IR 05000382/1998008

Insp Rept 50-382/98-08 on 980322-0502.Violations Noted. Major Areas Inspected:Operations,Maintenance,Engineering & Plant Support

ML20248F687
Person / Time
Site:	Waterford
Issue date:	05/29/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20248F664	List: IR 05000382/1998008 ML20248F661 ML20248F680
References
50-382-98-08, 50-382-98-8, NUDOCS 9806040385
Download: ML20248F687 (19)

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C ENCLOSURE 2 U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-382  !

License No.: NPF-38 Report No.: 50-382/98-08 Licensee: Entergy Operations, In Facility: Waterford Steam Electric Station, Unit 3 Location: Hwy.18 Killona, Louisiana Dates: March 22 through May 2,1998

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Inspectors: T. R. Farnholtz, Senior Resident inspector J. M. Keeton, Resident inspector Approved By: P. H. Harrell, Chief, Project Branch D Attachment: SupplementalInformation 9906040385 990529  ?

PDR ADOCK 05000382 ;

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EXECUTIVE SUMMARY Waterford Steam Electric Station, Unit 3 NRC Inspection Report 50-382/98-08

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Operations

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A violation of Technical Specification (TS) 6.8.1 was identified for the failure to provide l adequate instructions to specify the proper operation of the emergency diesel generator (EDG) at no or low load conditions (Section O3.1).

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Lack of attention to detail by the control room supervisor (CRS) and the nuclear plant operator resulted in a noncited violation, per Section Vll.B.1 of the NRC Enforcement Policy, for the failure to verify the positions of control element assemblies (CEA) within l the TS-required time period (Section O4.1).

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The root cause investigation for a contaminated spent resin spill was comprehensiv The proposed corrective actions were appropriate (Section 08.1).

I Maintenance

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The task to repair a steam leak on the high pressure turbine exhaust flange was performed in a professional manner. The engineering evaluation and support was very j good (Section M1.1). 1 I

Enaineerina

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A failure to implement adequate measures to ensure that correct response time acceptance criteria for the emergency feedwater, containment fan coolers, and injection i systems was established to meet the Updated Final Safety Analysis Report (UFSAR) -

assumptions and the design basis requirements were identified as a violation of 10 CFR 50, Appendix B, Criterion lli (Section E1.1).

- Two operability confirmation evaluations, which involved ASCO solenoids and a safety-related battery, appropriately addressed the operability of these components (Section E1.2).

- A violation was identified for the failure to test the thermal overload relays for all containment isolation valves as required by TS 4.8.4.2.b.1. The initial scope of the review to identify missed surveillance on all effected safety-related valves was narrowly focused (Section E2.1).

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-2-Plant Suooort

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The chemistry monitoring and biological control programs for cooling water systems were very good (Section R1.1).

Conduct of the course on respiratory protection training was professional, with appropriate individual attention from the instructor (Section RS.1).

In general, conduct of the licensee's practice emergency exercise was very good (Section P1.1).

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Report Details Summarv of Plant Status During this inspection period, the p! ant operated at essentially 100 percent powe . Operations 01- Conduct of Operations (71707)

01.1 General Comments (71707)

The inspectors performed frequent reviews of ongoing plant operations, control room panel walkdowns, and plant tours. Observed activities were performed in a manner consistent with safe operation of the facility. The inspectors also observed several shift tumovers 'and daily routine shift activities. The shift turnovers were professional and thorough. The inspectors observed operators using self-checking and peer-checking techniques when manipulating equipment. Three-way communication was consistently used by operators within the control room and in extemal communications with -

equipment operators and maintenance personnel.'

03 Operations Procedures and Documentation O3.1 Review of EDG A System Ooeratina Procedure Insoection Scone (71707. 61726)

The inspectors observed the routine, monthly surveillance test of EDG A using System Operating Procedures OP-009-002, " Emergency Diesel Generator," Revision 17, and

OP-903-068, " Emergency Diesel Generator and Subgroup Operability Verification,"

Revision 1 Observations and Findinas On April 20,1998, the inspectors observed the conduct of the monthly test of EDG The inspectors observed the prestart activities of the plant operators, using Procedure OP-009-002 and the EDG was started at 11 a.m., in accordance with Procedure OP-903-068. The EDG ran unloaded for a period of 53 minutes while engineered safety features actuation system subgroup relay functional testing was conducted. At 11:53 a.m., the EDG output breaker was closed and the EDG was loaded _

in accordance with the requirements of Procedure OP-009-00 The inspectors noted a precaution in Section 3.1 of Procedure OP-009-002, which

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stated, in part, that when the EDG is operating unloaded or at low load conditions for an extended period of time, then fuel injection pump temperatures should be checked periodically. If any pump gets too hot to comfortably hold your hand on, due to the pump not circulating fuel that would normally cool it,_tbag start loading or secure the EDG.

