IR 05000382/1985020

Insp Rept 50-382/85-20 on 850601-0731.Violation Noted: Failure to Meet Operational Mode Requirements Per Tech Spec 4.0.4 & Failure to Conduct 10CFR50.59 Review of Design Criteria for Control Room Habitability

ML20134M526
Person / Time
Site:	Waterford
Issue date:	08/26/1985
From:	Constable G, Flippo T, Andrea Johnson, William Jones NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20134M511	List: ML20134M508 ML20134M522 ML20134M526
References
50-382-85-20, NUDOCS 8509040157
Download: ML20134M526 (14)

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APPENDIX

U. S. NUCLEAR REGULATORY C012tISSION

REGION IV

i 4 NRC Inspection Report: 50-382/85-20 License: NPF-38 ,,

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. Docket: 50-382

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

142 De.'.n.ronde Street ,

-New Orleans, Louisiana '70174 Facility-Name: Waterford Steam Electric Station, Unit 3 Inspection At: ,Taft, Louisiana Inspection' Conducted: June 1 through July 31, 1985  !

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Inspectors: I h ( b T. A. Flippo,' Msident Inspector

@-#,-95 Date I

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D. b - m2 S-N-Af W. B. Jongs, Reactor Inspector Date

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A. R. Johnson, Reactor Inspector Date

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I- A'ssistin Personnel:- -Howard Onorato, Energy, Incorporated

>c Daniel Sanow,' Energy, Incorporated '

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K. D. Metcalf, EC&G Idaho, Inc.

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d. L.' Constable Chief Date Resctor_ Project'Section C

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8509040157 850828' 2 PDR G

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I Inspection Summary

! Inspection Conducted June 1 through July 31, 1985 (Report 50-382/85-20)

> Areas Inspected: Routine, announced inspection of: (1) Phase III Test Witnessing, (2) Test Results Evaluation, (3) Surveillance Testing and Calibration Control, (4) Station Batteries, (5) Control of Design Changes and

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Modifications, (6) Audits, (7) Phase III Quality Activities, (8) Auditor and 1- Inspector Training, (9) Control Room-Ventilation System Emergency Outside Air i

Intake Valves, and (10) Operational Mode Changes. The inspection involved i 448 inspector-hours onsite by three NRC inspectors and three contract j consultants.

i Results: Within the areas inspected, two violations were identified, i

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Details 1. Persons Contacted Principal Licensee Employees

• R. S. Leddick, Senior Vice President, Nuclear Operations

• R. P. Barkhurst, Plant Manager, Nuclear

• T. F. Gerrets, Corporate QA Manager

• S. A. Alleman, Assistant Plant Manager, Plant Technical Staff

• J. R. McGaha, Assistant Plant Manager, Operations and Maintenance

• L. M. Meyers, Operations Superintendent

• J. N. Woods, QC Manager

• A. S. Lockhart, Site Quality Manager

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• 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 staf . Plant Status The Waterford 3 site is presently in the startup testing phas The 100%

testing plateau has been completed and the nuclear steam supply system (NSSS) warranty run needs to be completed. The plant is in an outage to

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perform replacement of the main generator rotor retaining ring . Phase III Test Witnessing The NRC inspectors observed the performance of portions of the following

. Phase III tests:

SIT-TP-705 Nuclear and Thermal Power Calibration SIT-TP-716 Core Performance Record SIT-TP-718 Variable Tavg Test During the performance of the test, the NRC inspectors verified the following: The personnel conducting the test were cognizant of the test acceptance criteria, precautions, and prerequisites prior to beginning the tes .

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4 The test was conducted.in accordance with an approved procedure and the test procedure was used and signed off by personnel conducting the tes Data was collected and recorded as requested by the test procedure instruction No violations or deviations were identifie . Test Results Evaluation The NRC inspectors reviewed Phase III test results to verify that:

, All changes, including deletions to the test program, had been

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reviewed for conformance to the requirements established in the FSAR and Regulatory Guide 1.6 Deficiencies had been adequately addressed and corrective action

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- completed, The licensee had correctly analyzed the test data and verified that it met the established acceptance criteri The startup organization as well as the plant operating review committee (PORC) had reviewed and accepted the test result The following test packages were reviewed:

