IR 05000382/1986028

Insp Rept 50-382/86-28 on 861117-21.Violation Noted:Failure to Comply W/Procedures for Control of Temporary Alterations

ML20205B791
Person / Time
Site:	Waterford
Issue date:	03/13/1987
From:	Boardman J, Hunnicutt D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20205B729	List: ML20205B723 ML20205B754 ML20205B791
References
50-382-86-28, NUDOCS 8703300044
Download: ML20205B791 (12)

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APPENDIX B U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-382/86-28 License: NPF-38 Docket: 50-382 Licensee: Louisiana Power & Light Company (LP&L)

N-80 317 Baronne Street New Orleans, Louisiana 70160 Facility Name: Waterford Steam Electric Station, Unit 3 Inspection Conducted: November 17-21, 1986 Inspector: kN 3//3/F7

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John Boardman, Reactor Inspector Operations Da'te Section, Reactor Safety Branch Accompanied by: Howard Stromberg, EG&G ,

Clarke Kido, EG&G Approved By: h/

D. M. Hunnicutt, Chief, Operations Section 3//3/F7 Date '

Reactor Safety Branch Inspection Summary:

Inspection Conducted November 17-21, 1986 (Report 50-382/86-28)

Areas Inspected: A Region IV team inspection of licensee maintenance activities was performed. The inspection covered maintenance program implementation, maintenance program, instrument and control maintenance, and electrical maintenanc Results: Of the four areas inspected, one violation was identified (failure to comply with procedures for control of temporary alterations).

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DETAILS Persons Contacted

• J. Dewease, Senior Vice President, Nuclear Operations

• R. P. Barkhurst, Vice President, Nuclear Operations

• K. L. Brewster, Lic. Eng., Operational Licensing

• N. S. Carns, Plant Manager

• K. W. Cook, Nuclear Safety & Regulatory Affairs Manager

• C R. Gains, Operations Interface

• T. F. Gerrets, Nuclear QA Manager

• J. R. McGaha, 0&M Assistant Plant Manager

• F. J. Engle Bracht, Nuclear Administrative Services Manager

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

• T. H. Smith, Maintenance Superintendent

• A. S. Lockhart, Nuclear Operational Safety Analysis Manager

• K. L. Brewster, Licensing Engineer - Operational Licensing T. Moore, Electrical Supervisor T. Smith, Maintenance Superintendent B. Thigpen, Mechanical Maintenance Assistant Superintendent J. Begnaud, Mechanical Supervisor, Nuclear L. Lehmann, Mechanical Supervisor, Nuclear The NRC inspector also interviewed additional licensee and contractor personnel during the inspectio * Denotes those attending the exit interview on November 21, 198 The senior resident inspector attended the exit intervie . Actions on Previous Findings (Closed) Unresolved Item (50-382/8504-02) Closure of Ebasco purchase orders. For the orders included in the inspector's sample, licensee personnel provided documentation of closure satisfying the NRC inspector that no significant problem appears to exist in this are . Temporary Alteration Control During the inspection, the NRC inspector reviewed the following procedures provided by licensee personnel:

UNT-5-004, Revision 3, Administrative Procedure Temporary Alteration Control

ME-7-002, Revision 5. Maintenance Procedure Molded-Case Circuit Breakers and Thermal Overload Relays

