ML20138K237

Insp Rept 50-382/97-04 on 970223-0405.Violations Noted.Major Areas Inspected:Evaluating Aspects of Licensee Event Response,Operations,Maint,Engineering & Plant Support

ML20138K237
Person / Time
Site:	Waterford
Issue date:	05/05/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20138K222	List: ML20138K217 ML20138K224 ML20138K237
References
50-382-97-04, 50-382-97-4, NUDOCS 9705120284
Download: ML20138K237 (21)

See also: IR 05000382/1997004

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ENCLOSURE 2

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U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

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Docket No.: 50-382

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License No.: NPF-38

Report No.: 50-382/97-04

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Licensee: Entergy Operations, Inc.

Facility: Waterford Steam Electric Station, Unit 3

Location: Hwy.18

Killona, Louisiana

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Dates: February 23 through April 5,1997

Inspectors: L. A. Keller, Senior Resident inspector

T. W. Pruett, Resident inspector

G. A. Pick, Senior Project Engineer

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

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Attachment: Supplemental information

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1 9705120284 970505

PDR ADOCK 05000382 S

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EXECUTIVE SUMMARY

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Waterford Steam Electric Station, Unit 3

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NRC Inspection Report 50-382/97-04

' This routine, announced inspection included evaluating aspects of licensee event response,

" operations, maintenance, engineering, and plant support. The report covers a 6-week

period of resident inspection.

Ooerations

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Shift turnovers, operator knowledge of control panel annunciators and deficiencies,

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tagging program implementation, and control panel walkdowns were generally good

(Section 01.1). '

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Observed operations activities were generally performed in a manner consistent

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with safe operation of the facility (Section 01.1). )

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Operator response to a nearby chemical release of ammonia and declaration of an

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. Alert was conservative and consistent with the emergency plan (Section 04.1).

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A violation was identified for failure to implement Technical Specification

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requirements for limiting working hours and approving deviations. Management

demonstrated weak oversight of working-hour policies. In addition, management i

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delegated approval authority for overtime requirement deviations to an inappropriate I

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Operations personnel declared Train 8 of Shield Building Ventilation (SBV) operable

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The licensee properly implemented procedures for new fuel receipt inspections

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(Section M1.2.b).

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Enaineerina

A violation was identified regarding engineering's failure to recognize that the

maximum allowed Technical Specification flow rate for Train B of the SBV system

was exceeded, which resulted .in SBV Train B being inpperable in excess of the

Technical Specification-allowed outage time of 7 days and Train A being taken out

of service for maintenance during that period, rendering both Trains of SBV

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inoperable for 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> and 18 minutes (Section M1.3.b).

Engineering generally provided good technical support to operations and

maintenance. The violations identified with the emergency feedwater (EFW) were

the result of closing out old open issues and, as a result, did not necessarily reflect

current performance (Section E1.1).

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Two examples of a violation regarding inadequate 10 CFR 50.59 evaluations were

identified that involved the use of EFW flow control valves as containment isolation

valves and the valves did not have qualified direct position indication (Section E8.1).

Plant Sucoort

Housekeeping and material condition was geneirally good (Section 01.1)

Observed n.c..ation protection activities were performed in accordance with

procedures and were consistent with ALARA principles (Section R1.1).

Security properly implemented requirements for vehicle searches and protected area

illumination (Section S1.1).

The recently installed Taft Industrial Complex Communications radio enhanced the -

control room operators ability to monitor and assess nearby chemical releases

(Section 04.1).

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Report Details 1

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Summarv of Plant Status

The plant operated at essentially 100 percent power throughout this inspection period. An

Alert was declared on March 20,1997, following reports of a nearby chemical release.

f. Operations

01 Conduct of Operations

01.1 General Commena,p1707)

The inspectors performed frequent reviews of ongoing plant operations, control

I. room board walkdowns, and plant tours. Observed activities were generally

performed in a manner consistent with safe operation of the facility. Operator

response to a nearby ammonia release was gcod. Housekeeping and material

condition were generally good. The inspectors observed several shift turnovers in

the control room and determined that operators performed thorough discussions of

issues affecting plant operations and good control panel walkdowns. Operators

were knowledgeable of the reasons for annunciators c1d control panel deficiencier

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Spot checks of danger tags in the plant indicated the tagging program {

implementation was good. However, a review of the use of overtime by station

personnel during the month of February revealed violations of Technical

Specification (TS) requirements, as discussed below. -

04 Operator Knowledge and Performance

04.1 Nearb9 Ammonia Release and Declaration of Alert (93702. 71707. 71750)

On March 20, at 1:03 a.m. (CST), a toxic chemical Alert was declared at the

Waterford 3 site as a result of a release of gaseous ammonia from a nearby

chemical processing plant.

Just prior to the declaration of an Alert, numerous barges came loose from their

mooring upstream of the plant and were swept down the river. Three of the barges

hit the intake structure dolphins (which protect the circulating water intakes for the

main condenser). Minor damage was done to the dolphins; however, there was no

impact on plant systems.

