IR 05000382/1989016

Insp Rept 50-382/89-16 on 890717-21.Violation Noted.Major Areas Inspected:Operations Procedures

ML20247J707
Person / Time
Site:	Waterford
Issue date:	09/15/1989
From:	Gagliardo J, Hunter D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20247J687	List: IR 05000382/1989016 ML20247J685 ML20247J702
References
50-382-89-16, NUDOCS 8909200259
Download: ML20247J707 (10)

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.U.S. NUCLEAR REGULATORY COMMISSIO : REGION.I ;, NRC Inspection Report: 50-382/89-16 Operating License: ;NPF-38 j- ,

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Docket:1;50-382 s

Licenseef ' Louisiana Power &' Light Company (LP&L)

m' 317 Baronne Street

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New Orleans, Louisiana 70160 Facility Name: Waterford Steam Electric Station, Unit 3 (Wet-3)

Inspection At: W6t-3 Taft Louisiana Inspe'ction Conducted: July 17-21. 1989 Inspector: b %

D. H. Hunter, Senior Reactor Inspector, Operational IB9 Date Programs;Section, Division of Reactor Safety i

' Accompanyin Personnel: ,F.-W.;Hasselberg, Instructor Technical Training Center Approved: .

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[ t 'I 7Y-(J q El Gagliardb Chief, Operational Programs D6te /

SectioW, Division of Reactor Safety Inspection Summary Inspection Conducted July' 17-21, 1989 (Report 50-382/89-16)

Areas inspected: Routine. announced inspection of operations procedure Results: Within the area inspected, three violations were identified (inadequate review and approval of procedures, paragraphs 2.1.2, 2.6, and 2.7; failure. to perform the required biennial procedure reviews, paragraphs 2. and 2.6;.and inadequate abnormal procedures, paragraphs 2.5.1 and 2.5.2).

The overall program regarding safety-related operations procedures at Wat-3 fappeared to be acceptable; however, in the area of abnormal (annunciator and

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off-normal) procedures, the lack.of adequate procedures was identified in one

. area. ; Although the remaining procedures and instructions inspected appeared to be adequate,.the licensee failed to review and approve procedures related to

< safety as required, and had not performed required biennial procedure review g,y92 g y [ h ,

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!1.' Personnel Contacted n

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> .*R. P.' Barkhurst Vice President.- Nuclear L *J.1R. McGaha,' Plant Manager.'- Nuclear 4 f *J. J. Zabritski,' Quality Assurance '(QA) Manager (Acting) - Nuclear

• D.'F. Packer, Assistant Plant Manager, Operations and Maintenance

• R. S. Starkey, Operations Supervisor

-*T. H. Smith, Plant Engineering Superintendent

'*T. R. Leonard, Maintenance Superintendent - Nuclear

'R. Bennet, Operations, Quality Control Inspector

• D._E.' Baker, N0SA Manager

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M. Gren,' Senior QA Engineer

,*L'.JW. Laughlin, Site Licensing Supervisor E J.cWade,' Maintenance Engineer G.'.F..Kohler, 00A Supervisor .

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• F. Smith,. Senior Resident Inspector

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• T. Rb Staker, Resident Inspector

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• Attended: exit interview on . July 21, 198 Other licensee personnel were contacted during the inspectio . Procedures Review (42700)

. The inspectors reviewed and evaluated selected plant procedures to verify that the procedures and procedure changes for the safety-related activities were in conformance with the Technical Specifications and administrative controls and were technically adequate. Procedures and administrative controls in the following areas were selected for review:

Administrative procedures

General plant operating procedures

Safety-related system operating procedures

• Off-ncrmal/ alarm procedures

Emergency operating procedures

Maintenance procedures

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2.I' Administrative Procedures The inspectors selected and reviewed administrative procedures to assess the adequacy of the procedures regarding the control of safety-related activities. The inspectors identified concerns and provided connen regarding several of the procedures reviewed. The procedures reviewed and the inspector's consents are discussed below, as appropriat '

L' 2. Procedures Reviewed with no Specif1c Comments or Concerns UNT-001-002, " Procedure Classification, Type, Content, Numbering and Format," Revision ~12 (Changes 1 and 2)

UNT-001-003, " Procedure Initiation Review and Approval; Change and Revision;'and Deletion," Revision 11 (Changes 1-6)

UNT-005-003, " Clearance Requests, Approval, and Pelease," Revision 7 UNT-005-015, " Work Authorization Preparation and Implementation,"

Revision 0 (Changa 1, dated October 2, 1987; PORC Review on October 8, 1987; and plant manager (PM) Approval en October 9, 1987)

