IR 05000382/1985028

Insp Rept 50-382/85-28 on 851001-1130.Violations Noted: Failure to Perform Work Per Maint Procedures,Wet Cooling Tower Water Level Below Tech Spec Requirement & Annunciator Setpoints Below Tech Spec Min Value

ML20136F518
Person / Time
Site:	Waterford
Issue date:	01/02/1986
From:	Breslau B, Bundy H, Constable G, Filippo T, Flippo T, Luehman J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20136F504	List: ML20136F501 ML20136F511 ML20136F518
References
50-382-85-28, NUDOCS 8601070417
Download: ML20136F518 (10)

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APPENDIX B U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-382/85-28 License: NPF-38 Docket:

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50-382 Licensee: Louisiana Power & Light Company (LP&L)

142 Delaronde Street New Orleans, Louisiana 70174 Facility Name: Waterford Steam Electric Station, Unit 3 Inspection At: Taft, Louisiana Inspection Conducted: October.1 through November 30, 1985 p (~ ,

Inspectors: .M~' //2/66

[p.[G.'Luehman, Senior Resident Inspector Date

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b T. A. Flippo, Resident Inspector 4A&

D&ts LA //Al96 B. A. Breslau, Project Engineer, Project Dra te Section C, Reactor Projects Branch Y =

Y /2-3/- ff H. F. Bundy, Project Inspector, Project Date Section C, Reactor Projects Branch

_ . f x Approved: / ~ //t/64 T LT Constable 7 Chief, Project Section C Ddte Reactor Projects Branch 8601070417 860102 2 DR ADOCK 050

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Inspection Summary Inspection Conducted October 1 through November 30, 1985 (Report 50-382/85-28)

Areas Inspected: Routine, announced inspection of: (1) Plant Status; (2) Licensee Event Report Followup; (3) Monthly Maintenance; (4) Monthly Surveillance; (5) ESF System Walkdown; (6) Routine Inspection; (7) License Conditions; and (8) Wet Mechanical Draft Cooling Tower Water Basin Level. The inspection involved 198 inspector-hours onsite by four NRC inspector Results: Within the areas inspected, two violations were identified (failure to perform work in accordance with maintenance procedures, paragraph 5, and wet cooling tower water level below technical specification requirement, paragraph 10). One unresolved item was identified (annunciator setpoint errors, paragraph 8).

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DETAILS Persons Contacted Principal Licensee Employees R. S. Leddick, Senior Vice President, Nuclear Operations

• R. P. Barkhurst, Plant rianager, Nuclear T. F. Gerrets, Corporate QA Manager S. A. Alleman, Assistant Plant Manager, Plant Technical Staff N. S. Carns, Assistant Plant Manager, Operations and Maintenance J. N. Woods, QC Manager A. S. Lockhart, Site Quality Manager R. F. Burski, Engineering and Nuclear Safety Manager K. L. Brewster, Onsite Licensing Engineer G. E. Wuller, Onsite Licensing Coordinator

• Present at exit intervie In addition to the above personnel, the NRC inspectors held discussions with various operations, engineering, technical support, maintenance, and administrative members of the licensee's staf . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations or deviations. An unresolved item disclosed during the inspection is discussed in paragraph . Plant Statur At the beginning of the inspection period the plant was at about 20%

power, reaching 100% power later on October 1,1985. On October 2, 1985, a reactor trip occurred on low steam generator level following a feed pump trip which resulted from a failure in the feedwater control system. The plant again achieved criticality at 1:58 p.m. on October 2, 1985, however, another reactor trip, this time on high steam generator level, occurred that day at 8:35 p.m. The plant remained shut down to replace reactor coolant pump seals and was not returned to criticality until 7:34 p.m. on October 10, 1985. On October 20, 1985, at 7:20 p.m., with the plant again at 100% power, a reactor trip occurred resulting from an auxiliary high pressurizer pressure trip after loss of one of the main feedwater pumps The plant achieved criticality on October 30, 1985, the following da On November 15, 1985, with the plant at 100% power, a number of turbine steam transients occurred due to problems with Governor Valve 4 on the

