W3P86-2805, Forwards SALP Progress Rept,Including Summary Level Overview of 1986 Accomplishments in Each SALP Functional Area, Followed by More Detailed Discussion of Programs Initiated, Status & Achievements in Improving Plant Performance

Forwards SALP Progress Rept,Including Summary Level Overview of 1986 Accomplishments in Each SALP Functional Area, Followed by More Detailed Discussion of Programs Initiated, Status & Achievements in Improving Plant Performance

ML20207D597
Person / Time
Site:	Waterford
Issue date:	12/17/1986
From:	Cook K LOUISIANA POWER & LIGHT CO.
To:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
W3P86-2805, NUDOCS 8612310099
Download: ML20207D597 (51)

Text

r O

6

+ P. O. BOX 60340 LOUISIANA POWER & L1GHT/ 317NEW BARONi3ESTREET ORLEANS, LOUISIANA 70160 + (504) 595-3100

$uSN s*vsT$ December 17, 1986 W3P86-2805 A4.05 QA Mr. Robert D. Martin Regional Administrator, Region IV h h h b h h]i U.S. Nuc?ent Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 if!

Arlington, TX 76011 DECI8l%.

O

SUBJECT:

Waterford SES Unit 3 .

Docket No. 50-382 License No. NPF-38 SALP Progress Report

REFERENCES:

(1) W3P86-0066 dated May 1, 1982.

(2) NRC letter dated July 21, 1986 from R.D. Martin to G.W.

Muench.

Dear Mr. Martin:

By the reference (1) letter LP&L provided an initial response to the 1985 SALP Report for Waterford 3. In your reference (2) letter you indicated that our response appeared to adequately address the concerns and recommendations of the SALP Board and requested that LP&L keep you informed of progress in the SALP functional areas.

During 1985 and 1986 Waterford 3 management devoted a great deal of attention and resources to performance improvement in each SALP functional area. The significant accomplishments in 1986, such as the excellent plant capacity factor and large reduction in reactor trip frequency, reflect the strong management attitude towards safe, reliable and improving plant operation.

8612310099 861217 DR ADOCK 05000382 O PDR \ g(

s sugo 4

(. i i "AN EQUAL OPPORTUNITY EMPLOYER"

)[ L

V:

J .

.54 l :t H W3P86-2805._

Page 2-l

t. .

l l

We are pleased to provide you with the enclosed retrospective review of the

~

-important achievements of our staff during 1986. The attached report includes a summary level overview of 1986 accomplishments in each SALP-functional area, followed by a more detailed discussion of the programs initiated, their. status and achievements in improving the performance at.

- Waterford3. I'am at your disposal to discuss any aspect of plant operations for which-you may wish additional information.

l Yours very truly, K.W. Cook Nuclear Safety and

-Regulatory Affairs Manager l

l l KWC:MJM:ssf I

i

! cc: NRC Director Office of I&E j' G.W. Knighton (NRR) l J.H. Wilson (NRR) l J.E. Gagliardo (Region IV) l D. Crutchfield (NRR)

, G.L. Constable (Region IV) l P.S. Check (Region IV)

! E.H. Johnson (Region IV)

( NRC Resident Inspectors Office B.W. Churchill l W.M. Stevenson I

l l

I l

(_

ATTACHMENT t3 t W3P86-2805 Louisiana Power & Light Company

WATERFORD 3 SALP PROGRESS REPORT L .. .

1 LOUISIANA POWER & LIGHT COMPANY WATERFORD 3 SALP PROGRESS REPORT TABLE OF CONTENTS Page No. Section SALP Performance Functional Area 1 Intrcduction 4 Summary 10 A Preoperational/Startup Testing 12 B Plant Operations 21 C Surveillance 23 D Maintenance 27 E Quality Programs and Administrative Controls Affecting Quality 31 F Fire Protection 33 G Radiological Controls EXHIBIT G - Total Areas Contaminated in Radiation Controlled Areas 36 H Emergency Preparedness 38 I Training and Qualification Effectiveness EXHIBIT I - Skills Training Center 41 J Security and Safeguards 43 K Licensing Activities EXHIBIT K Commitments Management System EXHIBIT K Safety Analysis Report Update System 46 L Outages

-1

P ga 1 of 47 t

LOUISIANA POWER & LIGHT COMPANY WATERTORD 3 SALP PROGRESS REPORT INTRODUCTION The primary characteristics of the 1985 SALP review period for Waterford 3 were change and transition. Waterford 3 had received its low power license in December, 1984 and conducted low power physics tests during the firsc quarter of 1985. With receipt of the full power license in March, power ascension testing occupied the second and third quarters of 1985, including a nummer outage for turbine generator repairs. In late September, 1985 Waterford 3 commenced commercial operation.

Transition from construction and preoperational testing to startup testing and full power operations is a difficult process, at best, but it also presents the opportunity for an organization to mature, identify areas needing improvement, and strengthen areas of satisfactory performance. The 1985 SALP report reflects this process with some functional areas relatively low on the maturation curve exhibiting needed improvement, and other areas demonstrating excellence.

Although the numerical rating of certain functional areas may be subject to some disagreement, the specific problems identified in the 1985 SALP report were largely accurate. Many of the concerns identified by the NRC occupied management attention throughout the rating period and resulted in the implementation of improvement programs prior to receipt of the SALP report.

The SALP report, however, provided an independent viewpoint and a valuable cross-check of operational areas which could be improved, while indicating several areas where increased management attention was warranted.

The 1986 SALP rating period has seen the final transition from construction to operation for Waterford 3. During the time from January to the first refueling outage in late November tha plant operated at an 82.48% capacity factor - excellent performance for c first year of operation. The number of unscheduled plant trips was reduced from 22 in 1985 to 7 in 1986, meeting the goal set by management. The Waterford 3 organization now includes a new Senior Vice President-Nuclear Operations with a strong background in plant operations, as well as a new Vice President-Nuclear to manage site activities. The Nuclear Operations Department was restructured to place additional emphasis on plant operations and provide a permanent staff to increase organizational stability by retaining certain responsibilities previously delegated to contractors. Efforts have been made to improve communications with the NRC at the NRR, Region IV and Resident Inspector levels. Managenent has established and strongly emphasized a practice of increased openness and candor with the NRC.

Strong measures have been taken to decrease personnel errors while emphasizing individual responsibility and accountability. Management is more actively involved with the Waterford 3 staff to improve communications, in general, and work efforts. And, long range planning concepts are being developed consistent with the NRC and industry efforts toward the integrated living schedule concept.

e Pcgr 2 of 47 t

SALP Results The 1985 SALP report noted strength in the areas of Preoperational/Startup Testing, Security and Safeguards, and Surveillance, and improvement in Emergency Preparedness. NRC recognition of excellence in the Startup Testing Program was particularly noteworthy as it validated the extensive management attention to this area which occupied nearly three quarters of the rating period. Management intends to bring the same degree of professionalism to its first refueling outage.

The areas of Quality Programs and Administrative Controls Affecting Quality, and Plant Operations were noted as areas of decreased performance while the Maintenance area was again rated in category 3. The NRC indicated that Maintenance was improving by the end of the rating period.

The rating of 3 for the Operations area was made only after lengthy discussions. Important aspects of plant operations were well accepted by the NRC (e.g. "the performance of licensed personnel during operational events... was very good"). Notwithstanding these mitigative rating factors Waterford 3 management has taken aggressive steps to upgrade performance in these areas.

Initial SALP Response Upon receipt of the 1985 SALP report Waterford 3 management conducted additional in-depth reviews to identify areas of weakness which could benefit from new or strengthened improvement programs. Emphasis was placed upon NRC recommended actions in all functional areas with particular attention to those areas where performance ratings declined or remained at a lov level.

Most of the NRC's recommended actions had been identified and implemented well before publication of the SALP report. For instance, an aggressive trip reduction program was showing marked improvements in the frequency of feedwater/ condensate related trips by the time of commercial operation.

Existing improvement programs were reviewed against the specific concerns of the SALP report to either confirm the adequacy of the corrective actions or implement additional corrective actions to ensure that the concern did not recur. For the few areas not already covered by Waterford 3 improvement programs, management directed the implementation of new corrective actions to resolve the concern.

The management review of SALP culminated in the set of responses submitted to the NRC on May 1, 1986 (W3P86-0066). This initial SALP response demonstrated significant progress in key areas such as trip reduction, maintenance activities, staffing retention, etc. In some cases, however, corrective actions were in progress or awaiting implementation and, therefore, final conclusions as to effectiveness could not be made.

Current Status Pecently, the Nuclear Operations Department has been reorganized and additional permanent staff approved. In general, the new organization places plant operations, design engineering and construction under a site director, expands the role of training, consolidates similar functions, and

Pagn 3 of 47 t

places increased emphasis on important functions such as event analysis, trending, industrial safety and fire protection. Furthermore, the new organization provides for a dedicated Safety Review Committee (SRC) support 9taff to ensure that the functions of the SRC receive an~ appropriate level

, of attention.

At this time, the majority of actions necessary to address the 1985 SALP report are complete, with the exception of certain physical modifications that, by. necessity, can only be implemented during the first refueling outage.

The purpose of this progress report is to update the status of SALP related actions since the initial SALP response of May 1, 1986. In addition various activities have been initiated which have a direct bearing on a particular SALP functional area but were not identified at the time of the initial SALP response.

In the following pages each SALP functional area is discussed at length.

The May 1, 1986 response is summarized in an effort to provide a complete picture of our activities during 1986, however, the initial response i

contains a great deal of detail which should be referred to as necessary when reviewing the present report. The current status of each functional area is then reviewed including any relevant information for that functional area.

t 1

Pcg2 4 cf 47 LOUISIANA POWER & LIGHT COMPANY WATERFORD 3 SALP PROGRESS REPORT

SUMMARY

The primary characteristics of the 1986 SALP review period are progress and improvement. The strong plant capacity factor is an indication of fundamental change and improvement in operational, quality and support areas over that demonstrated during the 1985 SALP period. Each SALP functional area has shown improvement during 1986 - in some cases the demonstrated improvement is exceptional.

In the NRC's July 21, 1986 response to our May 1, 1986 initial SALP report Waterford 3 was requested to place emphasis on certain of the NRC's SALP recommendations:

Trip Reduction - Continued management attention has resulted in a sharp reduction in reactor trip frequency from 22 in 1985 to 7 in 1986. All but one of the 1986 trips would likely not have occurred with the Core Protection Calculator improvements to be implemented for Cycle 2.

Reactor Auxiliary Building (RAB) Airborne Radioactivity - Significant Waterford 3 resources and management attention have been devoted to the reduction of RAB activity. Over 100 valve leaks were repaired with further work scheduled during the refueling outage. Marked airborne reduction was achieved as a result of work done during the March, 1986 planned outage. RAB airborne activity continues to be increasingly localized with only two chronic activity areas remaining.

Both of these areas are being addressed during the refueling outage.

Station Information Management System (SIMS) - Good progress has been made on the implementation of SIMS to the point where various SIMS functions are already being utilized. Full implementation is on schedule for completion in 1987.

Mechanical Equipment EQ Requirements - The extraction of mechanical equipment qualification maintenance requirements from qualification documents and vendor technical manuals is complete. Incorporation of this information into maintenance procedures and practices has progressed well.

