ML20214W430

Insp Rept 50-382/87-10 on 870416-0515.Violation Noted: Failure to Adhere to Tech Spec Required Action for Inoperable Fire Penetration Seal

ML20214W430
Person / Time
Site:	Waterford
Issue date:	06/04/1987
From:	Jaudon J, Luehman J, Staker T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20214W415	List: ML20214W412 ML20214W416 ML20214W430
References
50-382-87-10, IEB-79-18, IEC-80-10, NUDOCS 8706160018
Download: ML20214W430 (9)

See also: IR 05000382/1987010

Text

(

h

.. ,

' APPENDIX B

U. S. NUCLEAR REGULATORY-COMMISSION

, _ REGION IV-

'

NRC Inspection Report: 50-382/87-10 License: NPF-38-

Docket: 50-382

Licensee: Louisiana Power & Light'Comoany (LP&L).

142 Delaronde Street.

New Orleans, Louisiana :.70174:

Facility Name: Waterford Steam Electric Station, . Unit 3;

Inspection At: -Taft, Louisiana'

Inspection Conducted: April 16 through'May 15, 1987

Inspectors: 14M/$/ $tildtwrn

J:'G. Luehman, Senior Resident Inspector

Tl}[f37

Date '

9:

!l6 au 0Ut1

+

T. 9.I Staker, Resident Ins,p'ector Date'

h

Approved:

s 7.' Jau

-

n,

o__

ef, Reactor Project

[

Section A Da[e 'I

Inspection Summary

'

Inspection Conducted April 16 through May 15, 1987 (Report 50-382/87-10)

Areas Inspected: Routine, unannounced inspection of: (1) Plant Status,

(2) Licensee Event Report (LER) Followup, (3) Followup of Previously Identified

Items, (4) IE Bulletins and Circulars, (5) Monthly Maintenance, (6) Monthly

Surveillance, (7) ESF System Walkdown, and (8) Routine Operational Safety

Inspection.

Results: Within the areas inspected, one violation was' identified (failure to

adhere to the Technical Specification required action for an inoperable fire

penetration. seal, paragraph 8).

382

I

-. . l

l

l

2

DETAILS

1. P_e_rs_o_n_s Contacted

Principal Licensee Employe_es

J. G. Dewease, Senior Vice President Nuclear Operations

• R.P.Barkhurst,VicePresident,NuclearOperations

• N. S. Carns, Plant Manager, Nuclear

T. F. Gerrets, Corporate QA Manager

S. A. Alleman, Assistant Plant Manager, Plant Technical Staff

J. R. McGaha, Assistant Plant Manager, Operations and Maintenance

J. N. Woods, Quality-Manager, Nuclear

A. S. Lockhart, Site Quality Manager

R. F. Burski, Engineering Service Manager

• G. E. Wuller, Onsite Licensing Coordinator

T. H. Smith, Maintenance Superintendent, Nuclear

• Present at exit interview.

In addition to the above personnel, the NRC inspectors held discussions

with various operations, engineering, technical support, maintenance, and

administrative members of the licensee's staff.

2. Followup of Previo_us_ly_ Identified Items

(Closed) Violation 382/8605-01, " Failure to Follow Procedures During

Station Modification 818." The NRC inspector has reviewed both of the

licensee's letters concerning this violation, dated May 2 and August 15,

1986, respectively. The licensee has suspended work on this modification

because major work needs to be done on the sample skid.

(Closed) Violation 382/8613-01, " Failure to Update a Component Cooling

Water (CCW) System Drawing to Incorporate a Design Change." In a letter

dated August 22, 1986, the licensee responded to this violation and

committed, in part, to revise Procedures PE-2-006 and PMP-323. The NRC

inspector verified that these procedures have been updated.

(Closed) Violation 382/8615-01, " Overdue Measuring and Test

Equipment (M&TE)." The NRC inspector verified that an M&TE accountability

Procedure (MD-1-021) has been implemented. After reviewing Procedure

MD-1-021, the NRC inspector had no further questions.

