ML20059H141
| ML20059H141 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 01/13/1994 |
| From: | Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20059H015 | List: |
| References | |
| 50-382-93-34, NUDOCS 9401260282 | |
| Download: ML20059H141 (19) | |
See also: IR 05000382/1993034
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APPENDIX B
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
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Inspection Report:
50-382/93-34
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License: NPF-38
Licensee:
Entergy Operations, Inc.
P.O. Box B
Killona, Louisiana
Facility Name: Waterford Steam Electric Station, Unit 3
Inspection At: Waterford Steam Electric Station, Unit 3 (Waterford 3)
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Inspection Conducted: October 31 through December 11, 1993
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Inspectors:
E. J. Ford, Senior Resident Inspector
J. L. Dixon-Herrity, Resident Inspector
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W. M. McNeill, Reactor Inspector
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Approved:
Thomas FT Stet a, C ief, Project Branch D
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inspection Summary
Areas Inspected:
Routine, unannounced inspection of plant status, onsite
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response to events, operational safety verification, maintenance and
surveillance observations, and followup on previous inspection items.
Results:
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The control room operators reacted swiftly and in accordance with
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procedures in response to both the loss of the plant monitoring computer
and the loss of all essential chillers (Sections 2.1.1 and 2.1.4).
A poor practice was identified in that gas bottles, although properly '
stored, were allowed by procedure to be temporarily impounded in Safety
injection Pump Room B (Section 2.1.2).
Two consumable materials were found left at work sites, but this was not
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found to be representative of their current consumable materials control
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program (Section 2.1.3).
9401260282 940120
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The delay in running Low Pressure Safety Injection Pump A following the
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identification of an unexplained sound event was identified as a
weakness (Section 2.2).
A poor practice was noted in that adequate lighting was not set up for
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the replacement of Chill Water Pump AB (Section 3.1).
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Electrical technicians were noted to use good electrical practices in
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the changeout of a battery charger breaker (Section 3.2).
A violation was identified for failure to obey the Radiation Work Permit-
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(RWP) instructions for entering a radiological restricted area in the
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overhead of the radiation control area (RCA).
Poor communication
between the health physics and mechanical maintenance personnel was also
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noted during this task (Section 4.2.1).
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Effective planning and communications were noted during the in-service
tests of Hydrogen Analyzers A and B (Section 4.3).
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Summar_y of Inspection Findings:
inspection Followup Item 382/9334-01 was opened (Section 2.4).
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Violation 382/9334-02 was opened (Section 4.2.1).
Violation 382/9201-01 was closed (Section 5.1).
Violation 382/9227-01 was closed (Section 5.1).
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Violation 382/9226-01 was closed (Section 5.2).
Violation 382/9316-01 was closed (Section 5.3).
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Unresolved item 382/9203-04 was closed (Section 6.1).
Inspection Followup Item 382/9217-02 was closed (Section 6.2).
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Inspection Followup Item 382/9314-03 was closed (Section 6.3).
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Unresolved item 382/9314-05 was closed (Section 6.4).
Inspection Followup Item 382/9316-03 was closed (Section 6.5).
Inspection Followup Items 382/9334-03 through -14 were opened
(Section 6.6).
Inspection followup Item 382/9334-04 was closed (Section 6.6.1).
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Inspection Followup Item 382/9334-05 was closed (Section 6.6.2).
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Inspection Followup Item 382/9334-06 was closed (Section 6.6.3).
Attachment:
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Attachment - Persons Contacted and Exit Meeting
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DETAILS
1 PLANT STATUS
The plant operated at full power from the beginning of the inspection period
until December 2, 1993, when power was reduced to 93 percent for routine
turbine valve testing. The plant returned to full power and operated there
until the end of the inspection report period.
2 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, and to ensure
that the licensee's management controls were effectively discharging the
licensee's responsibilities for continued safe operation.
2.1
Plant Tours
2.1.1
Plant Monitoring Computer Outage
On November 9, while the inspectors were observing the control panels to
determine the plant's status, the plant monitoring computer failed. This
computer provided more accurate and frequent calculation of the plant's
status, allowing the plant to operate closer to Technical Specification
thermal limits.
The control room operators reacted promptly in accordance
with Off-Normal Operating Procedure OP-901-501, Revision 0, " Plant Monitoring
Computer or Core Operating Limit Supervisory System Inoperable." Required
calculations were performed every 15 minutes to verify that the plant was
operating within the Technical Specification limits for local power density,
axial slope index, and departure from nucleate boiling ratio. The cause of-
the 35-minute outage was determined to be that Central Processing Unit 2B had
halted.
This unit was brought back on line, and the off-normal procedure was
exited.
2.1.2
Storage of Compressed Gas Bottles in Close Proximity to
Safety-Related Equipment
On November 16, while touring the reactor auxiliary building, the inspecto' rs
noted three bottles of argon that were stored in a temporary impound area in .
Safety Injection Pump Room B.
This pump room contained Train B's containment'
spray, high pressure safety injection (HPSI), and low pressure safety
injection (LPSI) pumps.
In addition to the pumps, the refueling water storage
pool was located directly above the room.
The storage pool gravity feeds
these three systems through a header that was located above the impound area.
The bottles were safety-chained to carts and the caps were in place in
accordance with site procedures.
