ML20247K395

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Insp Rept 50-382/89-06 on 890201-28.Violations Noted.Major Areas Inspected:Plant Status,Monthly Maint Observation, Operational Safety Verification,Onsite Followup of Events, ESF Walkdown & Followup of Previously Identified Items
ML20247K395
Person / Time
Site: Waterford Entergy icon.png
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

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T. R.'StakeF, Resident Inspector

Date

D. $. Ch'amberlain," Chief, Project Section A

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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),

b.

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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