ML20205B791
| ML20205B791 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 03/13/1987 |
| From: | Boardman J, Hunnicutt D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20205B729 | List: |
| References | |
| 50-382-86-28, NUDOCS 8703300044 | |
| Download: ML20205B791 (12) | |
See also: IR 05000382/1986028
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APPENDIX B
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report: 50-382/86-28
License: NPF-38
Docket: 50-382
Licensee: Louisiana Power & Light Company (LP&L)
N-80
317 Baronne Street
New Orleans, Louisiana
70160
Facility Name: Waterford Steam Electric Station, Unit 3
Inspection Conducted: November 17-21, 1986
Inspector:
kN
3//3/F7
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John Boardman, Reactor Inspector Operations
Da'te
Section, Reactor Safety Branch
Accompanied
by:
Howard Stromberg, EG&G
,
Clarke Kido, EG&G
Approved By:
h/
3//3/F7
D. M. Hunnicutt, Chief, Operations Section
Date '
Reactor Safety Branch
Inspection Summary:
Inspection Conducted November 17-21, 1986 (Report 50-382/86-28)
Areas Inspected: A Region IV team inspection of licensee maintenance
activities was performed. The inspection covered maintenance program
implementation, maintenance program, instrument and control maintenance, and
electrical maintenance.
Results: Of the four areas inspected, one violation was identified (failure to
comply with procedures for control of temporary alterations).
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DETAILS
1.
Persons Contacted
- J. Dewease, Senior Vice President, Nuclear Operations
- R. P. Barkhurst, Vice President, Nuclear Operations
- K. L. Brewster, Lic. Eng., Operational Licensing
- N. S. Carns, Plant Manager
- K. W. Cook, Nuclear Safety & Regulatory Affairs Manager
- C
R. Gains, Operations Interface
- T. F. Gerrets, Nuclear QA Manager
- J. R. McGaha, 0&M Assistant Plant Manager
- F. J. Engle Bracht, Nuclear Administrative Services Manager
- S. A. Alleman, Assistant Plant Manager, Technical Services
- T. H. Smith, Maintenance Superintendent
- A. S. Lockhart, Nuclear Operational Safety Analysis Manager
- K. L. Brewster, Licensing Engineer - Operational Licensing
T. Moore, Electrical Supervisor
T. Smith, Maintenance Superintendent
B. Thigpen, Mechanical Maintenance Assistant Superintendent
J. Begnaud, Mechanical Supervisor, Nuclear
L. Lehmann, Mechanical Supervisor, Nuclear
The NRC inspector also interviewed additional licensee and contractor
personnel during the inspection.
- Denotes those attending the exit interview on November 21, 1986.
The senior resident inspector attended the exit interview.
2.
Actions on Previous Findings
(Closed) Unresolved Item (50-382/8504-02) Closure of Ebasco purchase
orders.
For the orders included in the inspector's sample, licensee
personnel provided documentation of closure satisfying the NRC inspector
that no significant problem appears to exist in this area.
3.
Temporary Alteration Control
During the inspection, the NRC inspector reviewed the following procedures
provided by licensee personnel:
UNT-5-004, Revision 3, Administrative Procedure Temporary Alteration
Control
ME-7-002, Revision 5. Maintenance Procedure Molded-Case Circuit
Breakers and Thermal Overload Relays
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UNT-5-004, Revision 3. Section 3.1 defines a temporary alternation as any
short tem addition to, removal from or change in the function of a system
or any of its components which is not in accordance with approved
-Waterford III design.
Specific controls are required by UNT-5-004, Revision 3. for temporary
alterations, unless prescribed controls are contained in procedures which
perform temporary alterations.
ME-7-002, Revision 5. specifies and defines performance testing of
molded-case circuit breakers. Certain tests, such as the instantaneous
trip test, Section 8.5, specify removal of current-limiting fuses and
their replacement with shorting devices for the performance of the test.
No note, or procedure step, specifies or requires, the removal of the
shorting devices, and replacement of the fuses required for breaker
operability after completion of testing.
Procedure ME-7-002, Revision 5, does not reference procedure UNT-5-004.
' Licensee personnel indicated that temporary replacement of fuses with
shorting bars, particularly for shop testing, had not been considered
to be a temporary modification.
Failure to comply with UNT-5-004, Revision 3, Sections 4.0 and 5.0, and
subsections thereto, in the removal and replacement of fuses for testing
of circuit breakers is an apparent violation of 10 CFR Part 50,
Appendix B, Criterion V, and ANSI N18.7-1976, Section 5.2.2.
(382/8628-01)
4.
Maintenance Program
The NRC inspector reviewed the licensee's maintenance program.