The inspectors questioned the licensee
regarding the practice of storing compressed gas cylinders in such close
proximity to this equipment. The inspectors' concern was relayed to
operations and safety personnel.
Operations personnel determined that the
bottles were stored there for an in-progress design change that required
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cutting and capping LPSI and HPSI drain lines. Maintenance personnel were
' storing them there-in accordance with UNT-007-006, Revision 6, " Housekeeping,"
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and the "Waterford 3 SES Industrial Safety Manual." These documents required
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that a tag identifying the area as a storage location be displayed, that the
valve protection caps be in place hand tight, and that the bottles be secured
with a safety chain. The bottles had been stored there unused for at least a
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week. Maintenance personnel informed the control room that they would remove
the bottles from the area until they determined they were needed.
The bottles
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were moved to the hot machine shop. The licensee's position was that the
storage location was not a concern as the bottles were stored correctly, and
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no evaluation of temporary storage locations was procedurally required. The
inspectors identified the temporary storage of gas bottles in close proximity
to safety-related equipment as a poor practice.
2.1.3
General Site Tour
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During a tour on November 30, 1993, the inspectors noted several conce ns.
The first concern involved the moisture indicator on Emergency Diesel
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Generator B Air Dryer B2, which indicated that the dryer was no longer _ capable
of removing moisture. Operations personnel had the dryer checked, issued a
condition identification, and declared it inoperable. This did not affect the
operability of the emergency diesel generator as Air Dryer B1 was available.
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The second concern involved the failure to remove consumable materials from
two different work sites in the RCA in the reactor auxiliary building. This
concern was relayed to licensee safety personnel.
Both of the materials had
been labeled as approved for general use, but Administrative Procedure,
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UNT-007-003, Revision 8, " Control of Consumable Materials," required that
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consumable materials be removed from the job site when a work area was
unattended. Other recent plant tours did not identify any further lack of
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control of consumable materials; therefore, this may have been an isolated
occurrence. The licensee had the responsible departments review consumable
materials control requirements and issue a condition report.
In addition,
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this issue was discussed at a daily licensee meeting so that plant personnel
were reminded of the proper handling of consumable materials onsite.
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The third concern noted involved a loud chirping noise in the vicinity of the
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feedwater regulating valves.
The_ inspectors discussed the noise with
operations personnel responsible for that area. These personnel had noted the
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sound, but had done nothing at the time beyond identifying friction between
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supports in the area as a possible source.
The inspectors also queried system
engineering personnel to determine their knowledge of the noise.
They had
determined that the end pin connections on several snubbers in the area were
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making the noise due to the vibration in the feedwater line.
System
engineering had verified at the time that there was no concern and stated that
the chirping was intermittent and dependent on the weather. The inspectors
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were informed that operations had also verified that there was no concern
after the issue was raised by the inspectors.
A condition identification was
issued to address the lubrication and examination of the affected snubber's
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end pins during the next outage.
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2 1.4 Trip of Essential Chiller A
On December 8, while the inspectors were in the control room, they observed
the _ trip of Essential Chiller A on low chilled water flow.
Essential'
Chiller B had been out-of-service since December 7, to repair a refrigerant
leak which placed the plant in Technical Specification 3.7.12.
Since
Essential Chiller AB was not available to backup Essential Chiller A due to
the failure of its guide vane cycle timer, no essential chiller was available
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and the plant entered Technical Specification 3.0.3, which required the
problem to be resolved within one hour or commence a plant shutdown.
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control room staff responded to the loss of the essential chiller systems and
returned Train B to operable status in a timely and appropriate manner.
Fifty-nine minutes after Essential Chiller A tripped, Train B was recovered,
declared operable, and Technical Specification 3.0.3 was exited.
Essential Chiller AB was returned to service after the cycle timer was
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repaired and Technical Specification 3.7.12 was exited. A thermography camera
was used in the troubleshooting process to identify a spot on the B phase
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electrical overload block on Essential Chiller A that was approximately
100 degrees hotter than the other blocks.
Electrical maintenance determined
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that the bolt connecting this block to the overload heater was approximately
one turn loose.
The overload block was replaced and the bolt tightened.
These connections in the other two chillers were checked to ensure that there
were no additional hot spots. The licensee verified the tightness of all
connections on the buses every other refueling outage. A note was to be added
to the appropriate procedures to ensure these connections were checked during
this effort.
Licensee Event Report 93-10 and Condition Report'93-302 were to
be issued to document and determine the root cause for this event.
2.2 Sound Event Durina LPSI Pump A Run
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On November 10, the inspectors noted that there had been an unexplainable
sound event during the post-maintenance test of LPSI Pump A on
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November 9, 1993. The system was walked down by operations personnel
immediately following the event and no damage was found. The licensee issued
Condition Report 93-229 and formed an event review team to determine what had
happened.
The inspectors also walked down Train A of the LPSI system and
found no sign of damage.
The review team contacted personnel who witnessed the test, walked down the
system and, again, found no damage.
Interviewers determined that a sound was
heard in the control room, but this was later thought to be the. closing of a
breaker right below the control room. The sound at the pump was suspected to
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be the closing of Check Valve CS-117A.