SIT-TP-705 Nuclear and Thermal Power Calibration SIT-TP-716 Core Performance Record SIT-TP-717 CPC/COLSS Verification

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SIT-TP-726 Remote Reactor Trip with Subsequent Remote Plant ~

Cooldown SIT-TP-727 Total Loss of Flow Trip - Natural Circulation SIT-TP-740 100% Turbine Trip

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The,NRC inspectors determined that each of the above test packages was properly reviewed by the licensee and met the applicable acceptance criteri ,

No violations or deviations were identifie ~

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~5.~ Surveillance Testing and Calibration Control The purpose of this portion of the inspection was to ascertain whether LP&L had developed and implemented programs for control and evaluation of surveillance testing, instrumentation calibration not covered by Technical Specification, and inservice inspectio The Preventive Maintenance Schedule System (PMSS) computer provides

' for scheduling of most preventive maintenance. The schedules, as established in the data base, were not reviewed. The criteria for i establishing the schedules were reviewed during the Technical

, Specification surveillance program review and the calibration control review. The PMSS computer provides an accurate means of tracking and

scheduling surveillances and preventive maintenanc Technical Specification Surveillance Program An inspection was conducted of the licensee's Technical Specification

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Surveillance Program. Areas examined included the following:

(1) Establishment of a master index and cross reference (2) Assignment of duties and responsibilities

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(3) Proper documentation of data (4) Review of completed procedures for implementation The following procedures were reviewed by the NRC inspector:

UNT-7-004 Technical Specification Surveillance Control, Rev. 2 OP-903-035 Containment Spray Pump Operability Check, Rev. 5 -

Technical Specifications 4.6.2.lc and 4. OP-903-031 Containment Integrity Check, Rev. 2 - Technical Specification 4.6.1.la OP-903-021 RCS Water Inventory Balance, Rev. 2 - Technical

. Specifications 4.4.5.2.la and 4.4.5.2.1d OP-903-032 Quarterly ISI Valve Test, Rev.1 - Technical l

Specification 4. NE-5-103 COLSS Margin Alarm and Penalty Factor Verification, Rev. 1 - Technical Specifications 4.2.1.3, 4.2.3.2c, and 4.2.4.3

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2 MI-3-441 Turbine Generator Overspeed Protection System Calibration, Rev. 1 - Technical Specification 4.3.4.2c MI-3-384 Condensate Vacuum Pump Discharge' Radiation Monitor, Rev. 3 - Technical Specification 4.3.3.11, Table 4.3-9, Items 3a and 3d MI-3-101 Linear Power Channel Calibration,'Rev. 1 -

Technical Specification 4.3.1.1, Table 4.3-1, Item 2 MI-3-201 Plant Protection System Calibration, Rev. 3 -

Technical Specification 4.3.1.1, Table 4.3-1, Items 3, 4, 5, 6, 7, 8, 9, 10, 11, 14, 15, and 16 ME-3-210 Station Battery Bank'and Charger (Quarterly),

Revision 2 - Technical Specifications 4.8.2.lbl, 4.8.2.lb2, 4.8.2.lb3, and 4.8. ME-3-100 Fire Pump Diesel Starting Battery (Weekly). Rev. 2 Technical Specifications 4.7.20.1.3a1 and 4.7.10.1.3a2 ME-3-010 Hydrogen Recombiner Temperature and Power Measurement, Rev. 2'- Technical Specification 4.6.4.2a

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- MM-3-015 Emergency Diesel Engine Inspection, Rev. 2 -

Technical Specifications 4.8.1.1.2d1 and 4.8.1.2

MM-3-033 Computer Room Halon 1301 Fire Suppression System Flow Test, Rev. 0 - Technical Specification 4.7.10.3c2 OP-903-100 MOV Bypass Overload Test, Rev. 2 - Technical

' Specification 4.8.4.2a2 No violations or deviations were identifie f.lthough no violations were noted, the following two concerns were identified during the inspection:

(1) Technical Specification cross reference in UNT-7-004 identifies NE-2-102 as the procedure for completing surveillance 4.2.2.2 . The cross reference also identifies SIT-TP-725 as the procedure for initial performanc Procedure NE-2-102 does not exist. It has not been written. Since SIT-TP-725 was used for initial performance, the surveillance is current. No means of tracking