MD-001-014. " Conduct of Maintenance," Revision 3 MD-001-028, " Writer's Guide for Maintenance Department Procedures,"

Revision 1 2. Procedures Reviewed with Specific Comments or Concerns

" Nuclear Operations Management Manual"

Forward and Policy Statement

• Section V, " Nuclear Safety Quality Policies" Chapter 5 " Instructions, Procedures, and Drawings" Chapter 6, " Document Control" The inspector noted that the Senior Vice President - Nuclear Operations had stated the connitment to the quality program and that Chapters 5 and 6 addressed the control of safety-related procedure ' UNT-005-007, " Plant Lubrication Program," Revision 2 The procedure was found to have been reviewed by a plant operations review committee (PORC) subcommittee (S/C) and not the POR It had been approved by the assistant plant manager (PM) on April 14, 1989, and was not subsequently approved by the PM.

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.UNT 007-005, " Cleanliness Control " Revision 2

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.The procedure was found'to have been reviewed by only a PORC-S/C and approved by only the 3ssistant PM on February 14, 198 o

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The biennial review.of the procedure was due in February 1989, but the inspector found that it had not yet been performe .MD-001-011, " Maintenance Department Procedures Review and Approval; Change and Revision; and Deletion," Revision 4, dated

' July 30, 1988 The procedure was noted to be a department procedure and listed i ,

as PORC reviewed /PM approved procedure. Interviews revealed that the procedure was in the process of being upgraded to a PORC procedur *

MD-001-025, " Independent Verification Program," Revision 0

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The procedure was noted to have been reviewed by only a PORC-S/C and approved by only the assistant PM on December 14, 198 In summary, no significant safety concerns were revealed with regard to procedural adequacy. However, a number of the procedures had not received final approval recommendation by the PORC and had not been approved by the PM. One procedure biennial review was overdu Technical Specification 6.5.1 addresses the PORC functions as advisory to the PM on all matters related to safety and requires, in part, that the PORC shall be responsible for the review of all

. procedures required by Technical Specification 6.8 (Technical Specification 6.5.1.6.a); and that the PORC shall recommend in writing to the PM, prior to implementation, approval or disapproval of' items-considered (Technical Specification 6.5.1.7.a). The failure of the licensee to have PORC review administrative procedures related to safety is an apparent violation of the Technical Specification requirements stated abov This issue was previously identified in NRC Inspection Report 50-382/89-07 and the licensee had an extensive program of corrective action underway to correct the problem. Since these apparent violations are Severity Level V violations and since corrective action had been initiated, the violations will not be cited pursuant to the provisions of Section V.A. of the NRC Enforcement Policy (10 CFR 2, Appendix C).

Technical Specification 6.8.2 requires, in part, that each procedure  ;

of Technical Specification 6.8.1 shall be reviewed periodically as set forth in the administrative procedures. Section 5.7, " Biennial Review of Procedures," of Administrative Procedure UNT-001-003, L - - - - - - - -- -- __ _ --___----- _--- _ __

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defines this requirement. Step 5.7.1.1 specifies that all procedures-shall be reviewed at least once each 24 months from the approval ,date.. The failure to' perform the biennial review of Administrative L

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. Procedure UNT-007-005, " Cleanliness Control," Revision 2, as required i by Technical Specification 6.8.2 and Administrative Procedure UNT-001-003 is'an apparent viole.cion of this requiremen .The licensee had. initiated a major effort of upgrading all procedures and this procedure was scheduled to be upgraded under this progra Since this' apparent violation is a Severity Level V violation and since corrective action had been initiated, the violation will not be

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Section V.A.~of the NRC Enforcement Policy.

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2.2 General Operating Procedure __

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The inspector _ selected and reviewed the following general operating procedure to assess the adequacy of the procedur OP-010-001, " General Plant Operations," Revision 11 (7 permanent changes, 710 individual procedure actions, and 26 attachments encompassing Operational Modes 5, 4, 3, 2, and 1)

No' violations or deviations were identified during the review of this procedur .3 Safety-Related System Operating Procedures The inspectors reviewed selected system operating procedures to assess the adequacy of the procedures. 'The following procedures were reviewed and comments were provided to the licensee for consideration, as appropriate:

• OP-009-002, " Emergency Diesel Generator," Revision 10 (three permanent changes)

OP-009-003, " Emergency Feedwater," Revision 6

• OP-009-007, " Plant Protection System," Revision 3 (January 31,1987)

No violations or deviations were identified during the review of these procedure .4 Emergency Operating Procedure The inspectors reviewed selected emergency operating procedures to assess the adequacy of the procedures. Comments regarding the procedure were provided to the licensee for consideration. The biennial reviews for all i _ ,_ _ ---_ . -

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emergency operating procedures (EOPs) were overdue. However, the E0Ps were presently being upgraded and the effort was nearing completio Following training of licensed personnel, the revised E0Ps were to be implemented (August - September 1989).