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The inspectors did not observe the plant operators monitoring the fue! injection pump -

temperatures during the 53 minutes that the EDG was running unloaded, as required by the procedur The inspectors also noted that a caution appears in several places throughout the procedure, which stated, in part, not to allow the diesel generator to operate for an extended period of time unloaded The inspectors questioned the meaning of the term " extended period of time" as used throughout the procedure. The operations superintendent and system engineer stated the concem associated with the caution statement was carbon accumulation in the .

engine cylinders and a potential fire hazard. Some historical dor'uments indicated that, for this concem, a period of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> should be used as the meaning of" extended period-of time" using engineering judgement. However, no basis for this criteria was specife The precaution statement addressed a concem for overheating the fuel injection pumps at no or low loads. These pumps are cooled by fuel circulating through them during operation. However, at no or low loads very little fuel is available to cool the operating pumps, in inis case, the meaning of " extended period of time" may require a different interpretation. No historical documents that discussed this concern were availabl Because appropriate guidance was not provided in the procedure to ensure proper operation of the EDGs under all possible conditions, Procedure OP-009-002 was considered to be inaaequat During an activity unrelated to the observations discussed above, it was identifed by the inspectors that operation of the EDGs in an unloaded condition was an actual conce While observing an' exercise at the simulator, the inspectors noted that the EDGs started at the beginning of the scenario and ran unloaded for the duration of the scenario without operator attention. The total time the EDGs ran unloaded was approximately 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> This amount of time was less than the amount determined by engineering for a problem to occur; however, there was no indication that the EDGs would not have continued to operate in an unloaded condition had the scenario not bee The failure to provide a procedure that provides appropriate guidance to the operations staff is a violation of TS 6.8.1.a (50-382/9808-01).

c. Conclusions A violation of TS 6.8.1 was identified for the failure to provide adequate instructions to specify the proper operation of the EDG at no or low load condition _ _ _ _ _ - _ _ - _ _ _ _ - _ _ _ _ _

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3-04 Operator Knowledge and Performance 04.1 Missed TS-Reauired Surveillance Insoection Scooe (71707)

The inspectors reviewed the circumstances conceming a missed TS-required surveillance activity to verify the positions of a CEA within the core, b, Observations and Findinas On April 22,1998, at approximately 3 a.m., the licensee identified a condition where TS-required surveillance activities had not been performed within the required period of time. The specific TS requirements were as follows:

• TS 4.1.3.2: CEA position indication channels agree within 5 inches for the same CEA, verify each 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> TS 4.1.3.1.1: All CEAs are within 7 inches of other CEAs in its group, verify each 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> TS 4.1.3.5.b: Shutdown CEAs are greater than 145 inches, verify each 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> TS 4.1.3.7: Part length CEAs are within Transient insertion Limit (TIL),

verify each 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> . TS 4.1.3.6: Regulating group CEAs are within TIL, verify each 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> TS 4.1.1.1.1.b: Verifying CEA group withdrawal within TIL of TS 3.1.3.6, verify each 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> To satisfy these requirements, the licensee generated a computer printout for CEA position verification approximately every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. It was noted by the licensee that the printout times for the three computer printouts for April 21 were 4:59 a.m.,5 a.m., and 8:40 p.m. The time period between the 5 a.m. printout and the 8:40 p.m. printout was 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> and 40 minutes. This exceeded the allowed time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> plus a TS-allowable extension of 25 percent (a total of 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> maximum time between printouts) by 40 minute The cause of this event was identified as human error on the part 0; the CRS and the l nuclear plant operator when the printout times were not verified at the time they were removed from the printer. Two conditions contributed to this event:

