LP&L, Supplier QA Manager

N. S. Carns LP&L, Assistant Plant Manager, Operations and

Maintenance

T. R. Leonard LP&L, Plant P&S Superintendent

T. H. Smith LP&L, Maintenance Superintendent

T. Sleger, Jr. LP&L, Executive Assistant, Nuclear Operations

A. D. Jones LP&L, System Development / Analysis QA Manager

S. A. Alleman LP&L, Assistant Plant Manager, Plant Teciinical

Services

R. W. Kenning LP&L, Radiation Protection Superintendent

P. V. Prasankumar LP&L, Technical Support Superintendent

L. W. Myers LP&L, Operations Superintendent

M. C. Moody LP&L, Departmental Assistant

A. S. Lockhart LP&L, Site Quality Manager

R. G. Azzarello LP&L, Emergency Planning Manager

W. H. Spell Louisiana Nuclear Energy Division

R. M. Nelson LP&L, Licensing Manager

D. F. Packer LP&L, Training Manager

R. W. Lailheugue LP&L, Security Superintendent

F. J. Englebracht LP&L, Manager, Plant Administrative Services

- -

.

, ao m a mo mu a e-

s a fiX\/ F f A

l

'

MAY - Z 1986

-

3 3 s

LOUISI& L1GHT

POWER AN A / 317 BARONNESTREET * P. O. BOX 60340

NEW ORLEANS, LOUISIANA 70160 * (504)595-3100

NuiNIvsYIU

May 1, 1986 W3P86-0066

A4.05

QA

Mr. Robert D. Martin

Regional Administrator, Region IV

U.S. Nuclear Regulatory Commission

611 Ryan Plaza Drive, Suite 1000

Arlington, TX 76011

Subject: Waterford 3 SES

Docket No. 50-382

License No. NPF-38

NRC Report 85-30 - SALP BOARD REPORT

Reference: NRC letter dated 3/20/86 (Docket: 50-382/85-30), R.D. Martin

-

to R.S. Leddick (LP&L).

Dear Mr. Martin:

Attached is the Louisiana Power & Light Company response to the Systematic

Assessment of Licensee Performance (SALP) Board Report for Waterford 3

which was transmitted by the referenced letter.

If you have any questions on our response, please contact K.W. Cook,

Nuclear Support & Licensing Manager at (504) 595-2805, or myself.

Very truly yours,

G.W. Muench

Director of Nuclear Operations

GWM:GEW:ssf

~

cc: NRC, Director, Office of I&E ,g

G.W. Knighton, NRC-NRR

J.H. Wilson, NRC-NRR ,

igy [,j

y (L2

NRC Resident Inspectors Office

B.W. Churchill

'

idl)O

W.M. Stevenson

l ' k L

l

"AN EQUAL OPPORTUNITY EMPLOYER"

. - - - _ - -

'

.

5/1/86 ATTACHMENT TO W3P86-0066 l

Shsst I cf 32

.

LP&L RESPONSE TO SALP BOARD REPORT

Performance Functional Area -

A. PREOPERATIONAL/STARTUP TESTING

NRC Recommended Licensee Actions:

Licensee management is encouraged to apply the same attention to

detail during future facility operation including post-outage testing.

Response:

The Waterford 3 staff will continue to apply a high level of attention

to detail during future facility operation including post-outage

testing.

.

.- ..

,

' ' 5/1/86 ATTACHMENT TO W3P86-0066

Shast 2 of 32

.

Performance Functional Area -

B. PLANT OPERATIONS

NRC Recommended Licensee Actions:

An aggressive reactor trip reduction program, including human factors

evaluations and root causes determination, should be instituted to

reduce the reactor trip frequency toward the industry average. This

program should include an in-depth review of the events by experienced

operators from outside the plant operations department.

Licensee management must revise the overall trend related to staffing

which should help reduce the number of reportable events.

Additionally, support of the completion of the program to upgrade the

control room annunciator system should continue. Licensee management

should initiate a preplanned program to eliminate the RAB airborne

radioactivity problem. Also, licensee management should use the

formulation and review of the Technical Specification (TS) for the

broad range toxic gas detection system required by License Condition

2.C.4 as an opportunity to review the progress being made toward

reliable monitoring systems associated with the control room

,

ventilation system.

RESPONSES TO SPECIFIC RECOMMENDATIONS

B-1 Recommendation

"An agressive trip reduction program, including human factors

evaluations and root causes determination, should be instituted to

reduce the reactor trip frequency toward the industry average. This

program should include an in-depth review of the events by experienced

operators from outside the plant operations department."

B-1 Responset

The SALP report addresses 22 reactor trips from power in 1985. Some

of these trips resulted from random failures, human error and other

occurrences that would not be unexpected during the startup phase of a

nuclear power plant. The majority of the period encompassed the power

ascension phase of the first cycle of operation. Commercial operation

commenced on September 24, 1985, by which time the frequency of

feedwater-related trips (9 of the 22 trips) had been significantly

reduced. In 1986, no feedwater-related trips have been experienced to

date.

'

Plant management has given much attention to reduce reactor trips. In

this regard, the following measures have been taken or are now in

progress:

1. The Waterford 3 operations Superintendent is a member of the

Combustion Engineering Owner's Group Subcommittee on Reactor Trip

Reduction. Recommendations resulting from root cause analyses

and other subcommittee efforts are evaluated by management for

implementation at Waterford 3. Some of these recommendations

includer

. . . .'

,

'

5/1/86 ATTACHMENT TO W3P86-0066

Shost 3 cf 32

.

