ML20247K395
| ML20247K395 | |
| Person / Time | |
|---|---|
| Site: | Waterford |
| Issue date: | 03/25/1989 |
| From: | Chamberlain D, Will Smith, Staker T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20247K361 | List: |
| References | |
| 50-382-89-06, 50-382-89-6, NUDOCS 8904050238 | |
| Download: ML20247K395 (10) | |
See also: IR 05000382/1989006
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APPENDIX B
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50-382/89-06
Operating License: NPF-38
Docket: 50-382
Licensee:
Louisiana Power & Light Company (LP&L)
317 Baronne Street
New Orleans, Louisiana
70160
Facility Name: Waterford Steam Electric Station, Unit 3
Inspection At:
Taft, Louisiana
Inspection Conducted:
February 1-28, 1989
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Inspectors:
W. FFSmith, Senior Resident Inspector
D'a te
Q #(8-87
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T. R.'StakeF, Resident Inspector
Date
D. $. Ch'amberlain," Chief, Project Section A
3/d/8Y
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Approved:
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Date
Division of Reactor Projects
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Inspection Summary
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Inspection Conducted February 1-28, 1989 (Report 50-382/89-06)
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Areas Inspected:
Routine, unannounced inspection of plant status, monthly
maintenance observation, operational safety verification, onsite followup of
events, monthly surveillance observation, engineered safety feature (ESF)
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walkdown, and followup of previously identified items.
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Results: During a maintenance observation made during this inspection period,
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the NRC inspectors noted that a maintenance technician, with the permission of
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a nonlicensed plant. operator, operated a primary system valve which was red
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danger tagged open. This was indicative of failure on the part of the licensee
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to adequately proceduralize and train site personnel on the importance of not
disturbing danger tagged components. This is discussed in detail in
paragraph 3.
A violation was identified for failure to follow the governing
administrative procedure. Two further examples of personnel failing to adhere
to procedures are also cited indicating that corrective action in this area has
not been completely effective.
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A second apparent violation was identified in paragraph 4 for failure of the
licensee to comply with the Technical Specification (TS) action stntements
associated with the inoperability of an emergency diesel generator when the
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supporting component cooling water system was placed out of service for routine
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maintenance. This issue will be the subject of a meeting between NRC,
Region IV, and the licensee.
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During maintenance observations, safety equipment was assembled incorrectly on
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two separate occasions because of a lack of attention by maintenance personnel,
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combined with inadequate work instructions and failure to adhere to procedures.
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Additionally, the technical manuals for the high pressure safety injection pump
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motor was found to be not current, and the auxiliary component cooling water
pump manual was found incomplete.
Since equipment specific procedures are not
used for much of the plant's safety-related mechancical equipment, the
implementation of the LP&L maintenance program relies heavily on equipment
technical manuals which may be deficient in some instances.
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DETAILS
1.
Persons Contacted
Principal Licensee Employees
- R. P. Barkhurst, Vice President, Nuclear Operations
- N. S. Carns, Plant Manager, Nuclear
S. A. Alleman, Nuclear Quality Assurance Manager
P. V. Prasankumar, Assistant Plant Manager, Technical Support
D. F. Packer, Assistant Plant Manager, Operations and Maintenance
J. J. Zabritski, Quality Assurance Manager
- D. E. Baker, Manager of Nuclear Operations Support and Assessments
- J. R. McGaha, Manager of Nuclear Operations Engineering
W. T. Labonte, Radiation Protection Superintendent
G. M. Davis, Manager of Events Analysis Reporting & Responses
L. W. Laughlin, Onsite Licensing Coordinator
D. W. Vinci, Maintenance Superintendent
- A. F. Burski, Manager of Nuclear Safety and Regulatory Affairs
R. S. Starkey, Operations Superintendent
- W. E. Day, Trending, Compliance, and Response Supervisor
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- 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.
