ML20134M526

Insp Rept 50-382/85-20 on 850601-0731.Violation Noted: Failure to Meet Operational Mode Requirements Per Tech Spec 4.0.4 & Failure to Conduct 10CFR50.59 Review of Design Criteria for Control Room Habitability

ML20134M526
Person / Time
Site:	Waterford
Issue date:	08/26/1985
From:	Constable G, Flippo T, Andrea Johnson, William Jones NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20134M511	List: ML20134M508 ML20134M522 ML20134M526
References
50-382-85-20, NUDOCS 8509040157
Download: ML20134M526 (14)

See also: IR 05000382/1985020

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APPENDIX B.

U. S. NUCLEAR REGULATORY C012tISSION

REGION IV

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NRC Inspection Report: 50-382/85-20

License: NPF-38

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Docket: 50-382

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

142 De.'.n.ronde Street

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-New Orleans, Louisiana '70174

Facility-Name: Waterford Steam Electric Station, Unit 3

Inspection At: ,Taft, Louisiana

Inspection' Conducted: June 1 through July 31, 1985

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Inspectors: I h (b.

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T. A. Flippo,' Msident Inspector

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W. B. Jongs, Reactor Inspector

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A. R. Johnson, Reactor Inspector

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A'ssisting.

Personnel:- -Howard Onorato, Energy, Incorporated

Daniel Sanow,' Energy, Incorporated

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K. D. Metcalf, EC&G Idaho, Inc.

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d. L.' Constable Chief

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Inspection Summary

Inspection Conducted June 1 through July 31, 1985 (Report 50-382/85-20)

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Areas Inspected:

Routine, announced inspection of:

(1) Phase III Test

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Witnessing, (2) Test Results Evaluation, (3) Surveillance Testing and

Calibration Control, (4) Station Batteries, (5) Control of Design Changes and

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Modifications, (6) Audits, (7) Phase III Quality Activities, (8) Auditor and

Inspector Training, (9) Control Room-Ventilation System Emergency Outside Air

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Intake Valves, and (10) Operational Mode Changes. The inspection involved

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448 inspector-hours onsite by three NRC inspectors and three contract

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consultants.

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Results: Within the areas inspected, two violations were identified,

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Details

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Persons Contacted

Principal Licensee Employees

• R. S. Leddick, Senior Vice President, Nuclear Operations

• R. P. Barkhurst, Plant Manager, Nuclear

• T. F. Gerrets, Corporate QA Manager

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

• J. R. McGaha, Assistant Plant Manager, Operations and Maintenance

• L. M. Meyers, Operations Superintendent

• J. N. Woods, QC Manager

• A. S. Lockhart, Site Quality Manager

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• R. F. Burski, Engineering and Nuclear Safety Manager

K. L.. Brewster, Onsite Licensing Engineer

G. E. Wuller, Onsite Licensing Coordinator

• Present at exit interviews.

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

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with various operations, engineering, technical support, maintenance, and

administrative members of the licensee's staff.

2.

Plant Status

The Waterford 3 site is presently in the startup testing phase.

The 100%

testing plateau has been completed and the nuclear steam supply system

(NSSS) warranty run needs to be completed. The plant is in an outage to

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perform replacement of the main generator rotor retaining rings.

3.

Phase III Test Witnessing

The NRC inspectors observed the performance of portions of the following

Phase III tests:

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SIT-TP-705

Nuclear and Thermal Power Calibration

SIT-TP-716

Core Performance Record

SIT-TP-718

Variable Tavg Test

During the performance of the test, the NRC inspectors verified the

following:

a.

The personnel conducting the test were cognizant of the test

acceptance criteria, precautions, and prerequisites prior to

beginning the test.

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b.

The test was conducted.in accordance with an approved procedure and

the test procedure was used and signed off by personnel conducting

the test.

c.

Data was collected and recorded as requested by the test procedure

instructions.

No violations or deviations were identified.

4.

Test Results Evaluation

The NRC inspectors reviewed Phase III test results to verify that:

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All changes, including deletions to the test program, had been

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reviewed for conformance to the requirements established in the FSAR

and Regulatory Guide 1.68.

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Deficiencies had been adequately addressed and corrective action

completed,

c.

The licensee had correctly analyzed the test data and verified that

it met the established acceptance criteria.

d.

The startup organization as well as the plant operating review

committee (PORC) had reviewed and accepted the test results.

