IR 05000382/1989013

Insp Rept 50-382/89-13 on 890522-26.No Violations or Deviations Noted.Major Areas Inspected:Followup to Previous Insp Findings & Licensee Expeditious Actions Re Generic Ltr 88-17, Loss of Dhr

ML20245A945
Person / Time
Site:	Waterford
Issue date:	06/14/1989
From:	Ray Azua, Mckernon T, Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	LOUISIANA POWER & LIGHT CO.
Shared Package
ML20245A943	List: IR 05000382/1989013 ML20245A941
References
50-382-89-13, GL-87-12, GL-88-17, NUDOCS 8906220292
Download: ML20245A945 (7)

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APPENDIX

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U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-382/89-13 Operating License: NPF-38 Docket: 50-382 t

Licensee: Louisiana Power & L1ght Company (LP&L)

l 317 Baronne Street i New Orleans, Louisiana 70160 Facility Name: Waterford Steam Electric Station, Unit 3 (W-3)

Inspection At: W-3 Taft, Louisiana Inspection Conducted: May 22-26, 1989

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Inspectors: A 4 //f /ff T. O. McKernon, Reactor inspector, Test Date ProgramsIection,DivisionofReactorSafety

/ - S/hf/kV RV 1' huar+eactor Inspector, Test Prograins Date /

Section Division of Reactor Safety l

Approved: c 'A 4 //i //f j W. C. Seidl,e/ Chief. Test Progiams Section Date Division ofleactor Safety i

Inspection Summary Inspection Conducted May 22-26, 1989 (Report 50-382/89-13)

Areas Inspected: Routine, unannounced inspection of followup to previous inspection findings and the licensee's expeditious actions related to Generic Letter 88-17 (loss of decay heat removal).

Results: Within the areas inspected, no violations or deviations were identified. The licensee is developing comprehensive procedures and controls related to shutdown cooling operations in reduced reactor coolant system (RCS)

conditions, which appear to be responsive to Generic Letter 88-1 ,

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DETAILS I Persons Contacted LP&L

• J. R. McGaha, Plant Manager

• F. Koehler, Quality Assurance Audit Supervisor 1

• V. T. Collins, Shift Supervisor, Operations

• D. F. Packer, Assistant Plant Manager

• T. R. Leonard, Maintenance Supervisor

• D. V. Prasankumar, Assistant Plant Manager, Division of Technical Support

• H. C. Lesan, Radiological Engineer  !

• L. R. Simon, Radweste Engineer ]

• G. M. Davis, Event Analysis Manager

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• L. W. Laughlin, Site Licensing Supervisor

• R. W. Prados, Senior Licensing Specialist P. Baumgartner, Shift Supervisor C. Boudreaux, Maintenance Training Supervisor, Nuclear W. Smith, Simulator Training Supervisor, Nuclear i C. Toth, Nuclear Operation Training Manager J. O'Hern, Nuclear Operations Training Supervisor j I

NRC

• F. Smith, Senior Resident Inspector T. Staker, Resident Inspector

• Denoted those attending the exit interview on May 26, 198 . Followup to Previously Identified Inspection Findings (92701)

(Closed) Violation 382/8817-01: Failure to Follow Technical Specification (TS) Requirements for Procedure Change. This violation involved the deviation from the Isothermal Temperature Coefficient Measurement Procedure NE-2-060, in which RCS cooldowns were conducted incongruently with those procedural requirements specified. The licensee has discussed this matter with the test engineer and has l revised the procedure to allow test flexibility in determining when sufficient data has been accumulated during the test. This violation

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is considered close . Loss of Decay Heat Removal (Generic Letter No. 88-17) Temporary Instruction 2515/10 This portion of the inspection involved the review of the licensee's expeditious actions to prevent, and if necessary, respond to a loss of decay heat removal during operations in a lower RCS inventory level conditio During the inspection, the NRC inspectors reviewed the following procedures and documents:

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Operating Procedure OP-001-003, Revision 8, " Reactor Coolant System Drain Down," draft version i Operating Procedure OP-901-046, Revision 5, "Off-Normal Operating Procedure - Shutdown Cooling Malfunction," draft version

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• Licensee Letter W3P88-3091, " Generic Letter 88-17, Loss of-Decay-Heat Removal Response to Expeditious Actions," dated December 23, 1988 NRC Letter to Licensee, Subject: Comments on the Louisiana Power &

Light Company Response to Generic Letter 88-17 for the Waterford Unit 3 for Expeditious Actions to Loss of Decay Heat Removal (TAC No. 69791), dated March 8, 1989