No violations or. deviations were identified during the review of these procedure .5 Off-Normal and Annunciator Procedures The inspectors reviewed selected off-normal and annunciator procedures to assess the adequacy of the procedures. Concerns and comments regarding

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the procedures were provided to the licensee for consideration, as noted belo The administrative controls did not require documentation of steps. Some of the off-nomal and annunciator procedures contain significant steps, such as providing detailed instruction for isolating components or equipment under off-normal conditions. Paragraph 5.2.2 of ANSI N18.7-1076 states that the licens3e should provide guidance which includes verifica-tion of completion of~significant steps, by initials or signatures of checkoff lists." The inspector's expressed the concern that certain of the steps were critical and may need documentation and verification to ensure equipment would not be damaged resulting in a worsening of an

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expected transien This matter will be reviewed further by the inspector and followed during a subsequent inspectio (382/8916-01)

2. OP-901-054, " Loss of a Vital 120V Instrument Channel," Revision 2 The overall content of the procedure was adequate. Symptoms, including the alarms and. indications of a lost 120 volt vital AC bus were listed. The failed and inoperable equipment was listed. The operator actions and necessary recovery procedures were identified and the important Technical Specifications were referenced. However, the_ inspectors had the following comments regarding the procedure:

The procedure covered the possible loss of any of the four vital instrument buses. In order to perform the procedure for the loss of a single bus, the operator was required to page through the procedure, pick out the information for the affected bus, and then move on through the procedure. This was identified as an apparent human factors problem and should be considered in the upcoming procedure revision (e.g., as utilized in other procedures, the loss of each bus might be addressed individually).

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The inspector made a comparison of the expected annunciators resulting from a loss of vital AC 120 volt bus 3MC-5 to the list contained in the off-normal procedure of expected lost or inoperable equipment and indications. Several omissions were identified: (1) the procedure did not address the failure of incere instruments and the affected indication; (2) the procedure did not reference the inoperability of the core operating limit supervisory system (COLSS) off-normal procedure; and (3) the procedure did not address the reset of a partial engineered safety features actuation system (ESFAS) actuation following restoration of power to the failed instrument bu ' Technical Specification 6.8.1 requires, in part, that procedures shall be established covering the activities recommenced in Appendix A of Regulatory Guide 1.33, Revision 2, February 197 Appendix A of Regulatory Guide 1.33 Section 5 states, in part, that procedures for safety-related activities should be established which address expected abnormal and alarm conditions corresponding to the alarm annunicators. Section 5 further requires that alarm procedures should contain immediate actions that occur automatically, and immediate and long-term operator actions. Waterford-3 FSAR Section 13.5.2.1.d)

states'that the licensee's off-normal procedures would include loss of 120V AC vital instrument bus and loss of safety-related AC power distribution bus. The licensee's failure to provide an adequate procedure regarding the expected loss of a vital 120 volt AC instrument bus is an apparent violation (382/8916-02) of this requiremen . Loss of a Vital 4160 Volt AC Bus The extensive review of the Waterford-3 operating precedures and several interviews with operations department personnel indicated little specific procedural guidance was available for the operator in the event of a loss of a 4160 volt vital AC bu The annunciator procedure and the response for the loss of the normal supply to a 4160 volt vital bus required that the operator observe !

that the emergency diesel had started and was supplying the 4160 volt AC bus (i.e., a momentary loss of the vital 4160 volt AC bus).

The annunciator procedure and the response for diesel generator ,

trouble required the dispatching of an operator to the local DG j control panel to determine the problem in accordance with the i restoration procedure. The diesel generator Technical Specifications j were referenced in the procedur l

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Discussions with operations department personnel indicated some confusion as to which procedure would offer the best guidance to plant operators upon a sustained loss of power to one 4160 volt vital l AC bus. One manager indicated that the plant emergency restoration j

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procedure for post-trip degraded electrical system recovery might be i

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the most appropriate. A shift supervisor identified the operations t

procedure for electrical system alignment, which did include a procedure for restoring preferred power to the.4160 volt vital bus; however, the procedure failed to address the expected conditions resulting'from the loss of the bus, and neither of the above procedures could be used to guide or direct a plant operator in the continued operation of.the unit. Further, there was no list of possible. inoperable equipment or indications, in which Technical b Specifications were involved, whict were required for continued opert. tion of the' plant, or what equipment needed to be verified operable.

