IR 05000382/1989023

Insp Rept 50-382/89-23 on 890801-31.No Violations Noted. Major Areas Inspected:Plant Status,Onsite Followup of Events,Monthly Maint Observation,Monthly Surveillance Observation,Operational Safety Verification

ML20248C666
Person / Time
Site:	Waterford
Issue date:	09/26/1989
From:	Chamberlain D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20248C657	List: IR 05000382/1989023 ML20248C653
References
50-382-89-23, EA-89-192, NUDOCS 8910030538
Download: ML20248C666 (11)

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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION i REGION IV {

i NRC Inspection Report: 50-382/89-23 Operating License: NPF-38 EA 89-192 Docket: 50-382 l

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

317 8aronne Street New Orleans, Louisiana 70160 Facility Name: Waterford Steam Electric Station, Unit 3 (Waterford 3)

Inspection At: Taft, Louisiana Inspection Conducted: August 1-31, 1989 I'

Inspectors: W. F. Smith, Senior Resident Inspector Project Section A. Division of Reactor Projects T. R. Staker, Resident Inspector Project Section A, Division of Reactor Projects

Approved:

D. D. CMrberlain Chief, Project Section A Date i

Inspection Summary Inspection Conducted August 1-31, 1989 (Report 50-382/89-23)

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Areas Inspected: Routine, unannounced inspection of plant status, onsite Tollowup of events, monthly maintenance observation, monthly surveillance observation, operational safety verification, followup of previously identified items, and licensee event report followu Results: One apparer,t violation was identified involving failure to follow the licensee's procedure on clearances (tag-outs). An auxiliary operator was observed opening a valve which was red danger-tagged shut. This was a violation of safety requirements which are implemented by the licensee's procedure. There have been two recent similar violations identified in NRC Inspection Reports 50-382/89-01 and -89-06. The licensee's actions to train and counsel employees on this issue appear to have been ineffective to date. An enforcement conference with the licensee has been scheduled because of the repeat nature of this apparent violatio oo30ss 800927 PDR ADocr 0500g33; j

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2 l The reactor trip which occurred on August 19, 1989, as described in paragraph 3.a of this report, was brought about by a series of individual minor problems. The licensee's thorough, self-critical approach to identifying and correcting the causes of the trip was excellen l l

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'- 3-DETAILS Persons Contacted Principal Licensee Employees

• R. P. Barkhurst, Vice President Nuclear Operations

• J. R. McGaha, Plant Manager, Nuclear

• P. V. Prasankumar, Assistant Plant Manager, Technical Support D. F. Packer, Assistant Plant Manager, Operations and Maintenance A.15. Lockhart, Quality Assurance Manager D. E. Baker, Manager of Nuclear Operations Support ~ and ~ Assessments R. G. Azzarello, Manager of Nuclear Operations Engineering W..T. Labonte, Radiation Protection Superintendent-

• G. M. Davis, Manager of Events Analysis Reporting & Responses

• L. W. Laughlin, -Onsite Licensing Coordinator T. R. Leonard, Maintenance Superintendent-A. F. Burski, Manager of Nuclear Safety and Regulatory Affairs R. S. Starkey, Operations Superintendent

• G. F. Koehler, Operations Quality Assurance Audit Supervisor

resent at exit intervie In addition to the above personnel, the inspectors held discussions with various operations, engineering, technical support, maintenance, and administrative members of the licensee's staf . Plant Status (71707)

At the start of the inspection period, the plant was at full power. Full power operation continued until. a power reduction and subsequent trip'(for further discussion see. paragraph 3.a) on August 19, 1989.. The plant was returned to full power on August 23, 1989, and remained there through the end of.the inspection perio . Onsite Followup of Events (93702) Reactor Trip During Downpower Transient

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while the plant was at approximately(CEA)

power, the licensee conducted control element assembl percent testing, which moves each CEA about 5 inches in ecch direction. 'CEA 18 would not nove due to electrical problems so the licensee. commenced troubleshooting. The pull down and lower gripper current sensing .

devices appeared to have failed and were replaced. When retesting the CEA, it moved inward,. but not outward.- By 11:40 a.m. , the operator had inserted the CEA from 148 to 140 int'es, which was 5 inches below the minimum of-145 inches required by Technical Specification (TS) 3.1=.3.5. ' This placed the plant in a 6-hour shutdown TS action statement. At-the sane time, the CEA was ____-____ _ __

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.l-4-misaligned from the other CEAs in the group by 8 inches, the TS 3.1.3.1 limit being 7 inches. The TS action statement required the shutdown margin to be verified and, within 15 minutes of the CEA l deviation, power was required to be ramped down by 30 percent; from 92 to 62 percent. After 15 minutes had elapsed, power was rapidly reduced to 62 percent, 56 minutes from the time of CEA deviation. In i order to achieve the required rate of power reduction, the operators I borated the reactor coolant at a much greater rate than normal. This resulted in a delayed overshoot of negative reactivity, added to the Xenon transient, late in core life (refueling was only a month away).

