ML20244C695

Insp Rept 50-382/89-12 on 890416-0531.Violations Noted. Major Areas Inspected:Monthly Maint Observation,Monthly Surveillance Observation,Onsite Followup of Events & Evaluation of Licensee QA Program Implementation

ML20244C695
Person / Time
Site:	Waterford
Issue date:	06/08/1989
From:	Chamberlain D, Will Smith, Staker T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20244C677	List: ML20244C674 ML20244C692 ML20244C695
References
50-382-89-12, NUDOCS 8906150099
Download: ML20244C695 (10)

See also: IR 05000382/1989012

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APPENDIX B

U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-382/89-12 Operating License: NPF-38

Docket: 50-382

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

317 Baronne Street

New Orleans, Louisiana 70160

Facility Name: Waterford Steam Electric Station, Unit 3' (Waterford-3)

Inspection At: Taft, Louisiana

Inspection Conducted: April 16 through May 31, 1989

Inspectors:

7. F. Smith, Senior Resident Inspector l

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T. R. Staker, Resident Irispector

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Approved: d ) bh

D. D. Ottamberlain, Chief, Project Section A Date

Division of Reactor Projects

8906150099 890609

PDR ADOCK 05000382

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Inspection Summary

Inspection Conducted April 16 through May 31, 1989 (Report 50-382/89-12)

Areas Inspected: Routine, unannounced inspection of plant status, monthly

maintenance observation, monthly surveillance observation, onsite followup of  ;

events, evaluation of licensee quality assurance program implementation,  ;

operational safety verification, followup of previously identified items, and

licensee event report (LER) followup.

Results: Two violations were identified. The first violation (paragraph 3.d)  ;

involved failure to provide adequate maintenance instructions for the

replacement of a torque switch in Limitorque Motor Operated Valve (MOV) MS-416. ,

As a result, the torque switch termination washer stackup was incorrectly  ;

performed. Additionally, because of confusing directives between the I

maintenance procedure and the drawing detailing Okonite splices, the power <

leads were improperly spliced. Conflicts and confusion between these two

di vments have been the subject of considerat,'e discussion between the Region IV

HRC staff and the licensee, yet problems continue to emerge. Revisions made to

both documents appear to have created, as well as solved, some of these

problems. See NRC Inspection Reports 50-382/87-31, -88-21, and -88-25 and

LER 88-027.

The second violation (paragraph 4.d) involved failure of operations personnel

to comply with radiological warning signs. One operator reached into a

radiologically restricted area without proper clearance from Health Physics.

Others violated a radiation work permit requirement to wear a full set of

protective clothing while climbing into contaminated areas. The MC inspectors  ;

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expressed concern that more stringent controls may be necessary to prevent

similar problems from recurring.

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DETAILS

1. Persons Contacted

Principal Licensee Employees c

• 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

J. J. Zabritski, 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

• T. J. Gaudet, Onsite Licensing Coordinator

• Present at exit interview.

In addition to the above personnel, the NRC inspectors held discussions

with various operations, engineering, t - 'inical support, maintenance, and

administrative members of the licenses staff.

2. Plant Status (71707)

The plant was operated at full power for the duration of this inspection

period, except on April 21, 1989, when power was reduced to approximately

95 percent for routine isothermal temperature coefficient testing, and on

May 5,1989, when power was again reduced to approximately 95 percent for

routine turbine valve and control element assembly testing.

3. Monthly Maintenance Observation (62703)

The station maintenance activities affecting safety-related systems and

components listed below were observed and documentation reviewed to

ascertain that the activities were conducted in accordance with approved

procedures, Technical Specifications (TS), and appropriate industry codes

or standards.

a. Work Authorization 01033676. The licensee performed an investigation

to determine the cause of failure of component cooling water dry

cooling tower fan motor high speed terminations. They determined

that the failure occurred after the terminal lugs corroded because of

moisture intrusion into the installed Okonite taped splices. The

moisture intrusion was attributed to capillary action drawing

moisture into the splices through the woven cable jacket material

left installed next to the splices. The licensee's instructions for

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installing these cable splices, found on Drawing LOLI-1564-B-288, were

deficient because no requirement for removing the woven material from

the cable when installing splices was included. The licensee

indicated plans to reolace future taped splices with Raychem Class IE

motor termination splie kits, which they think will provide better  ;

seals. Because of the lead time to obtain the Raychem kits, it will

be some time before they become available. The licensee measured the i

temperature of all high speed motor leads for Dry Cooling Towers A

and B and found two motors in each division with questionable splices

due to a higher relative temperi.ture. The licensee then replaced

these splices and inspected the lugs. The NRC inspectors will follow i

up on licensee actions to assure the reliability of these splices

through periodic maintenance (Inspector Followup Item 382/8912-01).

i b. Work Authorization 01035812. The NRL inspector. observed the drilling

l of a 13/16-inch hole in the High Pressure Safety Injection (HPSI)

1 Pump B recirculation line flow restricting orifice. The hole was

drilled to obtain access to resolve an indication by radiography

during the licensee's investigation of a low recirculation flow

condition during pump testing. The licensee found and retrieved a

1/4-inch set screw from the flow orifice and later determined that

the screw was the same as several screws used on the pump internals.