Plant Status (71707)
At the start of the inspection period, the plant was operating at
100 percent thermal power. Operation at full power continued until
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February 4,1989, when power was reduced to 60 percent as a precaution
prior to realigning the A/B safety bus. The bus transfer was performed so
the A/B high pressure safety injection (HPSI) pump could replace the
of the B low pressure safety injection (gnment, an inadvertent actuation
inoperable B HPSI pump. After bus reali
LPSI) pump occurred. This is
discussed in paragraph 5.
After a successful bus transfer, the plant was
returned to full power operation. On February 18, 1989, the licensee
reported a loss of assessment capability per 10 CFR Part 50.72 when the
safety parameter display system (SPDS) was inoperable for greater than
I hour. The SPDS was restored to service later that day. The plant
remained at full power throughout the remainder of the inspection period.
3.
Monthly Maintenance Observation
(62703)
The station maintenance activities affecting safety-related systems and
components listed below were observed and documentation was reviewed to
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ascertain that the activities were conducted in accordance with approved
procedures, TS, and appropriate industry codes or standards.
a.
Work Authorizations 01028797 and 01028798.
The NRC inspector
observed portions of preventive maintenance performed on Auxiliary
Component Cooling Water (ACCW) Pump B.
The pump and motor oil were
sampled and changed out. A coupling alignment was performed after
the alignment was found to be out of tolerance. A leaking pump vent
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plug was repaired. After realignment, maintenance personnel measured
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pump and motor vibration, and operations personnel performed
quarterly inservice testing. The NRC inspector identified the
following concerns to the plant staff:
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(1) A condition identification (CI) tag (CI 8378, dated August 18,
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1987) indicating oil leakage at piping below the inboard pump
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bearing was observed.
No work was performed to correct this
condition.
(2) Two dial indicators (MMMT0 70.328 and MMMT0 70.331) were issued
to maintenance personnel to use for alignment measurements. The
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dial indicators were in their storage cases with accessories.
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The protective padding was missing from the storage cases.
(3) Two dial indicators were used to indicate pump motor movement
during the alignment. The devices were placed against a motor
foot while the other side of the foot was hammered. After
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subjecting the dial indicators to this shock, they remained in
active service.
(4) Work Authorization 01028798 required the coupling
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disassembly / reassembly to be performed per the Faulk section of
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the pump vendor's manual (B & W Pumps Instruction
Manual 457000254). The installed coupling was a Koppers, which
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was consistent with the vendor's manual.
The section of the
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vendor's manual on the coupling was incomplete. The instruction
sheets included in the manual were supplemental and required
coupling reassembly per the missing basic instruction sheets.
These sheets were not included in the vendor's manual or the
work package, therefore, the work instructions were not adhered
to. Consequently, the technicians performing the task either
did not read the instructions or they found this discrepancy and
completed the work with the deficient work package. When the
licensee finally acquired the missing instruction sheets, it was
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datermined that torquing requirements were specified for
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coupling reassembly. The coupling bolts were not torqued as
required during reassembly. This example of a failure to adhere
to procedures is an apparent violation of NRC regulations
(382/8906-01).
(5) During the performance of vibration testing on the ACCW
aump,
the NRC inspector identified that the motor mount bolts lad not
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been torqued as required by the pump technical manual. The
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maintenance technicians had failed to identify the torquing
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requirement and were pre)aring to return the pump to service.
After discussions with tie NRC inspector, the bolts were torqued
as required and the pump placed back into service. This is
considered another example of failure to adhere to procedures
(382/8906-01).
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(6) The locations for vibration measurements were not permanently
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marked in accordance with ASME,Section XI. The licensee is
currently marking applicable components in order to meet this
requirement,
b.