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• The night shift operators printed two computer printouts for the 4 a.m. to 6 period but only removed one set from the printer, leaving the other set on the printe The day shift operators attempted to print a set for the 12 p.m. to 2 p.m. period, but the request was not processed because of a plant computer discrepanc When the day shift operator went to retrieve the 12 p.m. to 2 p.m. computer printout, the second set of 4 a.m. to 6 a.m. logs were mistaken for the midday printout and filed as such. The next scheduled printout was generated at 8:40 p.m.,15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> and 40 minutes after the previous set had been take In response to this event, the licensee verified that the CEAs had not been moved from their parked positions at the upper electrical limit and that no alarms for a minor or major deviation had Deen received during the period in question. Also, an archived printout for CEA position was obtained to verify that the CEAs had remained within the TS-required positions during the time in question. The inspectors considered these actions appropriate and determined, based on this information, that this event was of minor safety significanc Corrective actions to prevent reoccurrence included counseling the CRS and nuclear plant operators who were involved in this event. The importance of verifying the dates and times on the computer printouts was stressed to the CRS and nuclear plant operators. A condition identification was generated to correct the plant computer discrepancy that resulted in the failure to process the print request. In addition, the details of this event will be placed in the operator required reading book to make other operators aware of the importance of ensuring TS-required logs are obtained within the required time frame. The inspectors considered these corrective actions to be appropriat The failure to perform a TS-required CEA position verification demonstrated a lack of attention to detail on the part of the CRS and the nuclear plant operators. This licensee-identified and corrected violation is being treated as a noncited violation consistent with Section Vil B.1 of the NRC Enforcement Policy. Specifically, the violation was identified by the licensee, it was not willful, actions taken as a result of a previous violation should not have corrected this problem, and appropriate corrective actions were l completed by the licensee (50-382/9808-02).

c. Conclusions l Lack of attention to detail by the control room supervisor (CRS) and the nuclear plant operator resulted in a noncited violation, per Section Vll.B.1 of the NRC Enforcement ,

Policy, for the failure to verify the positions of control element assemblies (CEA) within !

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-5-08 Miscellaneous Operations issues (92901)

08.1 Review of Root Cause Analysis for Soent Resin Soill a. lusoection Scooe (92901)

The inspectors interviewed licensee personnel involved in cleanup of the spent resin and the root cause investigation. The inspectors also performed a detailed review of the root cause analysi b. Observations and Findinos As reported in NRC Inspection Reports 50-382/97-28 and 50-382/98-04, a spill of contaminated resin occurred inside the reactor auxiliary building on December 26,199 The cause of the resin spill could not be determined until the resin was removed from the room to minimize the dose received by licensee personnel investigating the cause of the event. The resin removal was essentially completed on March 6,1998, and a licensee investigation was conducted to determine the root cause of the resin spil The individual performing the investigation found that Pump Casing Drain Valve RWM-1255, a %-inch globe valve, appeared to be partially open. The operator was unable to move the valve with normal force, but was able to move the valve by applying excessive force, approximately one-quarter turn with each attempt, in the close direction for a total of approximate!y one and one-half tum A review of the system history showed that Valve RWM-1255 had been opened for Clearance 97-0812 on April 10,1997. The valve was subsequently closed on April 19,1997, when the clearance was removed. The pump had not been operated until December 26,1997, when the resin spill had occurre The investigations team determined that at one and one-half turns, Valve RWM-1255 would have been 30-35 percent open. The investigators postulated that the most probable cause for the event was that Valve RWM-1255 did not fully close with use of J normal force because resin beads had collected on the seating surfaces of the valv {

When the pump was started on December 26, the pump discharge pressure was sufficient to flush the resin beads out and establish a flow path to the floor of the spent

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i resin tank pump roo The proposed long-term corrective actions included: (1) replace Valve RWM-1255 with a ball valve, (2) evaluate and improve the spent resin tank level indication, and (3) evaluate ,

and establish a camera in the spent resin tank or pump rooms to allow visual monitoring I when personnel access is restricted due to fluctuating radiation level I I

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-6- Conclusions The root cause investigation for a contaminated spent resin spill was comprehensiv The proposed corrective actions were appropriat . Maintenance M1 Conduct of Maintenance (61726,62707)

The inspectors observed all or portions of the following maintenance and surveillance activities, as specified by the referenced work authorization (WA) or surveillance procedure numbe *