Appropriate personnel in management, supervision, and crafts were
interviewed concerning their areas of responsibility and their
understanding of the applicable procedures.
The plant was preparing for its first refueling outage when the inspection
was conducted. Certain corrective and many preventive maintenance actions
had been rescheduled to be accomplished during the outage. Various
training classes had been held to prepare personnel for work on components
such as valves, pumps, snubbers, and energency diesel generators.
Personnel were temporarily reassigned to handle responsibilities in
maintenance planning and scheduling, plant engineering, and maintenance
training.
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Based on interviews with maintenance personnel and observation of
Condition Identifications Work Authorization (CIWAs) 28583, 29923, and
23768 it appeared to the NRC inspector that the licensee relies heavily
upon worker experience and verbal communication in the performance of
maintenance.
Maintenance procedures required careful interpretation and
were usually augmented by the worker's personal experience or detailed
instructions from the most cognizant supervisor.
A concern of the NRC
inspector was that some procedures as written may be too vague for a worker
with limited experience to properly perform the task.
It appeared that
procedural corrections and clarifications considered necessary by
maintenance personnel were not being routed to the planner so that the
procedures could be amended, as appropriate.
This concern was discussed
with the licensee, who indicated that a reorganization is scheduled
shortly to more closely integrate personnel and responsibilities.
In
implementation of this concept, the snubber maintenance program is
undergoing review by plant engineering, maintenance planning, and
mechanical maintenance.
The NRC inspector reviewed three maintenance activities (CIWAs 28583,
29923, and 23768).
The CIWAs were reviewed to determine craft compliance
with maintenance procedures, adequacy of maintenance procedures, and if
required procedures and materials were present during work performance.
Two completed corrective maintenance and three preventive maintenance
CIWAs were reviewed.
In addition, the maintenance history files for the
essential chillers were reviewed to determine if previous Freon leaks had
occurred.
No concerns were identified.
The following mechanical
maintenance tasks were reviewed:
a.
CIWA 25630, boric acid makeup tank pump discharge drain valve seat
leak repair,
b.
CIWA 27322, essential chiller B temperature controller Freon leak
repair.
c.
PM Task Carri MWORFRAB2, essential chiller WC1AB refrigerant filter
changeout.
d.
PM Task Card MWORFRAB2, essential chiller WCIAB compressor oil and
filter changeout.
e.
EQ Task Card MW0EFWP02, emergency feedwater pump AB (Terry Turbine)
oil system inspect, clean, and change filters.
Two additional concerns were identified during this review of the
maintenance program.
The first was that a plant wide trending analysis
program did not appear to be implemented.
The second concern was that
there did not appear to be a procedure being used that ensured consistency
in the documents transferred to storage.
In a number of packages (see
Sections 4 and 5 below) there were sections that did not appear to be
completed as required, and at times it could not be verified if all
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applicable documents were in the stored document files.
This will remain
an open item (382/8628-02) pending further review during a subsequent
inspection.
5.
Maintenance Program Implementation
The NRC inspector obtained a list of maintenance activities which were
scheduled for the week of November 17-21, 1986.
He selected three for
inspection to determine compliance with the regulations and the
Waterford 3 Administrative Procedures.
The three maintenance activities were detailed on Condition Identification
and Work Authorization (CIWAs) for the following corrective maintenance:
troubleshoot Freon leak found at electrical box on the compressor to
Essential Chiller AB,
troubleshoot RCS leakage past seals on Charging Pump B, and
preventive maintenance of type PSA-3 mechanical snubbers.
The CIWAs were identified as CIWA 28583, 29923, and 23768, respectively.
Each CIWA was reviewed for authorizing signatures, spare parts control,
inspection adequacy, mechanical qualification, adequacy of maintenance
performed and post-maintenance functional testing and restoration.
The
CIWA's were also reviewed to determine compliance with the requirements of
the following procedures:
MM-1-002, Revision 2, " Mechanical Maintenance Practice," dated
August 24, 1985.
MD-1-007, Revision 2, " Preventive Maintenance Task Identification,"
dated November 15, 1984.
"
MD-1-004, Revision 6, " Preventive Maintenance Scheduling," dated
May 21, 1985.
UNT-5-002, Revision 5, " Administrative Procedure, Condition
Identification and Work Authorization (CIWA)," dated January 13,
1986.
MD-1-011, Revision 3, Maintenance Procedure Development, Review,
Approval, Change, Revision, Deletion
MD-1-014, Revision 1, " Administrative Procedure, Conduct of
Maintenance," dated November 21, 1984.