Work Authorization 01032239. After repacking Charging Pump A/8, the
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pump failed to provide the minimum expected charging flow. This
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maintenance activity involved the removal and inspection of the pump
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discharge and suction valves for evidence of leakage. The NRC
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inspector reviewed the work documentation and noted that proper
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approvals were obtained to start the work, and the instructions
appeared appropriate to the circumstances. The mechanical and
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radiological work practices applied were acceptable. The planning
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effort was marginally acceptable. At the onset of the job, it became
necessary for the supervisor to make a change in the work instruction
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to reverse a spectacle flange so that the pump could be drained. A
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spectacle flange is similar to an orifice flange except that it has
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two states:
full flow or no flow (blanked).
Since the pump was
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already tagged out of service and the contents of the pump could have
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drained out of the spectacle flange while changing state, the
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auxiliary operator authorized a maintenance technician to momentarily
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close Drain Valve CVC-189 A/B to isolate the flange. The valve was
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danger tagged open as part of the clearance to work on the pump.
Operation of the valve with the tag intact appeared to be in
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violation of licensee procedures.
Upon investigating further, the
NRC inspector learned that when the maintenance mechanic identified
the need to isolate the spectacle flange to the operator, the
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operator obtained concurrence from the Control Room Supervisor (CRS)
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to operate the valve. The concurrence was obtained through a phone
talker, and as such, the CRS did not know the valve was tagged. The
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auxiliary operator apparently was not aware of the requirement to
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obtain written authorization to remove the tag before he could
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operate any tagged valve. This requirement exists in Administrative
Procedure UNT-5-003, Revision 7 " Clearance Requests, Approval, and
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Release." The auxiliary operator verbally authorized the maintenance
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technicians to operate the valve because there was a radiological
barrier that the operator could not cross without donning
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anticontamination clothing. This is an additional example of failure
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to follow procedures and is an apparent violation of NRC regulations
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(382/8906-01).
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The NRC inspector discussed the above problem with licensee
management.
Inanediate corrective actions included counseling the
individuals involved, discussing the importance of not operating
danger tagged components with maintenance and operations personnel,
placing a policy letter in the control room daily instruction book,
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submitting a request for training to stress tagged valves in General
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Employee Training, and review of procedure improvements. The NRC
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inspectors will review these actions and their effectiveness on a
continuing basis.
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Work on the charging pump was completed by February 21, 1989.
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pump suction check valves were replaced.
Upon retesting the pump,
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slightly less flow was obtained after the work than before the work.
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In accordance with the licensee's Inservice Testing Program, new
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baseline data was entered at the lower value, which was 42.8 gallons
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per minute (GPM). The NRC inspector questioned the licensee's
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decision to not determine and correct the cause of the low flow
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before returning the pump to service. The licensee explained that no
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cause could be found, and the pump was acceptable since the flow was
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2.8 GPM above the TS minimum of 40 GPM.
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c.
Work Authorization 01032220.
The NRC inspector observed portions of
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the repair of B HPS1 pump. The bearings were replaced on
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February 17, 1989, in an attempt to correct high HPSI pump motor
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vibration. On February 20, 1989, the licensee attempted two
uncoupled motor runs in order to determine if the cause of the high
vibration had been corrected.
Both times, the motor was secured
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because of excessive vibration. The licensee then decided to call on
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the pump motor vendor for assistance.
With the vendor's
representative present, the bearing covers were removed. The
bearings were damaged. The vendor's representative immediately
observed that the bearing oil rings (inboard and outboard bearings)
were installed incorrectly (on top of the bearing housing) and thus
the bearings were not being lubricated during motor operation.
Additionally, the bearing antirotation pins were not installed. The
bearings apparently failed because of the lack of lubrication, but
failure to install the antirotation pins would have caused a failure
after a longer period of operation perhaps after the performance of
operability testing and placing the pump in service.
The work instructions for installing the bearings (k!A 01032220)
required bearing babbit scrapping and clearance checks in accordance
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with the vendor's manual. The bearings were then isstalled and
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checked for proper fit. There were no specific instructions on oil
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ring location or antirotation pin installation. Maintenance
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personnel indicated that they believed that these were within the
skill of the craft for maintenance personnel. However, the NRC
inspector observed that the pump technical manual (457000272)
requires two checks after installation to verify correct oil ring
operation. These were not included in the work instructions and were
not performed.