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UNT-5-004, Revision 3. Section 3.1 defines a temporary alternation as any short tem addition to, removal from or change in the function of a system or any of its components which is not in accordance with approved-Waterford III desig Specific controls are required by UNT-5-004, Revision 3. for temporary alterations, unless prescribed controls are contained in procedures which perform temporary alteration ME-7-002, Revision 5. specifies and defines performance testing of molded-case circuit breakers. Certain tests, such as the instantaneous trip test, Section 8.5, specify removal of current-limiting fuses and their replacement with shorting devices for the performance of the tes No note, or procedure step, specifies or requires, the removal of the shorting devices, and replacement of the fuses required for breaker operability after completion of testin Procedure ME-7-002, Revision 5, does not reference procedure UNT-5-00 ' Licensee personnel indicated that temporary replacement of fuses with shorting bars, particularly for shop testing, had not been considered to be a temporary modificatio Failure to comply with UNT-5-004, Revision 3, Sections 4.0 and 5.0, and subsections thereto, in the removal and replacement of fuses for testing of circuit breakers is an apparent violation of 10 CFR Part 50, Appendix B, Criterion V, and ANSI N18.7-1976, Section 5. (382/8628-01) Maintenance Program The NRC inspector reviewed the licensee's maintenance progra Appropriate personnel in management, supervision, and crafts were interviewed concerning their areas of responsibility and their understanding of the applicable procedure The plant was preparing for its first refueling outage when the inspection was conducted. Certain corrective and many preventive maintenance actions had been rescheduled to be accomplished during the outage. Various training classes had been held to prepare personnel for work on components such as valves, pumps, snubbers, and energency diesel generator Personnel were temporarily reassigned to handle responsibilities in maintenance planning and scheduling, plant engineering, and maintenance trainin . .

Based on interviews with maintenance personnel and observation of Condition Identifications Work Authorization (CIWAs) 28583, 29923, and 23768 it appeared to the NRC inspector that the licensee relies heavily upon worker experience and verbal communication in the performance of maintenanc Maintenance procedures required careful interpretation and were usually augmented by the worker's personal experience or detailed instructions from the most cognizant supervisor. A concern of the NRC inspector was that some procedures as written may be too vague for a worker

with limited experience to properly perform the task. It appeared that procedural corrections and clarifications considered necessary by maintenance personnel were not being routed to the planner so that the procedures could be amended, as appropriat This concern was discussed with the licensee, who indicated that a reorganization is scheduled shortly to more closely integrate personnel and responsibilities. In implementation of this concept, the snubber maintenance program is undergoing review by plant engineering, maintenance planning, and mechanical maintenanc The NRC inspector reviewed three maintenance activities (CIWAs 28583, 29923, and 23768). The CIWAs were reviewed to determine craft compliance with maintenance procedures, adequacy of maintenance procedures, and if required procedures and materials were present during work performanc Two completed corrective maintenance and three preventive maintenance CIWAs were reviewe In addition, the maintenance history files for the essential chillers were reviewed to determine if previous Freon leaks had occurred. No concerns were identified. The following mechanical maintenance tasks were reviewed

CIWA 25630, boric acid makeup tank pump discharge drain valve seat leak repair, CIWA 27322, essential chiller B temperature controller Freon leak repai PM Task Carri MWORFRAB2, essential chiller WC1AB refrigerant filter changeou PM Task Card MWORFRAB2, essential chiller WCIAB compressor oil and filter changeou EQ Task Card MW0EFWP02, emergency feedwater pump AB (Terry Turbine)

oil system inspect, clean, and change filter Two additional concerns were identified during this review of the maintenance progra The first was that a plant wide trending analysis program did not appear to be implemented. The second concern was that there did not appear to be a procedure being used that ensured consistency in the documents transferred to storage. In a number of packages (see Sections 4 and 5 below) there were sections that did not appear to be completed as required, and at times it could not be verified if all

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applicable documents were in the stored document files. This will remain an open item (382/8628-02) pending further review during a subsequent inspectio . Maintenance Program Implementation The NRC inspector obtained a list of maintenance activities which were scheduled for the week of November 17-21, 1986. He selected three for inspection to determine compliance with the regulations and the Waterford 3 Administrative Procedure The three maintenance activities were detailed on Condition Identification and Work Authorization (CIWAs) for the following corrective maintenance:

troubleshoot Freon leak found at electrical box on the compressor to Essential Chiller AB, troubleshoot RCS leakage past seals on Charging Pump B, and preventive maintenance of type PSA-3 mechanical snubber The CIWAs were identified as CIWA 28583, 29923, and 23768, respectivel Each CIWA was reviewed for authorizing signatures, spare parts control, inspection adequacy, mechanical qualification, adequacy of maintenance performed and post-maintenance functional testing and restoration. The CIWA's were also reviewed to determine compliance with the requirements of the following procedures:

MM-1-002, Revision 2, " Mechanical Maintenance Practice," dated August 24, 198 MD-1-007, Revision 2, " Preventive Maintenance Task Identification,"

dated November 15, 198 "

MD-1-004, Revision 6, " Preventive Maintenance Scheduling," dated May 21, 198 *

UNT-5-002, Revision 5, " Administrative Procedure, Condition Identification and Work Authorization (CIWA)," dated January 13, 198 *

MD-1-011, Revision 3, Maintenance Procedure Development, Review, Approval, Change, Revision, Deletion MD-1-014, Revision 1, " Administrative Procedure, Conduct of Maintenance," dated November 21, 198 MM-6-023, Revision 1, " Mechanical Snubber (Shock Arresters)

Maintent.nce," dated October 21, 198 .

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MM-7-011, Revision 3, " Mechanical Snubber Test," dated November 14, 198 The troubleshooting of the Essential Chiller AB Freon leak was witnessed by the NRC inspector. The NRC inspector reviewed the job from receipt of the CIWA by the maintenance mechanic, through the mechanic's disassembly and inspection of the pump out compressor, his written work order instructing the planner to contact the vendor for detailed information and replacement parts, the planner's purchase order for the spare parts, and the maintenance supervisor's commitment to reassemble and test the chille Upon disassembly of the electrical box on the pump out compressor, the mechanics found that an unused electrical connection had been improperly sealed with a fibrous plug, and a cardboard and plastic spacer. A telephone call to the compressor manufacturer indicated that a double locking nut connection should have been made. The licensee amended the CIWA to plug the connection as specified by the manufacturer. The licensee intended to correct only Chiller AB, although there are two other identical chillers at the plant.

, The NRC inspector had two concerns relating to this maintenance work. The first concern was that the technical manual for the pump-out compressor lacked sufficient detail to describe the correct electrical connection When the licensee started work, he determined that the technical manual did not provide sufficient detail to allow repairs to be made. When disassembly was completed, the manufacturer was called ar.d his advice was followed to make repairs. These licensee actions adequately addressed this concer A second concern was that the licensee did not intend to inspect the other two essential chillers unless a similar Freon leak occurred, at which time the licensee would follow the same corrective action. The licensee was asked to confirm that the unused electrical connections for each essential chiller pump out compressor has been properly plugged and ensure that preventive measures are in place to prevent recurrence of the Freon leak problem. The licensee's actions had no significant effect on safety. The components were safety-related. The licensee was not correcting a known common mode failure mechanism that affected 2 of 3 safety system The troubleshooting of a charging pump seal leak was followed by the NRC inspector. The NRC inspector witnessed the job from receipt of the CIWA by the mechanic, through the obtaining of spare parts, verification of the status of equipment tagged out, and clearance for access to the vital are The NRC inspector discontinued observations during seal replacement and functional testing because of work area health physics requirement The licensee determined that the root cause of the seal failure was deficient packing. No concerns were identifie _ _ _ _ - _ _ _ . _ . _ _ _ _ _ . _ _ . _ _ . . _ _ _ _ _ _ _ _ _ _