OP-903-121 Safety Systems Quarterly IST Valve Tests

WA 01169284 High-Pressure Turbine Steam Leak Repair

OP-903-068 EDG and Subgroup Operability Verification

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OP-903-007 Turbine inlet Valve Cycling Test

OP-903-046 Emergency Feed Pump Operability Check in general, the inspectors found the conduct of these maintenance and surveillance activities to be good. All activities observed were performed with the work package and/or test procedures present and in active use. The inspectors observed supervisors and managers monitoring job progress. Quality control personnel were present whenever required by procedur M1.1 Steam Leait Reoair on the Hiah Pressure Turbine Exhaust Flance Insoection Scooe (62707)

The inspectors observed portions of the repair activity and reviewed the procedures and documentation.

f Observations and Findinas On April 6,1998, a steam leak was identified on the high pressure turbine exhaust line to j- Moisture Separator Reheater A. The insulation was removed and scaffolding was l erected in preparation for performing the leak repair. High temperatures in the vicinity of the leak required extreme caution and monitored work period Engineering Review ER-W3-98-0455-00-00 was prepared to support the leak repair effort. The engineer determined that the use of a 360-degree wire wrap repair in

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-7-accordance with Procedure MM-010-045, Revision 1, " Repair of On Stream Leak,"

Attachment 10.4, would be adequate to stop the leak. Maximum sealant injection pressure was determined to be 150 psi and sealant usage was limited to 25 tube WA 01169284 was issued to perform the leak repai On April 15, the wire wrap was performed in accordance with the procedure. When the cap nuts were installed and torqued, the steam leak stopped. The situation was evaluated and the engineer determined that the sealant would not be injected at that time. The WA was left open so that the sealant injection could be performed at a later date if the leak resume The inspectors observed thct proper precautions were taken while working in the elevated temperatures. The workers used appropriate precaution and were very knowledgeable of the task Conclusions The task to repair a steam leak on the high pressure turbine exhaust flange was performed in a professional manner. The engineering evaluation and support was very goo Ill. Enaineerina E1 Conduct of Engineering (37551)

E1.1 Surveillance Procedure Resoonse Time Acceotance Criteria a. Insoection Scooe (37551)

The inspectors reviewed three condition reports (CR) describing inconsistencies between surveillance procedure response time acceptance criteria, the Technical Requirements Manual (TRM) requirements, the current UFSAR Chapter 15 accident analysis, and the plant licensing basi b. Observations and Findinas On April 15,1998, the licensee issued CR 98-0537 to describe a condition where the surveillance procedure acceptance criteria for the turbine-driven Emergency Feedwater (EFW) Pump AB start response time was not adequate to support the current UFSAR Chapter 15 accident analysis, TRM Table 3.3-5 response time requirements, and plant licensing basis. The UFSAR Chapter 15 analysis assumed a time of 42 seconds from the time the engineered safety feature actuation system set point (low steam generator level) was reached until the pump was up to speed with offsite power available. The TRM also contained a 42-second response time requirement for low steam generator level. An acceptance criteria of s42 seconds was specified in Surveillance

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8-Procedure OP-903-047, " Emergency Feedwater Actuation Signal Test," Revision However, the surveillance procedure did not account for the sensor or plant protection system signal processing time because the test was initiated at the plant protection system cabinet A review of the latest test performed on EFW Pump AB indicated that the pump response time was 41.7 seconds Also, the worst case sensor and signal processing test times were 0.425 enconds. When added, these times total 42.125 seconds, which exceeded the 424econd limit. Using the canimum allowable acceptance criteria, a maximum time of 42.675 seconds would be possible. Based on this data, the acceptance criteria in tne surveillance procedure would have to be s41.3 seconds to ensure a total response time of s42 second Upon discovery, the licensee declared EFW Pump AB inoperable and entered the action statement associated with TS 3.7.1.2, which required placing the plant in hot standby within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Prior to exceeding this requirement, the licensee performed a test of EFW Pump AB and readjusted associated components in the Train A circuit to reduce the response time to within required limits. A review of the Train B circuit indicated that no adjustments were required. Following successful testing of EFW Pump AB, the licensee declared the pump operable and exited the TS action statement.'