B. PLANT OPERATIONS - B-1 Response (continued)

a. Enhancements for the Steam Generator Feed Pump vibration

instrument / trip and suction pressure trip.

b. Enhancement for Control Drive Mechanism System (Automatic

CEDM Timing Module Installation).

c. Revising Core Protection Calculator penalty factors

associated with Control Element Assembly drops and with

raising the Axial Shape Index trip to 20% Reactor Power.

d. Review the root cause determination processes employed at

other Combustion Engineering plants.

Items a and b above have already been implemented. Item e is

planned for future implementation. Item d is now in the first

stages of implementation.

2. A Maintenance Department Directive was issued in February,1985,

to provide guidance in minimizing inadvertent Engineered Safety

Feature Actuation System actuations and plant trips. This

"

directive addressed maintenance practices designed to prevent

inadvertent trips. Since issuance of that directive, no trips

have occurred that can be directly attributed to maintenance

practices.

3. In response to the reactor trips that were associated with the

Feed & Condensate System, the following corrective actions

resulted from the post trip reviews and analyses:

a. OP-10-001, General Plant Operations, was revised to enhance

procedural trip prevention measures (e.g., to address manual

control of Steam Generator water level at low power levels).

This has helped reduce trips caused by operator error

associated with the difficulty of manual control at low

power levels.

b. The following Steam Generator Feedwater Pump modifications

were implemented:

(1) Gage boards were installed to enhance monitoring and

tuning of the turbine governors.

(2) The turbine governors were overhauled.

(3) The high vibration trip was removed (alarm retained).

(4) An orifice was installed in the Condensate Pump

recirculation piping.

($) A time delay was added to the low pump suction pressure

trip.

'

. 5/1/86 ATTACHMENT TO W3P86-0066

Sh ct 4 of 32

.

f B. PLANT OPERATIONS - B-1 Response (continued)

l c. The Condensate Polisher and/or its operation were modified

as follows:

(1) The operating procedure was revised to reduce the

i

potential for system transients and operator error.

!

(2) Major polisher operations are now supervised by an

Operations Supervisor.

d. Steam Bypass Control Valves are stroked on a frequent basis

to verify operability.

In addition to the above post-trip corrective actions, the

following trip prevention measures were taken to reduce the

potential for postulated trips related to operation of the

Condensate and Feedwater Systems:

a. December, 1984 to Summer, 1985 Outage

(1) In recognition of the potential for a trip on high

, condenser level, the turbine drain tank level was

raised.

(2) Installed a 4-20 mamp to 10-50 mamp converter to

improve the compatibility of the Feedwater Control

System output signal to the input required by the

Feedwater Pump Turbine control system.

(3) Realigned feedwater pumps to drive turbines and

installed alignment keys on the pumps to avoid

misalignment which could cause coupling or bearing

!

distress. Doweled the base of the pumps to reduce pump

movement.

(4) Installed dedicated centrifuge to maintain the

feedwater pump turbine oil dry and clean.

i

(5) Improved Operations management and monitoring of

Condensate Polisher operations, including

administrative controls on policher vessel isolation.

Actions have been initiated to provide control room

!

indication of key Condensate Polisher parameters.

1

(6) Analyzed system operation for the hotwells and water

boxes resulting in improved system alignments (e.g.

with respect to isolated portiens of the condenser and

the associated potential for feedwater pump trip) and

improved management controls to minimize system

manipulations.

- . __ . - _ . _ - - - , - - _ _ - .-_--- -.__-__-_-_____ __-__,_ - _,._- -

__

' *

,

, 5/1/06 ATTACHMENT TO W3P86-0066

.

Shast 5 cf 32

B. PLANT OPERATIONS - B-1 Response (continued)

.

(7) As a continuing action, programs are in place to trend

feed pump vibration signature analysis data, and to

implement corrective actions for adverse trends.

b. Summer,1985 Outage

(1) Installed a governor / control gage board to provide for

operational monitoring, trouble shooting and analysis

for the system.

(2) A Westinghouse expert was retained to disassemble and

tune the governor and install new hoses.

(3) Drained, cleaned, and refilled the oil system; and oil

and steam leaks were corrected.

(4) Implemented a modification to the oil system to rectify

a pump seal vacuum problem.

(5) Disassembled, inspected, and. repaired, as needed, the

low and high pressure turbine stop valves and one

governor valve.

.

c. September, 1985 to the Present

A detailed operational review of the Feedwater Heater Drain

System was conducted to evaluate system performance and

take appropriate corrective action. Station designs have

been implemented to address items such ast

(1) Heater Drain Pump Discharge Valve trim changeout

(2) Trim changeout for No. 4 to No. 5 Heater Normal Drain

Valves

(3) Level Switch changes for No. 1 and No. 2 Heaters

(4) Addition of an orifice to the vent lines for the No. 6

Heater

(5) The Reactor Power Cutback System was successfully

tested prior to the March 1986 outage. Automatic

operation of this system should prevent trips

associated with the loss of one Steam Generator

Feedwater Pump at high power levels.

The following is a numerical summary of the Feed and Condensate

work packages issued and completed in 1985 and 1986:

System 1985 1986 Total

Feedwater 177 45 222

Condensate 138 50 188

l

,

. - , , . . - . . . _ . _ . _ _ _ , . - , - - . - _ , . . , . , . . _ . . - . , . - . . - . . . , - . _ - - . , - . - . , - , - . -

, . - . - - . . - - -

. --.