The following test packages were reviewed:

SIT-TP-705

Nuclear and Thermal Power Calibration

SIT-TP-716

Core Performance Record

SIT-TP-717

CPC/COLSS Verification

SIT-TP-726

Remote Reactor Trip with Subsequent Remote Plant ~

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Cooldown

SIT-TP-727

Total Loss of Flow Trip - Natural Circulation

SIT-TP-740

100% Turbine Trip

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The,NRC inspectors determined that each of the above test packages was

properly reviewed by the licensee and met the applicable acceptance

criteria.

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No violations or deviations were identified.

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Surveillance Testing and Calibration Control

The purpose of this portion of the inspection was to ascertain whether

LP&L had developed and implemented programs for control and evaluation of

surveillance testing, instrumentation calibration not covered by Technical

Specification, and inservice inspection.

The Preventive Maintenance Schedule System (PMSS) computer provides

' for scheduling of most preventive maintenance.

The schedules, as

established in the data base, were not reviewed.

The criteria for

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establishing the schedules were reviewed during the Technical

Specification surveillance program review and the calibration control

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review. The PMSS computer provides an accurate means of tracking and

scheduling surveillances and preventive maintenance.

a.

Technical Specification Surveillance Program

An inspection was conducted of the licensee's Technical Specification

Surveillance Program. Areas examined included the following:

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(1) Establishment of a master index and cross reference

(2) Assignment of duties and responsibilities

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(3) Proper documentation of data

(4) Review of completed procedures for implementation

The following procedures were reviewed by the NRC inspector:

UNT-7-004

Technical Specification Surveillance Control, Rev. 2

OP-903-035

Containment Spray Pump Operability Check, Rev. 5 -

Technical Specifications 4.6.2.lc and 4.0.5

OP-903-031

Containment Integrity Check, Rev. 2 - Technical Specification 4.6.1.la

OP-903-021

RCS Water Inventory Balance, Rev. 2 - Technical Specifications 4.4.5.2.la and 4.4.5.2.1d

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OP-903-032

Quarterly ISI Valve Test, Rev.1 - Technical

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Specification 4.0.5

NE-5-103

COLSS Margin Alarm and Penalty Factor

Verification, Rev. 1 - Technical Specifications 4.2.1.3, 4.2.3.2c, and 4.2.4.3

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MI-3-441

Turbine Generator Overspeed Protection System

Calibration, Rev. 1 - Technical Specification 4.3.4.2c

MI-3-384

Condensate Vacuum Pump Discharge' Radiation

Monitor, Rev. 3 - Technical Specification 4.3.3.11, Table 4.3-9, Items 3a and 3d

MI-3-101

Linear Power Channel Calibration,'Rev. 1 -

Technical Specification 4.3.1.1, Table 4.3-1, Item 2

MI-3-201

Plant Protection System Calibration, Rev. 3 -

Technical Specification 4.3.1.1, Table 4.3-1,

Items 3, 4, 5, 6, 7, 8, 9, 10, 11, 14, 15, and 16

ME-3-210

Station Battery Bank'and Charger (Quarterly),

Revision 2 - Technical Specifications 4.8.2.lbl,

4.8.2.lb2, 4.8.2.lb3, and 4.8.2.2

ME-3-100

Fire Pump Diesel Starting Battery (Weekly). Rev. 2

Technical Specifications 4.7.20.1.3a1 and

4.7.10.1.3a2

ME-3-010

Hydrogen Recombiner Temperature and Power

Measurement, Rev.

2'- Technical Specification 4.6.4.2a

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Emergency Diesel Engine Inspection, Rev. 2 -

Technical Specifications 4.8.1.1.2d1 and 4.8.1.2

MM-3-033

Computer Room Halon 1301 Fire Suppression System

Flow Test, Rev. 0 - Technical Specification 4.7.10.3c2

OP-903-100

MOV Bypass Overload Test, Rev. 2 - Technical

' Specification 4.8.4.2a2

No violations or deviations were identified.

f.lthough no violations were noted, the following two concerns were

identified during the inspection:

(1) Technical Specification cross reference in UNT-7-004 identifies

NE-2-102 as the procedure for completing surveillance 4.2.2.2a.

The cross reference also identifies SIT-TP-725 as the procedure

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for initial performance.

Procedure NE-2-102 does not exist.

It

has not been written.

Since SIT-TP-725 was used for initial

performance, the surveillance is current.

No means of tracking

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has been established to ensure that NE-2-102 is issued prior to

the next required performance date.

