ML20136E133

Insp Rept 50-382/97-03 on 970203-28.Violation Cited But Not Noted.Major Areas Inspected:Ts Requirement for Component Cooling Water Flow Through Containment Fan Coolers

ML20136E133
Person / Time
Site:	Waterford
Issue date:	03/07/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20136E111	List: ML20136E106 ML20136E133
References
50-382-97-03, 50-382-97-3, NUDOCS 9703130120
Download: ML20136E133 (10)

See also: IR 05000382/1997003

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! ENCLOSURE

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-382

l License No.: NPF-38

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l Report No.: 50-382/97-03

Licensee: Entergy Operations, Inc. i

Facility: Waterford Steam Electric Station, Unit 3

l Location: Hwy.18

Killona, Louisiana

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' Dates: February 3-28,1997

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Inspector: L. A. Keller, Senior Resident inspector

Approved By: P. H. Harrell, Chief, Project Branch D

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ATTACHMENTS:

Attachment 1: Supplemental Information

l Attachment 2: List of Documents Reviewed

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9703130120 970307

PDR ADOCK 05000382

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EXECUTIVE SUMMARY

Waterford Steam Electric Station, Unit 3

NRC Inspection Report 50-382/97-03

This special inspection reviewed the circumstances regarding whether the licensee

operated outside the Technical Specifications (TS) requirement for component cooling

water (CCW) flow through the containment fan coolers (CFC), and included aspects of

surveillance testing and engineering evaluations.

Results

The licensee failed to establish or maintain adequate design control for the

containment cooling system (CCS). Specifically, the licensee: (1) f ailed to utilize

appropriate CCW flow values through the CFCs in the containment loss-of-coolant

accident (LOCA) and main steamline break (MSLB) analyses and TS Surveillance

Requirement 4.6.2.2.b.2, and (2) credited three CFCs in the MSLB analysis while

TS only requires two CFCs. The failure to establish and maintain adequate design

control for the CCS is an apparent violation of Criterion lli of Appendix B to

10 CFR Part 50 (Section E1.2.b.1).

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• The licensee's test procedure for implementing TS Surveillance

Requirement 4.6.2.2.b.2 to verify 1325 gpm CCW flow through each CFC was I

inadequate. The procedure did not account for the fact that testing conditions were

not representative of the system alignment during accident conditions. The failure

to establish an adequate test procedure to implement TS Surveillance i

Requirement 4.6.2.2.b.2is an apparent violation of Criterion XI of Appendix B to 10 l

CFR P srt 50 (Section E1.2.b.2). j

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• ' In Or,tober 1995, the licensee conducted a special CCW flow balance test, which I

revealed that all four CFCs had CCW flow less than the 1325 gpm required by TS -J

Surveillance Requirement 4.6.2.2.b.2. The licensee failed to recognize the

applicability of the TS requirement to the degraded CCW flows and therefore started

up from a refueling outage and operated for approximately 10 months with all four

CFCs inoperable. The failure to maintain at least one CFC operable per train from

October 31,1995, until August 23,1996,is an apparent violation of TS 3.6.2.2

(Section E1.2.b.3).

• After full flow testing in August 1996 demonstrated the inability to achieve design

basis CFC flows, the licensee failed to implement appropriate corrective actions to

either restore the system to the design basis requirements or change the design )

basis in accordance with regulatory requirements. The failure to implement

adequate corrective action is an apparent violation of Criterion XVI of Appendix B to

10 CFR Part 50 (Section E1.2.b.4). I

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Report Details

E1.1 CFC System Information

a. Backaround Information

On August 12,1996, a licensee self-assessment team questioned the low flow

results obtained during a CCW flow balance test performed during Refueling

Outage 7, which occurred from September to October 1995, and the potential

impact on the system operability with respect to the TS 4.6.2.2.b.2 flow

requirement of 1325 gpm. In response to the self-assessment team's concern, the

licensee performed an operability evaluation to address the flow rates to the CFC

and determined that the coolers remained operable, even though it did not appear

that the TS surveillance requirement value had been obtained. The basis for the

licensee's position was that the value of 1325 gpm, provided in TS Surveillance

Requirement 4.6.2.2.b.2, was not the required flow with CCW aligned in the

accident response mode, but was intended to be an indication that the flow control

valve for the cooler was fully opened in response to a safety injection actuation

signal (SIAS). The licensee's position was forwarded to the Office of Nuclear

Reactor Regulation (NRR) for a determination of compliance with the TS. This issue

is fully discussed in NRC Inspection Report 50-382/96-11 as Unresolved >

ltem 50-382/9611-04.