_

'

, 5/1/86 ATTACHMENT TO W3P86-0066

Shast 6 ef 32

B. PLANT OPERATIONS - B-1 Response (continued)

These figures are indicative of the level of effort applied to

eliminate problems and to enhance the subject system's

reliability.

O

Future plans to enhance secondary system operation and to prevent

postulated trips include:

a. Investigating poasibility of bypassing high Steam Generator

level trip at low power levels.

b. Installing Steam Generator Feed Pump electronic governors.

c. Installing Condensate Polisher controls and instrumentation

in the Control Room.

4 In 1986, two trips have occurred to date, both resulting from

dropped Control Element Assemblies (CEA). The following

corrective actions have been implemented or will be implemented

in the near future to reduce the potential for future CEA and

software related trips.

'

a. Installed 91 ACTM cards, a Combustion Engineering

enhancement that reduces the potential for trips resulting

from Control Element Drive Mechanism and power supply

problems,

b. Conduct periodic Control Element Drive Mechanism tests at

low power levels to eliminate large CEA sub-group deviation

penalty factors and therefore reduce trip potential.

c. Implementation of better controls for Axial Shape Index.

d. Core Operating Limit Supervisory System Technical

Specification changes to:

(1) Eliminate restrictive Axial Shape Index controls.

(2) Minimize excessive Control Element Assembly movements

at power.

(3) Minimize unnecessary operator distractions in the

Control Room.

Future plans to enhance system operation include a software

revision to allow Control Element Assembly drops without inducing

reactor trips.

5. Additional plant improvements to reduce trip potential are

planned. Examples include:

a. Core Protection Calculator improvements

k

* 5/1/86 ATTACHMENT TO W3P86-0066

-

Shoot 7 cf 32

.

B. PLANT OPERATIONS - B-1 Response (continued)

(1) Elimination of low power trips that result from high

ASI values below 20% power.

(2) Elimination or delays of trips resulting from dropped

Control Element Assemblies.

b. Main Steam Isolation Valve Design changes to improve

reliability.

6. Additional managerial controls and procedural changes will be

considered for implementation to reduce trip potential. An

Operations Advisory Group, which consists of members of the

Operations Department, has been formed. This group functions to

advise plant management on the need for enhancements and changes.

A typical task being addressed by this group is the review of

plant surveillances and procedures to identify those steps that

are worthy of a two-man-rule (two personnel simultaneously

performing and witnessing specified tasks). Such identified

higher risk surveillances will be performed in a reader-for-

worker mode similar to that used in Japanese plants.

-

7. The plant uses a Potential Reportable Event system which, in

part, provides a mechanism for performing a review and root cause

analysis of plant trips and transients. Licensee Event Reports

(LER's) are one of the products of this system. LER's will be

enhanced to include more detail and a specific root cause

analysis. LER generation efforts will also be expanded to

incorporate more operationally-oriented inputs from members of

the Waterford 3 organization outside of the plant Operations,

Maintenance, and Technical Support Groups (e.g., Site Quality,

Quality Assurance and ISEG/ Operations Assessment).

8. The Plant Manager maintains a Reliability and Health Physics

Improvement List (established June 17, 1985) which is generated

by members of the plant organization and is reviewed for

disposition on a monthly basis. This list gives visibility to

important plant problems and proposed enhancements that affect

plant reliability. Those problems and enhancements related to

trip prevention consequently receive appropriate management

attention.

9. Waterford 3 has established a 1986 goal of a maximum of seven

automatic reactor trips. This goal requires a marked reduction

in trip frequency over 1985 performance.

10. Waterford 3 has taken positive measures as described below to

maintain steady staffing levels in the Operations Department.

This should help build and retain a plant-specific experience

base which will assist in reducing personnel errors and,

therefore, complement other trip reduction endeavors.

J. , h~ \

>

. , w

'

a

5/1/86 ; j , ATTACHNENT TO W3P86-0066

,- "-

F- / _ Sh::t 8 cf 32

'

p / ,,

'

. J

, .

B-2 Recommesdation:

" Licensee management must reverse the everall trend related to

staffing which should help reduce the number of reportable evints."

,

.c/ ('

B-2 Response: >

. Cr+ l

r .s , J. ,

Waterford 3 management has taken positive steps,to 16 prove Operations

personnel retentica and maintain a full compleuknt of/ operators:

a.

1. Five temporary additional operator positions have been created.

These positions have been filled with. individuals who will

,

undergo training and be used to supplement the existing staff.

This will provide a reserve of Operations parsonnel to help

nullify the effects of attr,itien. '.; i

' -

/

2. An incentive pay program for plant operators has been/ Initiated.

1

3. An operator license bonus program has'been established.

1

4 4 Operator pay scales are reviewed freiuently to ensure that they

4

compare favorably with the industry average.

. .

j '

! 5. An Operations Advisory Group has been established to provide a

>

vehicle for the operators to make recommendations to plant

,

management. This encourages operators to voice their epinions and

4 make recommendations on concerns that need management attention

'

and/or operator input. ' - i

~

, s

'

! It should be noted that the last operator resignation occurred ' no

December 20, 1985, which is indicative,that the above efforts are

having a positive affect on retention.' f'

i

I

i

!

'

.

I

~

'A p

( .* t

'

} <

-

,

I

h

1

- -,. - .,-, - = - - - _ - - - . - - .-.,.--L.-,,,.- .

.* .'

5/1/86 ATTACHMENT TO W3P86-0066

Sheet 9 of 32

.