(Closed)UnresolvedItem 382/8615-04, " Equipment Qualification (EQ) Status

of Safety-Related Limitorque Valve Operators." An inspection of the

licensee's EQ program was performed December 8-12, 1986, and the results

are documented in NRC Inspection Report 50-382/86-32.

. .

3

!

(Closed) Open Item 382/8616-04, " Updating of Refueling Procedures." The

NRC inspector has verified that the refueling procedures (with three

exceptions) listed in paragraph 9 of NRC Inspection Report 50-382/86-16

have been updated. After further review, Procedure MI-5-569 was

determined to be correct. The security precautions required for receipt

of new fuel, though not contained in either Procedure NE-1-001 or

NE-1-004, are contained in Procedure PS-11-106, "Special Nuclear Material

Deliveries to the Fuel Handling Building."

(Closed) Violation 382/8629-01, " Failure to Follow Security Procedures."

This violation is considered closed as no response to the violation was

required.

(Closed) Open Item 382/8701-02, " Rigging from Safety-Related Piping, in

Particular, the 'A' CCW Pump Suction and Discharge Piping." The. licensee

has performed an engineering evaluation to confirm that no damage has

occurred to this piping. Maintenance personnel have been rein'structed on

rigging practices. Procedure MM-1-002, " Mechanical Maintenance

Practices," has been changed to include instructions requiring the

performance of an engineering evaluation prior to rigging from any

safety-related piping to ensure that no damage will occur.

No violations or deviations were identified.

3. Plant Status

The plant operated at or near full power during the entire inspection

period.

On the morning of April 2E, 1987, a failed cap stud was discovered on the

"A" charging pump. The pump was imediately removed from service for

repairs, and the licensee initiated an investigation into the cause of the

failure. An analysis of the stud, performed by the licensee, indicated

that the stud suffered a fatigue failure. The-stud subsequently was sent

offsite for further analysis.

Because an extended lead time was required by the pump vendor for

providing a replacement stud, the licensee decided to fabricate

replacements onsite. In all, three replacement studs were manufactured

from the same material as the original (AFTM-453 Grade 660). One

replacement was used in place of the failed stud, the second in place of

the corresponding stud on the other side of the pump, and the third for

testing purposes.

The licensea has inspected the other two charging pumps and found no other

apparent problems with the studs. According to the licensee, no similar

failures have been reported by other nuclear power plants; however, the

pump vendor did know of one case of a stud failure due to improper

torquing.

No violations or deviations were identified.

j

_ ._______________

, . .

4

4 Licensee Event Repo_rt__(LER) Followup

The following LERs were reviewed and. closed. The NRC ' inspectors verified

that reporting requirements had been met, that causes had been identified,

that corrective actions appeared appropriate, that generic applicability

had been considered, and that the LER forms were complete. Additionally,

the NRC inspectors confirmed that no unreviewed safety questions were

involved, and that violations of regulations or Technical

Specification (TS) conditions had been identified.

(Closed)LER 382/85-36, " Inadvertent Actuation of Control Room Ventilation

Sy stem. " The NRC inspector reviewed work packages to verify that the

discriminator levels were adjusted for all.four Control Room Outside Air

Intake Radiation Monitors (CROAI) as described in this LER. The NRC

inspector observed that this discriminator level adjustment did not

eliminate the inadvertent system isolations because of the sensitivity of

the CROAI as evidenced by LERs 85-45, 85-48, and 86-29.

(Closed)LER 382/86-29, " Control Room Emergency Ventilation Actuation Due

to Radiation Monitor Spike."

(Closed)LER 382/87-05, " Safety Inspection Tank Level Below Technical

Specification Due to Level Instrument Reference Leg Leak." The NRC

inspector verified that the change to Procedure OP-09-008, discussed in

this report had been made.

(Closed)LER 382/87-06, " Inadvertent Fuel Handling Building Ventilation

Emergency Filtration System Actuation Due to Personnel Error." The NRC

inspector verified that Procedure MI-3-362 had been changed to incorporate

more specific jumper installation and verification instructions.