MM-6-023, Revision 1, " Mechanical Snubber (Shock Arresters)
Maintent.nce," dated October 21, 1986.
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MM-7-011, Revision 3, " Mechanical Snubber Test," dated November 14,
1986.
The troubleshooting of the Essential Chiller AB Freon leak was witnessed
by the NRC inspector.
The NRC inspector reviewed the job from receipt of
the CIWA by the maintenance mechanic, through the mechanic's disassembly
and inspection of the pump out compressor, his written work order
instructing the planner to contact the vendor for detailed information and
replacement parts, the planner's purchase order for the spare parts, and
the maintenance supervisor's commitment to reassemble and test the
chiller.
Upon disassembly of the electrical box on the pump out compressor, the
mechanics found that an unused electrical connection had been improperly
sealed with a fibrous plug, and a cardboard and plastic spacer.
A
telephone call to the compressor manufacturer indicated that a double
locking nut connection should have been made.
The licensee amended the
CIWA to plug the connection as specified by the manufacturer.
The
licensee intended to correct only Chiller AB, although there are two other
identical chillers at the plant.
The NRC inspector had two concerns relating to this maintenance work.
The
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first concern was that the technical manual for the pump-out compressor
lacked sufficient detail to describe the correct electrical connections.
When the licensee started work, he determined that the technical manual
did not provide sufficient detail to allow repairs to be made. When
disassembly was completed, the manufacturer was called ar.d his advice was
followed to make repairs.
These licensee actions adequately addressed
this concern.
A second concern was that the licensee did not intend to inspect the other
two essential chillers unless a similar Freon leak occurred, at which time
the licensee would follow the same corrective action.
The licensee was
asked to confirm that the unused electrical connections for each essential
chiller pump out compressor has been properly plugged and ensure that
preventive measures are in place to prevent recurrence of the Freon leak
problem.
The licensee's actions had no significant effect on safety.
The
components were safety-related.
The licensee was not correcting a known
common mode failure mechanism that affected 2 of 3 safety systems.
The troubleshooting of a charging pump seal leak was followed by the NRC
inspector.
The NRC inspector witnessed the job from receipt of the CIWA
by the mechanic, through the obtaining of spare parts, verification of the
status of equipment tagged out, and clearance for access to the vital
area.
The NRC inspector discontinued observations during seal replacement
and functional testing because of work area health physics requirements.
The licensee determined that the root cause of the seal failure was
deficient packing.
No concerns were identified.
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The NRC inspector followed preventive maintenance of Type PSA-3 mechanical
snubbers that was in progress.
Licensee personnel used procedure MM-6-023,
Revision 1.
During work, the NRC inspector observed that several steps in
MM-6-023 were not followed (for example, step:. 8.2.1.10, .11, and .12),
since they applied only to a major overhaul of the snubber.
Prior approval
to omit the steps had not been documented, or authorized by the maintenance
supervisor.
The mechanic's work was based on procedure MM-6-023, in
general, plus " hands-on" experience gained from a snubber workshop held at
the vendor's factory.
Revision 1 of procedure MM-6-023 was verified to be
the latest revision controlled by the document records department.
Discussions with the mechanic, supervisor, and planner indicated that the
snubber procedure would be revised in the near future.
The NRC inspector noted a weakness dealing with the administrative aspects
of the above maintenance.
As stated in the previous paragraphs, the
mechanics did not perform several steps that the craftsmen knew or
believed, were optional. This practice can result in an error and
maintenance which is not approved.
The NRC inspector's concern was that a
junior mechanic was undergoing on-the-job training by a senior mechanic
who did not follow the maintenance procedure as written.
The licensee was
asked to review procedures MM-6-023 and MM-7-11 and ensure that the
appropriate steps are identified for performance of all levels of
maintenance specified by these procedures.
This review will ensure
compliance with step 14 of Attachment 6.10 to Procedure MD-1-011, which
indicates that an optional step in a maintenance procedure shall be
clearly identified as such.
6.
Licensee Instrumentation Maintenance Program
The NRC inspector performed an inspection of the maintenance program in
the instrument and control areas in accordance with Inspection and
Enforcement Manual Section 62704 and the Waterford 3 Administrative
Procedures. Maintenance history, calibration records, procedures, work
item tracking forms, and maintenance work request forms were obtained and
reviewed.
Selected instrument and control supervisors and technicians of
the I&C Maintenance Organization were interviewed to determine their areas
of responsibilities, functions, and qualifications.
Two work activities in progress were witnessed by the NRC inspector to
determine if the technicians were following appropriate maintenance
procedures.