On January 29,1997, NRR concluded that Waterford, Unit 3, was in violation of TS

Limiting Condition for Operation 3.6.2.2 from October 1995, when Mode 4 was

entered, until August 23,1996, when the coolers were cleaned, retested, and it

was determined that at least one cooler in each train satisfied the minimum flow

requirement, as specified in TS Surveillance Requirement 4.6.2.2.b.2.

b. System Descriotion

The function of the containment heat removal systems under accident conditions is

to remove heat from the containment atmosphere such that containment pressure

and temperature limits are not exceeded. The two containment heat removal g

systems are the CCS and the containment spray system. The CCS consists of two

trains, each of which contains two CFCs, a ducted air distribution system, and

associated instrumentation Each of the four CFCs consists of a structural steel

housing, cooling coils and a two-speed vane axial fan. Three CFCs operate in fast ]

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speed during normal conditions. Upon receipt of a SIAS, the remaining fan starts in j

slow speed with the fans that were already running shifting to slow speed. Each of

the CFCs is cooled by CCW. CCW flow rate through each train is determined by a i

control valve (CC-835A or CC-835B) located on a common CCW return line. l

Valve CC-835A controls CCW flow through CFC A and C (Train A) while I

Valve CC-835B controls flow through CFC B and D (Train B). Normal CCW flow l

through each cooler is 670 gpm, while pot.taccident flow is assumed by the UFSAR i

to be at least 1350 gpm through each cooler. l

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E1.2 CCW Fiows Throuah CFCs and Comoliance with Reaulatory Reauirements

a. inspection Scoce (92903. 61726)

The inspector reviewed various design-basis documents, testing procedures, and

survei!!ance test results related to CCW flow through the CFCs. Additiona:ly, the

inspector reviewed the licensee's operability analysis and 10 CFR 50.59 evaluation I

regarding degraded CCW flows through the CFCs and interviewed selected

personnel. Specific documents reviewed are listed in Attachment 2.

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b. Observations and Findinas

b.1 Desian Control issues

TS Surveillance Requirement 4.6.2.2.b.2 states that each group of containment

cooling fans shall be demonstrated operable at least once per 18 months by i

verifying a cooling water flow rate of greater than or equal to 1325 gpm to each  !

cooler. The inspector determined that the 1325 gpm value was based on the j

UFSAR value of 1350 gpm listed in Table 6.2-21, " Design Data for Containment 1

Fan Coolers." The design flow came from the Architect / Engineer (Ebasco)

Specification 1564-745,which lists the design cooling water flow through each

cooler as:

Normal Operating Conditions 670 gpm

Design Basis Accident Condition 1350 gpm

Clean Tube Accident Condition 1350 gpm

The 1350 gpm value for CCW flow through the CFCs was used in the LOCA and

MSLB containment analyses, even though this number was nonconservative with v

respect to TS requirements (1325 gpm) and did not account for any possible

degradation of flow. The following table of CCW flow balance tests demonstrates

that actual CCW flow through the CFCs under design-basis conditions has been

consistently less than containment analysis assumptions, even without accounting

for instrument uncertainties:

CFC Stanuo Test October 1995 Aunust 1996

A 1350 gpm 1300 gpm 1340 gpm

B 1289 gpm 1200 gpm 1250 gpm

C 1358 gpm 1310 gpm 1310 gpm

D 1426 gpm 1290 gpm 1370 gpm

NOTE: The CCW system was cleaned in the first quarter of 1996

The licensee was unable to determine why the equipment specification value of

1350 gpm was used rather than an appropriate, more conservative flow value, but

believed there was margin within the containment analysis to use substantially

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lower CCW flow assumptiens. The failure to utilize appropriate, conservative CCW

flow values through the CFCs in the containment LOCA and MSLB analyses and TS

Surveillance Requirement 4.6.2.2.b.2 is the first example of an apparent violation of

Criterion lil of Appendix B to 10 CFR Part 50(50-382/9703-01, Example 1).