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main turbine. In each case, turbine output increased to about 105% powe These increases were detected by the core protection calculator (CPC)

channels but no pretrip setpoints were reached. The plant operators took actions to control the transients and, subsequently, the governor valve was closed and isolated. The plant operated the remainder of the inspection period at or near full powe No violations or deviations were identifie .. Licensee Event Report (LER) Followup The following LERs were reviewed and close The NRC inspectors verified that reporting requirements had been met, that causes had been identified, that corrective actions appeared appropriate, that generic applicability had been considered, and that the LER forms were complete. Additionally, the NRC inspectors confirmed that no unreviewed safety questions were involved and that violations of regulations or Technical Specification (TS) conditions had been identifie (Closed) LER 50-382/84-01 Engineered Safety Features Actuation on Control Room Isolation (Closed) LER 50-382/84-02 Fire Door Technical Specification Surveillance (Closed) LER 50-382/85-01 Failure to Post a Fire Watch (Closed) LER 50-382/85-08 Uncomplicated Reactor Trip (Closed) LER 50-382/85-11 Missed Samples (Closed) LER 50-382/85-12 Fire Protection Configuration in Fire Zone 27C (Closed) LER 50-382/85-15 Inoperable Liquid Effluent Monitor Rev. O and Rev. 1 (Closed) LER 50-382/85-16 Pressurizer Heat Capacity Less than Technical Specifications (Closed) LER 50-382/85-19 Missed Sample on Gas Decay Tank (Closed) LER 50-382/85-26 Inoperable Fire Wall (Closed) LER 50-382/85-27 Manual Actuation of the Reactor Protective System

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(Closed) LER 50-382/85-30 Inadvertent Actuation of Radiation Monitors - The NRC inspector suggested to the licensee that a review of the response to IE Circular 80-09 may be appropriat (Closed) LER 50-382/85-31 Automatic Actuation of Reactor Protective System Due to Feed Pump Trip (Closed) LER 50-382/85-35 Reactor-Trip Due to Inadvertent Turbine Runback Additionally, the NRC inspector noted that the licensee had not been including the identifiers required by 10 CFR 50.73(b)(2)(ii)(F) in the >

event report Subsequent reports have contained the identifiers as require . Monthly Maintenance Station maintenance activities affecting safety-related systems and components were observed / reviewed to ascertain that the activities were conducted in accordance with approved procedures, regulatory guides and industry codes or standards, and in conformance with T The NRC inspector reviewed two completed Condition Identification Work Authorization (CIWA) packages which involved the replacement of packing in Charging Pumps A and A The completed CIWA packages were reviewed to verify licensee conformance to the following:

. Licensee administrative requirements, including format, approval, and control

. Post-maintenance testing was appropriate for the repairs made

. Inspection and hold points were identified in the procedure or in a documented plan, and are based on a set of established guidelines

. Supplementary reference material, such as drawings and technical manuals, are adequate and controlled

. Activity is described in sufficient detail

. Consideration is given to radiological controls

. Provisions for cleanliness and housekeeping are adequate

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. Provisions for obtaining approval from operations as well as method for notifying operations when affected systems are removed from service and ready to be restored to normal service The licensee's Administrative Procedure UNT-5-002, Attachment 6.2, page 7, requires work group supervisor and Shift Supervisor (SS)/ Control Room Supervisor (CRS) initials to be noted in block 29 of the applicable CIWA indicating concurrence on proposed work instructions. However, the NRC inspector observed that the work group supervisor and SS/CRS did not initial block 29 in CIWAs 022173 and 022169 charging pump maintenance for Pumps A and AB respectivel UNT-5-002, Attachment 6.3, page 7, requires technical manual numbers and applicable sections be entered in block 28 of the CIWA. However, neither CIWA 022173 nor 022169 had the applicable technical manual sections referenced in block 2 UNT-5-002 further requires that part numbers for those items replaced be inserted in block 48 of the CIWA. CIWA 022173 had numbers inserted in block 48 which were procurement document numbers, not part number Maintenance Procedure MM-6-003, Section 4.0, " Precautions," and Section 5.0, " Initial Conditions," state these items will be included in the CIWA. CIWAs 022173 and 022169 did not include " Precautions / Initial Conditions."