The inspectors questioned why the pump
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was not run again under observation to allow the collection of additional
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data. The event review team leader explained that it was the Train B week for
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maintenance, and the delay gave them additional time to collect and review the
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had already accumulated. The inspectors considered this delay a
weakness 'n that seven days passed between the identification of an
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unexplainable aromaly in a safety-related system and the operation of the
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system to allow the team to observe and collect data first hand.
On November 16, the inspectors observed as LPSI Pump A was run as required by
Surveillance Procedure OP-903-30, Revision 2, " Safety Inject.on Pump
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Operability Verification," to see if the event recurred.
Containment Spray-
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Valve CS-125A was closed in preparation for the test as it was suspected to be
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a contributor in the cause of the noise.
The inspectors noted that when the
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pump started there was a loud noise and that the containment spray riser line
moved one to two inches.
Licensee personnel were stationed at the pump and on
the -35 foot level of the containment penetration area in the vicinity of LPSI
system piping.
Personnel stationed at the pump found that the movement was
not out of the ordinary, while the individual in the wing area saw what he
felt was excessive movement but identified no concerns with the containment
spray system. All involved personnel felt that some form of transient had
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occurred, and design engineering was assigned to investigate. On Noeember 19,
the pump was run again and up to one inch of movement was noted in the
vicinity of Valve SI-139A.
Based on the above information, a design
engineering evaluation found that a hydraulic transient had occurred, but-that
the movement was not unacceptable and would not affect the operability of the
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system. The operations superintendent was present at the pump during the
November 19, run and had the system vented after the run was complete. Air
was vented upstream of the flow control valve.
On November 30, the pump was run again under observation as a part of the
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closure process for the condition report to check to see if the event
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recurred. The observers noted a small amount of movement, much-less than had
been noted previously, and heard no noise. The licensee planned to observe
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the next scheduled surveillance pump start in approximately a month to ensure
the event does not recur.
The source of the air was still being researched by
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the event review team. At the time it was suspected that the vent procedure
used on Train A of containment spray during the investigation of the recent
problem with Valve CS-125A was a possible source of the air intrusion.
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2.3 Essential Chiller Histor_y
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Since the onset of colder weather, the inspectors noted an increase in the
number of essential chiller trips. This concern and the problems with the-
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chilled water pumps (discussed in Section 4.1) caused the inspectors to review-
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complete set of logs regarding the system's operation and problems, and that
the system was walked down on a regular basis.
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A number of problems had plagued this system.
The hot gas bypass system did
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not initially work well and was not used as a result of its inadequacy.
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system was repaired on all chillers last year and worked fine for one winter,
but started malfunctioning again this winter. Troubleshooting revealed that
one of the setpoints in the controls for the hot gas bypass valve had drifted
in the conservative direction, preventing the valve from opening when
required. These setpoints were reviewed, raised approximately two degrees,
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and arrangements were made to reset them annually as cold weather approached
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to prevent recurrence of the problem.
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Electrical problems that have caused trips in the last few months included
relay contacts that stuck and intermittent continuity problems in the
compressor wiring harness due to compressor vibration during low load periods.
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In both cases the problems could not be duplicated after occurrence.
Both
problems had caused trips on different chillers in the past and the causes.had
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been diagnosed. The relays were visually and electrically inspected and no
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problems were found.
An engineering review was conducted and it was
determined that no action was required in this case. The intermittent
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continuity problems could not be identified.
System engineering provided
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maintenance personnel with diagnostic information to allow for immediate
identification of the problem the next time a unit trips in the same manner.
Other problems included adding too much oil or adding an incorrect amount of
refrigerant during cold weather, preventing the units from properly running
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when the loads were increased. The first problem was eliminated with a
modification that added an oil skimmer line that returned oil from tha
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evaporator to the compressor. The second problem is an ongoing problem that
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the engineering personnel will try to eliminate by introducing a false load
while the chiller is being charged with refrigerant.
The main problem with the essential chillers during the winter season oas the
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low load demand. The system was designed for accident conditions an'.'uns at
loads closer to these conditions during the rest of the year without
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significant problems. The original design called for the two trains to be
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cross-connected, but due to problems associated with having an expansion tank
installed for each chiller, the decision was made not to operate the systems
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cross-connected. The only time that this cross-connected configuration has
been found to be a problem was during the winter months. Operations personnel
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were in the process of investigating other system configurations that could
possibly eliminate the low load demand problem.
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2.4 Potter Brumfield Relays
During the daily licensee meeting on December 10, engineering personnel
discussed the status of problems identified with Potter Brumfield relays. The
licensee had assisted the supplier, Combustion Engineering, in the
identification of a chloride contamination problem with the relay springs.
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This was not found to affect the operability of the relays immediately,. but
would shorten their service life.
Eight of the affected relays from the
warehouse were sent back to the manufacturer, Potter Brumfield, to replace the-
springs. Upon disassembling the relays for spring replacement, the
manufacturer noted a reduction in the end play on the relays, which they
subsequently found to be caused by oversized coils.
The end play was defined
as the amount of rotor assembly movement from end to end within the housing.
The relays were specified to have end play tolerances between 0.010 and
0.020 inches.
The end play dimensions measured on two of the relays
were 0.013 and 0.008 inches.
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All eight of the relays were found to have oversized coils, with the coil
height from the stator at the bottom of the coil ranging from 0.088 to
0.117 inches too large.