B-3 Recommendation:

" Additionally, support of the completion of the program to upgrade

Control Room annunciator system should continue."

B-3 Response:

An effort to upgrade the Control Room Annunciator System has been in

effect since early 1985. Direct upper management attention has been

applied to reduce the total number of invalid annunciations and to

clear those that are valid. From April, 1985 to March, 1986 a maximum

of 186 annunciators had been identified as problems. By the end of

the March 1986 Outage, 138 of the 186 had been cleared. Management

attention in this endeavor continues.

.

i

., ..

5/1/86 ATTACHMENT TO W3P86-0066

Shsst 10 of 32

,

B-4 Recommendation:

" Licensee management should initiate a preplanned program to eliminate

the RAB airborne radioactivity problem."

B-4 Response:

Waterford 3 Plant management has and will continue to place emphasis

on resolving the RAB airborne radioactivity problem. The following

items typify the efforts and results that have been accomplished to

date:

1. A management task force has been established to identify and

initiate actions to eliminate sources of airborne activity within

the plant as well as reduce releases to the environment. The

task force consists of representatives from the Operations,

Health Physics and Engineering Departments. In particular,

attention has been given to improving our capability to properly

remove fission gases from plant systems and, when appropriate,

hold them for decay. Valves within the Gaseous Waste Management

System have been reworked on several occasions and future

,

modifications to the system are planned. The Flash Tank has been

placed into service to reduce noble gases within the Boron

Management System components. Recent changes to our NPDES permit

have permitted us to reduce use of the Boric Acid Concentrators,

which has been contributing to the gas problem.

2. Health Physics and Operations personnel have worked together to

localize airborne radioactivity areas. This facilitates invoking

access controls to minimize personnel exposure and also focuses

source identification efforts to specific plant locations. Five

specific plant areas have been identified:

1. A pipe chase under the Charging Pumps in the Reactor

Auxiliary Building

2. The Charging Pump Rooms

3. The Boric Acid Makeup Tank Rooms (primarily room A)

4. The Volume Control Tank Room and a peripheral passageway

5. The Flash Tank Room

We have observed that the number of personnel temporarily

contaminated by short-lived gaseous decay products has dropped

significantly in recent months.

3. The Operations and Health Physics Departments are working

together in an attempt to correlate increases in airborne

activity levels with specific plant evolutions. Regular

operations shift caetings which include on-shift Health Physics

personnel are making individuals more aware of plant evolutions.

_ ._ __ . .

- _ - - _. . __

'

'5 5/1/86 ATTACHMENT TO W3P86-0066

Shaat 11 of 32

B. PLANT OPERATIONS - B-4 Response (continued)

4 The Operations Superintendent has placed increased emphasis on

operator professionalism and attention to detail when conducting

plant operations. Shift Supervisors and Control Room Supervisors

have been instructed to monitor operator activities more closely

and provide more on the spot guidance as to attention to detail.

Additionally, Operations has addressed specific systems which

require supervisory review and approval prior to manipulation of

the system. This guidance has resulted in the elimination of

airborne radioactivity sources evolving from poor operations

practices or deficient procedures.

5. The Plant Manager maintains a Reliability and Health Physics

Improvement List (established June 17, 1985) which is generated

by members of the plant organization and is reviewed for

disposition on a monthly basis. This list is used in part to give

visibility to important plant problems and proposed enhancements

relevant to health physics concerns. Such matters consequently

receive appropriate management attention.

,

It is worthy to note that the problem as described above is

! - essentially one of high concentrations of short-lived airborne

radioactivity and not a case of excessive personnel contamination and

exposure from long-lived radioactivity. The remedial actions as

, delineated in items 1 through 5 above have resulted in some success.

Increased emphasis has been placed on resolving the problems and on

expedient completion of associated corrective action.

. _ _ ,_ _- __.-___ _..__ _ . _ . - _ - _ - . -

__

. . - _

.,,

'

.

.'

5/1/86 ATTACHMENT TO W3P86-0066

Sheet 12 of 32

B-5 Recommendation:

"Also, licensee management should use the formulation and review of

the Technical Specification (TS) for the Broad Range Toxic Gas

Detection System required by License Condition 2.C.4 as an opportunity

to review the progress being made toward reliable monitoring systems

associated with the Control Room Ventilation System."

B-5 Response:

The Waterford 3 Plant Staff has vigorously pursued a multitude of

options in an attempt to tune and maintain the current monitoring

systems associated with Control Room ventilation. Attention is being

applied to enhance the operability and reliability of the existing

design in parallel with an investigation to identify a more reliable

design. The Waterford 3 Project Engineering Organization is now

heading up a review of Technical Specifications and design

configuration as well as maintenance and calibration practices in an

effort to resolve this problem.

.

1

I

__ _ _ _ _ _ _ - . _ , . ._ _ . . _ _

. . i

.

5/1/86 ATTACHMENT TO W3P86-0066

Shset 13 of 32

Performance Functional Area -

C. SURVEILLANCE

NRC Recommended Licensee Actions:

Licensee management should continue improvements in this area,

especially in the area of communications between different

disciplines. The licensee should develop an integrated and more

descriptive action statement tracking system. The combining of the

equipment out of service log and the tracking of action statements

would make the task of tracking TS related problems easier for the

control room operator.