On February 3,1997, the inspector requested a copy of the containment LOCA and

MSLB analyses in order to verify the assumptions used for the parameten: of the

CFCs. On February 5, prior to providing the analyses to the inspector, the licensee

initiated CR 97-0281 that documented that the MSLB analysis of record was

performed with the assumption that three CFCs were in operation. However,

TS 3.6.2.2 states, in part, that two independent groups of containment cooling fans

shall be operable with one fan to each group, in order to be consistent with respect

to TS 3.6.2.2, the MSLB analysis should have only credited two CFCs.

Additionally, UFSAR page 6.2-11 states, in part, that only two CFCs are assumed

to be running in the MSLB analysis, which is an error. The failure to credit the

appropriate number of CFCs in the MSLB analysis is a second example of an

apparent violation of Criterion 111 of Appendix B to 10 CFR Part 50

(50-382/9703-01, Example 2).

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Subsequent to the identification of this anomoly, the licensee reperformed the MSLB

7 analysis and confirmed that only two fans would be required to meet the

appropriate design basis requirements,

b.2 TS Surveillance Reauirement 4.6.2.2.b.2 Test Procedure

The licensee used Procedure OP-903-029, Revision 6, " Safety injection Actuation

Signal Test," to implement the requirements of TS Surveillance

Requirement 4.6.2.2.b 2. Tests conducted under Procedure OP-903-029 have

always resulted in flows through the coolers greater than 1500 gpm. However,

these tests were always conducted with CCW in a nonaccident alignment and

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testing conditions were such that flows through the CFCs were greater than would I

be expected during a design-basis accident system alignment. For example, during

an accident, the CCW trains isolate from each other (one CCW pump per train), l

flow is established through the emergency diesel generators, and flow increases i

through the shutdown cooling heat exchanger. In contrast, Procedure OP-903-029

establishes a valve lineup that cross-connects the CCW headers with normal l

Mode 5 loads. This has the effect of forcing more flow through the CFCs during

the surveillance test than would exist during an accident system alignment. The j

inspector concluded that Procedure OP-903-029 established nonrepresentative

testing conditions and was therefore inadequate. The failure to establish an l

o adequate test procedure to implement TS Surveillance Requirement 4.6.2.2.b.2is i

an apparent violation of Criterion XI of Appendix B to 10 CFR Part 50 1

(50-382/9703-02).

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b.3 Dearaded CCW Flows and TS Compliance

in October 1995, the licensee performed a special flow balance test for CCW in

accordance with Special Test Procedure (STP) 01140557,"RFO7 CCW Flow

Balance Test," Revision O. The licensee generated CR 95-0955 to document and

evaluate that CCW flow through the CFCs during this test was less than the UFSAR

value of 1350 gpm. The flow through the coolers was:

Train A CFC A: 1300 gpm

CFC C: 1320 gpm

Train B CFC B: 1200 gpm

CFC D: 1290 gpm

CR 95-0955 and its attached engineering analysis concluded that the CFCs

remained operable as long as CCW flow was greater than 1100 gpm; however, the ,

CR did not address the applicability of TS Surveillance Requirement 4.6.2.2.b.2. l

CR 95-0955 determined the apparent cause of the degraded CCW flows was  !

increased flow resistance through the dry cooling towers (DCT) as a result of

fouling. The CR concluded that as long as flow through the CFCs exceeded

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1100 gpm no operability concern existed. The plant was started up with the

expectation that the DCT tubes would be cleaned during planned system outages j

and the CCW full-flow test would be reperformed during the next refueling outage,

scheduled for the spring of 1997. The DCT cleaning was completed in

March 1996.