Thelicenseeconsultedwiththepumpvendor(Ingersol-Rand)and '

proceeded to disassemble the pump to inspect for missing set screws.

c. Work Authorization 01006018. High Pressure Safety Injection Pump B

was disassembled to investigate the source of a set screw found in

the pump recirculation line flow restricting orifice. The pump

rotating assembly was removed and disassembled. The licensee found

that two set screws were missing from the fourth stage impeller rings

which were severely damaged. In addition, wear and/or fretting was

found on eight of the nine stages. The NRC inspectors are following

the licensee's activities related to HPSI Pump B as part of the

response to issues raised in NRC Inspection Report 50-382/89-09.

During pump reassembly, the NRC inspector observed the pump shaft

. concentricity checks and noted that substantial adjustment was

required to bring the inboard end within the required tolerance. The

NRC inspectors are monitoring the licensee's investigation into the

cause of the pump damage. As of the end of this inspection period,

the results of that investigation were not yet available.

d. Work Authorization 01037167. The NRC inspectors observed repairs on

the Emergency Feedwater Pump A/B failed Steam Supply 1 solation

Yalve MS-416. The licensee determined that the cause of the valve

failure was that the torque switch swing arm pin had failed. The NRC

inspectors observed the torque switch replacement. During

installation, the NRC inspectors noted that the washers at the torque

switch wiring connections were not stacked in accordance with the

vendor's Manual No. 457000468, "Limitorque Maintenance Operation

Instruction." This was identified to the licensee by the NRC

inspectors and corrected prior to returning the valve to service. In

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addition, the NRC inspectors identified that the power supply i

terminations were not spliced in accordance with Drawing LOU-1564-B-288,

as required. ' This problem appeared to occur. because of inappropriate

labeling on the drawing. Problems with Okonite cable splice ,

instructions have been previously identified by both the NRC inspectors

and licensee personnel since January 1988. As a result of this  ;

additional' example, the NRC inspectors concluded that corrective  ;

actions .to date have been ineffective in preventing future viciations  ;

in this area. j

l In January 1988, the NRC inspectors identified in Violation 382/8731-03

that Okonite splices were not constructed in accordance with the  ;

drawing. _ In September 1988, the NRC inspectors identified another ]

problem with Okonite splice instructions in NRC Inspection

Report 50-382/88-21. In October 1988, the issue was raised again in

NRC Inspection Report 50-382/88-25.- The licensee's performance in

the correction of this problem has been poor. In LER 88-027, dated

November 30, 1988, the licensee stated that the B-288 drawings have ,

been revised and that the instruction, Procedure ME-4-809, " Low i

Voltage Power and Control Cable / Conduction Termination and Splices," l

now references the B-288 drawings to ensure consistency in splice '

construction. However, it is apparent from the recent example that

the licensee has not successfully removed all of the conflicts with  ;

the Okonite cable splice instructions.

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Failure to properly stack the washers on the torque switch electrical i

connections and failure to properly splice the power connections both ]

appeared to be the result of inadequate work instructions and, as

such, are in violation of NRC regulations (Violation 382/8912-02).

4. Monthly Surveillance Observation (61726)

The NRC inspectors observed the surveillance testing of safety-related

l systems and components listed below to verify that the activities were .

l 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 completeness.

The NRC inspectors ascertained that any deficiencies identified were

properly reviewed and resolved.

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a. Special Test 01037539, " Main Steam Isolation Valve 10% Exercise

Stroke Test MSIV #1." On May 18, 1989, the NRC inspector observed

the stroke test of Main Steam Isolation Valve (MSIV) No. 1. The

valve testing was performed with a revised procedure to require

checks of valve positions prior to manipulations to prevent excessive

MSIV valve closure and a potential plant trip. The previous test

method relied on automatic sequences of valves, and a sticking

solenoid valve resulted in a plant trip in 1987 (LER 87-011). The

test was conducted without any problems,

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b. Work ' Authorization 01037873. On May 22, 1989, the NRC inspector. j

1ob served th e performance of stroke time testing of Containment Cooler  ;

Isolation Valves CC-807A and CC-8228. The NRC inspector noted.that

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'the stroke times met the acceptance criteria and no problems were  :)

identified.