After hitting the protective structure at the Waterford 3 site, the barges continued

downstream and hit the loading dock of a chemical processing plant, which caused

a pipe used to transfer ammonia from the plant to a barge to rupture. The ruptured

pipe only released a " puff" of residual ammonia vapors since it was isolated from

the processing plant. The licensee was notified by the local emergency response

organization and declared an Alert to ensure all onsite personnel would seek

sheltering. At the time of the event, the wind was blowing in a direction from the

site toward the release point. At 1:42 a.m., the licensee confirmed that the release

had been of short duration and terminated the Alert.

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The inspectors reviewed the licensee's response to this event and determined that

the actions were conservative and consistent with the emergency plan. The

inspectors noted that the recently installed Taft Industrial Complex Communications

radio enhanced the control room operator's ability to monitor and assess the nearby

chemical release and improved the licensee's emergency response capabilities.

06 Operations Organization and Administration

06.1 Workino-Hour Limitations for Operations Personnel

a. Inspection Scoce (717071

The inspectors reviewed the use of operations department overtime during the

period of February 1 through March 1,1997, to ensure the licensee met the

working-hour limitations of TS 6.:c.2.e.

b. Observations and Findinas

TS 6.2.2.e requires that administrative procedures be developed and implemented

to limit the working hours of individuals of the nuclear plant operating staff. In the

event that unforeseen problems require substantial amounts of overtime to be used,  !

the guidelines include, in part, that an individual shall not be permitted to work more ,

than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24-hour period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period,  !

nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period, excluding shift turnover time.

Deviations shall be approved by the General Manager Plant Operations, Manager

Technical Services, Manager Operations and Maintenance, Operations

Superintendent, or higher levels of management. Procedure UNT-005-005,

" Working Hour Policy for Nuclear Safety-Related Work," Section 5.2.1, specified

that approval shall be received prior to exceeding the policy guidelines,

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During a review of February 1997 time records for 44 operations employees, the

inspectors determined that one shift technical advisor worked 31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br /> in a 48-hour

period, excluding shift turnover between February 21-22, and worked 76.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />,

excluding shift turnover time, in a 7-day period between February 17-23, without

receiving approval for the deviations.

The licensee provided the inspectors with two working-hour deviations that had

been approved for the employee on February 21 and 23, authorizing greater than

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of work in a 48-hour period. However, the deviations did not authorize

the employee to exceed working-hour limitations for February 22 and between

. February 17-23. Additionally, the deviation for February 23 was approved by the

Operations Administrative Assistant, a management position below the positions

described in the TS, after the hours were exceeded.

The inspectors performed a review of all working-hour deviations for operations

approved in February and determined that the Operations Administrative Assistant

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approved working-hour deviations for 12 additional individuals, ol which one

deviation was for himself. In addition, approval to exceed working-hour

requirements for 11 individuals occurred after the maximum allowed hours were

exceeded. Additional examples of failure to comply with working-hour requirements

involving maintenance personnel are discussed in Section M6.1. The failure to

implement the requirements for limiting working hours is the first example of a

violation of TS 6.2.2.e (50-382/9704-01).

c. Conclusions

Licensee management failed to provide effective oversight for the control of working

hours for operations personnel. A violation involving the failure to implement the TS

requirements for limiting working hours and approving working-hour deviations for

Operations personnel was identified.

II. Maintenance

M1 Conduct of Maintenance

M 1.1 General Comments

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a. Insoection Scope (62707,61726) I

The inspectors observed all or portions of the following maintenance and

surveillance activities:

PE-005-OO4 Control Room Air Conditioning in-Place Filter and Charcoal

Adsorber Testing

WA 01156772 Control Room Air Conditioning Charcoal Sampling

RF-002-001 Fuel Receipt inspection

WA 01155200 Shield Building Ventilation Testing

M1.2 Fuel Receiot Insnections (62707)

The inspectors observed new fuel receipt inspections on March 19, to determine if

the licensee adequately inspected and handled new fuel. The inspectors determined

that the licensee properly implemented procedural requirements for radiological

surveys, security inspections, industrial safety, handling of fuel, and quality control

inspections. Personnel involved with the receipt inspections had participated in the

requisite training and were knowledgeable of techniques associated with handling of

new fuel. The inspectors noted that the presence of the refueling supervisor and

the reactor engineering and performance superintendent contributed to the receipt

inspection process.

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M1.3 Shield Building Ventilation Surveillance Testina

a. Insoection Scone (61726) '

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The inspectors reviewed completed data sheets for SBV Train B to determine if

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adequate testing was performed to demonstrate satisfactory completion of TS '

Surveillance Requirement 4.6.6.1. '

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b. Observations and Findinas

TS Surveillance Requirement 4.6.6.1 requires that each SBV system be

demonstrated operable at least once per 18 months by verifying that the ventilation

system satisfies the in-place testing acceptance criteria and uses the test l

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procedures of Regulatory Positions C.S.a, C.5.c, and C.S.d of Regulatory i

Guide 1.52, Revision 2, March 1978, and the system flow rate is 10,000 acfm '

110 percent. On March 5,1997, engineering performed surveillance testing on

Train B SBV in accordance with Procedure PE-005-003, " Shield Building Ventilation

System Surveillance."