Significant improvements by SALP functional area are summarized below. The improvements summarized here are not all-inclusive. Additional improvements and detailed discussion are included in the individual sections for each functional area.

A. Preoperational/Startup Testing The first refueling outage testing is pinnned and coordinated with the same attention to detail as characterized the initial startup testing.

B. Plant Operations The management goal of a maximum of seven reactor trips was met during 1986. Of the seven trips, six were related to the Core Protection L

P ga 5 cf 47 s

Calculators and would likely not have occurred with the improvements scheduled for Cycle 2.

The LER process has been upgraded to include more detail and a specific root cause analysis. The reorganization includes a dedicated Event Analysis and Reporting Group to promote further work in this important area.

No licensed personnel resignations or departures occurred in 1986.

An Operations Advisory Group was created to advise management on the need and methodology for operational enhancements and changes. The Group's results are considered so successful that manogement intends to implement Maintenance and Technical Services Advisory Groups in the near future.

Significant progress has been made in reducing the number of invalid control room annunciations.

Airborne radioactivity in the Reactor Auxiliary Building has been reduced and limited to localized areas.

Following implementation of corrective actions, Health Physics personnel have observed a significant reduction in short-lived gaseous contaminations.

The Broad Range Toxic Gas Detection System is installed and data is being gathered to determine an optimum setpoint.

C. Surveillance The equipment out of service log has been effectively combined with a tracking mechanism for Technical Specification action statements.

The Operations and Chemistry Groups now utilize a mode change checklist to ensure non-routine surveillances are identified and performed. Since implementation of the checklists neither Operations nor Chemistry have missed a mode change surveillance.

D. Maintenance Of the plant trips experienced in 1986, none had as their root cause either inadequate maintenance practices or maintenance personnel error.

A functional Maintenance Lead Planner position was created and the number of permanent maintenance engineer positions was increased to six, all of which are now filled.

Spare parts procurement has been strengthened procedurally and through increased engineering input to the procurement process. Design specifications are maintained as controlled documents and updated during the station modification as-building process.

Implementation of the Station Information Management System (SIMS) is on schedule for completion in 1987. Several SIMS features are already

9 i

Prg2 6 cf 47 available for use including the component data base and access to the Commitment Management System.

Additional space has been provided to support timely calibration of contaminated equipment.

Programmatic controls for maintenance of equipment qualification have been upgraded. The extraction of electrical qualification maintenance requirements from qualification documents and vendor technical manuals has been completed and the extraction of similar information for mechanical equipment is underway.

E. Quality Programs and Administrative Controls Affecting Quality Procurement control has been strengthened through new procurement and procurement document procedures, and issuance of a specification for standard quality requirements. The reorganization provides for a dedicated Procurement Engineering Group.

Quality Assurance (QA) involvement in plant operations continued through standard audit activity and procedural and station modificaq, ion review. QA regularly attended NRC exit meetings and supported other plant operations as needed.

The Quality Control functions previously reporting to the Plant Manager have been transferred to the Quality Assurance Department under the new organization in order to provide a single integrated approach to quality for Watecford 3.

The annual management audit has confirmed the effective implementation of the Waterford 3 Quality Assurance Program.

Due to increased management attention, the number of closed station modification packages increased dramatically in 1986 from 17 to 255 as of late November. Procedural changes were also implemented to streamline the station modification close-out process.

A number of hardware and software deficiencies for the plant monitoring computer have been corrected to increase computer reliability. Technical Specification changes have been approved to reduce the impact of plant computer downtime on plant operations.

F. Fire Protection The Technical Specification surveillance requirements for fire barrier penetration seals have been successfully completed. The results of the surveillances along with walkdowns have demonstrated the integrity of the penetration seals and the adequacy of administrative controls.

Fire protection modifications required by license condition either have been installed, will be installed during the refueling outage, or will be deferred with the prior approval of the NRC.

As part of the Nuclear Operations reorganization a separate Fire Protection and Safety Group has been created. Increased emphasis has

Pcg2 7 of 47 been-placed on industrial safety through implementation, in late 1986, of DuPont's' successful Safety Training Observation Program (STOP) program.

G. Radiological Controls In early 1986 over 100 identified valve leaks were repaired, with a significant effort to be expended in this area during the refueling outage.

A contamination reduction task force was appointed to further address contamination concerns. The task force has completed its assignment and initiated corrective actions as discussed in Section B and G.

A waste gas problem task force was created to investigate sources of airborne activity and reduce releases within the plant, as discussed

-in Section G, below. Upon completion of the refueling outage and necessary. corrective action, the task force will reevaluate waste gas problems.

H. Emergency Preparedness The annual exercise was successfully conducted on October 15, 1986.

NRC findings indicate only one deficiency for which corrective action has been initiated. In addition, 10 drills were conducted during the course of the year. Through our own and outside observation it is our belief that we have steadily improved an already good emergency preparednern program.

Increased emphasis on emergency training continued with numerous special training sessions held for Waterford 3 (e.g. Operations, Health Physics, Dose Assessment) and outside agency personnel.

Waterford 3 continues to work closaly with State and Parish agencies in support of their emergency planning programs which have been rated amongst the best by FEMA.

I. Training and Qualification Effectiveness INPO has found acceptable the self-evaluation reports submitted by LP&L in the 10 areas required for accreditation. Team visits have been completed for 6 of the 10 programs areas. INPO and Waterford 3 share the goal of final accreditation of the first six programs by the end of the first quarter, 1987.

Waterford 3 operators have been enrolled in the University of Maryland's Nuclear Science and Engineering Program leading to a B.S.

degree in Nuclear Science.

Under the recent reorganization the Training Department now reports directly to the Vice President-Nuclear.

Waterford 3 submitted an operator exam question bank to the NRC in November, and factored information from the Region IV training maching into the training program to improve operator training and future exam performance.

Pcg 8 cf 47 a

The new 21,000 square foot Skills Training Center has been opened for maintenance and other personnel training. Over 60,000 square feet is now dedicated specifically for training activities, i

Tha Waterford 3 simulator is presently undergoing factory acceptance testing scheduled for completion in January, 1987. Following acceptance testing the simulator will be shipped to the Waterford 3 Energy Education Center for re-assembly and performance verification testing.

J. Security and Safeguards Waterford 3 continued to apply the same high level of quality in the selection and training of replacement security personnel during 1986.

The security personnel turnover rate of 40.6% in 1985 has been significantly reduced to 20% in 1986.

Effective drug awareness education programs and drug testing have combined to produce less than 3% positive urinalysis findings, well below the national average.

Strong measures have been, and are continuing to be, taken during 1986 to emphasize employee responsibility for security.

Special attention is being given to security during the refueling outage.

K. Licensing Activities Waterford 3 management continued its close involvement in licensing activities through periodic meetings of senior management with NRR, Region IV staff and Resident Inspector personnel. Senior management involvement has been instrumental in the development of good interfaces between the plant staff and licensing groupa.

During 1986, development of the Commitments Management System and the Safety Analysis Report Update System was completed and the systems fully implemented.

Waterford 3 membership in the Region IV Utility Group was formalized to promote enhanced response to Region IV initiatives and maintain cognizance of areas of concern to the Region.

L. Outages The first planned outage for Waterford 3 was conducted in March, 1986.

Preventive and corrective maintenance items, station modifications and surveillance testing were successfully completed ahead of schedule.

Forced outage management has been given a high priority at Waterford

3. We believe that the present approach provides a flexible and

! comprehensive process of work scoping, detailed preparation and l preplanning, and prioritized scheduling.

l l

' Y1, 9ll% .(;g,*.]'

- 4, f' - 4,,

t- . ii Peg 2 9 cf 47

-c -

ny g . ') o y ><

(, 3; t, ,,<l 3, A dedicsted Outage Preparation 11anager was appointed to coordinate activities required to prepare for,and implement the first refueling

', j outage.' Care has been tansn to prepare detailed work scoping and y planning, and in including all Waterford 3 organizations in the

. ' planning process. 4

t'i i ,

,1 -

' , Juring the outage the P1:mt Manager has assumed responsibility for l ,

. outage management.. Briefings of key personnel have taken place to

l. emphasize the importance,of security, radiation protection, quality,

, industrial safety, efficiency and compliance to procedures. . Strong emphasis is being placeOln individual accountability.

1 l Fuel for Cycle 2 has been rec.aived and preparations for fuel load have l

' t commenced.

\

e

, il

• f l-

'.[a k

!  ;~ , N l 4

'[ t l

' . f, i

. \;

se

! i pt1 l '. P e l 'i , 6' t .,'

\\ t s- ,

T-( / ') \

i '

\

i l '

l

'-'., t. ,

o: g

\

_N ( (.

• s,

\ '

I 4 4

• 1 5

'h

(

( ,

I., *

, *[ g s t

\

) , - - 5 ', s

\ '

(

1

(,

a i

t.

i b

k t

I \

( 3

) 6

Pcg2 10 of 47 LOUISIANA-POWER & LIGHT COMPANY WATERFORD 3 SALP PROGRESS REPORT Performance Functional Area 5

& PRE 01ERATIONAL/STARTUP TESTING 1985 SALP Category: 1 1983 SALP Category: 2 Summary of NRC Recommended Licensee Actions Apply the same attention to detail during future facility operation including post-outage testing.

Summary of LP&L May 1, 1986 Initial SALP Response The Waterford 3 staff will continue to apply a high level of attention to detail during future facility operation including post-outage testing.

Current Status The Waterford 3 first refueling outage is implementing a reload core  !

designed for a nominal 18 month Cycle 2. In addition to the core i differences from Cycle 1 various station modifications and maintenance activities will necessitate testing to confirm acceptable component and system performance as well as design calculations.

Waterford 3 intends to duplicate or exceed the successful Cycle 1 startup testing. To that end management has developed a comprehensive post-refueling startup test approach including the following elements:

Reload Physics Testing Station Modification Testing Post Maintenance Testing Other testing associated with outage objectives Physics testing procedures are based on guidelines developed by Combustion Engineering. Management overview of the testing is maintained through Plant Manager and Plant Operating Review Committee approval of testing procedures.

The startup testing approach being implemented is directed at minimizing l the time required to perform low power and power ascension testing while maintaining high standards of test performance and safety. For instance, during the past two years Waterford 3 personnel have been charter participants in a Combustion Engineering Owners Group program to improve power ascension testing. This program, which has been reviewed by the NRC and successfully tested at other Combustion Engineering CPC Plants, will be implemented following the refueling outage.

, , , - _ _ _ _ _ .__ _ _,_ _ _ _ _ ,,. _ . . . . , _ _ _ , ..~ ,____ _ ._.- _ _ -,.

Pcg2 11 of 47 As during the initial startup testing for Waterford 3, vendor technical experts will be retained to review procedures as needed and provide trouble-shooting assistance. As an example, Combustion Engineering personnel will be closely involved in providing assistance and advice during low power and power ascension physics testing, and in evaluating test results during and following test performance.

During the outage operators will receive approximately 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> of training covering station modifications and resultant procedure changes, and plant walkdowns. In addition, because of core changes, Technical Specification changes and station modifications, Waterford 3 management will ensure that sufficient time is allowed during the testing period for operator acclimation. Each of six shifts will spend time prior to and during startup for familiarization with the new core and other changes.