By 1:19 p.m., power had dropped to 21 percent when a reactor trip occurred. Core Protection Calculator (CPC) "A" was already in a tripped condition due to CEA 18 being out of .iequence. CPC "C" tripped because of high negative axial shape index (ASI), which was a CPC auxiliary trip. The operators entered the emergency entry procedure, and all systems responded normally. The plant was safely placed in hot standby (Mode 3). The inspector was in the control room most of the time and noted that operator actions were appropriate and timely with one exception. There appeared to be a misunderstanding of the extent of power reduction required by TS 3.1.0.1 after a single CEA deviation. Plant power had been reduced to about 90 percent in support of turbine inlet valve testing, which was in progress. The operators initially misinterpreted the TS to require a reduction to 70 percent from full power instead of a reduction of 30 percent from whatever power level the plant was at, which in this case was 92 percent. This delayed the start of power reduction approximately 15 minutes, with 60 minutes being the deadline for achieving 62 perce ' or les The licensee recognized that there were several lessons to be learned from this occurrence. A critique was held on August 21, 1989, and the licensee performed a comprehensive evaluation of the event and its causes. The root cause was considered to be failure of the gripper current sensors. Among the contributing causes, the licensee identified: (1) personnel error on the part of the operator when he-inserted CEA 18 below the insertion limit; (2) a pulldown current sen. <r drawn from the warehouse was defective; (3) the off-normal procedure, OP-901-009, "CEA or CEDMCS Malfunction," did not provide detailed direction in support of TS requirements; (4) a rapid reduction in power so late in core life was difficult to manage due to the Xenon transient; (5) the shutdown margin determination procedure needed clarification as it related to the reactivity worth of an inoperable CEA; (6) ASI was not monitored closely enough as indicated on the CPC; (7) Channel "C" excore nuclear instrument ,

output was later found to be reading out of specification high, '

causing the CPC to see a more negative ASI; and (8) during the last 10 minutes prior to the trip, Group 6 CEAs were withdrawn causing ASI to become more negative. The licensee has proposed taking corrective actions such as procedure revisions, operator training, component pretesting, possibly TS changes to request a relaxation of the

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. 3-5-requirement to perform a rapid down power transient for CEA misalignments late in core life, and improvements in simulator capabilities to. simulate late in core life conditions. The thoroughness of the licensee's self-critical approach subsequent to this. event was a significant improvement over past events and, as-such, reflects an improving trend in this area. Final corrective actions will be-tracked and evaluated by the inspectors under InspectorFollowupItem(IFI) 382/8923-01, Fire Seal Inspection and Repair Programs The licensee's efforts to identify. and correct all fire seal deficiencies at Waterford 3 have been documented in NRC Inspection Reports 50-382/88-28, -88-31, -89-03 -89-06, -89-08,'-89-12, and-89-17. In addition, the licensee reported the problems in LER 382/88-030, dated December 12, 1988. The licensee has issued updated revisions to the LER on May 30, 1989, and on July 14, 198 Of the 2014 seals inspected 634 required restoration. Of these 634 seals, 520 have been restored to the proper configuration, thus there were 114 left to correct as of the end of this inspection period. Of these, 68 are scheduled for work during the next refueling outage, which is scheduled to commence on September 22, 198 No violations or deviations were identifie . Monthly Maintenance Observation (62703)

The station maintenance activities affecting safety-related systems and components below listed were observed and documentation reviewed to ascertain that the activities were conducted in accordance with approved procedures, TS, and appropriate industry codes or standard Work Authorization 01043900. On August 23, 1989, the inspector observed replacement of the Emergency Diesel Generator "A" Fuel Cylinder Control Valve (EGA 409A). During the maintenance activity, at the request of the maintenance technicians, an auxiliary operator opened red danger-tagged Valve IA-5701, while the. tag was stil installed per Tag Authorization.89 *334-7.' Reportedly, the auxiliary operator obtained permission to do this from the control room supervisor after ensuring the maintenance ~ individuals. covered by the tag-out were present and agreeable. This was contrary to Section of Procedure UNT-005-003, Revision 8 " Clearance Requests, Approval, and Release," which required the tag to be cleared and removed before the valve was operated. This is the third time this year a red danger-tagged valve was operated by plant personnel when the tag clearly prohibited operation in accordance with UNT-005-003. O January 31,1989 (NRC Inspection Report 50-382/89-01),andon February 15, 1989 (NRC Inspection Report 50-382/89-06), maintenance mechanics operated red d xqzr-tagged valves.. The corrective actions taken by the licensee, i.e., counselling of. individuals and the