Response:

The equipment out of sertice system was established early in 1985 to

specifically identify the time and date that equipment was removed

from service, declared inoperable and subsequently returned to

service. It is used in conjunction with the operator shift-turnover

process to track the status of TS-related equipment and associated

, action statements. The governing procedure for equipment out of

service will be revised. The SALP recommendation will be factored

into that revision, as applicable, to ensure that an effective action

statement tracking system is employed. Also, the pending procedure

revision along with existing interface requirements specified in

corrective maintenance and surveillance control procedures will

improve overall inter-discipline communications.

With respect to non-routine surveillances such as those required for

changing plant modes, Waterford 3 uses a surveillance tracking system

combined with general operating procedures to ensure that such

surveillances are performed. This approach is also integrated with

planning and scheduling techniques to identify non-routine

surveillances in the schedules used to perform normal plant startups

and shutdowns. The tracking system normally used is the Maintenance

Planning and Scheduling System (MPSS) which is a computer-based system

utilized by most plant departments. However, in some cases a mode

change checklist is used in addition to the mechanisms addressed

above. This technique is currently used by the Operations Department.

A similar approach will be developed by the Chemistry Department in

response to recent problems encountered in that regard. They, like

Operations, are susceptible to such problems because of the nature of

the surveillances.

1

,

. - . - - - -. -.

.. .

5/1/86 ATTACHMENT TO W3P86-0066

Sheet 14 of 32

Performance Functional Area -

D. MAINTENANCE

NRC Recommended Licensee Actions:

The licensee should continue their increased management attention to

resolve the weaknesses identified in this area. Those areas which

should be of particular concern are:

(1) Improving the interface with outside organizations to ensure

spare parts are properly procured, vendor information is properly

incorporated in the procedures and information from the architect

engineer (AE) is used when making changes to or replacing plant

equipment.

(2) Upgrading the M&TE program to provide for timely calibration of

potentially radioactively contaminated equipment.

(3) Ensuring effective programmatic guidance is in place for

maintenance of equipment environmental qualification.

- OVERALL REPLY

Recommendation:

"The licensee should continue their increased management attention to

resolve weaknesses identified in this area."

Response:

To summarize and supplement previously submitted responses to the

violations and LER's addressed in the SALP report, the following are

typical Waterford 3 enhancements designed to improve the quality and

documentation of plant maintenance activities:

1. A Station Information Management System (SIMS) is being developed

for implementation in 1987. It is a computer-enhanced system

used for the identification, planning and tracking of maintenance

work items. It integrates equipment data bases, quality

requirements, maintenance history, repetitive task / corrective

maintenance tracking, NPRDS reporting, etc. into one

comprehensive systcm.

2. The number of permanent maintenance engineer positions has been

increased to a level of six and a Lead Planner position has been

established. At present three of the maintenance engineer

positions and the Lead Planner position are filled. This

improvement in staffing has improved the quality of maintenance

work and associated documentation.

3. UNT-5-002, Condition Identification and Work Authorization, has

been revised to enhance maintenance work controls and to make the

procedure more user-friendly.

.. .n

-

5/1/86 ATTACHMENT TO W3P86-0066

Shset 15 of 32

D. MAINTENANCE - Overall Reply (continued)

4. A Maintenance Trending procedure has been implemented. This

procedure provides a methodology for trending component /

equipment reliability so that corrective actions can be applied

to rectify and eliminate repetitive maintenance problems and

component failures.

5. A Maintenance Department Directive was issued in February, 1985,

to provide guidance in minimizing inadvertent Safety Feature

Actuation System actuations and plant trips. Since issuance of

that directive no plant trips and only one Engineered Safety

Feature Actuation have occurred that can be directly attributed

to errors by maintenance personnel.

6. Improved plant procedures on preventive maintenance, corrective

maintenance, temporary alterations and processing of replacement

parts and materials have been issued and implemented.

7. Increased emphasis on root cause analysis, as described in the

response to the performance functional area B, Plant Operations,

- will allow management to better focus on and resolve

maintenance-related problems.

8. Plant management has striven to improve maintenance work planning

techniques over the past two years. Many enhancements have been

implemented. Work in this area is continuing in parallel with

the SIMS project discussed in item 1 above.

9. Maintenance procedures and interface procedures under the

cognizance of other Waterford 3 departments have been

extensively utilized and revised as necessary, since issuance of

the operating license. Improved interfaces have resulted.

Particularly noteworthy are the enhancements made in the

following maintenance interfaces:

a. Technical Manuals and other vendor documents

l

b. Parts and materials, including consumables

'

c. Design conformance

d. Trending

e. Environmental Qualifications

l

f. Engineering and Quality Control

g. Training

i

l

i

--

r

. . . s

5/1/86 ATTACHMENT TO W3P86-0066

Sheet 16 of 32

D. MAINTENANCE (continued)

RESPONSES TO SPECIFIC RECOMMENDATIONS

D-1 Recommendation:

"Those areas ... of particular concern are: (1) Improving the

interface with outside organizations to ensure spare parts are

properly procured, vendor information is properly incorporated in

procedures and information from the architect engineer (AE) is used

when making changes to or replacing plant equipment."

D-1 Response:

Waterford 3 has implemented procedures to review, validate and control

vendor technical information and to incorporate that information into

plant procedures and tracking systems, where applicable. Special

emphasis has been placed on reviewing vendor technical manuals for

safety-related equipment and for incorporating preventive maintenance

and equipment qualification requirements into maintenance procedures,

task cards and other implementing documents. Exceptions have been

'

technically evaluated, justified and documented.

(1) During the period of November through December 1985, the Material

Requirements and Control Department was issued controlled copies

of the Architect Engineers Design Specifications, to be used for

the procurement of spare / replacement parts.