Procedure QP-10-001, Attachment 6.2, outlines the requirements for inspection hold points in the work packages. CIW'., 022173 and 022169 required hold points for verifying cleanliness; no hold points were established in the work instructions for verifying cleanliness of components prior to reassembl The above items are considered a violation and are identified as 50-382/8528-0 . Monthly Surveillance The NRC inspectors observed / reviewed TS required testing and verified that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that limiting conditions for operation (LCO) were met, and that any deficiencies identified were properly reviewed and resolve On November 21, 1985, the NRC inspector observed the performance of PE-5-004, Revision 2, " Control Room Air Conditioning Surveillance," on Train A. This test was performed to, in part, meet TS Surveillance Requirement 4. . .

For some portions of the surveillance test the licensee used contractor personnel, equipment, and procedure The NRC inspector verified that the contractor personnel had proper documentation of their qualifications as well as documentation of the calibration of their equipmen Additionally, it was verified that all contractor procedures used had received the proper licensee reviews and approva No violations or deviations were identifie . ESF System Walkdown The following selected ESF system was verified operable by performing a walkdown of the accessible and essential portions of the system on November 19-20, 198 . Emergency Feedwater System (Drawing LOU 1564-6-153, Sheet 2 and OP-9-003, Revision 3, Attachment 8.1)

No violations or deviations were identifie . Routine Inspection By observation during the inspection period, the NRC inspectors verified that the control room manning requirements were being met. In addition, the NRC inspectors observed shi't turnover to verify that continuity of system status was maintained. ihe NRC inspectors periodically questioned shift personnel relative to their awareness of the plant condition Through log review and plant tours, the NRC inspectors verified compliance with selected TS and limiting conditions for operation During the course of the inspection observations relative to protected and vital area security were made including access controls, boundary integrity, search, escort, and badgin On a regular basis, Radiation Work Permits (RWP) were reviewed and the specific work activity was monitored to assure the activities were being conducted per the RWP Selected radiation protection instruments were periodically checked and equipment operability and calibration frequency were verifie The NRC inspectors kept informed on a daily basis of overall status of plant and of any significant safety matter related to plant operation Discussions were held with plant management and various members of the operations staff on a regular basi Selected portions of operating logs and data sheets were reviewed dail , The NRC inspectors conducted various plant tours and made frequent visits to the control room. Observations included: witnessing work activities in progress; verifying the status of operating and standby safety systems and equipment; confirming valve positions, instrument and recorder readings, annunciator alarms; and housekeepin While verifying annunciator status in the centrol room the NRC inspector reviewed the unnunciator response procedures for wet basin level and selected other annunciators associated with TS required systems. The results are outlined below, OP-500-012, Revision 1, Annunciator C-11 and OP-500-011, Revision 1, Annunciator C-1 - Wet basin level low setpoints not the same and below TS minimum value. For details see paragraph 10 of this repor OP-500-009, Revision 1, Annunciators A-17, E-19, E-20, G-19, G-20, C-17, C-18, L-19, and L-20 as well as OP-500-011, Revision 1, Annunciator H-4 and OP-500-012, Annunciator H-14 - Specify wrong containment pressure high setpoint. TS setpoint is 17.1 psia while procedures specify 17.4 psia (except H-4 and H-14 which specify 18 psia), OP-500-009,. Revision 1, Annunciator A-13 - Specifies an incorrect value for the setpoint for log PWR high channel trip setpoin TS setpoint is .257% while the procedure specifies .895%. OP-500-009, Revision 1, Annunciators G-19 and 20 - Specify different pressurizer pressure setpoints. One procedure specifies 1684 psia while the other specifies 1889. Both setpoints are greater than or equal to TS required minimum setpoin OP-500-009, Revision 1, Annunciators M-19 and 20 - Specify steam generator level setpoints below that of TS. TS setpoint is $27.4%

