ML20136F518

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)

See also: IR 05000382/1985028

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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

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Inspectors: .M~' //2/66

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

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T. A. Flippo, Resident Inspector

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B. A. Breslau, Project Engineer, Project Dra te

Section C, Reactor Projects Branch

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H. F. Bundy, Project Inspector, Project Date

Section C, Reactor Projects Branch

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Approved: / ~ //t/64

T LT Constable 7 Chief, Project Section C Ddte

Reactor Projects Branch

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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 inspectors.

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

1. 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 interview.

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 staff.

2. 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 8.

3. 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 day.

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% power.

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 power.

No violations or deviations were identified.

4 .. Licensee Event Report (LER) Followup

The following LERs were reviewed and closed. 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 identified.

(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

appropriate.

(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 reports. Subsequent reports have contained the identifiers as

required.

5. 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 TS.

The NRC inspector reviewed two completed Condition Identification Work

Authorization (CIWA) packages which involved the replacement of packing in

Charging Pumps A and AB. 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 respectively.

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 28.

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 numbers.

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 reassembly.

The above items are considered a violation and are identified as

50-382/8528-01.

6. 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 resolved.

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 4.7.6.

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For some portions of the surveillance test the licensee used contractor

personnel, equipment, and procedures. The NRC inspector verified that the

contractor personnel had proper documentation of their qualifications as

well as documentation of the calibration of their equipment.

Additionally, it was verified that all contractor procedures used had

received the proper licensee reviews and approval.

No violations or deviations were identified.

7. 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, 1985.

. Emergency Feedwater System (Drawing LOU 1564-6-153, Sheet 2 and

OP-9-003, Revision 3, Attachment 8.1)

No violations or deviations were identified.

8. 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 conditions.

Through log review and plant tours, the NRC inspectors verified compliance

with selected TS and limiting conditions for operations.

During the course of the inspection observations relative to protected and

vital area security were made including access controls, boundary

integrity, search, escort, and badging.

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 RWPs. Selected radiation protection instruments were

periodically checked and equipment operability and calibration frequency

were verified.

The NRC inspectors kept informed on a daily basis of overall status of

plant and of any significant safety matter related to plant operations.

Discussions were held with plant management and various members of the

operations staff on a regular basis. Selected portions of operating logs

and data sheets were reviewed daily.

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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 housekeeping.

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,

a. 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 report.

b. 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),

c. OP-500-009,. Revision 1, Annunciator A-13 - Specifies an incorrect

value for the setpoint for log PWR high channel trip setpoint.

TS setpoint is .257% while the procedure specifies .895%.

d. 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 setpoint.

e. 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%

f. 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%.

g. 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 not.

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Each procedure should contain two setpoints, one with and one without

SIAS present.

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h. 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.

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l 1. 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,

l. 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

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operational setpoints arise.

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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 50-382/8528-03.

9. 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, 1985. The NRC inspector reviewed the procedure changes

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associated with this license condition change.

No violations or deviations were identified.

10. 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

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

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level, licensee operations personnel have maintained basin levels above

, , ; , 97%. indicated level. 'However, maintaining indicated level below 100%

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 instrumentation.

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[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 requirements.

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Thisisanapparentviolation(50-382/8528-02).

11. 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 inspection.

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