Material Requirements and Controls was also issued controlled

copies of the Q-List, EEQ-List, and MEQ-List to be used for

determination of Quality Classification and Requirements for

procurement of spare / replacement parts.

Procedure UNT-8-001, Revision 12, Processing of Procurement

Documents, requires Engineering input in those cases where the

previous technical / quality requirements of the original item

cannot be determined. Additionally an Engineering evaluation is

required for procurement of commercial grade items for use in a

Safety-Related application and changes or exceptions to the

technical requirements of the procurement documents. Copies of

the changes / exceptions and Engineering evaluations are forwarded

to the applicable Maintenance discipline.

Interface with vendors is common in the procurement process

especially when there is a question as to the equivalency of

parts quoted with part number changes and the proper method of

specifying materials and requirements. When part number changes

are found to not affect the item; drawings and other plant

documents are updated via the Station Modification process.

'5/1/86 ATTACHMENT TO W3P86-0066

Shaat 17 of 32

D. MAINTENANCE - D-1 Response (continued)

(2) Forms of interface which occur with outside organization to

ensure that spare parts are properly procured include:

a. A copy of each Discrepancy Notice (DN) is transmitted to the

responsible vendor's Quality Assurance Manager with a cover

letter identifying the problem and requesting that they

review the DN and take appropriate action to ensure the

discrepancy does not occur on future shipments,

b. LP&L expediters make periodic visits to facilities of major

vendors to identify and, if possible, resolve any problems

at that time.

c. Acknowledgement copies of quality related purchase orders

and revisions are sent to vendors. Receipt of acknowledged

copy is tracked and expedited if not received in 30 days.

d. The Vendor Technical Information Program (VTIP) procedures

have been revised to better coordinate and enhance the

review of vendor information. This should help ensure that

the latest information on vendor spare parts is included as

-

applicable in the appropriate documents.

e. In the design change procedure, specifications are treated

as design documents, and as such are updated in the

as-building process when the change affects the

specification. This should ensure that specifications are

maintained as-built.

f. Safety related specification revisions are being reviewed

for changes made from revision to revision for EQ and

seismic information. Approximately 30% of the safety

related specifications are under review for other technical

changes incorporated since the issuance of the purchase

order. The results of this review will indicate the need to

review the rest of the specifications.

l

!

l

- - - _

-_ _ _ -

-

__ - _ _ . - . - - _ _ - -

.

~

'

5/1/86 ATTACEMENT TO W3P86-0066

Shset 18 of 32

.

D. MAINTENANCE

D-2 Recommendation:

"Those areas ... of particular concern are: (2) Upgrading the M&TE

program to provide for timely calibration of potentially radioactively

contaminated equipment."

D-2 Response:

Measures have been taken to accommodate timely calibration of

potentially radioactively contaminated equipment. Such equipment is

handled in one of the following ways:

1. It is calibrated in the permanent Radiation Controlled Area (RCA)

by transporting calibration equipment into the RCA.

2. It is decontaminated and removed from the RCA for calibration.

If it cannot be decontaminated, then special radiation controls

are established to allow calibration outside the RCA. This is

.

accomplished by either,

a. Transferring the equipment to a calibration facility that is

equipped to handle contaminated equipment, or

b. If calibrated on site, temporary controls (and possibly a

RCA) are established.

1

'

3. It is deleted from the M&TE Program and either disposed of or

place ~d in long term storage.

Also, to the extent feasible, a set of standards for use in

calibrations within the RCA will be procured. Test equipment will be

modified, when possible, to prevent internal contamination.

!

I

l

.. -

- -. . _ _ . _ - _ , - _

- - . . - - _ _ - - - , .. - - - - - - _ - - - _ - .

- - - _ . - - - - . .-

'

. .

5/1/86 ATTACHMENT TO W3P86-0066

Sheet 19 of 32

.

D. MAINTENANCE

D-3 Recommendation:

"Those areas ... of particular concern are: ... (3) Ensuring effective

programmatic guidance is in place for maintenance of equipment

environmental quclification."

-

D-3 Response:

Waterford 3 has incorporated effective guidance in administrative

procedures which delineates engineering and maintenance

responsibilities for maintenance of equipment qualifications.

Specific electrical qualification maintenance requirements have been

extracted from qualification documents and Vendor Technical Manuals

and incorporated into maintenance procedures and practices. This

project, which was initiated in early 1985, is essentially complete.

1 Extraction and incorporation of mechanical qualification requirements

is currently in progress with an estimated completion date of

September 1, 1986. In the interim, qualifications are maintained by

direct transposition from qualification documents into specific work

' packages, where applicable. This is accomplished via work planning

techniques which utilize the Waterford 3 EQ List to identify those

components that are qualified.

.

_ _ ~ . _ _ . _ . - _ _ . _ . . _ _ . . _ _ - - . - , , _ . -

_ ~ _ _ . . _ - - _ _ . - _ _ . - , _ . _ . . _ _ _ _ . . _ - _ _ _ _ . - .

.

5/1/86 ATTACHMENT TO W3P86-0066 i

Shast 20 of 32

l

Performance Functional Area -

E. QUALITY PROGRAMS AND ADMINISTRATIVE CONTROLS AFFECTING QUALITY

NRC Recommended Licensee Actions:

The licensee management needs to work toward:

(1) A timely resolution of the NRC concerns regarding procurement

control.

(2) Involving the QA organization and other independent

organizational elements, such as the Independent Safety

Evaluation Group (ISEG), in problem areas. Representative

attendance at NRC exit interviews would enhance their

involvement.