If these checks were performed, trained technicians
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would have determined that the oil rings were not operating properly
(rotating) and thus not installed correctly.
The licensee could not
explain why these checks were not included in the work authorization
steps.
The new bearings were installed.
The motor vibration was returned to
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specification by rebalancing the rotor. The B HPSI pump was then
tested and returned to service.
By discussion with maintenance
personnel, the NRC inspector determined that the present vendor's
technical manual (4570272) for the HPSI pump and motar is not the
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most current. ThiscombinedwiththeACCWpumpmotormanualbeing
incomplete raised a concern on the implementation of the licensee s
maintenance program. The licensee's maintenance program
implementation relies heavily on these technical manuals because they
are used in place of approved procedures, in many instances, for
component specific maintenance. The NRC inspectors will followup on
the licensee's actions with regard to the maintenance of equipment
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technical manuals. A supplementary inspection of the recent series
of problems with the B HPSI pump is scheduled and will be documented
in NRC Inspection Report 50-382/89-09.
4.
Operational Safety Verification (71707)
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The objectives of this inspection were:
(1) to ensure that this facility
was being operated safely and in conformance with regulatory requirements,
(2) to ensure that the licensee's management controls were effectively
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discharging the licensee's responsibilities for continued safe operation,
(3) to assure that selected activities of the licensee's radiological
protection programs are implemented in conformance with plant policies and
procedures and in compliance with regulatory requirements, and (4) to
inspect the licensee's compliance with the approved physical security
plan.
The NRC inspectors visited the control room at least once each day when on
site and verified that proper control room staffing was maintained,
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operator behavior was professional and commensurate with plant conditions,
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and approved procedures were utilized and complied with. The panels were
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inspected for anomolics, and when found, were satisfactorily explained by
the operators.
Compliance with TS limiting conditions for operation was routinely
reviewed, particularly when action statements had to be met, as required,
when equipment was taken out of service for preventive or corrective
maintenance.
In each case, TS requirements were met, except on
February 22, 1989, when the Train A Component Cooling Water (CCW) System
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was placed out of service for preventive maintenance. This rendered
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Emergency Diesel Generator A and other major Train A components supported
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by CCW inoperable. When the NRC inspector observed this condition, he
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noted that only TS 3.7,3 was identified. TS 3.7.3 has an action statement
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that requires a plant shutdown in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if one CCW train is not
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operable. Upon questioning this, the licensee explained that TS 3.7.3 was
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the governing action statement. The NRC inspector noted that there were
no action statements for affected components / systems that required a
shutdown in less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; however,*TS 3.8.1.1.b for the emergency
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diesel generators required an offsite power. availability verification to
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be performed in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, which was not done. Additionally, the
accomplishment of TS 3.8.1.1.d which requires verification of certain
equipment operability in Train B within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> was not performed. CCW
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was restored to service about 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> later.
Failure to comply with the
action statements in TS 3.8.1.1 is an apparent violation of NRC
regulations. As it turned out, Train A CCW, and thus the affected systems
supported by CCW, were unnecessarily removed from service due to a
breakdown in communications. The planned outage was cancelled the evening
of February 21, 1989, but apparently nobody informed the operators.
The
NRC inspector expressed concern to licensee management that unnecessary
disabling of safety systems due to a planning and/or communication
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weaknesses should be prevented. Also, the licensee was requested to
determine how many times in the past year the CCW system was taken out of
service without complying with the action statements of TS 3.8.1.1.
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licensee researched the records and determined that this has occurred six
times since August 1987. These apparent examples of TS noncompliance will
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be the subject of further discussions between NRC Region IV and the
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licensee.
The NRC inspectors performed plant tours and noted that equipment
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appearance and housekeeping were good.