As result of this discovery, the licensee reviewed TRM Table 3.3-5 to identify any other inconsistencies of this type. Two other similar conditions were identified and documented as follows:

- CR 98-0545 Start Response Time for Containment Fan Coolers

- CR 98-0558 Start Response Times for the High-Pressure Safety injection (HPSI) and Low-Pressure Safety injection (LPSI) Systems In both thecc cases, the acceptance criteria contained in the surveillance procedures could possibly result in the response ames assumed in the FSAR and the TRM requirements being exceeded. However, a review of the actual test results indicated that the response time was within the requirements for both these cases. Because r.,f this, the containrnent fan coolers and HPSI and LPSI pumps were not declared inoperabl The inspectors reviewed the above referenced documents and discussed these issues with licensee personnel. Based on these reviews, it appeared that the actions taken by the licensee were appropriate upon discovery of the inconsistencie The failure to establish adequate measures to maintain applicable regulatory requirements and the design basis for the EFW system, containment fan coolers, and HPSI and LPSI systems is a violation of 10 CFR Part 50, Appendix B, Criterion 111, Design Control (50-382/9808-03).

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-9- Conclusions A failure to implement adequate measures to ensure that correct response time acceptance criteria, for the emergency feedwater, containment fan coolers, and injection systems, were established to meet the Updated Final Safety Analysis Report assumptions and the design basis requirements was identified as a violation of 10 CFR 50, Appendix B, Criterion il E1.2 Review of Operabildy Confirmation Evaluations Insoection Scone (37651)

The inspectors reviewed two licensee evaluations that were performed to confirm the operability of Automatic Switch Company (ASCO) solenoids inside the reactor -

containment building (RCB) and Station Battery A. Thees evaluations were conducted in accordance with Procedure W4.101, " Operability Confirmation Process," Revision b, Observations and Findings On April 1,1998, the licensee identified and documented in CR 98-0564, a concem where ASCO solenoid valves in the RCB that have conduit seals installed may nut have met the requirements of ASCO. There are a total of 29 ASCO solenoids in the RCB and an additional six solenoids in the annulus around the RCB All of the safety-related ASCO solenoid valves located in the RCB and annulus, which are required to operate following a postulated accident, have conduit seals installed to prevent moisture from entering the solenoid enclosure. ASCO recommended that the solenoids be vented to the atmosphere to prevent postaccident pressure equalization resulting in leakage past the gasketed cover or threaded surfaces. The concem was moisture intrusion in the solenoid enclosurc and possible failure of the assembl The licensee performed a detailed evaluation to confirm the continued operability of these solenoids in the sealed configuration. The evaluation stated that the configuration installed in the plant (sealed) had been successfully tested and documented. Also, the evaluation pointed out that a vented solenoid would simply provide an additional pathway for moisture intrusion into the enclosure in the form of vapor. The evaluation concluded that the ASCO solenoids in the RCB were operable in their installed configuratio The inspectors reviewed this evaluation and considered it to be reasonable and sufficiently detailed to support its conclusion. A review and approval of this evaluation was performed on April 22 by the Plant Operations Review Committe On April 27, the licensee issued CR 98-0581 to describe a condition where Station l Battery A showed evidence of broken intemal parts. Specifically, three cells in the Train A safety-related battery were identified as having one or more broken lugs located at the top of every other plate. These lugs form a circular area through which passes a l

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-10-rod. The purpose of this assembly was not immediately apnarent and it was not addressed in the technical manual or other vendor publications. Due to the configuration of the battery cells relative to each other, it was only possible to observe the condition of these assemblies in the eight outermost cell The licensee made an initial operability assessment and considered the battery operabl An evaluation was conaucted to confirm operability. This evaluation documented information supplied by the battery vendor and addressed electrical performance and seismic concems. The purpose of the lug and rod assembly was identified as part of the support structure for the positive plates. The loss of a lug could have resulted in the associated positive plate falling approximately %-inch, coming to rest on the bottom of the battery case. This condition was confirmed to not adversely affect the electrical performance of the battery. No seismic concerns were identified. Trains B and AB safety-related batteries were examined and no other damaged lugs were identified. One uninstalled spare cell was identified as having a broken lu The inspectors reviewed the evaluation and determined that it was adequate to confirm the operability of the Train A safety-related battery. The data contained in the evaluation and the interpretation of that data was reasonable to support the conclusion. No concerns were identified. The Plant Operations Review Committee reviewed and approved this evaluation on April 2 Conclusions Two operability confirmation evaluations, which involved ASCO solenoids and a safety-related battery, appropriately addressed the operability of these component E2 Engineering Support of Facilities and Equipment E2.1 Missed Surveillance on Thermal Overloads a. Insoection Scoce (37551)