(2) Technical Specification cross reference in UNT-7-004 identifies

OP-903-100 as the procedure for completing surveillance

4.8.4.2al.

This procedure addresses the requirements of

surveillance 4.8.4.2a2.

The MOV overload bypass devices

required to be tested are listed on Table 3.8-2.

All of these

devices are tested in Procedure OP-903-100 under the 4.8.4.2a2

criteria.

None of the devices are governed by the 4.8.4.2a1

criteria. A Technical Specification change should be noted on

the cross raference and/or Procedure OP-903-100 that none of the

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MOV overload bypass devices are governed by Surveillance

4.8.4.2al.

b.

Instrumentation Calibration Not Covered by Technical Specifications

An inspection was conducted of the licensee's instrumentation

calibration program.

Areas examined included the following items:

(1) Establishment of a master calibration schedule

(2) Assignment of duties and responsibilities

.(3) Proper documentation data

The following procedures were reviewed by the NRC inspector:

MD-1-004

Preventive Maintenance Scheduling, Rev. 6

MD-1-015

Administrative Controls of Measuring and Test

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Equipment, Rev. O

MI-1-005

Administrative Controls of Calibration and

Maintenance, Rev. 2

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MI-1-006

Calibration and Loop Check Frequency for Process

Instrumentation, Rev. 2

MI-5-160'

Calibration of Plant Protection System Test and

Calibration Card and DVM, Rev. 1

MI-5-211

Calibration of Control Valves and Accessories,

Rev. 2

MI-5-518

Control Element Drive Mechanisms Air Temperature

Calibration CDC-IT-5201A/B, Rev. 1

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Reactor Regulating System Inspection and Test,

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'MI-5-610

Equipment Drain Tank Level Loop Check and

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Calibration BM-IL-0616, Rev.1

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No violations or deviations were identified.

c.

Inservice Inspection

An inspection was conducted of the licensee's inservice inspection

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program.

Areas examined included the following items:

(1) Assignment of duties and responsibilities

(2) Control of Inservice inspection procedures

(3) Scheduling of tests

pump and valve

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-(4) Documentation of results

The following procedures and documents were reviewed by the

inspector:

UNT-7-020

Pump and Valve Inservice Testing, Rev. 1

PE-1-003

Control of Inservice Inspection, Rev. 1

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PE-1-004

Section XI Pump and Valve Reference

Data / Acceptance Criteria, Rev. 2

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PE-1-001

Section XI Repairs and Replacement, Rev. 2

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Pump and Valve Inservice Test Plan

Section XI Pump and Valve Reference Data / Acceptance Criteria

Notebook

No violations or deviations were identified.

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Station Batteries

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An inspection was: conducted of the licensee's station batteries.

Areas

examined included the following items:

a.', Visual inspection for' deterioration

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Technical Specification surveillance requirements

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c.

Maintenance guidelines

A visual inspection of the station batteries was conducted.

Areas

examined included cleanliness and condition of the' batteries and

their rooms.

The following procedures were reviewed by the inspector:

-ME-3-200-

Station Battery Bank and Charger (Weekly), Rev. 2

ME-3-210

Station Battery Bank and Charger (Quarterly), Rev. 1

ME-3-220

Station Battery Bank and Charger (18-Month), Rev. 3

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ME-3-230

Battery Service Test, Rev. 3

ME-3-240

Battery Performance Test, Rev. 2

ME-3-250

Station Battery Performance Evaluation, Rev.1

ME-3-201

Station Batte y and Charger (Weekly), Rev. 5

ME-4-213

Battery Intercell Connections, Rev. O

ME-4-231

Station Battery Charging, Rev. 4

No violations or deviations were identified.

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7.

Control of Design Changes and Modifications

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The NRC inspector reviewed the licensee's nuclear operations management

manual and Procedures PE-2-006 and PMP-302.

These documents outline the

requirements and responsibilities'for.the preparation, control, and review

of station modifications from request through implementation and final

closecut.

The station modification package is the vehicle by which design

changes and modifications are made and the use of the forms and documents

that become_ a part of the station modification package (SMP) provide the

required control of design changes.

The initiating document from the

station modification request (SMR) provides for the identification,

review, evaluation, and approval of design input.

Upon receiving the SMR

the action engineer includes a checkoff list of possible inclusions in the

station modification (SM).

The NRC inspector ascertained the requirements for the assurance

'that the changes do not involve an unreviewed' safety question is catisfied

by the required inclusion in SMP of a nuclear safety review checklist.