Pcg2 12 of 47 -

LOUISIANA POWER & LIGHT COMPANY WATERFORD 3 SALP PROGRESS REPORT Performance Functional Area B. PLANT OPERATIONS 1985 SALP Category: 3 1983 SALP Category: 2 Summary of NRC Recommended Licensee Actions

1. Institute an aggressive reactor trip reduction program,

2. Reverse the adverse trend related to staffing retention,

3. Support completion of a program to upgrade the Control Room annunciator system,

4. Initiate a program to eliminate the RAB airborne radioactivity problem, and

5. Review the progress being made toward reliable monitoring systems associated with the Control Room Ventilation System.

Summary of LP&L May 1, 1986 Initial SALP Response

1. Trip Reduction The large majority of the reactor trips during the SALP evaluation period occurred prior to Waterford 3 commercial operation (i.e. during the startup testing period). The trip causes can be roughly divided ir.to hardware and human error. For trips caused by hardware related problems one system predominated - the feedwater/ condensate system.

During 1985 and 1986 Waterford 3 management implemented extensive corrective action to reduce the frequency of feedwater/ condensate related trips. Numerous physical modifications (detailed in the May 1, 1986 response) were implemented including, as examples:

a. Overhauling turbine governors,

b. Improving the compatibility between the Feedwater Control System and the Feedwater Pump Turbine Control System,

c. Realignment of feedwater pumps and measures to reduce pump vibration,

d. Changing the time delay on the suction pressure trip for the main feedwater pumps, and

e. Successful testing of the Reactor Power Cutback System for loss of a feedwater pump at high power levels.

P ga 13 of 47 Similarly, management directives and administrative controls were implemented to further reduce feedwater/ condensate related trips. For instance, the condensate polisher operating procedure was revised to reduce the potential for system transients and operator error, and major polisher operations currently require the supervision of the Operations Supervisor.

As a result, by the time of commercial operation the frequency of feedwater/ condensate related trips had been significantly reduced and, as will be discussed below, completely eliminated in 1986.

Various management actions were instituted to address reactor trips due to human error. Amongst other items discussed in the May 1, 1986 response, these actions include: -

a. A Maintenance Department Directive to provide guidance in minimizing ESFAS actuations and plant trips,

b. Revisions of procedures such as the enhancement of OP-10-001 (General Plant Operations) to address manual control o:

steam generator water level at low power, and

c. Creation of an Operations Advisory Group to advise management on the need and methodology for operational enhancements and changes.

As noted below, operator error was not identified as the root cause of any trip during 1986.

In addition to corrective actions directed at the cause of actual plant trips, many initiatives were instituted to form the basis for an integrated trip reduction program. Waterford 3 established a 1986 goal of a maximum of 7 unplanned reactor trips (compared to 22 in 1985). In support of this goal, among other measures:

a. The Operations Superintendent participates in the CE Owners Group Trip Reduction Program,

b. The trip review process including identification of root cause has been upgraded, and

c. Studies were implemented to eliminate or reduce trips due to key contributors such as dropped CEAs, high ASI trips at low power levels and high steam generator level trips.

2. Staffing Retention Management authorized five additional temporary operator positions to form a reserve of Operations personnel. In order to retain existing operators an incentive pay and license bonus program was established, operator pay scales are frequently reviewed and an Operations Advisory Group was established to provide operators with a vehicle to make recommendations to plant management.

Pag 2 14 of 47

3. Annunciator System Upgrade By March, 1986 a total of 186 annunciators had been identified as problems. At the end of the March, 1986 outage 138 of the 186 had been cleared.

4. Elimination of RAB Airborne Radioactivity A management task force was established to identify and initiate actions to eliminate sources of airborne activity in the plant and reduce releases to the environment. Increased management attention resulted in the localization of airborne activity to primarily five areas:

a. A pipe chase under the charging pumps in the RAB,

b. The charging pump rooms,

c. The boric acid makeup tank rooms (primarily room A),

d. The volume control tank room and a peripneral passageway, and

e. The flash tank room.

Corrective actions were begun to reduce activity in these areas.

Although records are not generated to track the number of short-lived gaseous contaminations, Health Physics personnel have observed a significant reduction in such contaminations in the months immediately following corrective action implementation.

5. Review of Toxic Chemical Detection Systems Vigorous management, engineering and maintenance attention continued in order to identify more reliable toxic chemical detection systems and enhance the operability and reliability of the existing design.

Current Status In the area of plant operations, Waterford 3 management shared similar concerns to those identified in the 1985 SALP report. In fact, the corrective actions described in the May 1, 1986 response were largely initiated prior to receipt of the SALP report and were beginning to show marked improvements at that time, particularly in the area of trip reduction.

Many of the corrective actions are now complete and, in some cases, additional programs have been implemented to address changing circumstances. LP&L is justifiably proud of the progress made in a relatively short period of time and the initiative demonstrated at all levels of the Operations organization in identifying and resolving problems during the initial plant startup and the first cycle of operation.

m

PIga 15 cf 47

1. Trip Reduction The trip reduction effort continues to demonstrate significant improvement in total trip reduction consistent with the 1986 goal of a maximum of 7 automatic reactor trips. The plant has experienced a total of 7 reactor trips in 1986 compared to 22 trips in the previous SALP rating period.

At the SALP meeting on April 1, 1986, it was pointed out that only two reactor trips were experienced in the first quarter of 1986, and each of these was associated with hardware failures which caused a single Control Element Assembly (CEA) drop. Two additional reactor trips occurred for a total of four trips through August. The latter trips were associated with single failures of CEA position indication resulting in the application of high Core Protection Calculator (CPC) penalty factors leading to reactor trips. One trip occurred in September due to a Turbine Trip caused by Hi-Hi level in a moisture separator reheater (MSR) drain tank. Two trips occurred in October, one due to a single CEA drop and the other due to Axial Shape Index (ASI) during startup from the previous CEA drop trip. Operator error was not identified as the root cause for these trips.

The Control Element Assembly-related trip reduction measures discussed in the initial response to the 1985 SALP Report are still accurate.

However, in addition to hardware improvements Waterford 3 has participated in, and chaired, an extensive cooperative effort with other CPC plants to implement a CPC Improvement Program. The CPC Improvement Program has the dual purpose of reducing the need for future CPC software changes, and incorporation of algorithm and other changes to reduce the potential for unnecessary CPC-induced plant trips. One portion of the program addressed CEA desensitization to allow single CEA drops or position indication failures to be accommodated by the software so as not to result in a plant trip.

Another portion of the program provided acceptable results when raising application of the calculated axial shape from about 7% power to 17%. Had the CPC Improvement Program been in place during Cycle 1 all reactor trips during 1986 (except the September reactor trip on turbine trip) would likely have been avoided. Waterferd 3 has provided, and NRR has reviewed and approved, information concerning the CPC Improvement Program sufficient to allow implementation for Cycle 2.

The Combustion Engineering Owners Group Operations Subcommittee continues in its efforts to review the root cause determination processes employed at other Combustion Engineering plants. When the results are published (scheduled for December, 1986), Waterford 3 will review the results and consider incorporation of the good attributes into its procedures.

The CEOG Scram Reduction Program, also administered by the Operations Subcommittee, has continued its quarterly sharing of plant-specific trip information and analysis of generically applicable corrective actions. In addition to standard generic trip reduction activities the CEOG recently completed a study to relax reactor protection system and engineered safety features actuation systems (RPS/ESFAS) surveillance test intervals in order to reduce potential spurious

"] 5

.- P2ga 16 of 47-ae

'O trips induced by surveillance. testing. Waterford 3 intends to implement'the RFS/ESPAS testing improvements on a schedule consistent with the NRC's Technical Specification Improvement Program guidelines.

- The items listed in the May 1, 1986 SALP response as corrective action to prevent reactor trips associated with the feed and condensate systems are still accurate. .The steam generator feedwater pump.

electronic governors are scheduled for installation during.the refueling outage. In addition, Station'ModificationL1450 is.being *

' implemented to increase the pilot valve size of the. Steam Bypass Control Valves to improve operational reliability, thereby eliminating the necessity to stroke.these on a frequent basis.

, . 1 In order to reduce the' potential-for unnecessary trips at low power levels when steam generator level control is in manual, a bypass to the high steam generator level (non-safety related) trip will be.

implemented during the refueling outage. A Technical Specification change to allow trip bypass below 20% power has been submitted to NRR and published in the Federal Register. It is expected that the approved Technical Specification change will be available for startup following the refueling outage.

At the beginning of 1986 a loss of the plant computer required a reduction in power to accommodate Technical Specification requirements when the Core Operating Limit Supervisory System (COLSS) was unavailable. While not a plant trip, the loss of COLSS did require unnecessary plant transients _(i.e. power reductions). Waterford 3 commissioned Combustion Engineering to conduct analyses needed to revise the COLSS-out-of-service Technical Specification. Following NRC review the Technical Specification change was approved resulting in less severe power reduction requirements when COLSS is out of service.

Enhancements have been made to the Plant Potential Reportable Event (PRE) system to provide a better mechanism for performing root cause analyses of plant trips and transients. Licensee Event Report (LER).

generation techniques have been revised to include more detail and a specific root cause analysis. This has been accomplished by:

a. Incorporating a Technical Review Process specifically directed toward root cause analysis.

b. Reviewing the LER process with plant management with respect to root cause considerations,

c. Increased Plant Staff emphasis by the Plant Manager to stress responsibilities for completing PRES.

As further support for the enhancements to the LER process, Waterford 3 management recently created the Event Analysis and Reporting group to report directly to the Assistant Plant Manager for Technical Services, to promote further work in this important area.

6 l -

. - , , . - , - ,...~,r.~,. ,, ,.__..--,,,-.--_,--m----_,,.y ,,-.,_.,,m.__, , , , - , , _ , ,,c -.._,.,~,m

- , ,.,,-.m_-, - , . - , ,

,- Pags 17 of 47

2. Operations Staffing The programs and incentives for staffing retention discussed in the initial SALP response have been quite effective. Waterford 3.has had no resignations or departures of licensed personnel in 1986. -Vacant positions in the staffing of Shift Technical Advisors have been filled with qualified Plant Staff personnel. These personnel have brought experience from other plant groups including Reactor and Performance Engineering and the Health Physics organization.

3. Control Room Annunciator System Since the March, 1986 outage additional problem annunciators have been identified and corrected. As of November 25, 1986 a total of 57 annunciators problems remained to be resolved, the large majority of which are in various stages of being worked:

32 - working under station modifications 21 - working under CIWAs 2 - cards pulled - operators not using flowpath 2 - alarming radiation monitors Although the number of Control Room Annunciators in alarm has been reduced to an acceptable level, aggressive efforts continue to eliminate nonessential and invalid alarms. Waterford 3 management is routinely informed of the progress in this important effort.

4. Airborne Radioactivity Problems The corrective actions discussed in the 1985 initial SALP response have been fruitful. Significant progress has been achieved in identification of leakage sources and in reducing the Reactor Auxiliary Building (RAB) airborne radioactivity and associated short-lived gaseous personnel contaminations. Specific examples of this progress involve:

a. Airborne radioactivity areas within the RAB have continued to become more localized almost to the point of being completely eliminated. Specific creas of improvement include:

(1) Charging Pumps Pipe Chase - The addition of a temporary ventilation unit in this area has demonstrated that this problem can be minimized. A station modification request has been initiated to provide permanent ventilation to this area.