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has been established to ensure that NE-2-102 is issued prior to the next required performance dat (2) Technical Specification cross reference in UNT-7-004 identifies OP-903-100 as the procedure for completing surveillance 4.8.4.2al. This procedure addresses the requirements of surveillance 4.8.4.2a2. The MOV overload bypass devices required to be tested are listed on Table 3.8- All of these devices are tested in Procedure OP-903-100 under the 4.8.4.2a2 criteri None of the devices are governed by the 4.8.4.2a1 criteria. A Technical Specification change should be noted on

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the cross raference and/or Procedure OP-903-100 that none of the MOV overload bypass devices are governed by Surveillance 4.8.4.2al.

Instrumentation Calibration Not Covered by Technical Specifications An inspection was conducted of the licensee's instrumentation calibration program. Areas examined included the following items:

(1) Establishment of a master calibration schedule (2) Assignment of duties and responsibilities

.(3) Proper documentation data The following procedures were reviewed by the NRC inspector:

MD-1-004 Preventive Maintenance Scheduling, Rev. 6 MD-1-015 Administrative Controls of Measuring and Test Equipment, Rev. O

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MI-1-005 Administrative Controls of Calibration and Maintenance, Rev. 2

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MI-1-006 Calibration and Loop Check Frequency for Process Instrumentation, Rev. 2 MI-5-160' Calibration of Plant Protection System Test and Calibration Card and DVM, Rev. 1

MI-5-211 Calibration of Control Valves and Accessories, Rev. 2 MI-5-518 Control Element Drive Mechanisms Air Temperature Calibration CDC-IT-5201A/B, Rev. 1

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MI-5-561 Reactor Regulating System Inspection and Test,

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'MI-5-610 Equipment Drain Tank Level Loop Check and i 3 Calibration BM-IL-0616, Re i No violations or deviations were identifie Inservice Inspection

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An inspection was conducted of the licensee's inservice inspection program. Areas examined included the following items:

(1) Assignment of duties and responsibilities (2) Control of Inservice inspection procedures

, (3) Scheduling of tests pump and valve

-(4) Documentation of results The following procedures and documents were reviewed by the inspector:

UNT-7-020 Pump and Valve Inservice Testing, Rev. 1 PE-1-003 Control of Inservice Inspection, Rev. 1

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PE-1-004 Section XI Pump and Valve Reference

< Data / Acceptance Criteria, Rev. 2 Section XI Repairs and Replacement, Rev. 2

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LP&L Pump and Valve Inservice Test Plan Section XI Pump and Valve Reference Data / Acceptance Criteria Notebook No violations or deviations were identifie *

. - Station Batteries

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An inspection was: conducted of the licensee's station batterie Areas examined included the following items:

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a.', Visual inspection for' deterioration

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b Technical Specification surveillance requirements

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9 Maintenance guidelines A visual inspection of the station batteries was conducted. Areas examined included cleanliness and condition of the' batteries and their room The following procedures were reviewed by the inspector:

-ME-3-200- Station Battery Bank and Charger (Weekly), Rev. 2 ME-3-210 Station Battery Bank and Charger (Quarterly), Rev. 1

ME-3-220 Station Battery Bank and Charger (18-Month), Rev. 3

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ME-3-230 Battery Service Test, Rev. 3 ME-3-240 Battery Performance Test, Rev. 2 ME-3-250 Station Battery Performance Evaluation, Re ME-3-201 Station Batte y and Charger (Weekly), Rev. 5 ME-4-213 Battery Intercell Connections, Rev. O ME-4-231 Station Battery Charging, Rev. 4 No violations or deviations were identifie '

. Control of Design Changes and Modifications The NRC inspector reviewed the licensee's nuclear operations management manual and Procedures PE-2-006 and PMP-30 These documents outline the requirements and responsibilities'for.the preparation, control, and review of station modifications from request through implementation and final closecut. The station modification package is the vehicle by which design changes and modifications are made and the use of the forms and documents that become_ a part of the station modification package (SMP) provide the required control of design changes. The initiating document from the station modification request (SMR) provides for the identification, review, evaluation, and approval of design input. Upon receiving the SMR the action engineer includes a checkoff list of possible inclusions in the station modification (SM).