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The NRC inspector followed preventive maintenance of Type PSA-3 mechanical snubbers that was in progress. Licensee personnel used procedure MM-6-023, Revision 1. During work, the NRC inspector observed that several steps in MM-6-023 were not followed (for example, step:. 8.2.1.10, .11, and .12),

since they applied only to a major overhaul of the snubber. Prior approval to omit the steps had not been documented, or authorized by the maintenance supervisor. The mechanic's work was based on procedure MM-6-023, in general, plus " hands-on" experience gained from a snubber workshop held at the vendor's factory. Revision 1 of procedure MM-6-023 was verified to be the latest revision controlled by the document records departmen Discussions with the mechanic, supervisor, and planner indicated that the snubber procedure would be revised in the near futur The NRC inspector noted a weakness dealing with the administrative aspects of the above maintenance. As stated in the previous paragraphs, the mechanics did not perform several steps that the craftsmen knew or believed, were optional. This practice can result in an error and maintenance which is not approved. The NRC inspector's concern was that a junior mechanic was undergoing on-the-job training by a senior mechanic who did not follow the maintenance procedure as written. The licensee was asked to review procedures MM-6-023 and MM-7-11 and ensure that the appropriate steps are identified for performance of all levels of maintenance specified by these procedures. This review will ensure compliance with step 14 of Attachment 6.10 to Procedure MD-1-011, which indicates that an optional step in a maintenance procedure shall be clearly identified as suc . Licensee Instrumentation Maintenance Program The NRC inspector performed an inspection of the maintenance program in the instrument and control areas in accordance with Inspection and Enforcement Manual Section 62704 and the Waterford 3 Administrative Procedures. Maintenance history, calibration records, procedures, work item tracking forms, and maintenance work request forms were obtained and reviewed. Selected instrument and control supervisors and technicians of the I&C Maintenance Organization were interviewed to determine their areas of responsibilities, functions, and qualification Two work activities in progress were witnessed by the NRC inspector to determine if the technicians were following appropriate maintenance procedures. The two activities were: (1) MI-5-160, Revision 1, Calibration of Plant Protection System Test and Calibration Card and Digital Volt Meter (DVM), and (2) MI-3-350, Revision 5, Containment Purge Isolation Area Radiation Monitor Channel "A" or "B" Functional Test ARM-IR-5024S 50255, 5027 There were a number of discrepancies noted during the performance of these activitie The following are examples of procedures not being followed: Step 8.4 of MI-5-160 (Calibration of Plant Protection System Test and Calibration Card and DVM) indicated that the DVM should be turned on and set to Volt Direct Current (VDC) Auto with the "As Found" block to be filled in on Attachment 10.1. The technicians performing the

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calibration understood this step to mean the test instrument and not the DVM being calibrated. An entry was not made in Attachment 1 for the DVM. The actions were not consistent with the procedure. It should be noted that the instruction was misleadingly vague, since it appeared to be applicable to the test instrument instead of the DVM which is constantly energized and does not have an " Auto" positio Step 8.28 of MI-5-160 required that a calibration sticker be attached to the DV Instead it was attached to the panel above the DV Step 8.1.1 of MI-3-350 (Containment Purge Isolation Area Radiation Monitor Channel "A" or "B" Functional Test (ARM-IR-5027S)) required a jumper to be used when the Containment Purge Isolation Valves are shut. Discussions with the technicians indicated that the jumper installation was not always performed. Operations personnel dictated jumper installation and decided whether or not a potential existed for the valves to be operated before testing was completed. The procedure does not allow this choice.

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The second item found during work observations was that the procedures were in error in a number of step The following are examples where errors were noted: Step 8.19 of MI-5-160 indicated that both " Bistable Select" switches should be verified in the "Of f" position. Only one has an off position; the other has a line indicating of Step 8.20 of MI-5-160 indicated that the " Input Select" switch was to be set to " Input." The switch was not removed from or verified in the " Input" position at the start of the procedure. It is possible that the switch should have been verified in the " Input" position at the start of the procedure in order to ensure correct voltages, Step 8.3.4 of MI-3-350 indicated that the health physics technician was to be informed that the monitor was back in service. The procedure, however, does not require the health physics technician to be informed when it was removed from service. This was an omission from this procedure. The technician indicated that most of the other procedures had this requirement correctly identified. It should be noted that the I&C technician informed the health physics technician when the instrument was removed from service for testing, however, it was done as a normal practic The third item identified during work observations was that the procedures permitted specific or " equivalent" instruments to be used for performing a procedure. However, the licensee had not identified which instruments are equivalent to each other; nor was the basis for equivalency verified before testing was performed. This policy does not assure that instrument sensitivity requirements will be me _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ -

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Examples found by the NRC inspector where one instrument was identified and another used were as follows: Procedure MI-5-160, Revision 1, Step 6.0, indicated a Fluke 8500A DVM was to be used. Instead, a health physics (HP) instrument was use Procedure MI-3-350, Step 6.0, indicated a Fluke 8600A Digital Multimeter was to be used. Instead, an HP instrument was use Documentation associated with ten completed maintenance activities was obtained and reviewed. The ten activities were: CIWA 028825, nitrogen pump level switch NG-ILS-3006 out of calibratio CIWA 025448, component cooling water to dry tower isolation valve low air pressure switch CC-IPS-3085B mounting repair CIWA 029024, charging pump AB spurious low suction pressure trip switch (CVC-MPMP0001AB) troubleshootin CIWA 025719, steam generator No. 1 pressure transmitter SG-IPT-1013A erratic output troubleshooting, CIWA 025913, boric acid condensate tank "B" level controller (BM-ILIC-0626) repai CIWA 022177, annunciator LO705 troubleshooting and repai CIWA 006276, SUPS IAB blown fuse F42 replacemen CIWA 023828, chill water pressure transmitter CHW-IPT-5011BS leaking vent plug replacement, CIWA 025452, containment spray flow transmitter CS-IFT-7122AS high flow indicatio CIWA 028099, boric acid condensate tank "B" level controller (BM-ILIC-0626) maintenanc The review of these completed items identified three areas of apparent weakness as follows:

The first area was a concern related to not identifying equivalent instruments. CIWA (Condition Identification Work Authorization)

028825 (item a. above) identifies a 0-415 inches water column (INWC)

instrument to be used for calibration where an 0-830 INWC was use As stated previously, this does not ensure that necessary instrument sensitivities are me Another example was seen in CIWA-025448 (item b. above) where a 0-100 psi Heise test gauge and Fluke 8600A

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DVM were identified for use as test equipment. Instead of using the identified equipment, a Helicoid 0-100 psi gauge and a Triplet meter were use *

The second weakness identified during review by the NRC inspector was that there appeared to be inconsistencies in the document review process. In CIWA 025719 (item d. above) Section D (corrective maintenance control section) was not filled out. CIWA 025913 (item e. above) identified one of the test instruments by manufacturer's name and not by its control numbe This does not permit easy traceabilit *

A third weakness was incomplete reviews as identified in CIWA 022177 (item f. above). On CIWA 022177, addendum page 11, it was indicated that plant engineering was to evaluate the acceptability of the switches used for initiating the alarm. It was not apparent that the review had been performed. No other weaknesses were noted during the

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review of these maintenance documents. These concerns will be an open item (382/8628-03) to be reviewed generically during a subsequent inspectio . Licensee Electrical Maintenance Program The NRC inspector performed an inspection of the Maintenance Program in the electrical area. Maintenance history, work item tracking forms, maintenance work requests, qualification records, document control procedures, and replacement part control records were obtained and reviewed. Selected Electrical Maintenance Organization personnel (electrical supervisors and electricians) were interviewed to determine their areas of responsibilities, functions, and qualification Three maintenance action items were witnessed to ensure that the electricians performin0 the maintenance tasks followed the appropriate maintenance procedures. All three items involved the testing of HPCI Pump AB relays. Testing was performed in accordance with the following procedures:

' ME-7-035, Revision 1, G.E. Auxiliary Relays, Models HGA11A through HGA11X ME-7-030, Revision 1 G.E. Auxiliary Relays Models HGA17A through HGA17T ME-7-033, Revision 1, G.E. Auxiliary Relay HGA14 The NRC inspector identified two areas of concern. The first concern involved test equipment. In maintenance procedure ME-7-035, Step 6.2.1, Doble equipment, or equivalent, was identified to be used to perform the testing. The technicians performing the job used Multiamp equipmen Equivalency was not determined. As stated previously, not determining equivalency or having an established equivalency list in advance fails to ensure that instrument sensitivities are acceptabl . _ _ _ . __-. --