(2) Charging Pump Rooms - What had become a gas problem has been vastly improved with the repacking of the charging pumps on a preventive maintenance schedule that should minimize leakage. In addition, a station modification has been identified to improve the ventilation of the pump stuffing boxes.

Paga'18 of'47 (3) Boric Acid Makeup. Tank (BAMT) Rooms.- These rooms had been

- _ experiencing.relatively high' gas concentrations solely because of the: physical interfaces with the Charging Pump Rooms and Pipe Chase'via a pipe trench. With the improvement; experienced in the Charging Pump Fooms and Pipe JChase, the high airborne activity in the BAMT Rooms has, for:

all~ practical purposes, been eliminated.

2 (4) The Volume Control Tank (VCT) Room'and a peripheral passageway - Nitrogen and hydrogen inlet valves to the VCT were found'to be leaking gas from the VCT. gas space through the valve packing. - Adjustment of the packing eliminated these leaks.

(5) The Flash Tank Room - We believe that the Flash Tank Room i gas problem resulted from the same source as the VCT problem -

above. The frequency of airborne gas in the Flash Tank Room was greatly reduced after the VCT valves were adjusted.

b. . Valves within the Gaseous Waste Management System have experienced seat leakage problems because of corrosion products in the system. Eighteen (18) new valves are on order to be installed as replacements for the existing valves during the first. refueling outage (contingent upon timely delivery of the

, valves).

c. Presently, there appears to be only two chronic localized J

airborne activity areas. These are:

(1) The Letdown Heat Exchanger Room and nearby areas - Valve CVC-115, Letdown Header Relief Valve, has been a periodic problem. This valve (which is located above the heat exchanger) has been found to leak externally. Since the valve cannot be isolated, it has been contained as best possible. However, leakage past the containment still causes localized problems. The valve is scheduled to be reworked, and new trim installed, during the first refueling outage.

(2) Gas Decay Tank Room A - Gas from the Gas Decay Tanks had been slowly leaking past an isolation valve and a clean-out plug on the sample line condensate drain. The plug has been tightened and the clean-out bagged, however minor leakage continued on an intermittent basis. An additional isolation i

valve was then installed which appears to have eliminated the. problem.

5. Chemical Detection Systems Various op9 rational problems have been associated with the chlorine and Broad Range Toxic Gas Detector (BRTGD) systems resulting in numerous spurious actuations of the control room ventilation system.

Consequently, Waterford 3 has pursued various options in an attempt to resolve toxic chemical system operational concerns. Significant management and engineering resources have been assigned to the 3

- , . ~, y -

,,n , ,, ,,,.,--.m,, y y , , , , , _ , - - . , ,_m ,,,e , . , , , , ,,,-_,.,,,_,.,v.. .,...,,_.,_,,-,,,,-n.--- , . . - , e ,

Pega 19 of 47 resolution of this state-of-theJart problem. The folicwing is a description of the Waterford 3 integrated resolution:

Broad Range Toxic Cas Detection System The originally installed BRTCD system, procured from Process Analyzers, Inc., required excessive maintenance to start up and never operated reliably. Waterford 3 therefore initiated the procurement of a replacement system from HNU Systems, Inc., a reputable and well-established manufacturer of photofonization gas detectors and analyzers. The unit that most closely met the requirements for detecting the potentially hazardous gases in the Waterford 3 vicinity was the HNU Model 201, equipped with an ultra-violet lamp having a nominal energy of 11.7 eV. This system was placed in service to gain operational experience and data on June 28, 1985, and Waterford 3 so informed the Commission.

After a period of operation, the calibration of the Model 201 detectors was observed to drift appreciably, requiring frequent recalibration which precluded the collection of consistent, reliable background data. The problem was traced to the 11.7 eV lamps, which were not standard components of this system. HNU informed Waterford 3 that they were aware of problems with some of these lamps and that they were redesigning them. Following HNU's recommendation, Waterford 3 decided to re-equip the detectors with standard 10.2 eV lamps as an interim measure. After the detectors were proved to operate reliably with the standard lamps, Waterford 3 obtained new, modified 11.7 eV lamps from HNU. These new lamps were installed and tested in August, 1986, and are operating apparently better than the standard 10.2 eV units which they replaced.

The critical aspect of a reliable BRTGD System is the establishment of an optimum setpoint. Because of their broad range and varying sensitivities to different gases, determining an appropriate alarm setpoint for the PIDs is not simple and straightforward as it is for the ammonia and chlorine detectors. Since the normal chemical background will fluctuate excessively and the detectors respond differently to various gas mixtures, an optimum setpoint cannot be precalculated without extensive operating experience. Accordingly, Waterford will propose a technical specification and an operating period which should result in the establishment of an optimum setpoint and thus maximum operator protection and minimum spurious actuations.

The HNU Model 201 PIDs are currently operating and monitoring the ambient background. By startup after the refueling outage sufficient information should be available to establish a preliminary setpoint for the alarm. Waterford 3 will need to acquire about six months of further operation with the preliminary setpoint before establishing a fixed value for the setpoint. The setpoint for the control room alarm and isolation signals will be based on the lowest achievable IDLH concentration of detectable toxic gases providing reliable operation.

The specific setpoint value will be controlled administratively. The administrative control of the setpoint value will be advantageous in

I P;ga 20 of 47 that such administrative control will allow Waterford 3 to change the setpoint value, without instituting a change to the technical specification, to account for changes in the area chemical production or system enhancements, provided of course a 10CFR50.59 evaluation is performed in accordance with Waterford 3 procedures. A new technical specification will shortly be submitted to the NRC reflecting the stated resolut-lon.

Chlorine Detection System The chlorine detection system originally installed at Waterford 3 was supplied by Capital Controls Company, Advance Chlorine Leak Detector, Sensor 1030. ' Unreliable operation of the chlorine detectors resulted in frequent and prolonged operation of the control room ventilation system in the recirculation mode per Technical Specifications 3.3.3.7.1. The root cause prob 1cm was determined to be inherent in the design of the Capital Control detectors. Waterford 3 conducted an extensive engineering evaluation in order to identify a reliable replacement system. A replacement system manufactured by Sensidyne has been chosen, and a station modification for the installation of the new system has recently been approved. The new chlorine detection instrumentation will perform the same control and indicating functions as the Capital Control system. The isolation time of the Sensidyne detectors will be essentially the same. The performance of the new detectors will thus meet the existing safety requirements.

Since the new system utilizes different principles of operation, Waterford 3 will propose to the NRC in the near term a revision to techn,1 cal specification 3.3.3.7.1 in order to reflect the

-manufacturer's calibration recommendations.

Ammonia Detection System The Ammonia Detection System has functioned reliably and no changes are presently planned.

6. Demineralized Water Storage Tank To enhance plant reliability Waterford 3 will place on-line for Cycle 2 a 500,000 gallon demineralized water storage tank (DWST). The DWST will provide pure demineralized water to primary and secondary systems as needed, thus removing this function from the condensate storage tank which was susceptible to ammonia and hydrazine contamination.

' Pag 221 of.47 m

LOUISIANA' POWER-& LIGHT COMPANY WATERFORD 3 SALP PROGRESS REPORT Performance Functional Area C. SURVEILLANCE 1985 SALP Category: -2 1983 SALP Category: Not Assessed

. Summary of NRC Recommended Licensee Actions

1. Continue improvements in the area of communications between different disciplines,-and

2. Develop an integrated and more descriptive action statement tracking system.

W Summary *of LP&L May 1, 1986 Initial SALP Response The pending procedure revision for the equipment out of service system coupled with existing interface requirements specified in corrective

. maintenance and surveillance control procedures will improve overall

' inter-discipline communications. The procedure revision will also address <

the SALP recommendation to ensure an effective action statement tracking system is employed.

To improve the control of non-routine activities such as surveillances required by Technical Specification action statements .a mode change checklist will be employed in addition to the Maintenance Planning and 1 Scheduling System by those departments conducting such surveillances (primarily Operations and Chemistry).

Current Status I'

The equipment out of service procedure has been revised to provide a more effective tool for establishing retest requirements and to ensure that ,

testing is complete prior to declaring the equipment or system operable.

, This measure effectively combines the equipment out of service log with a tracking mechanism for Technical Specification action statements.

i

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

! changing plant modes, Waterford 3 uses a surveillance tracking system combined with normal operating procedures to ensure that such surveillances are performed. This approach is also integrated with planning and i 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, a computer-based system utilized by most plant departments.

i However, in applicable cases a mode change checklist is used in addition to

?

4

- . -,-v - - , ,,,ean va- n,c ..e.,----.+-- - - , - . . . - - - n~-r-- ,, n--nn,n-na. --, .---. -, w-.

Page 22 of 47 the mechanisms discussed above. The Operations Department implemented this technique prior to 1986. The Chemistry Department adopted the use of a mode change checklist in 1986 because of the nature of their surveillance responsibilities and to improve the level of Technical Specification compliance.

Management involvement in the surveillance area has had positive results.

During 1986 no deviations have been identified for surveillance requirements to restore equipment to an operable status, or for non-routine surveillances associated with mode changes and recovery from LCO action statements.

i

= ,. , , - , , - , - - .----., _m -,_m - , ___,,,. , , ..-.p- .,,v- .-, , ,

_, [ _

LPaga 23 of 47

-LOUISIANA POWER & LIGHT COMPANY

.WATERFORD 3 SALP PROGRESS REPORT <

v Performance Functional Area "D. ' MAINTENANCE.

1985 SALP Category: 3 1983 SALP Category: 3 Summary'of NRC Recommended Licensee Actions

1. Improve the interface with outside organizations to ensure:

an . spare parts are properly procured,

b. vendor information is properly incorporated in procedures,

c. architect engineer information is used when making plant changes,

2. Upgrade the M&TE program to provide timely calibration of-potentially r contaminated equipment, and

3. Ensure effective programmatic guidance is in place for maintenance of equipment environmental qualification.

S*ummary of LP&L May 1, 1986 Initial SALP Response Waterford 3 management attention in the maintenance area was not restricted

!' to the bmC recommendations. Fundamental changes were implemented to provide the Maintenance' Department with the management and administrative tools, and experienced personnel, necessary to build a strong organization.

Some of the significant changes discussed in the May 1, 1986 response

include

a. Creating a functional Maintenance Lead Planner position and increasing to six the member of permanent maintenance engineer positions,

b. Continuing development of an integrated computer database (Station Information Management System) for the identification, planning and tracking of maintenance work items, and

c. Issuance of improved plant procedures on preventive maintenance, corrective maintenance, temporary alterations and processing of replacement parts and materials.

The initial response to the NRC recommended actions is discussed below. ,

4 I'

i

Prg2 24 of 47 I

1

1. Improve Spare Part Procurement and Use of Vendor Information Spare part procurement has been strengthened through procedures which require engineering input where the technical / quality requirements of an original item are not specifically defined in its specification.

In addition, an engineering evaluation is necessary for changes or exceptions to the technical requirements of procurement of commercial grade components for use in safety-related applications.

The Vendor Technical Information Program has been revised to better coordinate and enhance the review of vendor information. This revision will help ensure that the latest information on vendor spare parts is included in appropriate documents.

The Material Requirements and Control Department was issued controlled copies of the Architect Engineer's design specifications, to be used for the procurement of spare / replacement parts. In addition, controlled copies of the Q-List, EEQ-List and MEQ-List were issued for accurate determination of quality cJassification and requirements for spare / replacement part procurement.