(Closed)LER 382/87-08, " Reactor Trip on High Steam Generator level Due to

Malfunction in the Feedwater Control System." After reviewing this

report, the NRC inspector had one comment for the licensee. The report

contained discussion of at least one failed component, yet block (13) of

the report was blank.

No violations or deviations were identified.

5. IE Bulletins and Circulars

(Closed) IEC 80-10, " Failure to Maintain Environmental Qualification." ,

The inspection of the licensee's program was completed in December 1986 l

and is documented in NRC Inspection Report 50-382/86-32. Because this

inspection did not address the issue of training, the NRC resident

inspector verified that training has been conducted in this area.

Additionally, the licensee's programs for specifically labelling equipment

, covered under the equipment qualification program and the identification i

of maintenance requests that could impact equipment qualification will

assist the licensee in maintaining equipment standards.

.

. - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ . _ _ _ . _ - . - _ . _ _ _ _ - . _ _ __ ___-...m.__.- _ __a. _.- . _.i _ _ _ . _ _ ._ _ -.____.-._.__m_a_m-.- _ .._.__ --__--.._

. . .

5

'(Closed) IEB 79-18, " Audibility Problems Encountered on Evacuation of

Personnel from High Noise Areas."During the first week of April 1987,

licensee engineering personnel conducted audibility surveys

at various plant locations to verify that the station alarms and

paging system could be heard over background noise. These surveys

were done to meet the commitment to test modifications to plant

communications systems, made in response to this bulletin, with the

plant operating at greater than 80 percent power.

No violations or deviations were identified.

6. Monthly Maintenance

Station maintenance activities affecting safety-related systems and

components were observed and reviewed to ascertain that the activities

were conducted in accordance with approved procedures regulatory guides,

industry codes or standards, and in conformance with YS.

'

Portions of the following condition identification work authorizations

(CIWAs) and maintenance procedures were observed by the NRC inspectors:

. CIWA 032658 - Troubleshooting Annuniciator C1209, Battery SAB

Trouble."

. CIWA 032276 - Removal and replacement of Firewrap B3541-SAB, located

between the "A" and "B" Essential Service Water Chillers.

. CIWA 032463 - Fan replacement CPC channel "B" auxiliary cabinet.

The NRC inspector observed an Instrument and Control (I&C) technician

removing i. defective fan from the bottom of the CPC channel "B" auxiliary

cabinet under CIWA 032463. The NRC inspector then inspected the new fan,

which the technician had drawn from storage, to verify it was in good

condition and properly identified. The technician explained that before

the new fan could be installed, a number of modifications had to be made

including removal of a dual speed switch and rerouting of the power supply

cable through the back of the assembly rather than out of the side. The

NRC inspector then reviewed the CIWA work instructions, which just called

for removal of the installed fan and replacement with the fan from the

warehouse. The NRC inspector promptly~ contacted the maintenance

superintendent to obtain the following information:

. The basis for modifying the fan assembly.

. Whether the CIWA alone was the proper mechanism for traking such a

change.

. Whether the work instructions on the CIWA were adequate if

modification instructions were available and the CIWA alone was

considered the proper control docurrent.

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

-

. _

...

.

t

6

,

The maintenance superintendent explained that the fans are being supplied

'

directly from the manufacturer rather than from Combustion Engineering,

Inc., (CE) and are being modified onsite. Although this fan was not

safety-related, this practice raised an additional concern on the part of

'

the NRC inspector. Did the licensee know if any modifications, beyond the

readily apparent dual' speed switch and the power' cable, had been requested

by CE for the fans they had purchased and supplied to the licensee? Has

l the licensee evaluated the necessity of such upgrades that were.not made

'

to fans purchased directly from the manufacturer? Followup of the basis-

for modifying the fan is identified as an open item (382/8710-01).

'No violations or deviations were identified.

!

'

7. M_onthly Surveillance

The NRC inspectors observed and reviewed TS required testina and

verified that testing was performed in accordance with adegaate

procedures, that test instrumentation was calibrated, that limiting.

l

conditions for operation (LCO) were met, end that any deficiencies

'

identified were properly reviewed and resolved.

l The NRC inspector observed the performance of portions of Licensee i

i Procedure OP-903-094, Revision 4, "ESFAS Subgroup Relay Test-0perating."

l During the test, the NRC inspector noted that many steps taken to restore

! systems to the operating lineup, once the relay test for a particular

component hcd been accomplished, were not covered by procedural steps.