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The second concern related to the adequacy of the procedures. Step 7.0 of maintenance procedure ME-7-033 indicated that the acceptance criterion was for the relay to pick up at rated powe The rated power was not included as part of the documentation but was determined by the technician from memory. This practice does not assure that the testing is acceptabl Another example was seen in Step 8.3.1.1 of ME-7-033, where terminals 1 and 7 were to be used for continuity verification when the relay was energize These terminals were connected to spare contact The procedure did not provide for checking contacts actually in use. This practice does not provide assurance that the relay will provide the protection intende No other concerns were identified during work observation j Procedures and other documentation associated with the following 11 i completed electrical maintenance activities were reviewed: CIWA 027805, wet cooling tower fan 6A breaker (ACC-EBTR-315A12MS)

replacemen CIWA 027484, dry cooling tower fan 58 motor (CC-EMTR-315B-3F) lug repai CIWA 006299, diesel generator feeder breaker (EBKR-3A145) spring release interlock support repai CIWA 021284, flow transmitters CC-IF-5570AS and BS hydro-test validatio CIWA 004376, static uninterruptable power supply (SUPS) 3B-5 bypass ,

transformer firing board (ID-IDEN-PSM85) temporary modificatio l CIWA 004392, SUPS 3B-S Bypass transformer firing board  ;

(ID-IDEN-PSM85) testing,

' CIWA 005619, MCC 38213 and 38311 missing grommets (MCC-CABLE-GR0MS)

evaluation and repai .

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CIWA 009388, all safety related motor operated valves inspection and

' heater operation verificatio !

i CIWA 025125, reactor building purge exhaust fan E22 motor '

(HVRE-MTR-3A7AS) polarization index procedure revisio : CIWA 027249, cabinet C-24 temperature control (IC-ITC-3024) burnt wire repairs, CIWA 023669, fuel handling building flitration unit B heater

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(HVFIHPL51148) troubleshooting and repair.

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l 12 During the review of completed maintenance packages by the NRC inspector, one concern was identified. This involved document completion and review.

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In CIWAs (025125, 02749, 023669, and 006299), Section D (Corrective Maintenance Controls Section) of the first page was not completed, or was filled out incorrectl These deficiencies in themselves were not highly I significant, however, they demonstrated a weakness in the final document I

review proces Three additional items were reviewed during review of the licensee's l

electrical maintenance program as follows:

l The first item was the overcurrent testing of breakers important to safet This involved the concern that some breaker manufacturers

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have specified that alternating current (AC) overcurrent testing be

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performed only once in the lifetime of a circuit breaker, with

! subsequent testing to be done using direct current (DC). The l licensee response to their concern indicated that it was applicable to one type of circuit breaker at Waterford. The breakers in question were tested using an AC test source, filtering the output through a rectifier bank when testing the breaker. The testing

, method adequately addressed the concern.

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l The second item was the replacement of Agastat time delay relays in emergency diesel generator sequencing circuits. The licensee was questioned about the use of qualified replacement relays. Procedures governing relay replacement were reviewed and found acceptabl *

The third item was the meggering (high voltage insulation test) for long installed runs of cables. The licensee's current practice is to megger cables at the circuit breakers. This practice is acceptable when cable runs are short. When the cable runs are long, the voltage drop in the cable could prevent a valid test of insulation breakdown l resistance. The licensee committed to reviewing this concern. This

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will remain an open item (382/8628-04) to be reviewed during a subsequent inspectio . Exit Interview l

l The NRC inspector met with the NRC senior resident inspector and the l licensee representatives identified in paragraph 1 at the conclusion of I

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the inspection on November 21, 198 The NRC inspector summarized the scope and findings of the inspection.

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