ML20205B791

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)

See also: IR 05000382/1986028

Text

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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

'

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 maintenance.

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

1. 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 inspection.

• Denotes those attending the exit interview on November 21, 1986.

The senior resident inspector attended the exit interview.

2. 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 area.

3. 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 design.

Specific controls are required by UNT-5-004, Revision 3. for temporary

alterations, unless prescribed controls are contained in procedures which

perform temporary alterations.

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 test.

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 testing.

Procedure ME-7-002, Revision 5, does not reference procedure UNT-5-004.

' Licensee personnel indicated that temporary replacement of fuses with

shorting bars, particularly for shop testing, had not been considered

to be a temporary modification.

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 5.2.2.

(382/8628-01)

4. Maintenance Program

The NRC inspector reviewed the licensee's maintenance program.

Appropriate personnel in management, supervision, and crafts were

interviewed concerning their areas of responsibility and their

understanding of the applicable procedures.

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 generators.

Personnel were temporarily reassigned to handle responsibilities in

maintenance planning and scheduling, plant engineering, and maintenance

training.

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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

maintenance. 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 appropriate. 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 maintenance.

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 performance.

Two completed corrective maintenance and three preventive maintenance

CIWAs were reviewed. 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:

a. CIWA 25630, boric acid makeup tank pump discharge drain valve seat

leak repair,

b. CIWA 27322, essential chiller B temperature controller Freon leak

repair.

c. PM Task Carri MWORFRAB2, essential chiller WC1AB refrigerant filter

changeout.

d. PM Task Card MWORFRAB2, essential chiller WCIAB compressor oil and

filter changeout.

e. EQ Task Card MW0EFWP02, emergency feedwater pump AB (Terry Turbine)

oil system inspect, clean, and change filters.

Two additional concerns were identified during this review of the

maintenance program. 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

inspection.

5. 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 Procedures.

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 snubbers.

The CIWAs were identified as CIWA 28583, 29923, and 23768, respectively.

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, 1985.

MD-1-007, Revision 2, " Preventive Maintenance Task Identification,"

dated November 15, 1984.

"

MD-1-004, Revision 6, " Preventive Maintenance Scheduling," dated

May 21, 1985.

UNT-5-002, Revision 5, " Administrative Procedure, Condition

Identification and Work Authorization (CIWA)," dated January 13,

1986.

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, 1984.

MM-6-023, Revision 1, " Mechanical Snubber (Shock Arresters)

Maintent.nce," dated October 21, 1986.

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MM-7-011, Revision 3, " Mechanical Snubber Test," dated November 14,

1986.

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

chiller.

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 connections.

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 concern.

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 systems.

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

area. The NRC inspector discontinued observations during seal replacement

and functional testing because of work area health physics requirements.

The licensee determined that the root cause of the seal failure was

deficient packing. No concerns were identified.

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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 department.

Discussions with the mechanic, supervisor, and planner indicated that the

snubber procedure would be revised in the near future.

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 such.

6. 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 qualifications.

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, 50275. There were a number of discrepancies

noted during the performance of these activities. The following are

examples of procedures not being followed:

a. 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 10.1

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" position.

b. Step 8.28 of MI-5-160 required that a calibration sticker be attached

to the DVM. Instead it was attached to the panel above the DVM.

c. 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.

,

The second item found during work observations was that the procedures

were in error in a number of steps. The following are examples where

errors were noted:

a. 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 off.

b. 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,

c. 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 practice.

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 met.

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Examples found by the NRC inspector where one instrument was identified

and another used were as follows:

a. 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

used.

b. Procedure MI-3-350, Step 6.0, indicated a Fluke 8600A Digital

Multimeter was to be used. Instead, an HP instrument was used.

Documentation associated with ten completed maintenance activities was

obtained and reviewed. The ten activities were:

a. CIWA 028825, nitrogen pump level switch NG-ILS-3006 out of

calibration.

b. CIWA 025448, component cooling water to dry tower isolation valve low

air pressure switch CC-IPS-3085B mounting repairs.

c. CIWA 029024, charging pump AB spurious low suction pressure trip

switch (CVC-MPMP0001AB) troubleshooting.

d. CIWA 025719, steam generator No. 1 pressure transmitter SG-IPT-1013A

erratic output troubleshooting,

e. CIWA 025913, boric acid condensate tank "B" level controller

(BM-ILIC-0626) repair.

f. CIWA 022177, annunciator LO705 troubleshooting and repair.

g. CIWA 006276, SUPS IAB blown fuse F42 replacement.

h. CIWA 023828, chill water pressure transmitter CHW-IPT-5011BS leaking

vent plug replacement,

i. CIWA 025452, containment spray flow transmitter CS-IFT-7122AS high

flow indication.

j. CIWA 028099, boric acid condensate tank "B" level controller

(BM-ILIC-0626) maintenance.

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 used.

As stated previously, this does not ensure that necessary instrument

sensitivities are met. 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 used.

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 number. This does not

permit easy traceability.

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

'

review of these maintenance documents. These concerns will be an

open item (382/8628-03) to be reviewed generically during a

subsequent inspection.

7. 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 qualifications.

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:

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a. ME-7-035, Revision 1, G.E. Auxiliary Relays, Models HGA11A through

HGA11X

b. ME-7-030, Revision 1 G.E. Auxiliary Relays Models HGA17A through

HGA17T

c. 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 equipment.

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 acceptable.

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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 power. 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 acceptable.

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

energized. These terminals were connected to spare contacts. The

procedure did not provide for checking contacts actually in use. This

practice does not provide assurance that the relay will provide the

protection intended.

No other concerns were identified during work observations. j

Procedures and other documentation associated with the following 11 i

completed electrical maintenance activities were reviewed:

a. CIWA 027805, wet cooling tower fan 6A breaker (ACC-EBTR-315A12MS)

replacement.

b. CIWA 027484, dry cooling tower fan 58 motor (CC-EMTR-315B-3F) lug

repair.

c. CIWA 006299, diesel generator feeder breaker (EBKR-3A145) spring

release interlock support repair.

d. CIWA 021284, flow transmitters CC-IF-5570AS and BS hydro-test

validation.

e. CIWA 004376, static uninterruptable power supply (SUPS) 3B-5 bypass ,

transformer firing board (ID-IDEN-PSM85) temporary modification. l

f. CIWA 004392, SUPS 3B-S Bypass transformer firing board  ;

(ID-IDEN-PSM85) testing,

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

evaluation and repair. .

!

CIWA 009388, all safety related motor operated valves inspection and

'

h.

heater operation verification.  !

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1. CIWA 025125, reactor building purge exhaust fan E22 motor '

(HVRE-MTR-3A7AS) polarization index procedure revision.  :

j. CIWA 027249, cabinet C-24 temperature control (IC-ITC-3024) burnt

wire repairs,

k. CIWA 023669, fuel handling building flitration unit B heater

,

(HVFIHPL51148) troubleshooting and repair.

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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 incorrectly. These deficiencies in themselves were not highly

I significant, however, they demonstrated a weakness in the final document

I

review process.

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

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electrical maintenance program as follows:

l

The first item was the overcurrent testing of breakers important to

safety. This involved the concern that some breaker manufacturers

!

have specified that alternating current (AC) overcurrent testing be

,

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.

l

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 acceptable.

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 inspection.

8. 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

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the inspection on November 21, 1986. The NRC inspector summarized the

scope and findings of the inspection.

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