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c. Procedure OP-903-032, Revision 6', "Surveillan'ce Procedure Quarterly

ISI Valve Test." The NRC inspector observed the inservice testing of  ;

Emergency Feedwater Flow Control Valves EFW-223B and EFW-224B. The.  ;

NRC inspector noted that the.results were acceptable.- 1

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d. Procedures OP-903-011, devision 5, "High Pressure Safety. Injection-

Pump Preservice Operability Check,'l and OP-903-030, Revision 6

" Safety Injection Pump Operability Verification." The'NRC inspectors

observed the operability checks and establishment of new inservice

testing reference values for HPSI Pump B following major repairs. i

The evaluation was conducted without incident; however, there were j

two deficiencies identified by the NRC inspectors which were 1

discussed with licensee management.

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Prior to testing the pump, the NRC inspector observed an auxiliary

operator entering an area posted as "High Radiation Area," "High

Contamination Areas," " Radiologically Restricted Area," and "Do Not

Enter Without Health Physics Permission." This entry was made

without obtaining Health Physics permission. This was not in. 1

accordance with Procedure HP-1-110,' Revision 8. " Radiation Work  !

Permits," which requires adherence.to posted radiological-signs and I

the applicable radiation work permit (RWP). The NRC inspector also '

noted that the applicable radiation work permit, RWP 89000002,  !

required Health Physics permission prior to entering high radiation i

areas or radiologically restricted areas. In' addition, several

operations personnel were observed climbing in areas posted as

contaminated without donning full protective clothing as required by

RWP 89000002. Failure to follow radiological work procedures is a

violationofNRCregulations(Violation 382/8912-03). I

5. Onsite Followup of Events (93702)

a. Fire Dampers Declared Inoperable .

On April 25, 1989, the licensee declared 75 fire dampers inoperable

because they were not installed in accordance with the manufacturer's

requirements and fire test configurations. .They were installed in

accordance with the Architect-Engineer's (Ebasco) drawings, which l

were in error. This condition has existed'since construction.

The licensee had been performing a 100 percent inspection of fire

seals (see paragraph 5.b below). During the inspection, the licensee

noted differences between penetration seals involving fire dampers. '

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While resolving .the differences, the' licensee'noted that' fire dampers

were not provided with adequate annular clearance to allow-for l

. thermal expansion should the. damper be exposed to the' heat of 'a fire. {

In addition silicone foam penetration seals installed adjacent.to 1

the dampers aggravated the condition because of thermal expansion of- ]

the silicone foam which, according to the licensee,1s approximately; j

-1 percent volume increase per 18'F. 1

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Preliminary calculations by the licensee'.s design engineering. group-

indicated that if' automatic' sprinkler protection existed on both

sides of the damper. thermal. expansion would be lessened to where'the'

l- operability of the damper would not be hampered. Waterford 3 has 154

fire-dampers, many.of which protect safety-related equipment. -Of the ,

. 121 dampers questioned,' 75 have been declared inoperable. They

l required further evaluation and/or rework. Fire watches required by

.the licensee's Fire Protection Program had already.been established

in support of thel fire seal-inspection. Forty-six did not appear to  !

have a problem because their annular space conformed to the damper- l

manufacturer's requirements and/or they had automatic sprinkler

protection on both' sides; however, the licensee has indicated an-

intent to inspect the 46 dampers to ensure they were properly

installed. As of the end of this inspection period, the licensee had ]

not . completed the evaluations ~nor was a decision made as to how to  ;

report the issue to the NRC. 'The NRC inspectors' will followup on 1

licensee actions under Inspector Followup Item 382/8912-04.

'b. Fire SealTInspection and Repair Program )

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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, and -89-08. In 1

addition, the licensee identified the problem in LER 382/88-030, 'l

dated December 12, 1988. As of the end of this inspection period, of

the 2014 seals inspected, 634 required restoration. Of the 634 i

seals' 446 have been restored to the proper configuration, thus there

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were approximately 188 fire impairments in effect as of the end of '

this inspection period. j

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In LER 382/88-030, the licensee indicated plans to submit a final

report by May 30, 1989. In view of the unexpsted additional

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discrepancies found, targeted completion dates havt slipped and, ,

therefore, the licensee informed the NRC inspectors that a brief

status report will be published as a revision'to the LER on May 30,

1989, with a final report by July-1!,1989.

No violations or deviations were identifiec,

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6. Evaluation af Licensee Quality Assurance Program Implementation (35502)

On May 23, 1989, regional management performed an evaluation of.the

effectiveness of the licensee's quality assurance (QA) program

implementation by conducting an in-office evaluation of the following:

a. NRC inspection reports for the past 12 months,

b. Systematic assessment of licensee performance (SALP) reports for the I

past 2 years. I

c. Region IV outstanding open items list.