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positive response to any 'of the' questions on the checklist require that a

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nuclear evaluation form be completed and included in the SMP.

This form

requires the design engineer to review and evaluate all the nuclear safety

questions outlined in 10 CFR 50.59.

An interview with two action engineers, was conducted and the NRC

inspector found them to be knowledgeable of the safety /nonsafety-related

classification requirements.

The fire protection guidelines of RG 1.120 are similarly handled by the

inclusion in the SMP of a fire protection / safe shutdown checklist.

A

positive response to any of the questions on the checklist and other

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criteria requires that a fire protection / safe shutdown review analysis

(FP/SSA) be prepared.

This document reviews components and fire

protection features for changes to such, and reviews the location of

additional fire loading relative to the modification for impact to

Appendix R to 10 CFR 50 to ensure the level of fire protection does not

decrease.

The fire protection / safe shutdown checklist and review form are

a part of a new procedure FP-1-022 that is not released but will be

implemented soon.

A document control system.has been administered that controls the release

and distribution of design change documents, controls changes to released

and approved documents, and provides for the control and recalling of

obsolete design change documents. The procedures referenced, particularly

QP-006-001, detail the controls of released documents.

When the SM is completed the administrative controls and Procedure

PE-2-006 require that a work completion notice (WCN) be sent out after the

operational documents are updated and the control room drawings are red

lined to reflect the changes.

This WCN alerts all the reviewing

organizations that the modification is complete.

This WCN is the official

notice for the updating of plant procedures, operator training, and the

posting of plant drawings that indicate a change is in place that effects

the drawing.

Return of WCN to the station modification coordinator (SMC)

indicates the required documentation update has been completed except for

the affected as-built drawings, which is done prior to SM closeout.

The NRC inspector verified that the responsibility and method of reporting

to the NRC of design changes that are safety-related is established and it

will be an annual report filed 1 year after initial criticality by the

licensing group.

The inspection identified what seems to be a problem in the implementation

of the program although there were no deviations from the established

administrative control and procedure outlines.

There is, however, a very

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large backlog of SMP in the WCN and drawing update stage. There were, in

fact, only 17 SMPs completely closed out and in project files with all

document updates done.

There were 125 awaiting drawing update and 206

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SMPs completed but awaiting some other form of review or document update.

This backlog of SMPs causes some problems in the operational documents

such as the red line drawings, where in at least one case, 5 SMs were

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posted on the drawing as being completed but not marked on the drawing, as

well as 3 additional SMs marked up on the drawing.

This represents a

total of 8 SMs affecting 1 drawing without any of them incorporated on the

. drawing. This is considered an open item (8520-01).

The NRC inspector reviewed the temporary modification to lifted leads and

jumpers requirements and found the procedure UNT-5-004 covers all the

requirements when used with additional form referenced in that procedure.

An examination of the temporary modification log indicated it was up to

date and that log entries were complete.

A field examination of the reactor protective system, the emergency safety

features, and the emergency diesel generator control cabinets revealed no

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lifted leads or jumpers in place.

No violations or deviations were identified.

8.

QA Program Audits

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This NRC inspection included activities for preparation and issue of the

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audit schedules, development of an audit plan and checklists, review of

objective evidence reviewed during the audit, audit report control and

distribution, and responses _to audits.

In general, the audit program was

found to be an effective status of implementation. The Technical

Specification audit program development and vendor audit programs are

progressing satisfactorily and the operations QA program audit are being

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satisfactorily implemented. The following audits were reviewed by the NRC

inspector:

Audits:

85-45

85-03

85-07

85-15

85-08

85-10

84-22

85-13

85-01

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Vendor Audits:

Combustion Engineering

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Desselle-Maggard

Cardinal Industries

Rockbestoes

. Southern Vital Records

McGraw-Edison

General Electric

Capitol Controls

Cajun Co.

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Siemen-Allis Co.

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During this portion of tne audit two items were noted which are considered

an open item and an unresolved item, respectively.

a.

QAP 302, paragraph 5.1.2.c requires onsite contr6ctors be audited

triennially.

Beyond this, the program does not adequately

address the following areas:

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Auditing onsite contractors in a timely manner once onsite

Establishing an onsite contractor audit schedule

Notification and placement of contractors on a schedule

Identification of work scope to be audited

Tracking and timely closure of audit findings

Procedure for removal from site if necessary

A current example of this concern is Unitec Company.