During tours, plant personnel were
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observed to be adhering to safety, health physics, and security
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requirements.
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The NRC inspectors monitored plant and equipment status by review of logs,
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operating panels, and attendance at licensee " Plan of the Day" meetings.
5.
Onsite Followup of Events
(93702)
a.
Inadvertent Actuation of Low Pressure Safety Injection
Pump (LPSI)
On February 4,1989, while performing testing on the A/B HPSI pump, a
licensed operator inadvertently started the B LPSI pump. The
operator was performing Step 12 of Attachment 10.3 to
Procedure OP-903-011, Revision 4, "High Pressure Safety Injection
Pump Preservice Operability Check." The step required placing the
switch on B LPSI pump to "0FF" prior to performing an essential
safety features actuation system test start of the A/B HPSI pump.
Because of the failure to place the B LPSI pump to "off", the
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B LPSI pump started. The pump was secured, and operating personnel
were sent to verify pump status.
The licensee decided not to report
this unplanned start of the B LPSI pump per 10 CFR Part 50.72 because
their policy was that an ESF actuation included actuation of the full
component circuit. After discussion with the NRC inspectors,
licensee management found the event reportable and a subsequent
report per 10 CFR 50.72 was initiated. The NRC inspectors identified
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that operations personnel failed to initiate a Quality Notice or
Potentially Reportable Event Report for this event.
In fact, the
LPSI pump start was not even recorded in the plant operator's log.
This was discussed with plant management. This is considered another
example of failure to follow procedures (382/8906-01),
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Fire Seal Inspection and Repair Status
The licensee has completed inspection of all accessible fire seals
(see NRC Inspections Reports 50-382/88-28,50-382/88-31,and
50-382/89-03), including the inspections in response to NRC
Information Notice 88-56, " Potential Problems with Silicone Foam Fire
Barrier Penetration Seals." The results of about 200 of these
inspections remain to be evaluated.
In addition, plant engineering
is evaluating obstructed and inaccessible seals in order to detc.mine
what inspections, if any, will be performed on these seals.
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6.
Monthly Surveillance Observation (61726)
The NRC inspectors observed the surveillance testing of safety-related
systems and components listed below to verify that the activities were
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being performed in accordance with the TS.
The applicable procedures were
reviewed for adequacy, test instrumentation was verified to be in
calibration, and test data was reviewed for accuracy and completeness.
The inspectors ascertained that any deficiencies identified were properly
reviewed and resolved.
Procedure MI-3-121, Revision 3, "CEAC Functional Test." On
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February 15, 1989, the NRC inspector witnessed functional testing of
control element assembly calculator (CEAC) Channel 1.
No problems
were identified.
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No violations or deviations were identified.
7.
Engineered Safety Feature (ESF) Walkdown (71710)
During the inspection period, the NRC inspectors initiated an inspection
of the LPSI system. Completion of the inspection is scheduled for
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March 1989, and the results will be documented in NRC inspection
Report 50-382/89-08.
No violations or deviations were identified.
8.
Followup of Previously Identified Items
(92701)
(Closed) Unresolved Item 382/8724-01: The Dyna-Weight balancing material
has been removed from all affected component cooling water dry cooling
tower fan motors. The licensee determined that five of the six affected
fan motors were serviced by a local non-Class 1E vendor during plant
construction. Use of the Dyna-Weight by the non-Class 1E vendor is normal
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practice.140 other safety motors'were serviced by this vendor. The
origin of thi nyna-Weight on the sixth fan could not be determined. All
affected-fans have been restored to Class IE by a qualified shop. This
item is closed.
No violations or deviations were identified.
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9.
Exit Interview
The inspection scope and findings were summarized on March 3,1989, with-
those persons indicated'in paragraph 1 above. The licensee acknowledged
the NRC inspectors' findings. The licensee did not identify as-
proprietary any of the material provided to, or. reviewed by, the NRC
inspectors during this inspection.
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