Surveillance Procedure OP-903-072, Revision 3, " Refueling Containment Building Penetration Check," dated May 16, 1988

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Operating Procedure OP-9-008, Revision 7, " Safety Injection System," 1 dated June 12, 1987

Operating Procedure OP-9-005, Revision 9,." Shutdown Cooling System,"

dated March 31, 1988 j

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Refueling Procedure RF-3-002, Revision 0, " Steam Generator Primary Side Services," dated December 17, 1987 During the inspection, the NRC inspectors reviewed expeditious actions taken by the licensee in the areas of training, containment closure procedures, provisions for independent measurement of the reactor core exit temperature and independent RCS level measurement during reduced RCS inventory level operations. In' addition, procedures and controls have been established to avoid RCS perturbations during reduced RCS inventory operations. Provisions for limitations on-the usage of nozzle dams, and a means of additional capability for makeup water to the RCS when shutdown cooling capability is lost, have been provided.-

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Generally, the licensee's procedures and program, appear sufficien However, the following observations were noted during review of applicable procedures and discussions with key personnel: OperatingProcedureOP-0dl-003, Sections 6.2,6.3,'and8.2contain procedures for monitoring RCS level duringl reduced inventory operations. These sections 1 state', in part, for reduced inventory operations, "As 6 minimum RCSElevel" indication available as follows:

RWLIS with Narrow Range and Wide Range indication or RLIS and HJTC indications." This statement is'not: responsive to Generic

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, Letter 88-17 requirement "or two independent RCS level indications i during reduced inventory conditions. The' narrow range indication and r

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-4-wide range indication meters utilize a common tap, common reference, and variable instrument lines. This condition does not satisfy the independence criteria as defined in Enclosure 3 to Generic Letter 88-1 Furthermore, the heated junction thermocouple system (HJTC) shall not be used as a primary level indication during reduced RCS inventory operations due to the system's characteristic discrete level indications at 20 to 24 inch intervals. The HJTC does not satisfy the continuous RCS level indication criteria of Generic Letter 88-17 and, as such, l should not be used for RCS level monitoring other than for the purpose of cross checking the refueling water level indication system (RWLIS) and the refueling level indication system (RLIS)

system indication A review of the above procedures noted that the licensee has made provisions for cross checking RCS level indications, as well as comparing drained volumes with RCS levels during drain down operation Additional provisions are stated for predicating actions based upon the lowest of the RCS level indications (RWLIS, RLIS, HJTC). During the exit int.:rview, the licensee noted that the procedure should require both the PLLIS with narrow and wide range indications and the RLIS be available for RCS level monitoring during reduced RCS inventory conditions, b. The licensee has attempted to make provisions for logging and tracking activities which effect or impair containment closure through the use of Attachment 11.11 of OP-001-003, " Containment Closure Impairment Log." The NRC inspector noted to the licensee that the above tracking method appeared sufficient in principle, but it did not account for the cumulative effect of numerous activities contributing to containment l closure impairment. The shift supervisor should have the capability'

of determining the cumulative effect of the containment closure impairment log (i.e., number of penetrations open, man-power available to effectuate closures, and effects of degraded containment atmosphere on containment closure times). This observation was presented to the licensee for consideration during the exit interview, c. Surveillance Procedure OP-903-072 required verification that the containment is capable of being closed. However, no provisions have been established to periodically demonstrate the containment cloture capability (i.e., equipment hatch) utilizing special equipmen Demonstrating this containment closure capability would ensure that personnel could accomplish the closure under degraded containment atmospheric condition d. Refueling Procedure RF-3-002, Revision 0, requires revision to incorporate nozzle dam restrictions as addressed in licensee letter W3P88-3091, " Generic Letter 88-17, Loss of Decay Heat Removal Response to Expeditious Actions," Section 8.2.1, dated December 23, 198 .  !

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-5-e. Operating Procedure OP-001-003, Revision 8 (Draft), Attachment 11.7,

" Refueling Water Level Instrument Connections Reference" figure is in ;

error. Both reference and variable legs are shown connected to a '

common line from the RCS hot leg and the pressurizer. Connections to indicators LT-108 and LT-109 should show separate parallel reference and variable leg instrument line f. Operating Procedure OP-001-003, Revision 8(Draft), Attachment 11.9, requires monitoring and recording core exit thermocouple (CET)

l temperatures and RCS level indications at one hour intervals. This requirement is sufficient for operations using the RWLIS (control !