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issuance of memoranda has apparently not been fully effective in correcting the problem. Failure to properly clear a red danger tag and remove the tag before operating Valve IA-5701 is an apparent violatio b. Work Authorization 01042938. The inspector observed calibration of the plant protection system low pressurizer pressure instrument Channel "D" bistable per the applicable sections of Procedure MI-003-201, Revision 5, " Plant Protection System Calibration," on August 7,1989. The calibration was performed after the channel failed to meet functional testing acceptance criteri The inspector verified that procedural acceptance criteria were met at the completion of the calibratio c. Work Authorization 01039438. On August 10, 1989, the inspector observed portions of preventive maintenance performed on the

"A" train component cooling water temperature loop instruments and controls in accordance with Calibration Procedure MI-005-563, Revision 1, " Component Cooling Water Temperature Control Log Calibration." The inspector noted that the maintenance data forms used by the technicians were not attachments to the procedure, which was reviewed by the Plant Operations Review Committee (PORC) and approved by the Plant Manager. Instead, they were separate steets included as part of the work authorization package. The foms contained procedural information such as voltages to insert and acceptance criteria. As the inspector pursued the matter further, it was found that nearly all instrument and control calibrations were implemented by properly reviewed and approved procedures, but the data was recorded on separate maintenance data forms which contained procedural information, the most connon being what voltages, pressures, temperatures, or levels at which to obtain calibration data. The forms were controlled, however, by PORC-approved Administrative Procedure MD-001-002, Revision 1. " Control, Review, and Revision of Maintenance Data Forms." The licensee's system of supplying controlled forms as, and when, needed in the work authorization packages appeared to be efficient and appropriate to the circumstances. The forms, and any changes made to them, were reviewed using the same technical expertise as would be used if they were attachments to the applicable PORC-approved procedure. The inspector determined that the licensee's PORC-approved maintenance data form program appeared adequate to ensure proper calibrations of safety-related instruments and control The inspector aise watched as the technicians spent at least 15 minutes trying to apply a voltage input to three decimal places as read on a precision digital voltmeter (DVM), in accordance with Step 8.11.11 of MI-005-563. The potentiometer had too coarse an adjustmnt to achieve the required, but apparently unnecessary, accuracy. The inspector discussed this from a generic standpoint with the licensee. The licensee acknowledged that appropriate

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-7-tolerances should be specified in such cases and committed to correct the specifics and make that a consideration when reviewing procedures in the future. This is a human factors improvement item which will be monitored by the inspectors during future routine surveillance and maintenance observations. No other problems were identifie Work Authorization 00002061. On August 20, 1989, the inspector observed replacement of the CEA drive mechanism pulldown ein tent sensing device for CEA 18. The device had failed to properly respond, causing inability of the CEA to withdraw. This problem became known on August 19, 1989, during routine CEA surveillance testing. There is additional discussion on the problem in paragraph 3.a abov Work Authorization 01042786. On August 3, 1989, the IB component cooling water (CCW) dry cooling tower fan motor failed. The inspector observed the termination and splicing of the replacement motor power leads on August 8,1989, Okonite taped in-line and V-type splices were used. Motor alignment was also observed. No problems were identifie The licensee dismantled the IB CCW fan motor and observed that an apparent ground in the motor winding caused the motor to overhea The licensee and motor vendor were evaluating the motor as of the end of this inspection period to determine the root cause of this failure and potential generic concerns. Followup on the evtluation of tho failed CCW dry cooling tower fan motor will be tracked under IFI 382/8923-0 . Monthly Surveillance Observation (61726)