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d. Licensee corrective actions for NRC inspection findings. 1

e. Licensee event reports for the past 12 months.

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On the basis of the evaluation, the NRC steff found no negative

performance trends in any of t;m seven SALP functional areas. Plant

Operations and Radiological Controls appeared to indicate-an improving

trend due, in part, to licensee actions to improve procedural compliance.

The Maintenance / Surveillance functional area showed little improvement due l

to continuing ' incidents of procedural noncompliance and procedure  ;

inadequacies. J

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The NRC Maff determined that no adjustments to regional inspection plans

will be required as a result of the above evaluation. j

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7. Operational Safety Verification (71707)

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 j

the licensee's responsibilities for continued safe operation, to ensure 4

that selected activities of the licencee'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 plan.

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The NRC inspectors verified that proper control room staffing was

maintained, access to the control room was properly controlled, and

control. room activities were commensurate with the plant configuration and

plant activities in progress.

Panels containing nuclear instruments and other protection system elements

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were examined to determine that required channels were operable.

The NRC inspectors, reviewed the control room logs', tag-out book, standing

orders, and the: equipment out-of-service log. No problems were found.

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Rwired leak rate calculations had been performed to quantify identified

and unidentified leakage from the reactor coolant systems. Leak rates

were within TS limits.

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Portions of the accessible plant areas were toured on a random basis such '

that, by the end of. the inspection period,'nearly all of the plant was

observed at least once, with emphasis and repeated inspections in areas

where there is more work and operations activity. The large number of

scaffolds erected in support of fire seal work appeared to be declining as

the work came nearer to completion. l

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No violations or deviations were identified. j

8. Followup of Previously Identified Items (92701)

a. (Closed)Unresolveditem 382/8825-01: Resolution of. insulation

thickness under pipe whip restraints installed on tne naactor 1

coolant, feedwater, and main steam systems in the reactor containment  !

building. The NRC inspectors reviewed a detailed engineering j

evaluation of Nonconforming Condition Report No. 258220, which j

identified six whip restraints in the above systems which had no q

insulation in the gap between the pipes and the U-Bars. .According to l

the evaluation which was approved by the Plant Operations Review l

Committee (PORC) on April 10, 1989 EBASCO(theArchitect-Engineer)  ;

performed a quantitative analysis and determir.ed that the whip

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restraints will perform their intended functions without insulation. 4

The licensee's Design Engineering Group recommended installation of i

the 1/4-inch Min-k insulation to reduce heat losses to the containment i

building. This item is closed.

b. -(Closed)UnresolvedItem 382/8717-01: Resolution of whether or not i

the'PORC should have reviewed Mechanical Maintenance Procedure MM-6-004,  !

Revision 3. " Shaft Coupling Alignment and Belt Tensioning,".as

required by TS 6.5.1.6.a. On February 17, 1988, the licensee issued

a comple.e rewrite of MM-6-004 (Revision 4). The procedure was-

reviewed by the PORC. On May S,1989, the licensee revised the

administrative procedures which controlled the PORC and procedure

review requirements. They adequately identified the types of

procedures which must be reviewed by the PORC and appeared to properly

implement the PORC review requirements of the TS. Failure of the

PORC to review MM-6-004 was in violation of NRC regulations. NRC

Inspection Report 50-382/89-07, dated April 17, 1989, addressed ,

concerns over PORC failures to meet quorum requirements and to  !

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conduct reviews required by the TS (Violation 382/8907-01). The NRC

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staff will follow up on the licensee's response to determine the j

adequacy of corrective actions taken. No additional violation will be

issued. This item is closed,

l' No violations or deviations were identified.

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' The following LERs were reviewed and closed. The NRC inspectors verifie'd  !

that reporting requirements had been met, causes had been identified, J

corrective actions appeared appropriate, generic applicability had been' . l

considered, and the LER forms were complete. The NRC inspectors confirmed ,

that unreviewed safety questions and violations of TS, license conditions,  :)

or other regulatory requirements had been adequately described, j

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a. (Closed)LER 382/88-033,-" Reactor Trip Resulting from Inadequate i

Administration Control of. Work Around-Sensitive Equipment" J

b., (Closed) LER 382h88-034, .'" Qualified Safety Parameter Display System

. Seismic Supports-Missing Since Initial Construction"

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~ No violations:or deviations were identified.

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10. Exit Interview'

The inspection scope and findings were summarized on June 5,1989, with .

. those persons indicated in ' paragraph 1 above. The' licensee acknowledged

the NRC inspectors' findings. The licensee did not identify as; j

proprietary any of the material provided to, or reviewed by,' the NRC .I

inspectors during this ' inspection. j

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