In the design change process, specifications are treated as design documents and updated during the as-building phase. This process should ensure that specifications are maintained as-built.

2. Upgrade of M&TE Program Timely contaminated equipment calibration is accomplished by:

a. Calibration in the permanent radiation controlled area (RCA) by transporting calibration equipment into the RCA, or

b. Equipment decontamination and removal from the RCA for calibration, or

c. Transfer of the equipment (under special radiation controls) to a calibration facility designated to handle contaminated equipment, or

d. Calibration of the equipment on site under temporary radiation controls (and, possibly, establishment of an RCA).

3. Programmatic Controls for Maintenance of Equipment EQ Administrative procedures inccrporate effective guidance to delineate engineering and maintenance responsibilities for maintenance of equipment qualification. Electrical qualification maintenance requirements were extracted from qualification documents and vendor technical manuals under an extensive program to incorporate such information in maintenance procedures and practices. Extraction of similar information for mechanical equipment is underway.

Paga 25 of 47 0

Current Status Waterford 3 management is committed to excellence in the area of maintenance. The low SALP rating for 1985 was disappointing because the fundamental restructuring of Maintenance activities had occupied management attention for some time and was beginning to show positive results. The recognition by the NRC that " performance appeared to be improving in the maintenance area" at the end of the rating period was encouraging and validated the extensive management efforts toward improvement.

The following discussions update various areas of the May 1, 1986 response.

Additional improvement initiatives are also reviewed. However, one aspect of the overall Maintenance Department performance improvement is not obvious from the individual improvement programs. Waterford 3 management is particularly pleased that of the plant trips experienced in 1986, none had as their root cause inadequate maintenance practices or maintenance personnel error.

1. Station Information Management System (SIMS)

The implementation of the Station Information Management System (SIMS) is on track for completion in 1987. This system will integrate equipment information, quality requirements, maintenance history, repetitive task / corrective maintenance tracking, NPRDS tracking, etc.

into one comprehensive data base to be used for the identification, planning and tracking of maintenance work items. Revision 5 to UNT-5-002, Condition Identification and Work Authorization partially implemented the maintenance work flow which will exist under SIMS.

The work flow and procedure are more logical and have enhanced the quality of maintenance work packages and historical documentation.

Minor modifications to UNT-5-002 are ongoing as the work flow process is refined.

Several features of SIMS are presently available for use:

The component data base is complete and on line. The data base completely describes each component including applicable drawings, locations, applicable technical manuals, EQ status and quality class NPRDS reportable components are identified SIMS provides access to the Commitments Management System (see Exhibit K-1) which tracks all plant commitments

2. Maintenance Staffing The six authorized maintenance engineer positions have been filled.

The maintenance engineers have contributed to improved routine daily maintenance; upgraded maintenance programs; and enhanced outage maintenance planning.

3. Maintenance Self Assessment In May, 1986 a Maintenance Self Assessment was performed by a six member team of Middle South Services and associated Middle South

P ga 26 of 47 Utilities company employees. The one week assessment was performed using INPO Guideline 85-038, " Guidelines for the Conduct of Maintenance at Nuclear Power Stations". Nine functional areas were evaluated ranging from Organization and Administration to Control and Calibration of Measuring and Test Equipment. The maintenance program was evaluated as meeting or exceeding the INPO recommendations.

Several recommendations were made and implemented to improve specific areas such as providing an I&C technical expert to the Training Department to assist in course development, strengthening of the predictive maintenance and failure and trend analysis programs, and .

revision of the CIWA procedure to make retest requirements more visible.

4. Management Assessment In May, 1986, an informal weekly plant inspection tour by plant management was instituted. The inspection team normally includes the Assistant Plant Manager-Operations and Maintenance, the Maintenance Superintendent, the Operations Superintendent and the Technical Support Superintendent. The results of each weekly inspection are reviewed and action items are assigned as needed. Items are then tracked until corrective action is completed. The inspection provides management the opportunity to assess the effectiveness of the maintenance program in order to identify problems at an early stage and to assess the overall housekeeping and material condition of the plant.

5. Spare Parts Procurement The improvements concerning spare parts procurement and vendor interfaces as addressed in the initial response to the 1985 SALP Report continue to be successfully implemented. A Waterford 3 QA audit of the entire procurement process found improvements in the program.

6. Measuring and Test Equipment Additional Metrology Laboratory space has been acquired which allows dedication of a portion of the previous metrology facilities for the calibration of contaminated or potentially contaminated Measuring and Test Equipment (M&TE). This equipment is now being routinely calibrated in the new facility or in the hot machine shop. Procedural changes have also been made which significantly strengthen the control and accountability of M&TE and better define the corrective action process when M&TE is found to be out of calibration.

7. EQ Maintenance Waterford 3 continues to implement its equipment qualifications and maintenance procedures. Maintenance tasks, design reviews and equipment walkdowns are performed as required to maintain equipment qualification in accordance with qualification documents. The extraction of mechanical qualification maintenance requirements from qualification documents and vendor technical manuals is current.

Incorporation of this information into maintenance procedures and practices is continuing.

e Page 27 of 47:

LOUISIANA POWER & LIGHT COMPANY-WATERFORD 3 SALP PROGRESS REPORT

! Performance Functional Area E. QUALITY PROGRAMS AND ADMINISTRATIVE CONTROLS AFFECTING QUALITY 1985 SALP Category: 2 1983 SALP Category: 1 Summary of NRC Recommended Licensee Actions

1. Timely resolution of concerns regarding procurement control,

2. Involve the -QA organization and other independent groups in problem areas,

3. Eliminate the Station Modification Package (SMP) backlog, and

4. Bring in the necessary resources from LP&L and MSU to help resolve plant computer problems.

Summary of LP&L May 1, 1986 Initial SALP Response

1. Procurement Control LP&L significantly strengthened its procurement process through issuance of a Nuclear Operations-wide procurement procedure, issuance of a specification for standard quality requirements and publication of a procedure for procurement document processing.

2. QA Involvement Waterford 3 management continued to utilize QA to review special areas of concern, in addition to the required auditing activity. QA was actively involved in areas as diverse as validating responses to NRC inspection findings, undergoing systems training, and support of Operations in the area of procedures. QA attended NRC exit meetings including the majority of meetings during the previous SALP evaluation period.

3. Station Modifications Significant progress has been made in closing Station Modification Packages (SMPs). Procedure changes were implemented to decentralize SMP closure in order to streamline the process.

Pig 2 28 of 47 0

4. Plant Monitoring Computer A number of computer system problems were corrected to reduce system failures, upgrade the manner in which the system actuates the annunciators, and decrease the failed system restart time by 50%.

The Computer Engineering Department has been supplemented by MSU, LP&L and contract personnel as needed to implement plant computer reliability improvements.

Current Status Although a SALP rating of 2 indicates acceptable performance, LP&L management was concerned with the decrease from Category 1. Increased management attention has resulted in an upgrading of those items considered by the NRC in the area of quality programs and administrative controls.

1. Procurement Control In addition to strengthening the procurement control process the Nuclear Operations reorganization provides for increased engineering input to procurement through creation of a new Procurement Engineering Group under the Nuclear Operations Engineering Manager.

2. Quality Assurance (QA) and ISEG Involvement The Quality Assurance organization continues to be involved in potential problem areas and normal plant activities such as the Plan of the Day meeting. Recognizing the importance of close QA involvement in the day-to-day quality activities of Waterford 3 as well as the need for preserving quality independence, management dire.:ted the consolidation of the QA and Plant Quality Control groups during the recent reorganization. The QA/QC combination is expected to strengthen both functions resulting in an integrated approach to quality on a daily and long-range basis.

The following tabulation of QA support activities through October, 1986 reflects additional involvement of the QA organization in Waterford 3 activities:

Audit (Regular) 33 Activity Audits 36 Unscheduled Audits 3 Procedures Reviewed 242 Station Modification Packages Reviewed 105 The recent Nuclear Operations reorganization has resulted in ISEG reporting to the Nuclear Operations Support and Assessments Manager who, in turn, reports directly to the Vice President Nuclear. Waterford 3 management is confident that the organization change will result in increased ISEG involvement in plant activities.

m P ga 29 cf 47 o

3. Station Modifications A concentrated effort to close out Station Modifications is on-going.

As of November 28, 1986 a total of 1778 SMs had been assigned with the following distribution:

395 Pending MP approval 218 Pending Work Center completion 536 Work completed; pending closure 374 Voided or pending void 255 Closed to Project Files As a point of comparison, the 1985 SALP report indicated that only 17 SMs were closed to Project Files.

Ch.anges to the three Station Modification-related procedures have been approved to decentralize closeout responsibility and to require Action Engineer review /signoff and control room redline updates prior to declaring the system / component operable. This helps to prevent premature opcration of equipment affected by each modification. The procedure revisions included a feature for partial closure of Station Modifications to facilitate restoration of critical components and equipment, while maintaining control over the closure process.

The procedure revisions also include provisions for a Station Modification Work Status Logbook in the control room. The Station Modification Work Status Log contains a current status of Station Modifications in the field as well as documentation of work completion and operations notification / acknowledgement for each modification.

This change provides current and readily available status information to the control room to prevent premature equipment operation. In addition, the procedures have been strengthened to ensure that control room drawings are as-built. Before new drawings are provided to the control room an additional engineering review is performed to verify accuracy.

The latest revisions to the Station Modification-related procedures as well as a more concerted effort between the Engineering, Construction and Maintenance Organizations to coordinate Station Modifications have and will yield more timely and improved closeouts. (The Nuclear Operations reorganization will enhance coordination of the Station Modification process by providing a more centralized group for initiating SMs.) As an example of enhanced coordination, pre-implementation meetings chaired by the Action Engineer were held for refueling outage station modifications. Through these meetings, affected organizations were briefed; responsibilities were identified; questions were answered; and schedules were finalized. This process was successful in eliminating interface problems and providing for smooth and timely implementation. Similar approaches will also be utilized for future non-outage related station modifications.

Forty-seven Station Modifications at a total cost of over $13M are planned for the first refueling outage.

)

Paga 30 of 47

4. Plant Monitoring Computer The Plant Computer Engineering procedure has been rewritten to provide more stringent controls for the Plant Monitoring Computer software.

These include:

a. All software revisions are reviewed for 10CFR50.59 applicability,

b. PORC reviews all software revisions for which 10CFR50.59 is applicable, and

c. A step-by-step method of reviewing, approving, implementing, testing and documentation of software changes is provided.

Several new station modifications have been initiated and scheduled to improve the overall reliability of the Plant Monitoring Computer.

Typical improvements that should result from these station

, modifications include:

1. Improved computer communication rates

2. -Enhanced computer memory reliability

3. Improved CRT resolution In order to provide more centralized control of the plant computer, the recent Nuclear Operations reorganization has transferred four dedicated computer maintenance personnel from the Maintenance Organization to the Computer Group.

Uaterford 3 continues to utilize a dedicated force of computer talent to maintain and enhance the reliability and performance of the Plant Monitoring Computer. This includes plant staff, Middle South Services, Inc., and contract personnel.

As discussed in Section B, Plant Operations, Technical Specification changes have been approved by the NRC to minimize the impact on plant operations (i.e. power reductions) upon loss of the plant computer.

5. Annual Management Audit During November, 1986 the Middle South Services Quality Assurance Section conducted its annual management audit of Waterford 3.