The inspectors reviewed the licensee's CR and documentation of the missed l i

surveillance on thermal overloads for motor-operated valves. The inspectors also reviewed the circumstances that required entry into TS 3. Observations and Findinas

On February 4,1998, CR 98-0159 was written to determine if the safety-related thermal i overload relays in the breakers for Containment isolation Valves MS-401 A and -401B should have been tested in accordance with the requirements of TS 4.8.4.2.b.1, which staMs a part. that the thermal overloads are calibrated at least once every 6 year l l

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On February 20, Design Engineering Electrical / Instrumentation and Control completed review and determined that the thermal overloads for Valves MS-401A and -4018 should have been tested in accordance with the TS and that the overloads should have been listed in the TRM. Licensing was given the task to perform a deportability determination -

by February 2 On March 12, licensing determined that the thermal overloads for Valves MS-401 A and-401B had not been tested, as required by TS 4.8.4.2.b, because the valves were not listed in TRM Table 3.8-2. CR 98-0366 was written to address the deportability issu When the CR reached the control room, the shift superintendent declared Valves MS-401 A and -401B and EFW Pump A/B inoperable and entered the appropriate TS action statements. The overloads were tested and the valves and EFW Pump A/B were restored to an operable status within approximately 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. The inspectors asked if there were any other valves that had not been appropriately listed in TRM Table 3.8-2 and thus required testing in accordance with TS 4.8.4.2.b. The response was that it was unlikely that there were others, but the review process should reveal to them if there were anymore valves that should be teste On March 30, a third CR was written. CR 98-0462 identified six additional valves with overloads that should have been listed in TRM Table 3.8-2 and tested in accordance with TS 4.8.4.2.b, but had not been. Valves SI-135A(B), -125-A(B), and -412A(B), in both trains of the emergency core cooling system, were inoperable because of the missed surveillance. The shift superintendent declared both trains of the emergency core cooling system inoperable and entered TS 3.0.3. TS 4.0.3, which allowed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to complete the appropriate surveillance, was entered. The surveillance were completed and the TS action statements were exited within the appropriate tim This is an additional example of narrowly focused scoping of a problem, similar to the issue with diaphragm valves discussed in NRC inspection Report 50-382/98-06. The inspectors determined that the failure to test the thermal overloads on all motor-operated valves is a violation of TS 4.8.4.2.b (50-382/9808-04). Conclusions A violation was identified for the failure to test the thermal overload relays for all containment isolation valves as required by TS 4.8.4.2.b.1. The initial scope of the review to identify missed surveillance on all effected safety-related valves was narrowly focuse E8 Miscellaneous Engineering issues (92903)

E8.1 (Closed) Licensee Event Reoort (LER) 98-005: Missed Thermal Overload TS Surveillance This LER is closed based on the discussion provided in Section E2.1 of this report.

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IV. Plant Support R1 Radiological Protection and Chemistry Controls i

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R1.1 Control of Zebra Mussels and Other Biologicals in Coolina Water Systems Inspection Scope (71750) j A review of the licensee's program for control of microbiological organisms was reviewed Observations and Findings The inspectors reviewed the licensee's program and procedures and determined that a continuous program for control of zebra mussels in the circulating water system in accordance with Procedure CE-003-157, Revision 2, " Zebra Mussel Monitoring," had t

been establishe The closed-loop systems, while not vulnerable to zebra mussels, were susceptible to microbiological. Chemistry conducted a continuous aggressive monitoring and water .

treatment program for the component cooling water, auxiliary component cooling water, diesel generator jacket cooling water, essential chill water, turbine component cooling water, and supplemental chill water systems. Each system was uniquely treate Conclusions i

The chemistry monitoring and biological control programs for cooling water systems were very goo R5 Staff Training and Qualification R General Emolovee Trainina a.- Insoection Scooe (71750)

The inspectors audited the respiratory protection training program to assess the quality of training provide Observations and Findinos

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. The inspectors audited the radiological respiratory protection training program. The course provided the appropriate level of training on the different types of respiratory protection equipment.