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On August 12, a licensee self-assessment team reviewed the STP 01140557 '

results and questioned whether the test, with CCW flows less than 1325 gpm to

each CFC, indicated that all four CFCs were inoperable. In response to the

self-assessment team's concern, tha %ensee performed an assessment of the CC'N

flows through the coolers under accident conditions and determined that the coolers  ;

remained operable and were in compliance with the TS operability requirements. j

The basis for the licensee's position was that the value of 1325 gpm, as specified I

in the TS, was not intended as a minimum flow requirement through the CFCs, but

was to verify that the flow control valve for the cooler was fully open in response to ,

a SIAS. The licensee's position and background information was forwarded to NRR  !

by NRC Region IV for a determination of.the intent of Surveillance

Requirement 4.6.2.2.b.2 and licensee compliance with the TS. l

On January 29,1997, NRR,in a letter to NRC Region IV, concluded that the intent

of TS Surveillance Requirement 4.6.2.2.b.2 was to verify CCW flows through the

CFCs were consistent with the design basis and accident analysis assumptions (i.e.,

each cooler was required to have a flow of 1325 gpm). Therefore, Waterford 3 l

was in violation of TS Limiting Condition for Operation 3.6.2.2 from October 1995, l

when Mode 4 was entered, until the coolers were retested and at least one cooler in j

each train satisfied the TS requirement of 1325 gpm. I

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On August 23,1996, the licensee performed a CCW full-flow test at 100 percent

power in accordance with STP 01150154,"CCW System Flow Balance Test,"

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Revision O. The purpose of the test was to determine the status of CCW flows and  ;

the effectiveness of the DCT cleaning. The results of the August 23 test were: '

Train A CFC A: 1340 gpm

CFC C: 1310 gpm

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Train B CFC B: 1250 gpm l

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CFC D: 1370 gpm  !

The inspector concluded that the licensee had violated TS 3.6.2.2 from

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October 31,1995, until August 23,1996, a period of approximately 10 months.

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The failure to maintain at least one CFC operable per train from October 31,1995,

until August 23,1996,is an apparent violation of TS 3.6.2.2(50-382/9703-03).

b.4 Corrective Action issues

As a result of concerns regarding CCW flow through the CFCs, the licensee

conducted a special CCW flow balance test in accordance with STP 01150154,on

August 23,1996. The test results indicated that one cooler in each train met the

TS-required 1325 gpm; however, the test also demonstrated the inability of three of

ie four CFCs to meet the design basis 1350 gpm flow. A 10 CFR 50.59 safety

evaluation was prepared for STP 01150154. The 1100 gpm CCW flow through the

CFCs acceptance criteria established in the CR 95-0955 operability evaluation was

endorsed by this 10 CFR 50.59 evaluation. This evaluation determined that CCW

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flows through the CFCs of 1100 gpm did not result in an unreviewed safety

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question and concluded that the proposed change did not reduce the margin of

safety as defined in the basis of any TS. The supporting documentation for this

! conclusion stated:

"New analyses have been performed for the design-basis accidents with

lower flow rates to the CFCs (1100 gpm vs 1350 gpm) and to the shutdown

cooling heat exchanger (2600 gpm vs 3000 gpm). The lower flow rates are

j sufficient to maintain the post-LOCA and post-MSLB containment peak

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pressure below the acceptable limit of 44 psig. The containment pressure is

slightly greater than 50 percent of the calculated peak at 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the

, accident. However since this is only used as an input to the LOCA offsite

dose calculation, the impact of the higher pressure is negligible.

Conservatisms in the existing dose calculation more than offset this impact.

Furthermore, since both CFCs on each train are normally operable, the

containment pressure is expected to be below the 50 percent criteria when

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two CFCs are running."

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The inspector noted that the bases for TS 3.6.2.2 states:

"The systems (containment spray and containment cooling) also reduce the

containment pressure by a factor of two from its postaccident peak within

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, resulting in lower containment leakage rates and lower offsite dose

rates."

The inspector concluded that the change of the acceptable CCW flow rates to the

CFCs from 1350 to 1100 gpm resulted in a reduction in the margin of safety as

defined in the bases of TS 3.6.2.2 and, therefore, represented an unreviewed safety

question. The inspector also concluded that by extension the operability evaluation

conducted under CR 95-0955, which originally established the 1100 gpm CCW

flow acceptance criteria, resulted in an unreviewed safety question.