The NRC inspectors observed the surveillance testing of safety-related systems and components listed below to verify that the activities were being performed in accordance with the TS. The applicable procedures were reviewed for adequacy, test instrumentation was verified to be in calibration, and test data was reviewed for accuracy and completenes The inspectors ascertained that any deficiencies identified were properly l

reviewed and resolve Procedure OP-903-107, Revision 6, " Plant Protection System Channel Functional Test." On August 7, 1989, the inspector observed functional testing on the plant protection system Channel "D" low pressurizer pressure instrument bistable per the applicable portions of OP-903-107 and verified that the acceptance criteria were satisfied. During performance of the functional testing, the inspector and reactor operator observed that two threaded fasteners were missing on the chanc21 relay card rack. These fasteners were required to be removed curing functional testing which had previously been performed on Channel "D" (with unacceptable results) on August 5, 1989. A relay card rack on the Channel "B" cabinet was also missing a fastener. In July 1989, the inspector observed

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-8-trissing fasteners in the CPC "D" cabinet (NRC Inspection Report 50-382/89-22) while observing the installation of missing seismic brackets on the CPC cooling fan (Violation 382/8922-03).

Thus far, the corrective action appeared insufficient. This was discussed with the licensee who, at the time of the exit interview, indicated that a plan was being developed to inspect all panels in the control room to identify and correct all missing fastener problem Followup of this matter will be completed in conjunction with closecut of the violatio Procedure OP-903-068, Revision 6, " Emergency Diesel Generator (EDG)

Operability Verification." Or, August 7,1989, the inspector observed the start and loading of EDG B to 4.3 rregawatts. This was a fast loading where the full load had to be assumed in less than 176 seconds. The EDG was satisfactorily started in 5.63 seconds, then successfully loaded in 149.9 seconds. The inspector witnessed the taking of cylinder pressures and vibration data and inspected the EDG while operating for leaks or other anomalies. No problems were found. The operators appeared to follow the applicable procedures, and the results of the surveillance test were satisfactor Procedure OP-903-007, Revision 4, " Turbine Inlet Valve Cycling Test."

This test has been performed monthly pursuant to TS 4.3.4.2, which required the test in order to verify operability of the turbine overspeed protection system. The inspector observed the cycling of the first two governor valves on August 19, 1989. Both valves performed satisfactorily, however, after the second valve was tested, problems with the operation of CEA-18 resulted in a sequer:ce of events leading to a reactor trip, thus tripping all of the turbine inlet valves. These events were described in paragraph 3.a of this inspection report. The turbine inlet valve cycling test was completed en August 22, 1989, as a part of the plant restart procedur No problems were identifie No violations or deviations were identifie . Operational Safety Verification (71707,60705)

The objectives of this inspection were to ensure that this facility was being operated safely and in conformance with regulatory requirements, to ensure that the licensee's management controls were effectively discharging the licensee's responsibilities for continued safe operation, to assure that selected activities of the licensee's radiological protection programs are implemented in conformance with plant policies and procedures and in compliance with regulatory requirements, and to inspect the licensee's compliance with the approved physical security pla The inspectors conducted control room observations and plant inspection tours and reviewed logs and licensee documentation of equipment problem Through in-plant observations and attendance of the licensee's

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-g-plan-of-the-day meetings, the inspectors maintained cognizance over plant status and TS action statements in effec On August 2 and 3,1989, the inspectors reviewed Refueling Procedure RF-002-001, Revision 2, " Fuel Receipt," and observed unloading, uncrating, receipt inspection, and transfer of new fuel assemblies to the spent fuel pool. The procedure appeared to be adequate. Receipt inspection and handling of the new fuel was conducted in a safe and deliberate manner and in accordance with the procedure. Other than a few delays caused by mino problems with shipping container hardware, the operation appeared to proceed smoothly. No fuel defects were identifie While conducting plant tours, the inspectors noted"that the large number of scaffolds erected around safety-related equipment was on the decline, as fire seal work was nearing' completion. In Inspection Report 50-382/89-08, the inspectors expressed concern over the lack of controls implemented in the new scaffold procedure, NOCP-207, Revision 0,

" Erecting Scaffold." The licensee has since. revised the procedure (Revision 1,datedAugust 18,1989). The inspectors reviewed the new revision and noted much improved controls; however, there was a note that would allow short-term scaffolds-to be attached to safety-related equipment for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or less without an engineering evaluation. From a seismic standpoint, the equipment could be rendered inoperable. The inspectors informed the licensee of the concern and the licensee committed to remove the note. The licensee also indicated that the procedure is under consideration for PORC review and plant manager approval. Completion '

of this task will be tracked under IFI 382/8923-0 The licensee conducted its ann 91 emergency exercise on August 30, 198 The senior resident irspector observed control room activities as a