room) indicators as the primary level indications; however, should l the RLIS or RWLIS (local) be used as the primary means of RCS level indication, then intervals of recording RCS levels should be 15 minute Procedure OP-001-003 had not established provisions for such a conditio In addition to the above, the NRC inspectors reviewed those training i rograms that the licensee committed to in Letter No. W3P88-3091 p(A4.05) Generic Letter 88-17 " Loss of Decay Heat Removal Response to Expeditious Actions," from R. F. Burski, Manager - Nuclear Safety and Regulatory Affairs, to the NRC, dated December 23, 198 The NRC inspector reviewed Lesson Plan No. A010-000-00 "Diablo Canyon Unit 2 Loss of RHR Event and Generic Letter 88-17 Concerns Seminar."

on and other loss of RHR The lesson planthe addresses the Diablo Cany(July 1986 loss of shutdown

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events including Waterford 3 events cooling; May 1988 LPSI pump cavitation). It compares the events and points to the lessons learned. The lesson plan also summarizes Generic Letter 88-17, particularly Enclosure 1, and provides a review of the changes made to the RCS Drain Down Procedure OP-1-003, implemented as corrective actions for the May 1988 event. In addition, a review of the RWLIS backfill procedure (failure to follow procedures in this area, was a contributor to the May 1988 event) is also conducte The NRC inspectors noted from the licensee's training records that prior to reporting on shift for the November 3, 1988, draindown, licensed operators and auxiliary operators received the training outlined in the lesson plan described abov The licensee's training program currently includes reduced RCS inventory training as part of prerefueling outage training (within 6 months of operating the plant in a reduced inventory condition).

This training is conducted for operations personnel and includes a review of the draindown procedure, the shutdown cooling operating and off-normal procedures, and a review of the shutdown cooling syste s N

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-6-In addition to the items described above,.the control room operator simulator training has been expanded to include the following loss of shutdown cooling (SDC) scenarios: Exercise No. W525-101-00 " Loss of SDC (Loss of Heat Removal .

l Capability - CC Pump Failure)" Exercise No. W525-100-00 " Loss of SDC (System Leakage - RCSl Break)" Exercise No. W525-102-00 " Loss of SDC (Loss of Flow - Valve Closure)"

- The NRC inspectors reviewed these exercises and found them to be-l sufficien The NRC inspectors also reviewed Lesson Plan No. M011-881-01,

"2. LossofHeatRemoval(NRCGenericLetter87-12)." This plan was noted to consist of a copy of Generic Letter 87-12 with c?ly some highlighted comments in the margin such as " Stress Timely Closure."

Although the generic letter is.self explanatory in many ways, it does require the instructor to provide site specific information such as the timely closure of the equipment hatch, assuming worst cas conditions. The'NRC inspector noted that under these conditions each instructor is required to determine on his own how detailed that-explanation should be. The mechanism to verify the accuracy of: i his statements is not present (i.e., the source.of the site specific '

information is not'11sted or verified before use by the instructor).

A more detailed lesson plan would aid the instructor and reduce the

- chances of the transmittal of erroneous informatio Another observation made by the NRC inspectors concerned the timely .

closure of.the equipment hatch under worst case conditions. According to the licensee, under such conditions the equipment hatch is required to be closed within~1.5 to 2.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />. No detailed explanation is 4 provided to the personnel on how this is. achieved when the equipment hatch is cluttered with power lines, communication lines, air hoses, and possibly other pieces of.cquipment. In' addition, no actua.1 drill  !

in this area has been performed in which an attempt is made to clos'e the equipment hatch within the times' stated, assuming worst case radiological conditions, (i.e', can the personnel achieve this with

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full protective clothing and with respirator equipment). '  :

The licensee has expressed a high degree of confidence that the hatch can be closed within the times stated. and as a result, does not plan y '

to perform such a drill. Thisobservationisnotedasobservation(c)

above.

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. -7-In the area of maintenance training for potential effects on shutdow cooling, the licensee informed the NRC inspectors that the training of maintenance personnel has been conducted by lectures and discussions-on a shop basis. Furthermore, maintenance procedures, which have the potential to effect shutdown cooling and containment closure, were )

being revised to incorporate the appropriate cautions and limitation ]

The NRC inspectors verified the above, in part, through a-review of- i the licensee's local leak rate testing procedur Excluding the observations noted above, the licensee's expeditious actions appear responsive to Generic Letter 88-1 I No violations or deviations wer2 identified'in the review of-this program are . Exit Interview The inspection scope and findings were summarized with those persons identified in paragraph 1 on May 22, 1989. The licensee did not identify any proprietary information provided to, or revi wed by, the NRC inspector ,

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