(3) Devote the necessary resources to eliminate the SMP backlog.

(4) Bring in the necessary resources from LP&L :nd Middle South

Utilities to help resolve the plant computer problems.

. Response:

(1) Procurement Control - LP&L has and continues to apply management

attention and qualifiedgmanpower resources to assure receipt of

acceptable material, parts, and components for use at Waterford

3. As a result of these efforts, LP&L has significantly

strengthed its procurement process through the issuance of

NOP-006, " Nuclear Operations Procurement" (Jan. 1986);

Specification 600, " Standard Quality Requirements (Feb. 1986);

and UNT-8-001, Rev. 12, " Processing of Procurement Documents"

(Feb. 1986).

(2) QA Involvement - QA issued 23 reports in addition to the required

audits during the evaluation period. In summary, they are - 5

monitoring activities, 3 evaluations, 6 unscheduled audits, and

9 activity audits. These activities were performed to review and

assess subjects of special interest to management including

problem areas and areas of concern. Operations QA has an ongoing

activity audit process for observing performance of various

activities. Ten activity audits have been performed between

January 1, and March 31, 1986.

In addition, the QA organization has been (is) actively involved

in support of ongoing activities such as:

-

Validating responses to NRC Inspections upon Licensing

request

-

Participating as drill team members in emergency

preparedness activities

-

Providing assistance to Site Quality for CIWA reviews

-

Undergoing training as Shift Advisors - Two QA individuals

completed the training

-

Support of Plant Operations for procedure and administrative

work

_ _ _ _ _ _ _ _

~

.

5/1/86 ATTACHMENT TO W3P86-0066

Shsst 21 of 32

E. QUALITY PROGRAMS AND ADMINISTRATIVE CONTROLS AFFECTING QUALITY

Response (continued)

-

Evaluating training activities in support of INPO

accreditation.

Additionally, Quality Assurance attends the Plan-of-Ehe-Day

meetings on a regular basis. QA attended 19 of 30 NRC exit

meetings during the period of the SALP Report. The organization

does not generally attend exits involving topics of a sensitive

nature such as NRC investigations into allegations or security

investigations.

ISEG Involvement - ISEG has been involved in problem areas and

issued eight reports during the evaluation period. In summary,

they are: 5 reports of Phase III Testing problems and 3 reports

of special interest areas. Four additional reports have been

issued since January 1, 1986.

ISEC can become involved in any area identified as a problem or

concern through its own determination or at the request of

. management (e.g., Safety Review Committee, Senior Vice President,

Engineering and Nuclear Safety Manager, Plant Manager). ISEG has

prepared reports on subjects requested for review by management

'in the past and will continue to do so.

ISEC has not historically attended NRC exit meetings. With

verbal notification by the NRC Resident Inspector, ISEG will send

a representative to those exit meetings where problem areas will

be identified by the NRC. This will enhance ISEC's ability to

investigate and provide recommendations to plant management.

(3) Station Modifications - LP&L has put forth a concerted effort to

improve the closeout of station modification packages. As of

April 11, 1986, 45% (678 of 1511) of all station modifications

had been closed.

Also, changes to three procedures are being implemented that

streamline the review process by decentralizing closure

activities. The action engineer is now responsible for closeout

processing which includes review /signoff of each implementing

CIWA prior to Shift Supervisor / Control Room Supervisor removing

the clearance. This change enhances the program by preventing

premature operation of plant equipment affected by the

modification. Another enhancement related to the procedure

changes was the provision for partial closure of station l

modifications with multiple CIWAs.

.

(4) Plant Monitoring Computer - Since the end of the appraisal period

several tasks have been completed which will improve the

reliability of the Plant Monitoring Computer (PMC). Among them

are the following: correcting three separate errors in CPU #1

and #2 which were causing system failures, correcting an error in

the way the system actuates annunciation and decreasing the time

_

5/1/86 ATTACHMENT TO W3P86-0066

Shrat 22 of 32

E. QUALITY PROGRAMS AND ADMINISTRATIVE CONTROLS AFFECTING QUALITY

Response (continued)

it takes to restart a failed system by 50%. Numerous other tasks

are also underway to improve overall system reliability.

The plant Computer Engineering section has been augmented by a

Middle South employee on a full time basis and by LP&L

Engineering Services Staff on numerous special problems. LP&L

continues to retain several contract personnel assigned to the

plant Computer Engineering section and their function is to

enhance the performance of the plant computer system.

.

. . . 4 ,

-

5/1/86 ATTACHMENT TO W3P86-0066

Shaat 23 of 02

Performance Functional Area -

F. FIRE PROTECTION

NRC Recommended Licensee Actions:

Licensee management should be directed toward:

(1) Installation of the fire protection equipment required by license

conditions.

(2) Resolution of fire barrier problems including implementation of a

program to maintain fire barriers functional.

Response:

(1) Waterford 3 has complied and will continue to comply with license

conditions concerning the installation of fire protection

equipment. Required equipment will be installed or modified as

appropriate in accordance with license commitment dates.

.

(2) Since the issuance of the low power license, Waterford 3 has

-

satisfactorily completed the Technical Specification (TS)

surveillance on fire barrier penetration seals. The results of

this surveillance, along with the results of previous walkdowns,

demonstrates both the integrity of the currently installed

penetration seals and the adequacy of the administrative controls

associated with penetration seal installation.

The impairments that have been identified were identified for non

TS seals and have been and will continue to be resolved on a case

by case basis,

i

,

i

!