The suspected cause was the use of "Go/No-Go" gauge
made to the wrong dimension.
This gauge was used to determine the acceptable
coil height during fabrication.
The oversized coils resulted in a reduction
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of rotor end play which could prevent the relay from changing states.
Approximately 74 of the affected models of the relay (Models 7032, 7033, and
7034) were installed in the engineered safety features actuation system at
Waterford-3. All of these relays were replaced during Refuel Outage 5 due to
a previously identified outgassing problem with the relay coils.
Eighty-two percent of these relays had been tested every 62 days, as required
by the Technical Specifications.
The remainder were required to be tested
every 18 months and had been tested once since installation.
No failures due
to loss of rotor end play had been identified by the licensee during this
testing.
On December 10, the licensee entered Site Directive W4.101, Revision 0,
"Nonconformance/ Indeterminate Analysis Process," to evaluate the operability
of the relays.
The evaluation concluded that continued use of the relays
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would be acceptable based on the previous surveillance test results.
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current surveillance frequency was to be maintained and plans were being made
to replace all of the relays during the next outage or one train during each
of the next two outages, depending on the availability of the relays. The
relays were purchased as commercial grade then qualified as nuclear materials
by the supplier. The manufacturer and supplier were working to determine the
reportability of the affected batch of relays.
Inspection Followup
Item 382/9334-01 was opened to track the resolution of this problem.
2.5 Conclusions
The control room operators reacted immediately and in accordance with
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procedure in response to both events; the loss of the plant monitoring
computer and the loss of all essential chillers. One poor practice was
identified in that gas bottles, although properly stored, were allowed by
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procedure to be temporarily stored in Safety Injection Pump Room B.
Two
consumable materials were found left at work sites, but this was not found to
be representative of their current consumable materials control program.
3 MONTHLY MAINTENANCE OBSERVATION (62703)
The station maintenance activities affecting safety-related systems and
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components listed below were observed and documentation reviewed to ascertain
that the activities were conducted in accordance with approved work
authorizations (WAs), procedures, Technical Specifications, and appropriate
industry codes or standards.
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3.1
Installation of Chilled Water Pump AB
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On November 9,1993, and several times later in the week, the inspectors
observed different stages of the installation of new Chill Water Pump AB. The
pump was installed using Design Change DC-3251 and WA 99003251. This work was
to correct a history of packing seal leaks and multiple occurrences of shaft
failure.
The original supplier could no longer supply qualified replacement
parts and new enhanced design pumps were purchased from a qualified supplier.
The design change utilized the existing motor, modified the pump's foundation,
and installed the new pump.
The inspectors noted that the installation was done in a cramped, poorly lit
location behind Essential Chiller AB.
Due to the inadequate lighting the
workers resorted to the use of a flas3Li<$t-wMTrdr+ ing the foundation
modification. This was considered
poor work practice y the inspectors an
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was expressed as such to licensee
nagement.
A'ter the modification was complete, operations personnel noted that they had
f o fill the oil reservoir (bubbler) several times a day.
The oil, in some
.ases, would drain into the bearing casing soon after the pump started.
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was also found to be leaking out of the casing, but not at the same rate.)
The same problem had been identified on Chill Water Pump A, but they found
that they did not have to add oil as often as they did on Chill Water Pump AB.
According to the manufacturer this type of pump had this problem in the past
and the solution was to remove the oil slinger pin (1 of 2) closest to the
bubbler penetration.
The spinning pin had a tendency to create a void that
pulled all the oil in the bubbler into the casing. The manufacturer stated
that removal of the pin would not affect the shaft balance.
While checking the balance on a similar pump from the warehouse before and
after removing the pin, the licensee found etching on the shaft surface where
the lip seal of the bearing casing contacted the shaft. An additional pump
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from the warehouse had-the same etching.
The licensee shipped the two shafts
from the warehouse back to the manufacturer for rework. Once returned, these
shafts were scheduled for installation in Chill Water Pumps AB and A.
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shafts removed would then be sent back for modification and later installation
in the two disassembled pumps from the warehouse.
3.2
Indeterminate Status on Battery Chargers
On November 19, the inspectors observed the breaker in Battery Charger AB2
being replaced in accordance with WA 01115444. While replacing the breaker in
Battery Charger AB1, a technician noted that although the charger technical
manual called for a Model LAB 2400 breaker, a Model LAB 2700M breaker was
installed.
Condition Report 93-260 was completed to determine the root cause
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and the licensee entered Site Directive W4.101, Revision 0,
"Nonconformance/ Indeterminate Analysis Process," for all six safety-related
battery chargers. The licensee had previously identified that the
Model LAB 2700M breaker was installed in one of the other chargers several
months prior and completed a nonconformance identification.
There was a long
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lead time in procuring the LAB 2400 breakers and they were not in stock in the
warehouse. The licensee had no records of previous replacements and they
concluded that the breakers had been installed by the manufacturer.
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manufacturer indicated that either breaker could be used. The licensee has
had a history of problems with one charger tripping as the other charger in
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the train was brought on line. The LAB 2400 breaker had both thermal and
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magnetic trips instead of just a magnetic trip that breaker LAB 2700M had and a
higher amperage range (2000-4000 amps versus 350-700 amps.) 'The lower
amperage range of the installed LAB 2700M breaker was a possible cause of the
tripping problem, so the licensee replaced all six breakers. The maintenance
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personnel performing the task on Charger AB2 followed the work package
instructions and used good electrical practices.