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These concerns were provided to the licensee for consideration. The procedural guidance provided for the loss of a vital 4160 volt AC volt bus was inadequate, in that the expected conditions and the expected corrective actions were not adequately addresse The failure to provide an adequate procedure regarding this expected plant condition is ariother example of the violation (382/8916-02) of Technical' Specification 6.8.1 as cited.in paragraph 2.5.1 abov .6 Mechanical Maintenance Procedures L The inspector reviewed selected mechanical maintenance procedures to assess the adequacy of the procedures. Comments were provided to the licensee for consideratio ~

KM-006-005, " Emergency Diesel Generator Maintenance," Revision 2, was found to have been reviewed by only a PORC-S/C and approved by only the assistant PM on January 7, 1987. The licensee's failure to provide for a review of the procedure by the PORC and to have it approved by the PM is another example of the apparent violation discussed in paragraph 2. above. Also, the biennial review was overdue for this procedure. The failure to perform the biennial review of this procedure is another example of the apparent violation discussed in paragraph 2. The inspector requested a work package associated with the most recent major maintenance activity for an EFW pump or the turbine. The EFW AB turbine had been disassembled for bolting material replacement during a 1988 outage. The inspector was given Work Authorization (WA)

No. 01005453, " Emergency Feedwater Pump AB Turbine, Change Pedestal to Base and Casing Bolts and Nuts to Establish Material Traceability,"

(Reviewed and approved November 23, 1987, and work performed between May 3 and 8, 1988). Interviews revealed that the package represented the typical mechanical maintenance activity when a specific procedure was not available.

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-9 The inspector noted that the work package was assembled in accordance with the administrative procedure prior to the performance of the maintenance activity. The work package included a detailed work instruction, which included specific references to the vendor manual, attached to WA. The WA package was reviewed and approved at the department level and contained the required A5ME and QC reviews and also the shift supervisor / control room supervisor sign-off prior to implementatio No violations or deviations were identfied during the review of these procedure .7 Electrical Maintenance Procedures The inspector reviewed selected electrical maintenance procedures to assess the adequacy of the procedures. The following procedures were reviewed and comments were provided to the licensee for consideration, as appropriate:

ME-004-021, " Emergency Diesel Generator," Revision 5 The procedure was noted to have been reviewed by only a PORC-S/C and approved by only the assistant PM on February 28, 198 ME-004-121, "4.16kV Switchgear," Revision 3 The procedure was noted to have been reviewed by only a PORC-S/C and approved by only the assistant PM on March 17, 198 "

ME-004-371, " Emergency Feedwater Motor," Revision 4 The procedure was noted to have been reviewed by only a PORC-S/C and approved by only the assistant PM on December 9, 198 The failure to provide a final review by PORC of the electrical maintenance procedures is another example of the apparent violation discussed in paragraph 2. .8 Instrument and Control Maintenance Procedures The inspector reviewed selected instrument and control maintenance procedures to assess the adequacy of the procedures. Procedure MI-005-425,

" Emergency feedwater Pump Turbine Governor Control System Calibration,"

Revision 1 (March 18, 1987), was found to have received its biennial review in May 1989. The review had been completed on May 28, 1989, but the procedure had not yet been revised at the time of the inspectio No violations or deviations were identified during the review of these procedure _ _ _ _ _ _ _ _ _ -

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-10-s Quality' Assurance Audits The inspector reviewed the reports of two audits conducted by the licensee in the area of procedures to assess the adequacy of the audits. Comments were provided to the licensee for consideration, as appropriat *

Audit Report No. SA-87-001.2. " Technical Specification Administration," December 16, 1987, through January 15, 1988 Audit Report, Item 5.E. and audit details, Item 3 E, addressed Technical Specification 6.8 and Appendix A of Regulatory Guide 1.3 No findings were noted by the licensee; however, one observation was identified concerning the lack of a procedure addressing a loss of a protective system channel. No response was require Audit Report No. SA-88-001.1, " Technical Specification Administration," December 19, 1988, through January 20, 1989 Audit Report, Item 5.E. and audit details, Item 3.E, addressed Technical Specification 6.8 and Appendix A of Regulatory Guide 1.3 No findings were noted by the license Based on the results of this NRC inspection in the area of abnormal procedures (annunciator and off-normal procedures), consideration should be given to reevaluating the scope and content of the QA audits. The licensee's QA audit program should have identified the procedure inadequacie No violations or deviations were identified during the review of this program area, and the inspector had no further questions regarding this

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matte . Exit Interview The inspectors met with the licensee representatives (denoted in paragraph 1.0) on July 21, 1989. The inspectors summarized the purpose, scope, and findings of the inspection. The licensee acknowledged the comments and noted that the off-normal procedures and the procedure review and approval process would be evaluated, as appropriat The licensee did not identify any proprietary information.

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