This observation was discussed with the operations superintendent who

agreed that necessary system re:;toration steps should be included, at

least by reference, to the appropriate system operating procedure.

,

The NRC inspector observed the. performance of Procedure OP-903-053,

Revision 4, " Fire Protection System Pump Operability Test," on May 14,

1987. The performance of this procedure fulfills the requirement of'

TS 4.7.10.11b and 4.7.10.1.2.a, The electric motor driven pump and the

No. 2 diesel driven pump were operated satisfactorily. The No. 1 diesel

driven pump reached the operating temperature limit and was secured by the

operator, as required, prior to completion of the surveillance.

Instrument and control technicians were then requested to troubleshoot the

diesel Coolant Control System, subsequently, the pump was returned to full

service.

No violations or deviations were identified.

! 8. ESF_ System Walkdown

The Component Cooling Water (CCW) system was verified operatinnal by

performance of a walkdown of selected essential and accessible portions of

the system on April 16 and 17,1987.

I

L The NRC inspector used the CCW valve lineup specified in Attachment 10.1

'

of Procedure OP-903-049, Revision 4, " Component Cooling Water and

._-

. . .

7

,

Auxiliary Cooling Water Loop Operability Check," in conjunction with

Drawing L00-1564-G-160.

l On completion of the inspection, the NRC inspector made the following

l consnents to licensee management:

.- A few tail pieces downstream of vent and drain valves did

have pipe caps installed as shown in the CCW system LOU-1564-G-160.

. An Ebasco QA hold tag was installed on piping upstream of

l

ACC-124A. This tag was apparently left over from construction.

. A plate on Valve ACC-126B contained instructions on how to engage

the valve handwheel. There was no handwheel installed on the

valve stem, and no CIWA tag was on the valve to identify this

condition. The valve was operable remotely.

. The NRC inspector observed a stepladder in the "A" Shutdown

CoolingHeatExchanger(SDHX)roomthatwaslockedtotheSDHX

Component Cooling Water Inlet Isolation Valve CC-949A. The NRC

inspector brought this to the attention of the shift supervisor

emphasizing that this is a seismically qualified system.

. The NRC inspector observed that a portable hydraulic jack was

installed between the handwheel of Valve CC-563 (Component Cooling

Water Pump Suction Header Loop Isolation Valve) and the floor of the

reactor auxiliary building. The jack did not have a temporary

l

alteration tag attached, and no CIWA tag was attached to the valve.

The NRC inspector brought this to the attention of operations and

technical support personnel. The NRC inspector was concerned because

no evaluation was performed on the affect of this jack on the valve

operation (requesttocloseonESFAS)ortheseismicperformanceof

the valve and attached oiping (Seismic I). Also, no means of control

was established for the temporary installation of this hydraulic

jack. The shift supervisor informed the NRC inspector that the valve ,

would perform its required functions with the jack installed; I

however, no evaluation or means of control of this jack installation )

existed. The licensee later decided that a temporary alteration was

the proper method of evaluating and controlling the installation of

this jack, and a temporary alteration was established.

l . The NRC inspector observed a fire seal in the "A" Component Cooling

Water Heat Exchanger room that appeared to be impaired. The NRC

inspector identified the seal as III-A0-155 and observed that damming

l material was placed over the seal and that this material was held in

place with duct tape. The fire impairment log was reviewed, and no l

record of an impairment for this seal was found. On April 17, 1987,

the NPC inspector informed the shift supervisor of this condition.

On April 30, the NRC inspector again inspected Fire Seal III-A0-155

l

and found it to be in the same condition as described above. The NRC

inspector again reviewed the fire impairment log and found that no

I

l

l _ _ -__ A

- _ _ _ -

.

.. .