I

. *5/1/86 ATTACHMENT TO W3P86-0066

Shsst 24 of 32

Performance Functional Area -

G. RADIOLOGICAL CONTROLS

NRC Recommended Licensee Actions:

Management attention is needed in order to correct the numerous

gaseous and liquid leaks that have resulted in excessive contamination

of workers and plant areas. The training and qualification program

for radwaste operators should be improved for the purpose of reducing

the number of operator errors associated with operating the various

radwaste systems.

Response:

Waterford 3 Management has applied significant resources in an attempt

to correct gaseous and liquid leaks that have the potential for

resulting in contamination of workers and plant areas. Some of the

resultant corrective action is delineated in the response to the

performance functional area B, Plant Operations, of the SALP report.

Further delineation is as outlined below:

1. System outages in recent months have resulted in reworking over

100 identified valve leaks. In addition, the Plant Manager has

given specific direction to increase emphasis in this regard by

developing a comprehensive list of leak sources and by scheduling

and implementing repair work on a component availability basis.

Emphasis is to be on primary leaks as opposed to secondary leaks.

An example of this emphasis is the fact that such work was

considered important enough to be allowed on the critical path

during our March outage. It will always be necessary to weigh

the risks and license requirements of equipment outages against

the need to meet our contamination goals while in power

operation. Waterford 3 management is prepared to discuss any

such concerns of NRC inspectors at the time of any future

occurrence.

2. Station Modifications have been identified to address many of the

design problems having impact on the spread of contamination. Of

35 station modifications identified, 22 have been essentially ,

completed to date and the remaining 13 have been prioritized. *

Typical examples are:

a. Valves within the Gaseous Waste Management System will be '

replaced with the new valves with improved seat leakage

characteristics.

b. Gas Surge Tank safety valve will be modified and the

pressure set point was increased.

I

c. The addition of ventilation has proven beneficial to prevent

localized buildup of airborne activity.

. . - _

-. . _ - _ . . - _ , . . _ . . , _ _ - --.

__ ._ _ . _ _ ___

"

'5/1/86- ATTACHMENT TO W3P86-0066

. Shast 25 of 32

G. RADIOLOGICAL CONTROLS - Response (continued)

l

d. Rerouted plumbing vent from the Vent Gas Collection Header <

to the RAB - HVAC System.

J

e. Changed threaded connections to welded connections on

Primary Sample Panel. Also, sample panel ventilation has j

been improved.

f. RAB floor drains will be rerouted downstream of Waste Tank

Strainer to prevent backup of drains.

3. When valves are repacked, graphoil-type packing is now being used

in lieu of the original vendor-supplied packing. This packing is

proving to be more effective in minimizing valve leakage and

should have an extended life in comparison to the old styles of

packing.

4. Maintenance personnel have received additional training on valve

packing techniques to reduce the number of valve leaks by

employing good maintenance practices.

~

5. Waterford 3 takes exception to the SALP report use of " excessive"

, when referring to personnel contaminations. INPO data indicates

i

that skin and clothing contaminations for 1985 were slightly

greater than 300 per plant. Waterford 3 experienced 53 skin

contaminations in 1985. Although clothing contaminations were

not documented until late in the year, it is estimated that there

were 20 to 25 clothing contaminations for 1985.

l The total skin and clothing contamination for 1985 is therefore

( approximately 75 which is far below the INPO average (industry

performance). Approximately 75 contaminations is also well below

l the INPO Best Quartile level of 125 skin and clothing

l

contaminations per year. It should be noted, however, that INPO

data does not reflect contaminations resulting from short-lived

daughter products of noble gases; i.e., such contaminations are

not reported as personnel contaminations. The 75 Waterford 3

contaminations also do not include the results of noble gas

daughter product contaminations. While we are concerned with

skin contaminations, we consider the term " excessive" to not

accurately describe the Waterford 3 situation.

6. Waterford 3 averaged 9000 sq. ft. of area surface contamination

in 1985. A preliminary study on contamination reduction

following our March outage has been generated and the Plant

Manager has established specific direction in this regard. A

contamination reduction task force has been established to:

a. Walkdown the plant to identify leaks that have not been

previously identified.

b. Verify that leaks that have been repaired are not still

leaking,

i

'

-- - .- _- - -.

*

, 5/1/86 ATTACHMENT TO W3P86-0066

Shast 26 of 32

.

G. RADIOLOGICAL CONTROLS - Response (continued)

c. Perform minor maintenance on existing leaks that can be

readily fixed.

d. Remove boric acid buildup on the exterior of repaired valves

to provide for prompt identification of new leaks.

e. Contain leaks on valves where practicable.

f. Decontaminate areas when practicable,

g. Accurate determination of contaminated areas (total sq. ft.)

has been and will continue to be trended. These

calculations are compared to plant goals in this regard and

to current industry standards and performances,

, h. An assessment of Radwaste System Training is being conducted

by plant groups and departments. The results will be

factored into appropriate (Nuclear Auxiliary Operator)

training programs.

,

7. As stated in the response to the performance functional area B,

Plant Operations, of the SALP report, increased emphasis has been

placed on:

' '

a. Operations - Health Physics interfaces to enhance leak

reduction,

b. Correlation with plant evolutions to determine the sources

of contamination.

c. Increased operator attention to detail and more supervisory

involvement in evolutions that may effect the spread of

contamination.

'

8. The Plant Manager's Health Physics Reliability Improvement List

has been an effective tool in giving attention to contamination-

,

ML20203E180

Text

Navigation menu

Search