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3.3 Controlled Ventilation Area S_ystem (CVAS) B Outage
On November 23, the inspectors observed as mechanical maintenance technicians
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cleaned and lubricated couplings and bearings for the CVAS B blower. The
inspectors noted that WA 01114270 was completed, and that the task was
performed in accordance with the instructions. After cleaning the bearings,
quality assurance was contacted to verify cleanliness before the bearings were
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repacked and to observe as the bearing and coupling casings were torqued.
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inspectors verified that the correct lubricants were used and that the torque
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wrenches were calibrated.
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3.4 Conclusions
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Electrical technicians were noted to use good electrical practices.
A poor
maintenance practice was noted in that adequate lighting was not set up for
the replacement of Chill Water Pump AB.
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4 BIMONTHLY SURVEILLANCE OBSERVATION (61726)
The inspectors observed the surveillance testing of safety-related systems and
components listed below to verify that the activities were being performed in
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accordance with the licensee's programs and the Technical Specifications.
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4.1
Emergency Feedwater Pump A Surveillance
On November 22, 1993, the inspectors observed the operation of Emergency
Feedwater Pump A.
The pump was started to verify that it developed a
discharge pressure greater than or equal to 1298 psig on recirculation _ flow
and to inspect the oil slinger rings. The inspectors noted that the pump ran
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smoothly at normal temperatures.
The technicians found no problems with the
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oil slinger rings.
Following the test, the inspectors verified with a control
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room operator that the discharge pressure met the acceptance criteria.
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4.2 HECA Absorber Test Canister Removal Preparations
4.2.1
CVAS B
On November 23, the inspectors observed as mechanical maintenance personnel
prepared to open CVAS B to take a carbon sample from the filters. During the
prepcration for the task, the inspectors noted one of the workers climbing
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down from the top of the unit. The inspectors questioned the action after the
worker climbed up and down a second time.
The individual explained that he
was taking measurements of the unit. The unit's top was approximately 10 feet
above the +46 foot floor level of the RCA, so the top of the unit was
considered a radiological restricted area,
i.e., an area not routinely
surveyed by health physics.
The inspectors questioned the health physics
technician assigned to the task and determined that health physics personnel
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had not been informed of the need to enter the overhead area.
The inspectors had several concerns. The worker had entered a radiological
restricted area without informing health physics personnel. The health
physics technician at the scene claimed to have noted the infraction the first
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time the overhead was entered, but did not clearly communicate the concern to
the individual to prevent his entering it a second time and was not present to
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observe the second entrance due to other responsibilities in the area.
The inspectors discussed the incident with raoiation protection and mechanical
maintenance supervision.
Postings at the entrance to the RCA described the
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overhead areas in the RCA as radiological restricted areas. A radiological
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restricted area was defined as an area not routinely surveyed by health
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physics in Administrative Procedure HP-001-219, Revision 9, " Radiological
Posting Requirements." The radiation superintendent stated that the overhead
should have been surveyed before entry and that the health physics technician
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should have informed the individual of this requirement. Administrative
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Procedure HP-001-101, Revision 9, "ALARA Program Implementation," required
that individual employees strictly adhere to RWP instructions and
requirements.
Standing mechanical maintenance RWP 93000007 required that
health physics personnel be contacted prior to entering radiological
restricted areas.
Mechanical maintenance supervision investigated the incident and found that
several personnel misunderstood the posting at the entrance to the RCA. They.
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. thought it only applied to the -4 foot level of the RCA. The technician
involved considered the +46 foot floor level of the RCA to be a clean area.
The handout for General Employee Training Requalification, required' annually
for all employees, used the overhead (defined as greater than eight feet from
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the floor) in the RCA as an example of a radiological restricted area.
The
area over CVAS B was surveyed soon after the work in the area was complete and
dose rates in the area were found to be less than 2 mrem /hr. The incident was
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discussed with the individuals involved and Condition Report 93-286 was
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generated to determine the root cause and corrective actions required. The
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failure to obey the RWP was a violation of Technical Specification 6.8.1
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(382/9334-02).
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4.2.2
Shield Building Ventilation System B
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On November 23, after completing the task on the CVAS B, the workers took a
sample from Shield Building Ventilation Building System B.
This task was
performed in accordance with WA 01115543 and Maintenance Procedure MM-006-017,
Revision 4, "HECA Absorber Test Canister Removal." The health physics
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technician took samples in the plenum and then prepared a confined space
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permit to allow entry into the unit.
Both quality assurance personnel and the
mechanical maintenance supervision observed the task. The inspectors
questioned having unused blanking covers loose in the plenum.
The system
engineer researched the question and found that an evaluation may have been
done, but it could not be located. Design engineering completed an evaluation
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and determined that seismically, the blanking plates could be stored in the
unit.
4.3 In Service Test (IST) Test of Hydrogen Analyzer Valves
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On November 30, the inspectors observed as Hydrogen Analyzer A and B sample
valves were tested in accordance with Surveillance Procedure OP-903-120,
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Revision 1, " Containment and Miscellaneous Systems Quarterly IST Valve Tests."