The results of the audit generally indicate that the Waterford 3 Quality Assurance Program for the functional areas audited is being effectively implemented in accordance with established policies and procedures. Waterford 3 management is presently evaluating the audit ,

findings and will direct corre:tive actions as appropriate. In general, the low number and nature of the findings have validated the increased management attention to quality matters during 1986.

6. Preliminary EQ Audit Results During the week of December 8, 1986 the NRC conducted a review of Waterford 3 compliance with 10CFR50.49 (electrical equipment qualification). Although the audit results have not yet been l

m, - - --r-- - q-r +

Pega 302 og 47 received, the Inspection Team indicated the following preliminary observations during the exit meeting:

1. The Waterford 3 EQ program complies with.10CFR50.49,

2. EQ files were found to be auditable and in good order.

3. A review of the procedures governing equipment qualification revealed a well-structured program.

The preliminary EQ Audit results reflect our firm management commitment to compliance with NRC programs and requirements. Based on the information presented during the audit we are confident that the items identified by the Audit Team which were not resolved during the course of the audit can be addressed to the satisfaction of the NRC.

Pa'gs 31'of 47:

LOUISIANA POWER & LIGHT COMPAhT WATERFORD 3 SALP PROGRESS REPORT

_ Performance Functional Area F.- FIRE PROTECTION 1985 SALP Category: 2 1983 SALP Category: Not Assessed

~

Summary of NRC Recommended' Licensee Actions

'1. Install fire protection equipment required by license conditions, and

-2. Resolve fire barrier problems and implement a program to maintain fire barriers functional.

. Summary of LP&L May 1, 1986 Initial SALP Response Equipment required by license condition will be installed or commitments modified with NRC concurrence.

The Technical Specification' surveillance requirements for all fire barrier .

penetration seals have been successfully completed. The results of the.

surveillances along with previous walkdowns'have-demonstrated the integrity of the penetration seals and the adequacy of administrative controls.

Current Status As part of the Nuclear Operations reorganization a separate Fire Protection and Safety Group has been created. Increased emphasis has been placed on industrial safety through implementation, in late 1986, of DuPont's successful Safety Training Observation Program (STOP) program. This concept has much broader applicability than industrial safety and will be evaluated for use in other areas of individual responsibility.

Fire protection modifications required by license condition either have been installed, will be installed during the refueling outage, or will be deferred with the prior approvel of the NRC. Those changes already implemented or to be implemented during the outage include a number of modifications connected with the Associated Circuits Analysis, and installation of permanent smoke detectors in the control room panels.

Deluge capability for certain charcoal filter units will be installed during the outage as committed, however, Waterford 3 has a request pending with NRR to defer portions of the instrumentation and controls associated with the deluge systems if circumstances prevent completion by the end of the outage.

As part of the FSAR update process the Fire Protection Section of the FSAR has been reformatted to consolidate information in order to upgrade its effcetiveness as a reference document for Waterford 3 and the NRC. The updated FSAR will be submitted to the NRC by December 18, 1986.

Pagn 32 of 47 Waterford 3 management = continues to emphasize improved performance in the area of fire protection, and-has taken a conservative approach in

^

addressing fire barrier problems, including actual testing to resolve certain questions regarding penetration seal configurations. Station modification procedures adequately identify and control fire barrier impairments which may occur.in the course of the modification. Fire barrier repair and restoration procedures have been implemented to control the repair of fire. rated seals and wraps impaired as a result of station modification or routine maintenance activities.

2 l

+

4 i

l 1

3 f-i I

l

m PIga 33 of-47 LOUISIANA POWER & LIGHT COMPANY RATERFORD 3 SALP PROGRESS REPORT Performance Functional Area G. RADIOLOGICAL CONTROLS 1985 SALP Category: 2 1983 SALP Category: 2 (Confirmatory Measurements - 3)

Summary of NRC Recommended Licensee Actions

1. Correct gaseous and liquid leaks that are resulting in excessive contamination of workers and plant areas; and

2. Improve the training and qualification program for radwaste operators.

Summary of LP6L May 1, 1986 Initial SALP Response (This topic is partially addressed under Section B, Plant Operations.)

Waterford 3 management has vigorously pursued elimination of the sources of radioactive contamination. In the first quarter of 1986 over 100~

identified valve leaks were repaired. To address design problems associated with contamination 35 station modifications were prepared of which 22 had been essentially completed by the time of the SALP response.

The Plant Manager has placed high priority on the elimination of leak soutees to the extent that leak reduction work was placed on the critical path for the March, 1986 outage.

A concamination reduction task force was established to identify new leak sources, perform maintenance, contain leaks and decontaminate areas where

-practicable.

Waterford 3 agrees, in general, with the SALP report recommendations, however, exception is taken to the use of the word " excessive" when referring to personnel contaminations. As discussed in the May 1, 1986 response, the total skin and clothing contamination for 1985 was below the industry average as reported by INPO.

Current Status (This topic is partially addressed under Section B, Plant Operations).

Waterford 3 has and continues to apply significant resources to correct gaseous and liquid leaks that have potential for resulting in contamination of workers and plant areas.

1. During the upcoming refueling outage, a significant effort will be expended on repair of leaks particularly those in plant systems that cannot be isolated for rework while the plant is at power. The Maintenance and Operations Departments have reviewed plant systems, especially valves, to develop a comprehensive work list in this regard.

P:ga 34 of 47 o

2. In addition to the Station Modifications addressed in the initial response to the 1985 SALP Report, additional station modifications have been identified:

a. Addition of permanent ventilation capability for the Charging Pump Pipe chase, and

b. Improved ventilation of the charging pumps stuffing box.

3. Additional training on valve repacking techniques was provided for maintenance personnel prior to the refueling outage.

4. Work planning efforts to support the refueling outage include consideration for minimizing personnel contamination and the spread of contamination. The Waterford 3 ALARA Program will be applied whenever necessary.

5. A plant goal for contaminated areas (6000 total sq. ft.) was established and performance in this regard has been and will continued to be trended (see attached EXHIBIT G). An evaluation of the level of effort necessary to achieve the goal is currently being performed as well as a comparison to industry performance. A revised goal will be determined based upon the results of this study.

Meeting the current contaminated area goal of 6000 square feet would require successful decontamination of 90% of the safeguard rooms (approximately 5000 square feet) . Extensive Radwaste and HP efforts have been devoted to decontamination and release of these rooms only to have them re-contaminated in short order. It presently appears that the 6000 square foot goal is not reasonably achievable despite best efforts.

In order to determine industry success in decontamination Waterford 3 surveyed several plants and discovered contaminated areas range from 2,000 to 55,000 square feet. Goals for comparable plants range from 10,000 square feet to 55,000 square feet (for a 2 unit facility).

Although further evaluation is underway, it is likely that the contaminated area goal for Waterford 3 should properly be in the 10,000 square foot range. With this assumption, the trend in Exhibit G indicates success in limiting the spread of contamination.

6. The contamination reduction task force established by the Plant Manager in April, 1986 has completed its assignment and corrective action has either been initiated or scheduled for initiation as discussed above and under Section B, Plant Operations.

The storage capacity of the Liquid Waste Management System has been more than quadrupled with the addition of a 40,000 gallon waste hold-up tank.

The additional storage capacity allows flexibility in operation and treatment of waste, better utilization of manpower, and more hold-up time for decay of short-lived radionuclides prior to treatment and release of effluents.

A waste gas problem task force has been created to investigate sources of airborne activity in the plant and reduce releases to the environment.

Their efforts include:

Pcgn 35 of 47

a. Problems with the check valves on the vents for the Holdup Tanks and Equipment Drain Tank have caused difficulties with venting these tanks. A station modification to resolve this problem will be worked during the refueling outage.

b. Valves associated with the Equipment Drain Tank (EDT) and Equipment Drain Sump have caused localized problems on the_-35' elevation of the RAB. CIWAs have been written to rework the valves. The EDT relief valve will be tested during the refueling outage to verify the lift pressure at 10 psig. A Waste Gas Compressor trip was reworked, which had been causing EDT pressure.

increases.

c. The Gas Surge Tank relief valve will be reworked during the outage to increase its setpoint from 35 to 55 psig,

d. CIWAs will be worked during the refueling outage to repair leaks on the Volume Control Tank vent line and a flange atop the Gas Surge Tank.

Upon completion of the refueling outage, the waste gas problem task force will monitor the effectiveness of these corrective actions in reducing the airborne activity problems.

For Cycle 2 Waterford 3 has submitted Technical Specification change requests intended to eliminate the heat tracing on the boric acid makeup system by reducing the boron concentration in solution to below 3.5 weight i percent boron. An indirect effect of the boron concentration reduction will be increased repair turnaround times (and hence lower dose exposure) for boron system components that, to this time, have been affected by boron precipitation and crystal formation.

Attachment:

EXHIBIT G - Total Areas Contaminated in Radiation Controlled Areas.

o e - - - - -

---

~--r---,n -n-- , ,.--,7

b-TOTAL AREAS CONTAMINATED

~ iN RADIATION CONTROLLED AREAS 12

./

~

11 . .

10~

& P- - ---

9 LD f 8 .i. ..c'

~ '

E" E 7 . ,' ,.

t.a CC o

g -

.i'se-

@5 5 .

O 4 .

(n .c_

3 2

1 . .

O FFMMA^AMMJ

~

J J J J J A A 5 s's'D'b'N AA EEAAPPPAAUUUUUUEE ECCO NNBBRRRRRYYNNLLGGPPPTTV  !>.E O-0 20 1 0 1 0 1 2 1 2 1 2020 1 0 1 3 1 2 1 os 7 1 4848 1 59 3704825926048 1 g DATE l r?""n&Etan w% i g

, Pcgs 36 of147-e1 LOUISIANA POWER & LIGHT COMPANY WATERFORD 3 SALP PROGRESS REPORT Performance Functional Area

-H. EMERGENCY PREPAREDNESS 1985 SALP Category: 2-

'1983 SALP Category: 3 Summarv'of NRC Recommended Licensee Actions

'1. Ensure proper response to NRC-identified items -Notices of Violation'

.and deficiencies,.and

2. Evaluate the emergency preparedness retraining program as to scope and depth.

Summary of LP&L May 1, 1986 Initial SALP Response 3

')

Waterford 3 management continues to place particular attention on the resolution of concerns, deviations, etc., identified by the NRC.

An extensive review of the 1985 requalification training lesson plans was conducted to incorporate improvements based on INPO comments, NRC comments /

concerns'and drill / exercise areas of identified weakness.

Current Status In' order to continue the improvement indicated by the 1985 increased SALP rating Waterford 3 management has placed continuing emphasis en the

.importance of emergency preparedness through training and drill participation. We continue to work closely with State and Parish agencies in support of their emergency planning programs which have been rated amongst the best by FEMA. Through out own and outside observation it is our belief that we have steadily improved an already good emergency preparedness program. Additional information for the 1986 SALP rating period includes:

1. Annual Exercise The annual exercise was conducted on October 15, 1986. Based on comments from NRC, FEMA and Waterford 3 evaluations the exercise -

was viewed as a success and an improvement over last year's activity. NRC results indicate one deficiency identified in the area of EOF comcend and control. Waterford 3 is actively pursuing changes to facility layouts, procedures and training to address the deficiency.