They were

qualified in Jely 1984 to work onsite but the first audit was not

completed until July 25, 1985.

(0 pen Item 8520-02)

b.

A review of vendor audit files found two active vendors had not

received the required annual evaluation.

Southern Vital Records is

missing a 1984 evaluation and Siemens-Allis Company is missing the

1983 and 1984 evaluations.

(Unresolved Item 8520-03)

No violations or deviations were identified.

9.

Phase III Quality Activities

The inspection in this area concluded that activities committed to are

being effective!y implemented.

Commitments include audits, procedure

reviews, and test data reviews.

In the event any test deficiencies are

noted, they are tracked via the CIWA system.

Plant quality does

get involved with all required holdpoints as deemed required in CIWA

resolutions.

Phase III operations QA audits included 84-45, 84-46, 85-01,

and 85-05. An audit of M&TE activities is scheduled for August, 1985.

No violations or deviations were identified.

10. Auditor and Inspector Training

The inspection included verifying certification documents were current,

all necessary supporting documentation was available, and responsibilities

coincided with training and qualifications.

All aspects of the training

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program reviewed during this audit were found to be effectively

implemented.

No violations-or deviations were identified.

11. Control Room Ventilation System Emergency Outside Air Intake Valves

The FSAR discusses the design criteria for control room Nabitability in

Chapter 6.4.

The criteria used for location and power supply for the

valves is discussed.

The ability to operate the system from the control

room with the loss of a vital bus is one of the design criteria.

OP-03-014, " Control Room Heating and Ventilation," provided the normal

lineup for these valves.

Contrary to the FSAR, all valves were normally

aligned closed.

The NRC inspector found no evidence that a proper

10 CFR 50.59 review was conducted to calculate dose rates which an

operator would experience if these valves had been manually opened from

outside the control room. When the licensee was informed of this dis-

crepancy, a change was made to the procedure (June 26, 1985).

This is considered a violation.

12. Operational Mode Changes

On June 11, 1985, Waterford 3 Steam Electric Station was in Mode 5 (cold

shutdown) when operations personnel were performirg Surveillance Procedure

OP-903-069, " Integrated Emergency Diesel Generator / Engineered Safety

Features Test." As part of the above procedure, operations personnel were

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attempting to prove the operability of the Emergency Diesel Generator "B"

automatic load sequence timer as required by Technical Specification 4.8.1.1.2.d.12.

While testing Load Block 7, Relay S7X actuated in 121.6

seconds, which was outside the plus/minus 10% tolerance of the sequenced

load block time (168 plus/minus 16.8 seconds).

However, operations

personnel did not review the test data until 1545 hours0.0179 days <br />0.429 hours <br />0.00255 weeks <br />5.878725e-4 months <br /> on June 20, 1985.

Waterford 3 entered Mode 4 (hot shutdown) at 1028 hours0.0119 days <br />0.286 hours <br />0.0017 weeks <br />3.91154e-4 months <br /> on June 20, 1985,

with Emergency Diesel Generator B inoperable.

Technical Specification 4.0.4 requires that " Entry into an OPERATIONAL-

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MODE or other specified conditions shall not be made unless the

surveillance requirement (s) associated with the limiting condition for

-operation'have been performed within the stated surveillance interval or

as otherwise specified."

LP&L Operating Procedure OP-10.001, Revision 4, " General Plant

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Operations," requires that when entering Mode 4 (hot shutdown) both

emergency diesel generators be operable.

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This is considered a violation.

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13.

Open Items-

The following new items were identified during this reporting period:

8520-01

Open Item

Large Backlog of Incomplete SMPs (paragraph 7)

8520-02

Open Item

Contractor Audit Program Inadequate

(paragraph 8a)

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8520-03

Unresolved

Vendor Audit Files Incomplete (paragraph 8b)

Item

8520-04

Violation

Failure to Conduct Proper 10 CFR 50.59 Review

(paragraph 11)

8520-05

Violation

Failure to Meet Opt.'ational Mode Requirements

(paragraph 12)

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14.

Site Tour

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At various times during the course of this inspection period, the NRC

inspectors conducted general tours of the reactor building, reactor

auxiliary building, and turbine building to observe ongoing maintenance

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and testing.

No violations or deviations were identified.

15.

Exit Interviews

The NRC inspectors met with the licensee representatives at various times

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during the course of the inspection.

The scope and, findings of the

. inspection were reviewed.

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