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On March 20, the inspectors performed a review of the data sheets associated with

the performance of the SBV Train 8 surveillance test completed on March 5.

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l Procedu.e PE-005-003, Attachments 10.2,10.3, and 10.4, recorded that the actual t

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flow rate during the test was 11,911 acfm. The inspectors noted that

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Procedure PE-005-003, Section 7.0, " Acceptance Criteria," specified that the  !

required flow rate was 10,000 acfm 10 percent. In addition, Sections 8.3,

" Airflow Capacity and HEPA/HECA DP Check," 8.4, "In-Place Leak Test - HEPA

Filters," and 8.5, "In-Place Leak Test Adsorbent," included notes that required the

flow rate to be 10,000 acfm 110 percent to perform testing.  !

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In response to the inspectors observation, the licensee initiated Condition

Report (CR) 97-0664, declared SBV Train B inoperable, and adjusted Damper

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Valve SBV-101B to reduce the air flow rate to within the allowable acceptance

l criteria. Testing performed on March 20, following adjustment of the damper,

j determined that the flow rate was reduced to 10,828 acfm.  ;

On March 21, the inspectors reviewed Work Authorization 01155200 and noted

that two contractors and the SBV system engincer had reviewed the flow rate data

and signed that the results were acceptable after completion of the testing. The j

system engineer stated that, although the acceptance criteria of 10,000 acfm '

10 percent was clearly specified in the procedure, he, as well as the contractors,  !

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incorrectly believed that the acceptance criteria was 11,000 acfm i10 percent.

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The inspectors noted that operations did not review the results from the partially i

completed test even though the operations staff returned the system from an

inoperable to operable status. The lack of operations' oversight contributed to the

restoration of an inoperable component to an operable status. In response to the

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inspectors' concern, the licensee initiated a review to determine if additional

procedural controls needed to be implemented to ensure operations maintained

cognizance of partially completed surveillance tests.

The inspectors questioned engineering to determine what detrimental effects could

result from increased air flow through the SBV unit. Engineering stated that two

effects were possible. First, the residence time of the charcoal would decrease,

which could result in radioiodine not being absorbed by the charcoal. The

inspectors determined that the residence time was not adversely affected because:

(1) the American National Standards Institute (ANSI) N510 acceptance criteria for

residence time is 120 percent and the actualincrease in flow was less than

19 percent, (2) the minimum required amount of charcoal to adsorb radiciodine

following an accident is 704 pounds and the actual amount of charcoal installed is

1895 pounds, (3) laboratory testing performed by the vendor indicated that the

increased air flow would have increased the penetration of methyl iodide to

0.016 percent, which is less than the 0.175 percent allowed, and (4) the in-place

charcoal adsorber test results did not indicate any breakthrough of halides.

Secondly, increased flow rates could affect the high efficiency particulate air (HEPA)

filters or channel the charcoal, which would result in a decrease of radiciodine

removal capability. The inspectors determined that the reduction in radiciodine

removal capability was not a significant concern because: (1) the testing performed

on March 24 demonstrated that channeling of the charcoal adsorbers had not

occurred, (2) charcoal overfilling in the filtration unit minimized the potential for

carryover, (3) the 4-inch bed depth is greater than the minimum required 2-inch bed

depth,'and (4) the actual flow of 11,911 acfm is less than the rated flow of

12,000 acfm for SBV HEPA filters.

On March 21, the licensee informed the inspectors that between March 19,

4:02 a.m. and March 20,4:20 p.m., a period of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> and 18 minutes, both

trains of SBV were inoperable. Train A was inoperable for planned maintenance and

Train B was inoperable due to exceeding the required TS maximum flow rate of

11,000 acfm. The operators allowed SBV Train A to be tagged out for

maintenance, since they were unaware of the March 5 surveillance test failure for

SBV Train B. The inspectors determined that the failure to recognize that SBV

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Train B exceeded its maximum TS flow rate limit before the 7-day allowed outage

time expired is a violation of TS 3.6.6.1 (50-382/9704-02). .

in addition to the above, both Trains of SBV were inoperable for a period exceeding

the limiting condition for operation allowed outage time. However, since the

licensee was not aware of the inoperability of Train B due to noncompliance with

surveillance requirements until identified by the inspectors, actions could not have

been taken to address the Technical Specification 3.0.3 noncompliance issue. For

this reason, a separate violation of Technical Specification 3.0.3 was not cited.

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c. Conclusions

A violation was identified regarding the failure to recognize that the maximum

allowed TS flow rate for SBV Train B was exceeded during surveillance testing on

March 5,1997. The licensee's review and approval process for this surveillance

was inadequate in that the error remained undetected until identified by inspectors

on March 20. Since the licensee was not aware that Train B was inoperable due to

noncompliance with surveillance requirements, actions could not have been taken to

address the Technical Specification 3.0.3 noncompliance when Train A was taken

out of service for maintenance. For this reason, and with the recognition that SBV

Train B remained functional, a separate Technical Specification 3.0.3 violation was

not cited.

M1.4 Review of Testina Reauirements for Safety Class Comoonents

a. Insoection Scone (61726)

The inspectors performed a review of non-American Society of Mechanical

Engineers (ASME) code components designated as Safety Class 2 or 3 to determine

if adequate testing or maintenance to ensure that the required postaccident function

was maintained.