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-13-1 Conclusions Conduct of the course on respiratory protection program was professional, with appropriate individual attention from the instructo P1 Conduct of EP Activities P Observations of Emeroency Exercise I

' Insoection Scone (71750)

The inspectors monitored the performance of a licensee practice drill to verify

- compliance with the appropriate requirement Observations and Findinas

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. On April 15,1998, the inspectors observed a site-wide emergency exercis Observations were conducted in the control room (simulator), Technical Support Center, and emergency operations facility. Both state and parish emergency response agencies participated in the exercis The inspectors observed that, in general, the exercise activities were very goo However, one problem and one potential weakness was observed. The problem was -

that the simulator scenario time was not real time. This caused some confusion during communications with the Technical Support Center, emergency operations facility, and operations support center because their clocks showed real time. The emergency planning manager stated that this problem would be resolved for future exercise Conclusions in general, conduct of the licensee's practice emergency exercise was very goo S1' Conduct of Security and Safeguards Activities S Observation of Routine Security Activities The inspectors observed routine ingress and egress at the protected area access poin Security officers appropriately performed screening and search of personal item F6 . Fire Protection Organization and Administration l.

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F Revised Occupational Safety and Health Administration (OSHA) Reaulation Affectina Fire Briaade Staffina

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-14- insoection Scooe (71750)

A review was conducted to determine the licensee's implementation of a new OSHA regulation regarding changes in the staffing of the fire brigad Observations cnd Findinas The inspectors discussed with licensee management, the changes to 29 CFR 1910.134, which requires two of the five fire brigade members to remain outside the zone of the fire for rescue purposes. This, in essence, would restrict combating the fire to a single hose (three member fire brigade versus the normal two hoses for a five member brigade),

which could inhibit the ability to mitigate a fire in a timely manner. Licensee management stated that this issue was being reviewed and would be addressed by Entergy for all four sites (Waterford 3, Arkansas Nuclear One, Grand Gulf, and River Bend) prior to the required implementation date of October 5,199 Conclusions The licensee had appropriate plans to implement the revised OSHA regulation for fire brigade staffin V. Management Meetings X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management on May 12,1998 Ine kensee acknowledged the findings presente The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie l

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ATTACHMENT 1 SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED

Licensee

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F. J. Drummond, Director Site Support C. M. Dugger, Vice-President, Operations E. C. Ewing, Director, Nuclear Safety & Regu atory Affairs C. Fugate, Operations Superintendent T. J. Gaudet, Manager, Licensing J. G. Hoffpauir, Manager, Operations T. R. Leonard, General Manager, Plant Operations D. C. Matheny, Manager, Operations G. D. Pierce, Director of Quality D. W. Vinci, Superintendent, System Engineering A. J. Wrape, Director, Design Engineering INSPECTION PROCEDURES USED IP 37551: Engineering IP 61726: Surveillance Observation IP 62707: Maintenance Observation IP 71707: Operations IP 71750: Plant Support Activities IP 92901: Followup - Operations IP 92903: Followup- Engineering ITEMS OPENED. CLOSED. AND DISCUSSED ,

Ooened I

50-382/9808-01 VIO Failure to establish adequate procedure to provide guidance for proper operation of the EDG at no or low loads (Section O3.1). l

50-382/9808-02 NCV Failure to perform TS-required CEA position verification l (Section 04.1).

50-382/9808-03 VIO Failure to establish adequate measures to maintain applicable regulatory requirements and the design basis for the EFW system, the containment fan coolers, and the HPSI and LPSI systems (Section E1.1).

50-382/9808-04 VIO Failure to perform appropriate surveillance because of inadequate procedures (Section E2.1).

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Closed 50-382/9808-02 NCV Failure to perform TS-required CEA position verification (Section 04.1).

50-382/98-005 LER Missed Thermal Overload TS Surveillance (Section E8.1).

LIST OF ACRONYMS USED ASCO Automatic Switch Company CEA control element assembly CFR Code of Federal Regulations CR condition report CRS control room supervisor EDG emergency diesel generator EFW emergency feedwater HPSI high pressure safety injection LPSI low pressure safety injection NRC Nuclear Regulatory Commission NUREG NRC technical report designation PDR Public Document Room psi pounds per square inch RCB reactor containment building TIL transient insertion limit TRM Technical Requirements Manual TS Technical Specification UFSAR Updated Final Safety Analysis Report WA work authorization