The NRC inspector ascertained the requirements for the assurance

'that the changes do not involve an unreviewed' safety question is catisfied by the required inclusion in SMP of a nuclear safety review checklist. A ,

positive response to any 'of the' questions on the checklist require that a 1

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nuclear evaluation form be completed and included in the SM This form requires the design engineer to review and evaluate all the nuclear safety questions outlined in 10 CFR 50.5 An interview with two action engineers, was conducted and the NRC inspector found them to be knowledgeable of the safety /nonsafety-related classification requirement The fire protection guidelines of RG 1.120 are similarly handled by the inclusion in the SMP of a fire protection / safe shutdown checklist. A positive response to any of the questions on the checklist and other

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criteria requires that a fire protection / safe shutdown review analysis (FP/SSA) be prepare This document reviews components and fire protection features for changes to such, and reviews the location of additional fire loading relative to the modification for impact to Appendix R to 10 CFR 50 to ensure the level of fire protection does not decrease. The fire protection / safe shutdown checklist and review form are a part of a new procedure FP-1-022 that is not released but will be implemented soo A document control system.has been administered that controls the release and distribution of design change documents, controls changes to released and approved documents, and provides for the control and recalling of obsolete design change documents. The procedures referenced, particularly QP-006-001, detail the controls of released document When the SM is completed the administrative controls and Procedure PE-2-006 require that a work completion notice (WCN) be sent out after the operational documents are updated and the control room drawings are red lined to reflect the changes. This WCN alerts all the reviewing organizations that the modification is complete. This WCN is the official notice for the updating of plant procedures, operator training, and the posting of plant drawings that indicate a change is in place that effects the drawing. Return of WCN to the station modification coordinator (SMC)

indicates the required documentation update has been completed except for the affected as-built drawings, which is done prior to SM closeou The NRC inspector verified that the responsibility and method of reporting to the NRC of design changes that are safety-related is established and it will be an annual report filed 1 year after initial criticality by the licensing grou The inspection identified what seems to be a problem in the implementation of the program although there were no deviations from the established administrative control and procedure outlines. There is, however, a very I large backlog of SMP in the WCN and drawing update stage. There were, in

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fact, only 17 SMPs completely closed out and in project files with all document updates don There were 125 awaiting drawing update and 206

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SMPs completed but awaiting some other form of review or document updat This backlog of SMPs causes some problems in the operational documents such as the red line drawings, where in at least one case, 5 SMs were

. posted on the drawing as being completed but not marked on the drawing, as well as 3 additional SMs marked up on the drawing. This represents a total of 8 SMs affecting 1 drawing without any of them incorporated on the

. drawing. This is considered an open item (8520-01).

The NRC inspector reviewed the temporary modification to lifted leads and jumpers requirements and found the procedure UNT-5-004 covers all the requirements when used with additional form referenced in that procedur An examination of the temporary modification log indicated it was up to date and that log entries were complet A field examination of the reactor protective system, the emergency safety features, and the emergency diesel generator control cabinets revealed no i lifted leads or jumpers in plac No violations or deviations were identified.

> QA Program Audits

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This NRC inspection included activities for preparation and issue of the

! audit schedules, development of an audit plan and checklists, review of objective evidence reviewed during the audit, audit report control and distribution, and responses _to audits. In general, the audit program was found to be an effective status of implementation. The Technical Specification audit program development and vendor audit programs are progressing satisfactorily and the operations QA program audit are being i

satisfactorily implemented. The following audits were reviewed by the NRC inspector:

Audits: 85-45 85-03 85-07 85-15 85-08

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85-10 84-22 85-13 85-01 Vendor Audits: Combustion Engineering i

Desselle-Maggard Cardinal Industries Rockbestoes

. Southern Vital Records McGraw-Edison General Electric Capitol Controls Cajun C .

Siemen-Allis C Yarway

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During this portion of tne audit two items were noted which are considered an open item and an unresolved item, respectivel QAP 302, paragraph 5.1.2.c requires onsite contr6ctors be audited trienniall Beyond this, the program does not adequately address the following areas: .