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b. Observations and Findinas

Waterford 3 Safety Evaluation Report (SER), July 1981, Section 3.2.2, " System

Quality Orcup Classification," specified that: systems important to safety be

properly classified as Safety Class 1,2,3, or non-nuclear safety components; meet

the guidance of Regulatory Guide 1.26, " Quality Group Classifications and

Standards for Water, Steam, and Radioactive Waste Containing Components of

Nuclear Power Plants;" and are described in Updated Final Safety Analysis

Report (UFSAR) Table 3.2-1, " Classifications of Structures, Systems, and

Components." Quality Group A (Safety Class 1) and Quality Group B (Safety

Class 2) components have been constructed in accordance with ASME Section Ill,

Class 1 and Class 2, respectively, including third-party inspection. Quality Group C

(Safety Class 3) components have been constructed in accordance with

ASME Section lil, Class 3 requirements, with the exception that the Code N-symbol

stamp was not applied to these components and the third party inspection by an

authorized inspection agency, as defined in the Code, was not implemented.

Class 3 components were purchased only from suppliers who possessed the

appropriate ASME Certificate of Authorization. The NRC Staff approved the

licensee's alternate testing program for Quality Group 3 components constructed in

accordance with ASME Section 111.

UFSAR Section 3.2.2, " Safety System Classifications," spccified that systems

important to safety and the containment boundary are classified in accordance with

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ANSI N18.2 and that the safety classifications meet the intent of Regulatory  !

Guide 1.26.

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In January 1997, the inspectors identified four Safety Class 3, non-ASME code i

class valves in the hydrogen analyzer system that were not in the testing or  ;

maintenance program. Based on the SER and UFSAR, the inspectors believed that  :

the valves were required to be in the ASME Section XI test program or a t

10 CFR Part 50, Appendix B, testing program equivalent to an ASME Section XI

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Following the inspector's observation, the licensee determined that there were '

approximately 600 safety-related pumps and valves (skid-mounted and <

nonskid-mounted) that were designated Safety Class 2 or 3, which were

constructed to the applicable ASME Section 111 standard, but not designated ASME

Code Class 2 or 3. Of the 600 components, 393 were identified as having an i

active safety function to either mitigate the consequences of an accident or place  !

the reactor in cold shutdown. Six. teen systems were affected, including j

containment cooling, essential chilled water, emergency diesel generator, hydrogen

analyzer, ventilation, instrument air, and main steam. In addition to the four ,

hydrogen analyzer valves, two instrument air valves and eight switchgear ventilation

valves were determined not to be in a testing or maintenance program. Prior to the

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inspectors' observation, the licensee had not identified if testing or maintenance of t

the components was adequate to ensure that the required accident condition

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irrespe'ctive of the statements in the SER and UFSAR, the licensee believed that

inservice testing per ASME Section XI or an equivalent 10 CFR Part 50, Appendix B,

testing program, was not required since the components are not specifically

designated ASME Code Class 1,2, or 3. Testing of non-ASME code safety class

components is considered an unresolved item pending further review by the Office

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of Nuclear Reactor Regulation (NRR) (50-382/9704-03).  !

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c. Conclusions

An unresolved item involving testing of non-ASME code components designated as

Safety Class 2 or 3 was identified.

M6.1 Workina-Hour Limitations for Maintenance Personnel

a. Insoection Scone (71707)

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The inspectors reviewed the use of maintenance department overtime during the  !

period of February 1 through March 1,1997, to ensure the licensee met the '

working-hour limitations of TS 6.2.2.e.

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b. Observations and Findinos

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The inspectors reviewed the working-hour deviations for Electrical and

instrumentation and Control personnel and determined that four individuals received

approval after exceeding the requirements for working a maximum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in

any 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period.

The inspectors reviewed the mechanical maintenance department time sheets for

63 individuals, because no deviations had been approved for February 1997. The  !

inspectors determined that there were 36 unapproved working-hour deviations i

involving 23 individuals. Specifically, there were 3 examples of exceeding 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />

in a 24-hour period, 28 examples of exceeding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48-hour period, and

5 examples of exceeding 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7-day period. The inspectors determined

that the failure to implement the working-hour limitations for the maintenance

department is a second example of a violation of TS 6.2.2.e (50-382/9704-01).

The inspectors questioned the mechanical maintenance supervisor and determined

that supervisory personnel did not know that hours worked on nonsafety-related

tasks are required to be included when determining the total number of hours

worked prior to performing safety-related activities. Additionally, management

reviews of working hours were inadequate in that supervisors did not recognize the

excessive hours worked and because management did not question the lack of

deviations submitted during the monthly audit even though mechanical maintenance

had been working large amounts of overtime for emerging issues and preparation for

the refueling outage.

c. Conclusions

Thirty-six examples involving 23 individuals exceeding the maximum allowed

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working hours was identified as an additional example of the TS 6.2.2.e violation

for limiting working hours. Maintenance and Operations management oversight of

working hours was inadequate in that several reviews failed to identify that several

personnel had exceeded the TS requirements.