" player" and noted e,cellent performance on the part of plant operators with respect to decling with the casualties 65 they occurred and th ,

i procedure utilization and compliance. The detaiiod results of th/

exercise will be documented in NRC Inspection Report 50-382/89-24 No violations or deviations were identifie . Followup of Previously Identified Items (92701,92702) (Closed)OpenItem 382/8803-01: This item dealt with followup on improvements to the licensee's training request program. The revision made on July 28, 1988, to Procedure NTP-004, " Training Request," should provide a more timely disposition of training requests. This item is closed, (Closed) Violation 382/8808-07: The licensee failed to identify root-valves in the operating procedure for the fuel handling ventilation system. The procedure was corrected on June 23, 1988. By December 2,1988, three other operating procecures for control room,

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-10-reactor auxiliary building, and shield building ventilation systems were corrected for similar problems. This violation is closed, (Closed) Open Item 382/8819-06: The licensee had committed to obtain a TS change and clarify the acceptance criteria in the fire pump i

surveillance procedure. On February 2,1989, TS Anendment No. 50 was issued, removing fire protection from the TS. On August 17, 1989, the licensee added appropriate tolerances to the fire pump acceptance criterion in accordance with ASME Code Section XI. This item is closed, (Closed) Violation 382/8901-01: Failure to control technical l documents as required by administrative procedure. The inspector I verified that Maintenance Procedure MD-001-002 was revised as l committed. The appropriate field controls appeared to be in effec This item is close (Closed) Violation 382/8902-03: This violation dealt with the licensee's problems during the procurement process of the identification and control of items requiring shelf life controls, and with the dedication of corsnercial grade items for safety-related applications. Based on a review of licensee Letter W3P89-0070 and Procedure N0EI-152, Revision 1, this item is considered closed.

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No violations or deviations were identified.

l Licensee Event Report (LER) Followup (92700,90712)

The following LERs were reviewed and closed. The inspectors verified that reporting requirements had been met, causas had been identified, i

corrective actions appeared appropriate, generic applicability had been

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considered, and that the LER forms were complete. The inspectors l

confirmed that unreviewed safety questions and violations of TS, license conditions, or other regulatory requirements had been adequately l describe (Closed) LER 382/E3-023, " Containment Spray Pump Inoperable Due to Inadequate Procedural Control of Maintenance Test Equipment." The inspector reviewed the changes made to Maintenance Administrative Procedure MD-1-021, Revision 2. "M&TE Accountability Procedures," and noted that controls were strengthened to er.sure that M&TE usage did not exceed 16 qualitative or quantitative uses unless authorized in writing by the maintenance assistant superintendent, and then it was limited to 16 more such uses unless additional extensions were granted by the next level of management, which was the maintenance superintendent. There was no limit to the number of uses when official data was not taken, such as during diagnostic or troubleshooting activities. Nring a maintenance team inspection conducted January 17 through February 10, 1989, the team identified another case where M&TE was used 46 times without proper authorization. The licensee documented the incident and took

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-11-corrective action to ensure that M&TE personnel complied with the revised procedure requirements. On August 31, 1989, the inspector reviewed the licensee's M&TE- records of accountability and found no further problems. Corrective actions found in place appeared to be adequate. This LER is close (0 pen)LER 382/88-026, " Tubing and Supports Not Seismically Qualified

- Due to Personnel Errors." The inspector reviewed the licensee's corrective actions and noted that emphasis had been increased on the timeliness of corrective actions as evidenced by the weekly status meetings conducted by the licensee, which the inspectors have periodically attended. Extensive improvements have been made in the licensee's 10 CFR 50.59 safety and environmental impact evaluation process. The implementing procedure, Nuclear Operations Procedure NOP-13, was approved on July 14, 1989. However, the procedure had an effective date of December 31, 1989, which is about 6 months later than the expected date reported in the LER. The licensee explained that the development of the procedure took longer than anticipated. Implementation training will take until the end of this year due to work and meeting loads imposed by the forthcoming refueling outage of September 22 through October 19, 1989. The licensee committed to revise the LER to reflect the later completion date. This LER will remain open until NOP-13 is implemented and the effectiveness of the revised program is evaluate No violations or deviations were identifie . Exit Interview (30703)

The inspection scope and findings were sunmarized on September 1,1989, !

with those persons indicated in paragraph 1 above. The licensee acknowledged the inspectors' findings. The licensee did not identify as proprietary any of the material provided to, or reviewed by, the inspectors during this inspectio J i

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