2. Training Emergency Planning Dose Assessment seminars have been completed for EOF and TSC dose assessment personnel. Six Health Physics

w

.c Pcga 37 ofL47

~

,7

.x Technician seminarisessions have been held. Training for.St.-

Charles Hospital. support personnel.has been completed. Annual training for risk Parish response organizations was held by the State'of Louisiana. In addition,-the' State of Louisiana'with Waterford 3, has completed training for 1986 for support' parishes. Waterford 3 is working'with the Louisiana Office of Emergency Preparedness (LOEP) to produce a training tape for ambulance drivers.

3. Drills' Ten drills (excluding the annual exercise) were conducted in 1986. These drills' included a Rumor Control Drill, Onsite and Nearsite Emergency Organization Call Out Drills, two full response site drills and two Control Room Breathing Air Drills.

Waterford 3 plans to implement a similar drill schedule for 1987.

The 1987 drill schedule will be finalized in December of 1986.

4. Miscellaneous Emergency Planning Items Facility status boards were replaced (with the exception of dose assessment status-boards) with permanent boards before the annual exercise. The new boards were evaluated during the exercise and functioned well. Permanent dose assessment status boards were ordered in November, 1986.

Waterford 3 is in the process of developing CEPADAS program operability / availability history in an effort to identify the changes necessary to upgrade.the program.

Six new Alert / Notification System sirens were added within the 10 mile EPZ in 1986.

An Agricultural Public Information Brochure has been approved by the State of Louisiana. Distribution in 1987 will be limited to Parish Agricultural Agents' Offices.

Favorable response on the Alert / Notification System Report has been received from FEMA. It is anticipated that the FEMA test of the system will be conducted in Spring, 1987.

4

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

v. =

- :,' Ptg1 38 of 47-LOUISIANA POWER & LIGHT COMPANY WATERFORD 3 SAL" PROGRESS REPORT Performance Functional Area I. TRAINING AND QUALIFICATION EFFECTIVENESS 1985 SALP Category: ~ 2 1983 SALP Category: 2-Summary of-NRC Recommended Licensee Actions

'1. Complete all' actions necessary to obtain INPO accreditation by December, 1986,

2. Evaluate PRES, LERs, CIWAs, quality notices, etc. to measure and

' increase training effectiveness, and-

3. Continue management attention towards timely completion of the Waterford 3 simulator.

Summary of LP&L May 1, 1986 Initial SALP Response It is_the intent of. management to complete NUMARC commitments concerning accreditation by August, 1986. The December, 1986 actual accreditation date is. subject to INPO's ability to support that schedule.

As part of Waterford 3's Systematic Approach to Training, the review of LERs and most other problem identification documents is an essential element in improving the training program effectiveness.

Management attention continues to be directed to completion of the plant specific simulator. Although contractor difficulties are being experienced, Waterford 3 is ensuring that problems are resolved quickly and in detail.

Current Status Waterford 3 is committed to the concept that training is central to the continued good performance of the plant, and vital as a base for future improvement. The following information is indicative of continued management interest during the latter portion of 1986.

1. INPO Accreditation That portion of accreditation which is under Waterford 3 control is still on schedule as indicated in the initial response to the 1985

, SALP Report. Waterford 3 has submitted to INPO self-evaluation reports in the 10 areas required for accreditation. INPO has indicated that all self-evaluation reports are acceptable. An INPO team visit, the second step in the accreditation process, was

. - . ~.. . . . - - . - .. - . .

3 9- Pege 39 of 47 V

3 r  ;

conducted in October for 6 of 10 programs selected for. accreditation.

The team visit:for the other-4 programs will be scheduled.in 1987 by.

4 INPO. INPO and Waterford 3 share the. goal of completing the final

. -accreditation step (the' Accreditation Board) for-the first six.

programs by the-end of the first quarter of 1987,

2. Training Effectiveness Waterford 3 participated in a meeting conducted by tha NRC Region IV.

to discuss' performance based training. This meeting provided valuable feedback on this topic which-has been reviewed in comparison to the Waterford 3 operator training program. With this input .Waterford 3

' operators should demonstrate improved performance on future licensing exams..

As agreed to in the seminars discussed above, Waterford 3 submitted an operator exam bank to the.NRC on November 15, 1986.. The exam bank.is ,

. cross-referenced to NRC's Knowledge and Abilities Catalog for Nuclear Power Plant Operators, PWRs (NUREG 1122) - the first such document in Region IV.

3. Plant Simulator The Waterford 3 Nuclear Power Plant simulator'is now-in factory acceptance testing at the Singer-Link Company's Columbia, MD Fabrication Facility.. Individual systems tests for each simulated plant system were completed on December 2, 1986. The balance of the simulator acceptance tests (plant startup/ shutdown, malfunctions, and transients tests) arc scheduled for completion by late January, 1987.

l At that time the-simulator will be packaged and shipped to the

!- Waterford 3 Energy Education Center for re-assembly and performance of re-verification tests of the simulator hardware and simulation computer programs.

Construction work on the Energy Education Center rooms intended to house the simulator control room panels and associated computer systems is complete. The simulator facilities are now ready to

receive the simulator.

4. Skills Training Center During 1986 Waterford 3 converted the 6B Construction Warehouse on the ,

plant site to establish and implement a new Skills Training Center.

The renovated warehouse contains approximately 21,000 square feet dedicated for maintenance training and personnel processing space.

The attached Exhibit I provides details on the Waterford 3 Skills Training Center.

3 j 5. B.S. Degree Program Waterford 3 has enrolled our operators in the University of Maryland's Nuclear Science and Engineering Program that leads to a B.S. degree in i Nuclear Science. This program is specifically designed to improve

{ overall cechnical knowledge in operating a commercial nuclear power plant. r

I*- Page 40 of 47

6. Reorganization Under the recent reorganization, the Training Department now reports directly to the Vice President-Nuclear. The scope of the Training-

-Department is_ intended to be expanded to include training in addition to the general employee, emergency planning and plant technical' training now being provided.

Attachment:

EXHIBIT 1_- Skills Training Center 4

1

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

. Atttch nt to W3P86-2805 EXHIBIT I SKILLS TRAINING CENTER GENERAL:

The W-3 Skills Training Center is a renovated warehouse containing approximately 21,000 square feet of training and personnel processing space.

All areas have central air conditioning and heating except the S/G Mock-Up enclosure (32) and the Mechanical Mock-Up Lab (22).

This building will be used for skills training of Nuclear and Fossil maintenance personnel within the LP&L organization. Additionally, personnel will be processed through General Employee Training, Radiation Worker Tr'ining, Respirator Training, Security Badging and Health Physics requirements (Whole Body Counting and Respirator Fitting).

Ali hallways are 8-10 feet wide and all entrances to classrooms and labs are double-door to facilitate ease of equipment transfer and personnel movement. Each discipline area is segregated so that movement from classroom to lab will not require use of the hallways thus minimizing disturbance of other classes.

All classrooms contain whiteboards and variable lighting level capabilities.

Ceiling height for all rooms is 9 feet (except Mechanical Lab (20-25 feet) and S/G Mock-Up (30 feet).

The following is a legend indicating specific information about each room:

1 Electrical Maintenance Classroom:

o Capacity - 12 students 2 Electrical Lab:

o 3 Electrical Motor Stations o 3 Relay Test Stations o Capacity - 2 students / station 3 Basic Electricity and Electronics Lab:

o 8 BE&E workstations /each has built-in test equipment and modularized component packages for student experiments ranging from practical electricity and electronics to digital programming and troubleshooting, o 1 Instructor Demonstration Bench with scaled-up versions of individual components for student demonstration.

o Capacity - 16 students (2/ workstation) 1

Attachnant'to W3P86-2805' EXHIBIT I

-4 I&C Classroam:

o _ Capacity - 12 students

-5 Test Equipment Reference Areas:

.o Storage areas for test equipment, components and ready reference material for I&C and Electrical Maintenance Training.

1 o Workbench area for. component repair.

6 I&C Mock-Up Area:

.o Plant Specific Component Training

, 7 I&C Lab:

o Quintech Modular I&C Training lab containing 4 calibration stations, 4 process control stations (level, pressure, temperature and flow), 2 Westinghouse 7300 process analog control stations, associated instrumentation and test equipment.

o Special features of this lab are the ability to free-line loops from station-to-station and fault-insertion capability.

13 Mechanical Classroom:

o Capacity - 12 students 14 Electrical Mock-Up Area:

o Plant Specific Component Training 15 Classroom: (Extra) o Capacity - 12 students 16 GET Dressout Area:

o To be used for performance testing of Anti-C dressout and respirator training.

17 GET Classroom:

o Capacity - 50 students o Used for General Employee Training, Radiation Worker Training, and Respirator Training, o Special feature includes rear-screen projection system (18).

2

~*

Attachmant to W3P86-2805 3 #- EXHIBIT I 19 Alternate GET Classroom:

o Capacity - 40 students o To be used as a back-up for GET classroom during heavy training periods.

20 Breakroom:

o Capacity - 40 o Refrigerator, sink, cabinets, microwave ovens (2) coffee and vending machines.

21 Health Physics:

o To be used for processing personnel whole body counting and respirator fits.

22 Mechanical Mock-Up Area:

o Plant Specific and generic mechanical training aids.

22A Mechanical Tool Room:

'23-25 Weld Area:

o Contains 2 weld booths and weld prep area to train and certify welders in various processes.

26 Security:

o To be used for security badging and issue of parking permits.

27-30 Instructor Office Space 31 . Reference Storage Area.

o Storage of reference material o Quiet-study area l

l 32 S/G Mock-Up

Enclosure:

i f' o Will contain a plant specific mock-up of the lower portion

, of the Steam Generator up to and including the tube sheet.

NOTE: Crane operations and Forklift Training will be given in the rear j yard area, i

i 3

, ., Attachment to W3P86-2805 EXHIBIT I (32) e SiG " " "

aNCLOSURE SKILLS TRAINING CENTER I

MM

' (31) ,

WELD BOOTHS REFER.STOR.

AREA SEC, (23)

(27) (28) (29) (30)

. BADGING y OFF. OFF. OFF. OFF.

, . J. .

, TOOLS

(

CORRIDOR (9A).

HEALTH REAR SCREEN PHYSICS (22)

PROJ. ROCM (ig; l MECH. MOCK-UP (20} LAB BREAKROOM GET CLASSROOM (19)

ALTERNATE GET CLASSROOM (16) 5 (15)

GET ,

CLASSROOM .

DRESSOUT g ggy e

o (f4) MECH.

O

, CLASSROOM ELECT.

CORRIDOR (8A) yggg_yp

• _ R/R R/R (3) l BE&E CORRtDOR (8)

LAB ,

E (5) (6)

TEST l&C MOCK-UP

=

EQUIP.

(2) REFER. ,

AREA i

ELECT.

(7)

(4) I&C LAB i (1) l&C ELECT. CLASSROOM CLASSROOM u e 4

Pcg] 41 of 47

-Q LOUISIANA POWER & LIGHT COMPANY WATERFORD 3 SALP PROGRESS REPORT Performance Functional Area J. SECURITY AND SAFEGUARDS 1985 SALP Category: 1 1983 SALP Category: 2 Summary of NRC Recommended Licensee Actions Ensure that the quality of selection and training techniques for replacement of security personnel continues at a high level.

Summary of LP&L May 1, 1986 Initial SALP Response Waterford 3 management intends to apply, as a minimum, the same high level of quality in the selection and training of replacement security personnel.