Ill. Enaineerina

E1 Conduct of Engineering

E1.1 General Comments (37551)

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In general, engineering provided good technical support to operations and

l inaintenance. However, the SBV system engineer failed to recognize that SBV

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Train B f ailed its surveillance on March 5, which resulted in the system being

inoperable for greater than the TS allowed outage time. Daily reviews of CRs

indicated engineering personnel had an appropriately low threshold for identifying

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problems. Violations were identified in Section E8.1, but were the result of closing

out open issues which do not necessarily reflect current performance.

E2 Engineering Support of Facilities and Equipment

E2.1 Review of Fr .ility and Eouipment Conformance to UFSAR Descriotion

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 j

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

performing the inspections discussed in this report, the inspectors reviewed the  !

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

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inspectors verified that the UFSAR wording was consistent with the observed plant  :

practices, procedures, and/or parameters. No anomalies between the UFSAR and

operation of the facility were identified. l

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E2.2 Paintino in Areas in Communication with Safetv-Related Ventilation Systems  !

a. Insoection Scoce (37551)

The inspectors performed reviews of engineering evaluations to determine if

adequate guidance had been provided to personnel performing painting activities in .

areas of the plant serviced by safety-related ventilation systems. I

b.  !

Observation and Findinos

On February 21, the inspectors performed tours of the reactor auxiliary building ,

wing areas and noted the application of paint and polyurethane as part of the plant  !'

protective coating project. The inspectors noted the application of approximately

15 gallons of paint (within the last 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) in this area, which is serviced by the

controlled veritilation area system (CVAS). The inspectors were concerned that the

quantity of volatile organic compounds (VOC)in the paint could degrade the  ;

effectiveness of the CVAS charcoal adsorbers if an automatic initiation occurred. l

CVAS is a fission product removal and control system, which in conjunction with

other systems, limits the postaccident radiological release. CVAS uses

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high-efficiency charcoal adsorbers impregnated with potassium trioxide to remove l

99 percent of iodines in the form of methyliodide. '

The inspectors questioned the licensee to determine if an evaluation had been

performed or if a maintenance procedure restricted the amount of VOCs in areas

that could affect the ventilation system charcoal adsorbers. The licensee stated

that they had not previously evaluated the quantity of VOCs that would render the ,

CVAS inoperable and that maintenance procedures did not restrict the quantity of l

paint in any given area. The failure to have a procedure that limited the amount of l

VOCs introduced into an area that could adversely affect safety-related ventilation '

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charcoal adsorbers is the first example of an unresolved item. On March 20,1997,

a letter was submitted to NRR on behalf of all Entergy plants. The letter requested

that NRR provide an interpretation of the requirements specified in the TS for testing

of charcoal. This issue remains unresolved pending a review by NRR of the letter

(G0-382/9704-04).

In response to the inspectors observation, the licensee initiated a letter, dated

February 24,1997, from J. M. Laque to C. J. Toth, " Painting in Areas Which

Communicate with a Safety-Related ESF Filtration Unit." The letter specified that

the plant philosophy has been, if an engineered safety feature (ESF) unit starts while

painting is in progress or while the paint is curing and giving off odor, the applicable

TS shall be entered. However, if too much paint is being applied and until the

curing is complete, both trains of ESF units for the serviced area may actually be

inoperable since Waterford 3 has no analysis for this condition. In response to the

letter, the licensee secured painting in all ESF areas and initiated Problem Evaluation

Information Request (PEIR) TS-089 to determine the amount of paint that can be

introduced into an ESF area and not affect the operability of the ESF ventilation

units.

PElR TS-089 concluded that, provided the paint in an ESF area is limited to specific

quantities, the ESF unit is capable of performing its postaccident function. The

maximum allowed quantity of paint specified for CVAS was 8 gallons. The licensee

initiated CR 97-0533 and performed an operability assessment because the actual

amount of paint used exceeded the quantity specified in PEIR TS-089. The

operability assessment concluded that 15 gallons of paint would not have an affect

on the charcoal adsorber. The conclusion was based, in part, on the results of a

study presented at the 21st Department of Energy /NRC Nuclear Air Cleaning

Conference. The study results indicated that the charcoal adsorber would be

effective in reducing radiciodines, provided the absorber was not subjected to more

than 10 percent by weight of VOCs.

Prior to painting in the wing areas, the licensee initiated PEIR CON-3 to evaluate the

use of sacrificial charcoal adsorbers during painting and PEIR 61020 regarding the

operation of ventilation units following painting. PEIR CON-3, dated

October 23,1996, concluded: (1) that the use of a sacrificial charcoal adsorber

during painting to capture vapors prior to entering the ESF units is a prudent

precaution, (2) a designated storage location for the sacrificial charcoal adsorbers

needed to be established, and (3) TS requirements should be followed when

painting. The inspectors performed a walkdown of the sacrificial units with the

painting supervisor and determined that the units were used during the normal

working hours of the painting crew (approximately 7 a.m. to 4 p.m.). The

inspectors determined that the sacrificial units may have been effective in

minimizing poisoning of ESF charcoal during the normal working hours. However,

securing the sacrificial units during off working hours could have resulted in

unnecessary poisoning of the ESF charcoal adsorber,

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TS Surveillance Requirements 4.6.6.1.b (SBV),4.7.6.1.b (control room emergency

filtration), 4.7.7.b (CVAS), and 4.9.12.b, (fuel handling ventilation), requires, in