8

impairment had been issued for the seal. The on-watch shift

supervisor was notified of the problem. On May 1, the NRC inspector

contacted the loss control engineer,to discuss the fire seal. The

loss control engineer directed maintenance personnel to remove the

damming material and inspect this fire seal. The seal was.found to

be impaired due to an apparent _' attempt to route conduit or cabling

through it. A fire impairment was issued, and an hourly fire watch

tour was initiated (as required by plant' Technical Specifications).

The licensee could not find records of the work that was performed on

Fire Penetration Seal III-A0-155. The failure to follow the TS i

action statement for inoperable fire seals (3.7.11) is an apparent

violation (382/8710-02).

No other violations or deviations were identified.

9. Routine Operational Safety Inspection

l By observation during the inspection period, the NRC inspectors verified

that the centrol room manning requirements were being met. In addition,

the NRC inspectors observed shift turnover to verify that continuity of

system status was maintained. The NRC inspectors periodically questioned

shift personnel relative to their awareness of the plant conditions.

Through log review and plant tours, the NRC inspectors verified compliance

with selected TS and limiting conditions for operations.

During the course of the inspection, observations relative to protected

and vital area security were made including access controls,. boundary

integrity, search, escort, and badging.

On a regular basis, radiation work permits (RWP) were reviewed, and

specific work activity was monitored to assure the activities were being

conducted per the RWPs. Selected radiation protection instruments were

periodically checked, and equipment operability and calibration frequency

were verified.

The NRC inspectors kept themselves informed, on a daily basis, of overall

status of the plant and any significant safety matters related to plant

operations. Discussions were held with plant management and various

members of the operations staff on a regular basis. Selected portions of

operating logs and data sheets were reviewed daily.

The NRC inspectors conducted various plant tours and made frequent visits

to the control room. Observations included: witnessing work activities

in progress; verifying the status of operating and standby safety systems I

and equipment; confirming valve positions, instrument and recorder

readings, and annunciator alarms; and housekeeping.

While performing a routine plant tour, the NRC inspector observed that the

containment spray riser level pump breakers were in the "on" position.

The NRC inspector noted that this was in conflict with Procedure OP-9-001,

l

!

1

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

.

,

"

,,,a

,

.9:

Revision'4, " Operating Procedure Containment' Spray,"_which requires these

breakers to be in the "open" position and-danger tagged.

The NRC inspector brought this to the-attention of the shift su'pervisor

who then directed operations personnel to open and tag these breakers and

^

also verify that the riser level pump suction and discharge valves are

,

shut as required by Procedure OP-9-001. The breakers for the riser pumps

are required to be tagged solely for equipment protection as they perform

no safety function. However, this failure to follow established

'

procedures appeared to be the result of a poorly thought-out procedure,

because continued tagging and untagging were required. The licensee

committed to review this area.

While performing a routine plant tour, the NRC inspector observed that the

lifting hoists installed on the 480 volt switchgear cabinets in the "A,"

"B," and "A/8" safety switchgear rooms have attached signs with

3 instructions to install seismic restraint bolts when' not in use. The NRC'

'

inspectcr then~ observed that these bolts were not installed.

The NRC inspector brought this. discrepancy to the attention of plant

management, and the seismic restraint bolts were installed. The NRC'

i inspector discussed methods for ensuring that these bolts are installed-

after use such as instructions in procedures that require use of these

'

hoists. The NRC inspector also questioned the hoist mounted on the

! seismic qualified 480 volt switchgear cabinet in the "B" safet; switchgear

room since there appears to be no device for restraining this hoist (no

seismic restraint bolts or provisions for installing them). Followup on

the hoist seismic qualification and the addition of instructions to

install seismic restraint bolts after maintenance in procedures is an open

j item (382/8710-03).

4

No violations or deviations were identified.

j 10. Exit Interview

The inspection scope and findings were summar' zed on May 18, 1987, with.

i those persons indicated in paragraph 1 above. The licensee acknowledged

'

the NRC inspectors findings. The licensee did not identify as proprietary

i any of the material provided to or reviewed by the NRC inspectors during

this inspection.

4

-

i

,

_ _. ,