Current Status Waterford 3 management continues to apply the same high level of attention to the security program including the implementation of safeguards requirements and the selection and training of replacement security personnel.

The security personnel retention rate has shown marked improvement in 1986.

The 1985 turnover rate of 40.6% has been reduced to 20% for 1986.

Waterford 3 management has long supported a drug awareneus education program within Nuclear Operations. Our education efforts coupled with random drug testing and requirements for drug testing prior to plant access badging have resulted in very low positive urinalysis findings. Of 1500 urinalysis tests recently conducted less than 3% had positive findings compared to a national average of 20-32%.

In response to the increasing incidence of terrorist activity worldwide and the recent Palo Verde event Security management personnel undertook a review of the capability of Waterford 3 to mitigate such events. The evaluation, which pre-dated NRC activity in this area, resulted in the immediate implementation of specific security improvements and contingency plans to protect against potential terrorist activity.

Waterford 3 continues to be recognized as having one of the top security forces in the industry. It has come to our attention that various NRC offices have recommended that other nuclear plant security personnel model aspects of their security program on that utilized by Waterford 3 Security.

Some other significant areas / items of improvement accomplished in the security program during 1986 to date include:

Paga 42 of 47 Q

1. The number of plant access levels was increased from 24 to 94.

2. Key control system has been enhanced by:

Approval granted for computer to assist in control of keys / locks.

Replacement of locking mechanism in security doors to include automatic relocking feature.

Added additional series of locks to increase the capability of the key system.

3. For contingencies, an additional equipment issue point inside the Reactor Auxiliary Building (RAB) was established.

4. The functional position of Compliance Analysis Officer has been established in the Security Organization.

5. For training purposes, safeguards contingency drill scenarios have been initiated.

Recently, Waterford 3 management has taken additional strong measures to strengthen the security awareness of Nuclear Operations employees:

a complete rewrite of the General Employee Training Security Section,

- Immediate briefing of personnel granted unescorted access concerning security breaches, Issuance of policy memoranda from the Senior Vice President dealing with " Personnel Errors - Accountability and Responsibility" (October 1, 1986) and " Fitness for Duty Program Co-Worker Involvement" (October 16, 1986) , and

- Establishment of bi-annual meetings of the Region IV Security Manager's group.

Management is placing special attention on security during the refueling outage. Prior to the outage the Senior Vice President and the Vice President-Nuclear Operations held meetings with supervisory personnel to discuss outage security requirements. Similar meetings were held by the Plant Manager with maintenance personnel (including craft).

a Pcg2 43 of 47 LOUISIANA POWER-& LIGHT COMPANY WATERFORD 3 SALP PROGRESS REPORT Performance Functional Area K. LICENSING ACTIVITIES 1985 SALP Category: 2 1983 SALP Category: 2 Summary of NkC Recommended Licensee Actions

1. Management should continue to be highly involved in licensing activities, and

2. Areas of improvement should concentrate on:

a. More responsiveness in providing NRC staff with information concerning licensee events, and

b. Provide for better communication between plant staff and the licensing group.

Summary of LP&L May 1, 1986 Initial SALP Response Waterford 3 management continues its close involvement in licensing activities and with the NRC staff.

While it may appear that expeditious information concerning operational events is not always forthcoming, premature release of information can be counter-productive. It must be understood that much detailed information is not immediately known (or may be speculative in nature) and must be verified prior to release.

Waterford 3 management involvement in licensing activities has been beneficial in development of good interfaces between the plant staff and licensing groups.

Current Status In addition to the information provided in the initial SALP response Waterford 3 licensing activities continued to expand to the mutual benefit of LP&L and the NRC:

1. Management Support / Involvement in Licensing Activities Waterford 3 management continues to foster good interfacing of Plant Staff and Licensing. Management recognizes the importance of good working relationships for achieving sound communications in order to be consistently responsive in meeting schedules and goals of good practice for licensing activities. Management directs cooperative efforts to ensure timely transmittals to NRC of accurate information on operational events and responses to NRC questions / concerns.

.. Prg2 44 of 47 NRC interface responsibilities are controlled by LP&L Executive Directives (ED's) and Nuclear Operations-Administrative Procedures (NOAP's) to ensure that the information which is transmitted to the NRC is organized, timely and accurate.

In order to increase Licensing involvement in Region IV activities, Licensing staff now are involved with NRC inspection exit meetings.

2. Commitments Management Systems (CMS)

During 1986 Waterford 3 continued the development, completed and implemented its. Commitments Management System (CMS) for the Waterford 3 operations. A detailed description of CMS is given in attached Exhibit K-1.

3. Safety Analysis Report Update System (SARUS)

During 1986 LP&L continued development of, and implemented, the SARUS information management system described in Exhibit K-2.

The Waterford 3 updated Final Safety Analysis Report has been printed and will be filed with the NRC by December 18, 1986.

4. Region IV Utility Group (RUG IV)

In June 1986 Waterford 3 formally became a member of the Region IV Utility Group which was formed in October, 1984. The purpose of the RUG IV group is to provide for the exchange of information among the utilities with operating plants regarding operations, maintenance, and management to enhance the safe operations of the facilities; and to assist in interfacing with NRC. In addition, the group monitors proposed and new regulations to determine their impact on operations and reviews inspection and enforcement reports in order to determine those generic areas of concern to the NRC Region IV office.

5. Industry Group Membership Waterford 3, through its Licensing Group, maintains membership on a number of industry groups whose intent is the resolution of generic safety issues. For instance, the primary purpose for the formation of the CE Owners Group was the generic resolution of TMI Action Items such as emergency procedure guidelines. Other utility groups are issue-specific such as the Nuclear Utility Group on Station Blackout. Membership in these groups serves the dual purpose of promoting high level technical interaction with the NRC and close relations between Waterford 3 groups to support the technical resolution of various issues.

6. Reload Licensing In early 1986 management identified the need for close communication between Waterford 3 and the NRC in order to support license activities for the refueling outage and Cycle 2. To that

o-3 . P7ga 45 ef 47 end the Licensing Group held'a' series of briefings with NRR staff beginning in May, 1986. Firm schedules were provided for submittal of the Reload Analysis Report and Technical Specification changes. Submittal schedules were met and the Licensing Group has coordinated timely responses to NRC questions as they occurred. At the present time it appears that no outage or restart activities will be restricted by delays in license-related approvals.

Attachment:

EXHIBIT K Commitment Management System EXHIBIT K Safety Analysis Report Update System

a-Atttchm:nt to W3P86-2805

,, - EXHIBIT K-1 o

COMMITMENTS MANAGEMENT SYSTEM The Commitments Management System (CMS) currently tracks identified regulatory requirements and manages information concerning LP&L's compliance. Categories of commitments on the computerized CMS include those requiring a one-time action as well as those requiring ongoing compliance.

CMS Reports, as applicable, contain pertinent information on regulatory commitments including:

o Source of the commitment o responsible departments / personnel o priority code o regulatory agency o origination, scheduled completion, forecast and closure dates o status o summary description, commitments text and comments o implementing or closure documents, and o reference documents.

CMS can function as an automated tickler file, providing management with timely reports to keep abreast of due-date requirements and can assist in the procedure revision process by providing a CMS report of those commitments identified as being implemented by a particular document.

CMS search capabilities include: text strings, implementing document number, responsible organization / person, priority basis, due date, source, etc.

Update and maintenance capabilities provide the latitude to add or revise data as necessary to maintain current information concerning commitments.

.Attachnent to W3P86-2805 o

e# EXHIBIT K-2 SAFETY ANALYSIS REPORT UPDATE SYSTEM The Safety Analysis Report Update System'(SARUS) is an information management system that combines an administrative document control system with a computerized process to aid in ensuring that the master copy of the Final Safety Analysis Report (FSAR) is current and verified.

Through SARUS, users have access to all text data entered in the document

-database, such as license documents, correspondence, regulations and design changes. System features include:

o Computerized text storage of the Final Updated Safety Analysis Report (FUSAR) and all affecting documents and.related correspondence.

o Document-keyword database and computer software that programmatically cross-reference specific sections of the FSAR and other documents through keywords and documentation identification number (DIN).

o An easy-to-use document reference tool to allow multiple users to interactively search documents having unique logical combinations of keywords or key phrases.

o A text search program scans documents sorted on computer and indexes them against a list of approximately 7,000 key phrases.

The user can enter any keyword and generate a report of all documents in which the keyword is found.

o An internal cross-reference subsystem contains a database of all forward and backward references to FSAR sections, tables, appendixes, figures and questions.

o O p;ga 46 ef 47 LOUIS!ANA POWER & LIGHT COMPANY WATERFORD 3 SALP PROGRESS REPORT Performance Functional Area L. OUTAGES 1985 SALP Category: Not Assessed 1983 SALP Category: Not Assessed

1. Outage Management Outage management activities are focused on several key areas: Forced Outage Management, Refueling No. 1 Outage Preparation and Long Range Outage Planning.

Forced Outage Management continues to progress from guidelines implemented in late 1985 to a flexible and comprehensive process of work scoping, detailed preparation and preplanning, and prioritized scheduling from various plant conditions through power reduction and extended cold shutdowns. Program refinement and post outage critiques remain active. The maintenance, at all times while operating, of a pre-planned forced outage list by the Duty Plant Manager has served Waterford 3 well.

2. March 1986 Surveillance Outage The first planned outage at Waterford 3 was performed during March 1986. The Unit was removed from service on March 7th at 1446 hours0.0167 days <br />0.402 hours <br />0.00239 weeks <br />5.50203e-4 months <br /> and re-synchronized to the grid on March 30th at 1920 hours0.0222 days <br />0.533 hours <br />0.00317 weeks <br />7.3056e-4 months <br />. The Unit returned to 100% power operation on April 2, 1986. The mid-cycle outage was required to perform technical specification surveillances due prior to the next planned shutdown for first refueling.

Prioritized outage presentive and corrective maintenance items and station modifications were scheduled and successfully implemented.

The outage was accomplished ahead of the original schedule and undet the management target of 30 days. The effectiveness of this outage was demonstrated by the rapid return to full power and the completion of the cycle with excellent plant performance.

3. Refueling Outage No. 1 Refueling Outage No. I preparation was accomplished with a dedicated Outage Preparation Manager to coordinate activities required to prepare for nnd implement the Refueling Outage. The Refueling Outage is organized in three distinct phases: Outage Preparation, Implementation and Post Outage Review. The preparation stage, including detailed work scoping, is complete. New fuel was received in time to support fuel load. Participation by affected Nuclear Operations Groupc in developing outage implementation schedules in parallel with good mobilization planning should result in a safe and successful outage.

I

6 j4 -

.Pcg3 47 of 47 During the outage implementation phase the Plant Manager has assumed responsibility. Briefings of key personnel have taken place to emphasize the importance of security, radiation protection, quality, industrial safety, efficiency and. compliance to procedures. Strong

. emphasis is being placed on individual accountability.

Outage testing and training is discussed under the applicable SALP functional area, e.g. Section A, Preoperational/Startup Testing.

4.; Long Range Outage Preparation The Operations and Maintenance Departments have formed the core (LP&L Employees) of a Long Range Scheduling unit within the Planning and Scheduling group. With current efforts dedicated to refueling' outage scheduling, development of a site specific integrated living schedule program will commence later this year or in early 1987.