. part, that each air filtration train be demonstrated operable following painting in any

ventilation zone communicating with the system by verifying that the ventilation

system satisfies the in-place testing acceptance criteria and uses the test

procedures of Regulatory Positions C.5.a, C.S.c, and C.S.d of Regulatory

Guide 1.52, Revision 2, March 1978. Regulatory Guide 1.52, Positions C.S.a,

C.5.c, and C.S.d, endorsed Sections 5,10, and 12 of ANSI N510-1975, " Testing of

Nuclear Air Cleaning Systems," respectively.

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PEIR 61020, dated February 15,1989, concluded that a waiting period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

following painting was recommended before starting the affected ESF unit. The

24-hour period was based on the release rate of solvents (VOCs) during a 7-day

period at 71-74 F and 29-38 percent humidity. The evaluation determined that

approximately 66-79 percent of the solvents are released in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, 83-90 percent

are released within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and that 8-13 percent remained after 7 days. The  ;

licensee stated that, provided the 24-hour waiting period was met, testing was not I

required pursuant to the TS following painting in any ventilation zone

communicating with the system. The inspectors noted that the TS did not specify

an acceptable waiting period following painting, which would obviate the

performance of required testing. The use of a waiting period in lieu of performing

testing is the second example of an unresolved item involving plant painting and

remains unresolved pending review by NRR (50-382/9704-04).

On March 20, the licensee stated that, in addition to the waiting period described in

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' PElR 61020, communication between the area being painted and the ESF unit did

not exist, provided the ESF unit was not operated because of isolation dampers and

the normal ventilation system was in operation. The inspectors determined that

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isolation dampers were installed between the painted areas and ESF charcoal

l adsorbers; however, the integrity of the physical barrier was not periodically verified

i through testing, inspection, or maintenance.

l ANSI N510, Section 5, " Visual Inspection," specified that, as a minimum, a list of

items in Appendix A, " Check List for Visual Inspection," should be checked.

Appendix A, item A-8, " Dampers," specified that inspection of the dampers

includes missing seats or edging and condition of resilient seals. The inspectors

noted that, as of March 31, the licensee had never performed visual inspections of

the dampers. The licensee stated that the damper seats were not required to be  ;

inspected because of the orientation of the dampers in the ventilation system and '

because failure of the seating surfaces and resilient seals would not affect the

operability of the ESF unit.

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The inspectors determined that crediting the dampers as a physical barrier to permit

communication with the charcoal adsorber was a nonconservative conclusion in that

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no testing, inspection, or maintenance to demonstrate the integrity of the damper

sealing surf aces was performed. The failure to perform visual inspections of the

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damper isolation valves (IVs) as required by ANSI N510 is the first example of an

unresolved item related to damper testing and remains unresolved pending a review

by NRR (50-382/9704-05).

The licensee stated that, with the exception of the control room ventilation system,

the normal ventilation system maintained a negative pressure at the damper

isolations; therefore, an additional barrier to communication with the charcoal

adsorber existed in that, if damper leakage occurred, airflow would be away from

the ESF units. The normal control room ventilation system maintains a positive

pressure on the isolation dampers. The licensee believed that a second barrier to

communication existed in that a flow path through the charcoal adsorber did not

exist since the normal ventilation system applied the same static pressure to both

the inlet and outlet damper valves. Crediting the use of a ventilation system to

provide a communication barrier in order to obviate TS testing requirements is the

second example of an unresolved item involving testing of dampers and remains

unresolved pending a review by NRR (50-382/9704-05).

c. Conclusions

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An unresolved item was identified involving the failure to issue a procedure for

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controlling painting activities in the plant in order to limit the amount of VOCs

introduced into an area that could adversely affect safety-related ventilation

charcoal adsorbers and the use of a waiting period following painting to obviate TS

requirements. A second unresolved item was identified regarding the lack of

maintenance or visual inspections for dampers credited as a barrier to VOCs and

crediting the operation of nonsafety-related ventilation systems to provide a barrier

to ESF filtration units and VOCs.

E8 Miscellaneous Engineering issues (92903)

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LClosed) Unresolved item 50-382/96202-08: Adequacy of emergency

feedwater (EFW) containment isolation Valves (IV) changes, including past

operability evaluations.

NRC Inspection Report 50-382/96-202 documented concerns with the acceptability

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of Flow Control Valves (FCVs) EFW-223A(B) and -224A(B) as containment IVs.

FCVs EFW-223A(B) and -224A(B) and Isolation Valves (IV) EFW-228A(B)

! and -229A(B) are normally closed, air-operated valves that fail open on a loss of

instrument air. Both Trains A and B split into two parallel paths with an FCV and an

IV in series in each path. IVs EFW 228A(B) and -229A(B) have direct closed /not

closed position indication as required by TS 3.3.3.6 and Regulatory Guide 1.97.