Before starting, operations personnel involved reviewed and discussed the
procedure. During the test of both units, operations maintained good
communications and followed the procedures. The test on Hydrogen Analyzer A
went as planned with good results.
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During the test of Hydrogen Analyzer B, the sample indicator light for the
annulus illuminated.
This was not the expected response for the test.
Procedurally, a low flow alarm had been expected. The light then went out and
the low flow alarm properly came on. The operators stopped the test to
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discuss the unexpected light, but decided to continue after receiving the low
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flow alarm and approval from their supervisor.
The test was later repeated,
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but the anomaly did not recur. A condition identification was completed to
have maintenance investigate the problem.
4.4 Conclusions
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A violation was identified for failure to obey the RWP instructions for the
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radiological restricted area in the overhead of the RCA.
Poor communication
between the health physics and mechanical maintenance technicians involved was
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noted in this incident.
Effective planning and communications were noted
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during the in-service tests of Hydrogen Analyzers A and B.
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5 FOLLOWUP ON CORRECTIVE ACTIONS FOR VIOLATIONS (92702)
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5.1
(Closed) Violation 382/9201-01:
Failure to Control Changes to Drawings
and (Closed) Violation 382/9227-01:
Failure of Corrective Actions
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The original violation on failure to control changes to drawings was
identified in NRC Inspection Report 50-382/92-01 and then in NRC Nspection
Report 50-382/92-27. The violation in NRC Inspection Report 50-382/92-27
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contained two examples, one of which identified that the corrective actions to-
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the original violation were inadequate. The inspectors found-that the
governing Administrative Procedure UNT-005-004, " Temporary Alteration
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Control," had been revised.
Revision 10 to the procedure incorporated the
changes listed in the response to Violation 382/9227-01. :These changes
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included limiting the number of personnel who could change information on
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drawings and providing a checklist to control the temporary alteration
process.
The temporary alteration numbering scheme was to be revised and
provisions made to improve the oversight that operations personnel provided
over the temporary alteration process. The inspectors reviewed the revised
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procedure and the attendance records of training on the revised procedure.
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Violation 382/9227-01 was identified by the licensee in Condition Report.93-086 which had been closed.
The inspectors reviewed the drawings and microfiche files of drawings in the
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control room.
In this review all six current temporary alterations were
verified to be properly noted on the 13 affected drawings.
In addition, a
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sample of 40 drawing revision notices was verified to be annotated on the
affected drawings. The actions taken by the licensee appeared to have
corrected the original problem.
They addressed the failure to establish
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effective corrective action that included implementation of corrective
actions.
The licensee did not agree that their corrective actions failed.
Their response letter took the position that the corrective actions had not
been implemented fully. The additional corrective actions have been fully.
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implemented and are effective in controlling drawings.
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The other example of the violation cited in NRC Inspection Report 50-382/92-27
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identified a possible failure in the corrective actions made to a previous
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violation in that the details on how to perform independent verification were
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deleted from the procedures as part of the corrective actions. The inspectors
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verified that Administrative Procedure UNT-005-010, " Independent Verification
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Program," was revised to provide detailed procedures on how to perform
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independent verification and that training on the event had been provided for
the maintenance department.
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5.2 (Closed) Violation 382/9226-01:
Failure of Existina Procedure to
Control the Use of Chemicals in the Control L g
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This violation identified the failure of Administrative Procedure UNT-007-003,
Revision 8, " Control of Consumable Materials," to prevent the use of a
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commercial contact cleaner in the control room.
Use of the cleaner on a
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safety-related control panel damaged 16 safety-related control switches.
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Further review of the program indicated that the procedure was not being
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adhered to in those areas it did cover.
The inspectors reviewed the
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corrective actions taken by the licensee to prevent recurrence. UNT-007-003
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was revised to include the control room in the defined consumable materials
controlled areas (CMCAs). The inspectors noted that appropriate signs were
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posted on all entrances to the control room. A task force was assembled and
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all CMCAs were walked down on February 17, 1993, to identify unlabeled or.
unapproved consumable materials.
On January 20 and 21, 1993, safety meetings
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were held to discuss the event and te stress the proper use of consumable.
materials. An industry survey was conducted.
This resulted in a revision to
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UNT-007-003 to require walkdowns of CMCAs; to coordinate with purchasing to
approve consumable materials before ordering; to provide a better definition
of consumable material; and to expand the list of exempteu items.
Also, the
consumable materials program was transferred from the chemistry department to
the environmental department.
The last action taken was.to cause the
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different der .rtments that use consumable materials to assist in facilitating
the identif
4 tion and approval of consumable materials necessary 'in their
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areas.
The inspectors conducted a tour of the turbine and reactor auxiliary buildings
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on November 15 and 16, 1993, and found no consumable materials.
The
inspectors discussed the program with environmental / safety personnel and found
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that additional improvements were planned in labeling and documenting of
materials. Monthly tours by the environmental / safety group had identified
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problems, but they found that the site was improving. The protected area was
upgraded to a consumable material controlled area. The licensee also
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indicated that the different departments were cooperating in identifying and
submitting the paperwork for non-approved materials.
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5.3 (Closed) Violation 382/9316-01:
Failure to Enter Off-Normal Procedure
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Off-Normal Procedure OP-901-102, "CEA or CEDMCS Malfunction," was not referred
to upon determining that part-length Control Element Assembly CEA-28 was
immovable during the performance of a surveillance.