The licensee's position was that an unreviewed safety question did not exist for the

degraded CCW flows because 10 CFR 50.59 does not apply to

operable-but-degraded situations, when there is an intention of eventually restoring

the equipment. Additionally, the licensee stated that there was no specific time

limit for equipment being unable to meet a design basis assumption (i.e.,1350 gpm)

before it became a "de facto" change to the facility. This approach was consistent

with the licensee's intention to wait 18 months before performing another flow

balance test without a 10 CFR 50.59 evaluation. However, it should have been

apparent from test results that the design basis requirement of 1350 gpm through

each CFC could not be " restored" since the CFCs have been unable to consistently

achieve this flow rate under full flow conditions, including preoperational startup

testing. The failure to implement corrective actions to either restore the design

basis required CFC flows, or change the design basis in accordance with regulatory

requirements,is identified as an apparent violation of Criterion XVI of Appendix B to

10 CFR Part 50(50-382/9703-04).

On February 11,1997, the licensee changed the design basis regarding CCW flow

through the CFCs from 1350 to 1100 gpm via the 10 CFR 50.59 process. The

licensee performed a reanalysis of the LOCA and MSLB events using the same

computer code (Contemp Lt-26) described in the UFSAR, which had been previously

approved by the NRC. However,in order to achieve acceptable results with the

lower flows, the licensee had to assume additional CFCs were in operation than

were originally assumed. The licensee recognized that the new CFC assumptions

(2 vs 1 for LOCA, and 4 vs 2 for MSLB) were nonconservative relative to the TS

requirements in affect. In order to account for the nonconservative requirements of

the TS, the licensee issued Standing Instruction 97-02, which administratively

required all four CFCs to be operable or entry into a 72-hour action be performed to

either restore the equipment to operable status or be in Hot Shutdown within the

following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The licensee felt that this was acceptable interim action until

TS 3.6.2.2 could be formally changed.

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c. Conclusions

• The licensee inappropriately utilized the maximum vendor specified flow

through the CFCs as the minimum assumed flow in the design basis and

accident analyses. Full flow tests consistently demonstrated the inability to

achieve these flows. The inspector concluded that the licensee failed to

establish or maintain adequate design control for the CCS. The failure to

maintain adequate design control for the CCS is an apparent violation of

Criterion 111 of Appendix B to 10 CFR Part 50.

• The test procedure that verified the 1325 gpm TS 4.6.2.2.b.2 required CCW

flow through each CFC did not ensure that test conditions verified the

system could supply sufficient flow in a postaccident alignment. The failure

to establish an adequate test procedure to implement TS 4.6.2.2.b.2 is an

apparent violation of Criterion XI of Appendix B to 10 CFR Part 50.

• A special CCW flow balance test revealed that all four CFCs had CCW flow

less than the 1325 gpm required by TS 4.6.2.2.b.2, and the licensee failed

to recognize that the degraded flows rendered the CFCs inoperable. The

failure to maintain at least one CFC operable in each train for approximately

10 months is an apparent violation of TS 3.6.2.2.

• After full flow testing in August 1996 demonstrated the inability to achieve

design basis CFC flows, the licensee failed to implement appropriate

corrective actions to either restore the design basis or change the design

basis in accordance with regulatory requirements. The failure to implement

adequate corrective action is an apparent violation of Criterion XVI of

Appendix B to 10 CFR Part 50, Appendix B to 10 CFR Part 50.

E.2.1 Review of Facility and Eauioment Conformance to UFSAR Descriotion

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A recent discovery of a licensee operating a facility in a manner contrary to the

UFSAR description highlighted the need for a special focused review that compares

plant practices, procedures and/or parameters to the UFSAR descriptions. While

performing the inspections discussed in this report, the inspector reviewed the

applicable portions of the UFSAR that related to the areas inspected. The following

inconsistencies were noted between the wording of the UFSAR and the plant

practices, procedures and/or parameters observed by the inspectors:

• UFSAR page 6.2-11 specified that the MSLB analyses assumes two CFCs

are running. However, the accident analysis of record assumed three CFCs

were running.