FCVs EFW-223A(B) and -224A(B) have a 0-100 percent valve demand positioner

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that reflects the desired valve position but does not give direct indication of

actuated position. Operators can determine valve position by using the EFW flow

indicators, which are qualified accident monitoring instruments in accordance with

Regulatory Guide 1.97.

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On May 12,1995, the Onsite Review Committee approved the 10 CFR 50.59

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evaluation for Licensing Document Change Request (LDCR) 95-0071, which

changed UFSAR Table 6.2 32, " Containment Penetrations And Isolation Valves,"

and Technical Requirements Manual (TRM) Table 3.6-2, " Containment isolation ,

j Sp c fica ly, this ch nge al ed ither FC s E 2 A(B) and -224A(B) or  !

! IVs EFW-228A(B) and -229A(B) to perforrn the containment isolation function i

" should one of these series valves become inoperable. During discussions with

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licensee personnel, the inspectors found that the licensee would depend upon  ;

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FCVs EFW-223A(B) and -224A(B) as fulfilling a containment IV function whenever

the respective EFW IV in series became inoperable. The licensee indicated that  ;

these penetrations met General Design Criterion (GDC) 57 for a closed system  :

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inside containment.

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The inspectors found that LDCR 95-0071 added Note Y to UFSAR Table 6.2-32 to

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indicate that both FCVs EFW-224A(B) and -224A(B) and IVs EFW-228A(B) i

and -229A(B) met the containment isolation requirements of GDC 57. Note Y ,

indicated that the compensatory actions of TS 3.6.3 will only apply when both

j valves in series are inoperable. LDCR 95-0071 added this same note to TRM  !

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Table 3.6-2. The inspectors determined that the 10 CFR 50.59 evaluation for

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LDCR 95-0071 failed to address that FCVs EFW-223A(B) and -224A(B) did not

i have direct closed /not closed position indication. I

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TS 3.3.3.6, Table 3.3-10, " Accident Monitoring instrumentation," and the bases for

TS 3.3.3.6 specified that containment IV position indication, consistent with the  ;

requirements of Regulatory Guide 1.97, is required for the Category 1 containment

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IVs subject to the requirements of TS 3.6.3. Regulatory Guide 1.97 requires that i

containment IVs have direct closed /not closed position indication. On the date the i

licensee approved LDCR 95 0071, FCVs EFW-223A(B) and -224A(B) were required

to have direct closed /not closed position indication as required by Regulatory '

Guide 1.97. The failure of personnel to identify TS 3.3.3.6 required direct

closed /not closed position indication for Regulatory Guide 1.97, Category 1, j

containment IVs is the first example of an inadequate 10 CFR 50.59 evaluation

(50-382/9704-06).  !

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On November 1,1995, the Onsite Review Committee approved the 10 CFR 50.59  !

evaluation for LDCR-95-0135, " Removal of Valves CAP-102, CAP-205,

EFW-223A(B), EFW-224A(B) from FSAR Table 7.5-3 and Clarification in

Table 6.2-32." This 10 CFR 50.59 evaluation deleted FCVs EFW-223A(B) and  ;

-224A(B) from UFSAR Table 7.5-3, " Accident Monitoting Instrumentation," because

the licensee determined that the valves met the conditions for Regulatory i

Guide 1.97, Type B, Category 2, instruments. UFSAR Table 7.5-3 listed both

Type A and Category 1 accident monitoring instruments. This change referenced

the 10 CFR 50.59 evaluation for LDCR 95-0071 discussed above anri indicated that l

the EFW FCVs could continue to perform the conteinment IV function.

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The inspectors found that a reviewer identified that FCVs EFW-223A(B) and

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! -224A(B) could be removed from UFSAR Table 7.5-3 because the valves were i

Regulatory Guide 1.97, Category 2, valves. The reviewer indicated that reliable

indirect position indication was available. Also, the reviewer concluded that

removal from this UFSAR table would be acceptable because: (1) the allowed

outage time for TS 3.3.3.6 was 7 days, whereas TS 3.7.1.2 allows only 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />,

and (2)

occur the use of FCVs EFW-223A(B) and -224A(B) as containment IVs would

infrequently.

The inspectors identified that the reviewer incorrectly identified 7 days instead of

48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> as the allowed outage time for TS 3.3.3.6 since FCVs EFW-223A(B) and

-224A(B) had less than the minimum number of channels OPERABLE. Automatic

containment IVs were required to have direct closed /not closed position indication in

accordance with Regulatory Guide 1.97. The 5 pectors determined that the

reviewer failed to recognize these requirements when he performed the

10 CFR 50.59 evaluation and allowed the continued use of FCVs EFW-223A(B)

and -224A(B) as containment IVs. The failute to use a correct TS-allowed outage

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time and failure to identify that indirect position indication was unacceptable is the

second example of a violation for an inadequate 10 CFR 50.59 evaluation

(50-382/9704-06).

On January 24,1997, the inspectors questioned the conclusion of a revised

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reportability evaluation associated with CR 96-1658. The reportability evaluation

concluded that the indirect position indication for FCVs EFW-223A(B) and -224A(B)

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met the intent of TS 3.3.3.6. On January 29,1997, the licensee determined that

indirei:t position indication was not consistent with the requirements of Regulatory

Guide 1.97.