The root cause was
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determined to be a failure of operations personnel to enter the procedure.
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Condition Report 93-083 was written to track the event. The inspectors
reviewed the corrective actions taken by the licensee. The responsible
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individual was counselled and licensee management discussed the event with
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operations personnel during requalification training.
Also,.the event was..
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added to required reading.
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6 FOLLOWUP (92701)
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6.1
(Closed) Unresolved Item 382/9203-04: The Use of Helicoils on Thread
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Repair
This item was opened to follow up on a possible violation of NRC regulations
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regarding the use of helicoils on a steam generator thread repair.
The
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licensee used helicoils for steam generator thread repair in May 1991.
The
repair process was subjected to a 10 CFR 50.59 review and approved on
March 11, 1991. The inspectors reviewed the documentation for the
10 CFR 50.59 review and the Analytical Report CENC-1805. Analytical
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Report CENC-1805, dated March 15, 1988, which accepted the application of
helical inserts for stud hole thread repair, was on file with the nuclear
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steam supplier.
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On March 14, 1991, ASME Code Case N-496 was issued to clarify the code
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requirements on the use of helical inserts. The licensee was not aware of
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this code case at the time and had used the 10 CFR 50.59 process to make this
change.
The inspectors reviewed Code Case N-496 and the certified material
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test reports on the helical material. The licensee had complied with the
requirement of ASME Code Case N-496. The NRC issued a safety evaluation on
February 21, 1992, which approved the use of helical coil threaded inserts.
Due to the above chronology of events, no violation of NRC regulations
occurred.
6.2
(Closed) Inspection Followup Item 382/9217-02:
Question of When Loos
Should be Signed
This item was opened to review actions taken by the licensee to ensure that
logs are not signed off until they are complete. The inspectors verified that
Operating Instruction 01-004-000, " Watch Station and Shift Logs," was revised
to indicate that only one individual's signature was necessary and that
individual was responsible for all entries made in that log. Records of
training provided in February 1993 were reviewed and found to be complete.
The training was provided to all operations personnel who worked on shift and
stressed that the logs were not to be signed off until they were complete.
6.3
(Closed) Inspection followup Item 382/9314-03:
Resolution of
Discrepancy Between Relief Valve Design Pressures
This item identified a discrepancy between Combustion Engineering Calculation
C-PEG-ll7 and Ebasco Purchase Specification LOV-1564.124 for Safety Relief
Valves SI-406A and B used for low temperature over pressure protection in the
shutdown cooling system. The inspectors discussed this item with licensing
and design engineering.
The design responsibility for these valves was with
Ebasco, the architecture engineer.
Documentation could not be provided to
describe the discrepancy by either company. The inspectors noted that ASME
Code Data Sheet NV-1 identified a set pressure, 415 psig, but the design
pressure was not specified.
The actual design pressure, 440 psig, was above
the set pressure. Therefore, the pressure of the system would never challenge
the design pressure of the valve.
Thus, the lack of documentation explaining
the discrepancy between the Combustion Engineering and Ebasco documentation
doesn't appear to be a problem.
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6.4
(Closed) Unresolved Item 382/9314-05:
Reportability of. * I gt_y
Valves Exceeding the Technical Specification Toleranct
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The question of whether safety valves exceeding Technical _recification
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tolerances should have been reported to the NRC was raised by this item. The
Office of Nuclear Reactor Regulation reviewed the question and their
interpretation that it was a reportable event was forwarded to Region IV
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licensees by Region IV in a letter dated December 8, 1993. The inspectors
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reviewed the status of corrective actions being taken by the licensee in
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response to the event. The licensee had continued testing the main steam
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safety valves and found additional valves out of tolerance in November 1993.
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These were documented in Condition Report 93-259. The licensee was in the
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process of documenting the out-of-tolerance conditions addressed in both this
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unresolved item and the condition report in a licensee event report. An
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addi*ional corrective action being taken by the licensee was to require that
licensee event reports be issued to document similar~out-of-tolerance
conditions identified in the future. With the clarification of the reporting
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requirements and the corrective actions being taken by the licensee, this item
is no longer a concern.
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6.5 (Closed) Inspection Followup Item 382/9316-03:
Failure to Review
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Material Safety Data Sheet (MSDS)
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This item was opened to review the licensee's response to an industrial hazard
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concern. The failure to review the NSDS for paint being used in a reactor
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auxiliary building stairway allowed personnel to be exposed to potentially
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hazardous paint fumes. The licensee tested the concentration of the fumes
being released by the drying paint with Drager tubes.
Test results indicated
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that the concentrations were.below the threshold limit values and permissible
exposure limits. The MSDSs for all protective coatings being used on site at
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the time were reviewed to identify additional problems and none were found.
Drager tubes were ordered so they would be available for future testing.
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Meetings were held with the painters to stress the need to review MSDSs, to
test the concentrations of airborne contaminates when working in areas with
poor ventilation, and to utilize forced ventilation if necessary. A
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precaution was also added to the generic painting work authorization to have
threshold limit values and permissible exposure limits checked-as conditions
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warranted. Also, a new document, " Guidelines for Painting in Enclosed Areas,"
outlined the precautions required to prevent over-exposure to' solvents in
paints and provided a list of the areas requiring ventilation for the
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different paints used on site.