Auditing onsite contractors in a timely manner once onsite Establishing an onsite contractor audit schedule Notification and placement of contractors on a schedule Identification of work scope to be audited Tracking and timely closure of audit findings Procedure for removal from site if necessary A current example of this concern is Unitec Compan They were qualified in Jely 1984 to work onsite but the first audit was not completed until July 25, 1985. (0 pen Item 8520-02) A review of vendor audit files found two active vendors had not received the required annual evaluation. Southern Vital Records is missing a 1984 evaluation and Siemens-Allis Company is missing the 1983 and 1984 evaluations. (Unresolved Item 8520-03)

No violations or deviations were identifie . Phase III Quality Activities The inspection in this area concluded that activities committed to are being effective!y implemented. Commitments include audits, procedure reviews, and test data reviews. In the event any test deficiencies are noted, they are tracked via the CIWA system. Plant quality does get involved with all required holdpoints as deemed required in CIWA resolutions. Phase III operations QA audits included 84-45, 84-46, 85-01, and 85-05. An audit of M&TE activities is scheduled for August, 198 No violations or deviations were identifie . Auditor and Inspector Training The inspection included verifying certification documents were current, all necessary supporting documentation was available, and responsibilities coincided with training and qualifications. All aspects of the training

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program reviewed during this audit were found to be effectively implemente No violations-or deviations were identifie . Control Room Ventilation System Emergency Outside Air Intake Valves The FSAR discusses the design criteria for control room Nabitability in Chapter 6.4. The criteria used for location and power supply for the valves is discussed. The ability to operate the system from the control room with the loss of a vital bus is one of the design criteri OP-03-014, " Control Room Heating and Ventilation," provided the normal lineup for these valves. Contrary to the FSAR, all valves were normally aligned closed. The NRC inspector found no evidence that a proper 10 CFR 50.59 review was conducted to calculate dose rates which an operator would experience if these valves had been manually opened from outside the control room. When the licensee was informed of this dis-crepancy, a change was made to the procedure (June 26, 1985).

This is considered a violatio . Operational Mode Changes On June 11, 1985, Waterford 3 Steam Electric Station was in Mode 5 (cold shutdown) when operations personnel were performirg Surveillance Procedure OP-903-069, " Integrated Emergency Diesel Generator / Engineered Safety Features Test." As part of the above procedure, operations personnel were

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attempting to prove the operability of the Emergency Diesel Generator "B" automatic load sequence timer as required by Technical Specification 4.8.1.1.2.d.12. While testing Load Block 7, Relay S7X actuated in 12 seconds, which was outside the plus/minus 10% tolerance of the sequenced load block time (168 plus/minus 16.8 seconds). However, operations personnel did not review the test data until 1545 hours0.0179 days <br />0.429 hours <br />0.00255 weeks <br />5.878725e-4 months <br /> on June 20, 198 Waterford 3 entered Mode 4 (hot shutdown) at 1028 hours0.0119 days <br />0.286 hours <br />0.0017 weeks <br />3.91154e-4 months <br /> on June 20, 1985, with Emergency Diesel Generator B inoperabl Technical Specification 4.0.4 requires that " Entry into an OPERATIONAL- -

MODE or other specified conditions shall not be made unless the surveillance requirement (s) associated with the limiting condition for-operation'have been performed within the stated surveillance interval or as otherwise specified."

A LP&L Operating Procedure OP-10.001, Revision 4, " General Plant Operations," requires that when entering Mode 4 (hot shutdown) both emergency diesel generators be operabl . _ _ _ . . ._- _ _

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This is considered a violation.

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1 Open Items-The following new items were identified during this reporting period:

8520-01 Open Item Large Backlog of Incomplete SMPs (paragraph 7)

8520-02 Open Item Contractor Audit Program Inadequate (paragraph 8a)

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8520-03 Unresolved Vendor Audit Files Incomplete (paragraph 8b)

Item 8520-04 Violation Failure to Conduct Proper 10 CFR 50.59 Review (paragraph 11)

8520-05 Violation Failure to Meet Opt.'ational Mode Requirements (paragraph 12)

! 1 Site Tour i

At various times during the course of this inspection period, the NRC inspectors conducted general tours of the reactor building, reactor auxiliary building, and turbine building to observe ongoing maintenance r and testin No violations or deviations were identified.

1 Exit Interviews

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The NRC inspectors met with the licensee representatives at various times ~

during the course of the inspection. The scope and, findings of the

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