while the procedures specifies 26.9% OP-500-0012, Revision 1, Annunciator A-20 - Specifies a low refueling pool water storage level below that required by TS. TS setpoint is 82%

while the procedures specifies 78.6%. OP-500-011 Annunciator K-1 and OP-500-012, Annunciator K-11 - Steam Generator 2 response indicates setpoint if Safety Injection Actuation System (SIAS) signal is present. Steam Generator 1 does no ~

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L 9 Each procedure should contain two setpoints, one with and one without SIAS present.

. OP-500-011, Revision 1, Annunciator M-7 and OP-500-012, Revision 1,

AnnunciatorM-17-Specifydifferentsubcoolingmarginsetpoints.One l> channel specifies 20 F while the other specifies 30 F.

L l Other annunciater response procedures for systems such as toxic gas monitoring and loose parts monitoring indicate that setpoints were to be added "later." The annunciators are operable and have some setpoints but they have not been reflected in these procedures, Finally, in an effort to address some of the problems identified above, j the NRC inspector and a senior reactor operator (SR0) attempted to consult l the plant setpoint document. In many cases this document was of little

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use because setpoints were expressed only in terms such as inches or volts. Setpoints expressed only in such terms are of little use to control room operators if questions of annunciator and/or equipment l

operational setpoints arise.

L l Though annunciators serve as operator aids and are not the means by which i TS parameters are verified, havir.g the correct setpoints on the respc.1se procedures is necessary to help the operators determine if a valid

! abnormal condition exists. Presently, this is especially true for the i Waterford 3 control room with the large number of continuously illuminated annunciators. The correction of the setpoint errors in the above procedures is identified as an Unresolved Item 50-382/8528-0 . License Conditions (Closed) 2.c.9.g., Continuous fire watch in the relay room at the isolation panel - In a letter to the Office of Nuclear Reactor Regulation (NRR) dated June 7, 1985, the licensee informed the NRC of the completion of the changes required to terminate the continuous fire watch. The changes necessary had earlier been outlined to the NRR in a letter dated February 22, 198 The NRC inspector reviewed the procedure changes

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associated with this license condition chang No violations or deviations were identifie . Wet Mechanical Draft Cooling Tower Water Basin Level

! As a followup to the annunciator response procedure problems for the wet I tower basin level discussed in paragraph 10 of this report, the NRC inspector requested licensee support engineering to review the basis of the setpoints used. The subsequent review revealed that the level I indication instrumentation for the two basins had been calibrated so that l 100% indicated level corresponded to the minimum level required by TS l

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F f3 (Under the assumption that 100% indicated level equated to 100% actual

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1. '(/ 2 level, licensee operations personnel have maintained basin levels above

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c violates.the1TS requirement. When this calibration problem was -

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identified, the-licensee promptly filled both basins to overflowing and

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initiated ~ action to recalibrate the level instrumentatio ,

[TS 3.7.4 ACTION b. requires that with both towers inoperable due to basin

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low water level, one tower has to be restored to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and both restored to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Being

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unaware of the level calibration problem, licensee personnel had not followed the TS requirement '

Thisisanapparentviolation(50-382/8528-02).

1 Exit Interview  ;

The inspection scope'and findings were suninarized on December 2,1985, with those persons indicated in paragraph 1 above. The licensee acknowledged the NRC inspectors' findings. The licensee did not identify as proprietary any' of the material provided to or reviewed by the NRC inspectors during this inspectio ,-

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