6.6 (0 pen) Inspection Followup Items 382/9334-03 through -14:
Weaknesses
ldentified during the Interfacina System LOCA Inspection (50-382/90-200)-
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An inspection was conducted from July 30 through August 10, 1990, and
documented in NRC Inspection Report 382/90-200.
The primary objective of this
inspection was to evaluate specific plant design features, systems, equipment,
procedures, operations activities, and human actions that could affect the
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initiation or progress of an interfacing system loss-of-coolant accident.
Twelve weaknesses were identifieu and will be tracked as Inspection Followup
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Items (IFI) under NRC Inspection Report 50-382/93-34.
Three will be closed i,n
this report and the remaining nine will remain open for review and closure.in
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the next period:
Ifl 382/9334-03:
Lack of Design Calculation
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IFI 382/9334-07:
Material Condition of SI-108A and B
IFI 382/9334-08:
Spacing Calculation for SI-108A and B
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IFI 382/9334-09:
Failure to Identify Radioactive Leaks
IFI 382/9334-10:
Lack of Recorder for Volume Control Tank Level
IFI 382/9334-11:
Inaccessibility of SI-106A and B from Floor level
IFI 382/9334-12:
Component Label Readability Problems
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IFI 382/9334-13:
Procedural Weaknesses
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IFI 382/9334-14:
Lack of Guidance for Scenario Involving LPSI Pump Leak
6.6.1
(Closed) Inspection Followup Item 382/9334-04:
Numerous Component
Identifiers
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During the above inspection, inspectors noted that three different numbering
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systems were used for valves at Waterford-3. This was found confusing and a
possible concern. The licensee evaluated the concern and determined that
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individuals who dealt with the systems on a day-to-day basis easily
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differentiated between the systems.
The Station Information Management System-
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database was available to convert from system to system.
Procedures also ' .
prevented the deletion of any of the three types of component identifiers from
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documentation for historical record.
6.6.2
(Closed) Inspection Followup Item 382/9334-05:
Failure to Establish
Action to Compensate for Disabled Alarm
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The inspectors considered the removal of an alarm indicator 'without
establishing a compensating alarm or . spec al watch condition a procedural
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weakness. However, Section 5.1.I of Operating Instruction 01-002-000,
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Revision 8, " Annunciator and Alarm Station Control," listed situations where
annunciator cards 1could be removed from service. A temporary alteration
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request was required to be generated and the annunciator entered in the
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equipment out-of-service log.
If a condition identification was written on
the annunciator, a condition identification tag was required to be ~ affixed to
the annunciator window. A yellow dot was required to be placed on those
annunciators that had been disabled. Operators were required to check to
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ensure that only windows with yellow dots were out at the beginning of each
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shift.
Permanently installed indications and alarms were to be used by the
operator for disabled annunciators. These actions in Revision 8, the
applicable revision, were sufficient to compensate for a disabled alarm.
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6.6.3
(Closed) Inspection Followup Item 382/9334-06: Weaknesses within
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Surveillance Procedure OP-903-008
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The inspectors identified several weaknesses while observing Surveillance
Procedure OP-903-008, Revision 2, " Reactor Coolant System Isolation Leakage
Test." This procedure was revised on November 30, 1990, to address the
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weaknesses identified. The method of determining the gross leak rate for
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Safety Injection Tank Discharge Valves SI-329A, -3298, -330A, and -330B was
changed to account for instrument inaccuracies. The method for determining
the gross leak rate for Cold leg Injection Pressure Isolation Valves SI-335A,
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-335B, -336A, and -336B and Hot Leg Injection Pressure Isolation
Valves SI-512A and -512B was changed to a volume collection method.
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ATTACHMENT
1 PERSONS CONTACTED
1.1
Licensee Personnel
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- R. E. Allen, Security and General Support Manager
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- R. G. Azzarello, Director, Design Engineering
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- T. J. Gaudet, Operational Licensing Supervisor
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- J. B. Houghtaling, Technical Services Manager
- L. W. Laughlin, Licensing Manager
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- A. S. Lockhart, Quality Assurance Manager
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- B. R. Loetzerich, Licensing /E0I
D. E. Marpe, Mechanical Maintenance Superintendent
- D. F. Packer, General Manager, Plant Operations
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R. D. Peters, Electrical Maintenance Superintendent
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- J. A. Ridgel, Radiation Protection Superintendent
- D. L. Shipman, Manager, Planning and Scheduling
- D. W. Vinci, Operations Superintendent
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- Denotes personnel that attended the exit meeting.
In addition to the above
personnel, the inspectors ccntacted other personnel during this inspection
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period.
2 EXIT MEETING
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An exit meeting was conducted on December 15, 1993. During this meeting, the
inspectors reviewed the scope and findings of the report. The licensee
expressed a position on one of the inspection findings documented in this
report.
The decision to delay the Low Pressure Safety injection Pump A start,
which was addressed as a weakness in this report (Section 2.2), had been
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reviewed by the licensee from an operability standpoint. The pump was found
to be operable, and therefore an expedient start was deemed unnecessary. The
licensee did not identify as proprietary any information provided to, or
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reviewed by, the inspectors.
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