• UFSAR Tables 6.2-21 and 7.5 3 specified that the CCW flow through the

CFCs during accident conditions was 1350 gpm. However, full flow testing

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has consistently shown that 1350 gpm has not been achieved for all the

CFCs.

E8 Miscellaneous Engineering issues (92903)

E8.1 (Closed) Unresolved item 50 382/9611-04: compliance with TS Surveillance

Requirement 4.6.2.2.b.2 and adequacy of 1325 gpm value. The concerns ,

associated with this unresolved item resulted in this special report. The '

enforcement items identified in this report supersede this item and therefore this

item is closed.

V. Manaaement Meetinas -

X1 Exit Meeting Summary

The inspector presented the inspection results to members of licensee management

at the conclusion of the inspection on February 28,1997. The licensee

acknowledged the findings presented.

The inspector asked ti e licensee whether any materials examined during the

inspection should be considered proprietary. No propriotary information was

identified.

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ATTACHMENT 1

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SUPPLEMENTAL INFORMATION

PARTIAL LIST OF PERSONS CONTACTEQ

Licensee

R. G. Azzarello, Manager, Maintenance

C. M. Dugger, Vice-President, Operations

T. J. Gaudet, Manager, Licensing

T. R. Leonard, General Manager, Plant Operations

9 D. C. Matheny, Manager, Operations ,

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D. W. Vinci, Superintendent, System Engineering

A. J. Wrape, Director, Design Engineering

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INSPECTION PROCEDURES USED

61726 Surveillance Observations

j 92903 Followup - Engineering

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ITEMS OPENED. CLOSED. AND DISCUSSED

Opened

50-382/9703-01 eel An apparent violation of Criterion lli with two examples

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regarding failure to maintain adequate design control for the

CCS (Section E1.2.b.1)

50-382/9703-02 eel An apparent violation of Criterion XI regarding the failure to

, establish en adequate test procedure to implement the

requirements of TS Surveillance Requirement 4.6.2.2.b.2

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(Section E1.2.b.2)

50 382/9703-03 eel An apparent violation of TS 3.6.2.2 regarding the failure to

maintain at least one CFC operable per train

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(Section E1.2.b.3)

50-382/9703-04 eel An apparent violation of Criterion XVI regarding the failure

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to implement adequate corrective actions for inability to

meet CFC design basis (Section E1.2.b.4)

Closed

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50 382/9611-04 URI Compliance with TS Surveillance Requirement A 6.2.2.b.2

and adequacy of 1325 gpm value (Section E8.1)

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LIST OF ACRONYMS USED

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] CCS Containment Coating System

CCW Component Coo ing Water

CFC Containment Fan Coolers

CFR Code of Federal Regulations

CR Condition Report l

DCT Dry Cooling Tower ,

gpm gallons per minute

LOCA Loss Of Coolant Accid 1 -

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MSLB Main Steamline Break ; i.;.,.,, y )

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NRC Nuclear Regulatory Commission I

NRR Office of Nuclear Reactor Regulation

psig pounds per square inch gauge

SlAS Safety injection Actuation Signal i

STP Special Test Procedure

TS Technical Specification

UFSAR Updated Final Safety Analysis Report

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ATTACHMENT 2

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LIST OF DOCUMENTS REVIEWED

Updated Final Safety Analysis Report (UFSAR) Section 6.2, " Containment Systems"

UFSAR, Chapter 6, LOCA and MSLB Containment Ana!yses

Ebasco CFC Specification LOU-1564.745

CR 97-0281,96-1331,-1328,-1266,-1250, and 95-0955

STP 01150154, Revision 0, "CCW System Flow Balance"

STP 01140557, Revision 0, "RFO 7 CCW Flow Balance Test"

Startup CCW Flow Balance Test SPO-36-002

TS Change Request NPF-38-81

Surveillance Procedure OP-903-029, Revision 6, " Safety injection Actuation Signal

Test"  ;

Engineering Calculation EC-195-004, Revision 0, "CCW Flow from CFC Coils

Instrumentation Loop Uncertainty Calculation"

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