The licensee inappropriately depended upon FCV EFW-224A as a containment IV for

approximately E2 hours from June 11-14,1996. This exceeded the shutdown

requirements for TS 3.3.3.6 of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> plus 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to HOT SHUTDOWN. The

inspectors determined that while the licensee violated the requirements of

TS 3.3.3.6, a separate violation was not apprpriate since this was a consequence of

the inadequate 10 CFR 50.59 evaluation violation (50-382/9704-06).

After the NRC identified poor performance of 10 CFR 50.59 evaluations in

October 1996, the operations manager initiated a standing instruction to prevent

i operators from allowing FCVs EFW-223A(B) and -224A(B) to function as

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containment IVs. The standing instruction identified that only IVs EFW-228A(B)

and -229A(B) would be used as the containment IVs for Penetrations 3 and 4.

The Onsite Review Committee approved LDCR 97-0110, " Technical Requirements

Manual Table 3.6-2; UFSAR Table 6.2-32," on January 9,1997. LDCR 97-0110

removed Note Y from TRM Table 3.6-2 that allowed either the flow control or IVs to

perform the containment isolation function. The LDCR also assigned Table 6.2-32,

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Note U, to FCVs EFW-223A(B) and -224A(B), which indicated no credit was taken

for these valves meeting the requirements of GDC 57.

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IV. Plant Support

R1 Radiological Protection Controls

R1.1 General Comments (71750)

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Routine tours of the radiological controlled area revealed that: (1) posting of areas

was in accordance with requirements, (2) controlled access areas were properly

locked, (3) personnel were wearing appropriate dosimetry and protective clothing, '

and (4) the small amount of contaminated areas continued to be a strength.

The inspectors concluded that observed radiation protection activities were

performed in accordance with procedures and were consistent with ALARA

principles.  ;

S1 Conduct of Security and Safeguards Activities

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S 1.1 Protected Area illumination and Vehicle insnection (71750) s

On March 19, the inspectors performed a tour of the protected area and observed a

vehicle inspection of a truck entering the protected area. The inspectors noted that

i the licensee had provided adequate illumination of toured sections of the protected

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area. Additionally, security performed a thorough inspection of a truck entering the

protected area.

V. Manaaement Meetinas

X1 Exit Meeting Summary

The inspectors presented the inspection results to members of licensee management

at the conclusion of the inspection on April 9,1997. The licensee acknowledged

the findings presented.

The inspectors asked the licensee whether any materials examined during the

inspection should be considered proprietary. No proprietary information was

identified.

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ATTACHMENT

SUPPLEMENTAL INFORMATION

PARTIAL LIST OF PERSONS CONTACTED

Licensee

R. G. Azzarello, Manager, Maintenance

C. M. Dugger, Vice-President, Operations

T. J. Gaudet, Manager, Licensing

T. R. Leonard, General Manager, Plant Operations

D. C. Matheny, Manager, Operations

D. W. Vinci, Superintendent, System Engineering

A. J. Wrape, Director, Design Engineering

INSPECTION PROCEDURES USED

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37551 Onsite Engineering

61726 Surveillance Observations

62707 Maintenance Observations

71707 Plant Operations

71750 Plant Support Activities

92903 Followup - Engineering

93702 -

Event Response

ITEMS OPENED CLOSED, AND DISCUSSED

Opened

50-382/9704-01 VIO Failure to implement requirements for limiting overtime

(Section 06.1)

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50-382/9704-02 VIO Failure to recognize SBV Train B failed its TS surveillance

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for maximum flow rate (Section M1.3)

! 50-382/9704-03 URI

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Testing of non-ASME code safety class components

(Section M1.4.b)

50-382/9704-04 URI Failure to have a procedure that provided guidance on the

introduction of VOCs in an area serviced by an ESF

filtration unit (Section E2.2.b)

50-382/9704-05 URI Requirement to perform visual inspections of damper

isolation valves as required by ANSI N510 (Section E2.2.b)

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50-382/9704-06 VIO Inadequate 50.59 evaluations for containment isolation

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valves (Section E8.1) {

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50-382/96202-08 URI Adequacy of EFW containment isolation valve changes

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including past operability evaluations (Section E8.1) t

LIST OF ACRONYMS USED i

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acfm actual cubic feet per minute

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l ALARA as low as reasonably achievable '

ANSI American National Standards Institute  !

ASME American Society of Mechanical Engineers

CST Central Standard Time

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CFR Code of Federal Regulations

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CR condition report

CVAS controlled ventilation area system

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EFW emergency feedwater i

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ESF engineered safety feature l

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FCV flow control valve '

GDC General Design Criterion

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HEPA high efficiency particulate air i

LDCR Licensing Document Change Request

l NRR Office of Nuclear Reactor Regulation i

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NRC Nuclear Regulatory Commission l

PEIR Problem Evaluation /Information Request (

SBV shield building ventilation I

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! SER Safety Evaluation Report i

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. TRM Technical Requirements Manual

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TS Technical Specifications

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UFSAR Updated Final Safety Analysis Report 1

VOC volatile organic compounds

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