The two activities were: (1) MI-5-160, Revision 1,
Calibration of Plant Protection System Test and Calibration Card and
Digital Volt Meter (DVM), and (2) MI-3-350, Revision 5, Containment Purge
Isolation Area Radiation Monitor Channel "A" or "B" Functional
Test ARM-IR-5024S 50255, 50275.
There were a number of discrepancies
noted during the performance of these activities.
The following are
examples of procedures not being followed:
a.
Step 8.4 of MI-5-160 (Calibration of Plant Protection System Test and
Calibration Card and DVM) indicated that the DVM should be turned on
and set to Volt Direct Current (VDC) Auto with the "As Found" block
to be filled in on Attachment 10.1.
The technicians performing the
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calibration understood this step to mean the test instrument and not
the DVM being calibrated.
An entry was not made in Attachment 10.1
for the DVM.
The actions were not consistent with the procedure.
It
should be noted that the instruction was misleadingly vague, since it
appeared to be applicable to the test instrument instead of the DVM
which is constantly energized and does not have an " Auto" position.
b.
Step 8.28 of MI-5-160 required that a calibration sticker be attached
to the DVM.
Instead it was attached to the panel above the DVM.
c.
Step 8.1.1 of MI-3-350 (Containment Purge Isolation Area Radiation
Monitor Channel "A" or "B" Functional Test (ARM-IR-5027S)) required a
jumper to be used when the Containment Purge Isolation Valves are
shut.
Discussions with the technicians indicated that the jumper
installation was not always performed.
Operations personnel dictated
jumper installation and decided whether or not a potential existed
for the valves to be operated before testing was completed.
The
procedure does not allow this choice.
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The second item found during work observations was that the procedures
were in error in a number of steps.
The following are examples where
errors were noted:
a.
Step 8.19 of MI-5-160 indicated that both " Bistable Select" switches
should be verified in the "Of f" position.
Only one has an off
position; the other has a line indicating off.
b.
Step 8.20 of MI-5-160 indicated that the " Input Select" switch was to
be set to " Input." The switch was not removed from or verified in
the " Input" position at the start of the procedure.
It is possible
that the switch should have been verified in the " Input" position at
the start of the procedure in order to ensure correct voltages,
c.
Step 8.3.4 of MI-3-350 indicated that the health physics technician
was to be informed that the monitor was back in service.
The
procedure, however, does not require the health physics technician to
be informed when it was removed from service.
This was an omission
from this procedure.
The technician indicated that most of the other
procedures had this requirement correctly identified.
It should be
noted that the I&C technician informed the health physics technician
when the instrument was removed from service for testing, however, it
was done as a normal practice.
The third item identified during work observations was that the procedures
permitted specific or " equivalent" instruments to be used for performing a
procedure.
However, the licensee had not identified which instruments are
equivalent to each other; nor was the basis for equivalency verified
before testing was performed.
This policy does not assure that instrument
sensitivity requirements will be met.
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Examples found by the NRC inspector where one instrument was identified
and another used were as follows:
a.
Procedure MI-5-160, Revision 1, Step 6.0, indicated a Fluke 8500A DVM
was to be used.
Instead, a health physics (HP) instrument was
used.
b.
Procedure MI-3-350, Step 6.0, indicated a Fluke 8600A Digital
Multimeter was to be used.
Instead, an HP instrument was used.
Documentation associated with ten completed maintenance activities was
obtained and reviewed.
The ten activities were:
a.
CIWA 028825, nitrogen pump level switch NG-ILS-3006 out of
calibration.
b.
CIWA 025448, component cooling water to dry tower isolation valve low
air pressure switch CC-IPS-3085B mounting repairs.
c.
CIWA 029024, charging pump AB spurious low suction pressure trip
switch (CVC-MPMP0001AB) troubleshooting.
d.
CIWA 025719, steam generator No. 1 pressure transmitter SG-IPT-1013A
erratic output troubleshooting,
e.
CIWA 025913, boric acid condensate tank "B" level controller
(BM-ILIC-0626) repair.
f.
CIWA 022177, annunciator LO705 troubleshooting and repair.
g.
CIWA 006276, SUPS IAB blown fuse F42 replacement.
h.
CIWA 023828, chill water pressure transmitter CHW-IPT-5011BS leaking
vent plug replacement,
i.
CIWA 025452, containment spray flow transmitter CS-IFT-7122AS high
flow indication.
j.
CIWA 028099, boric acid condensate tank "B" level controller
(BM-ILIC-0626) maintenance.
The review of these completed items identified three areas of apparent
weakness as follows:
The first area was a concern related to not identifying equivalent
instruments.
CIWA (Condition Identification Work Authorization)
028825 (item a. above) identifies a 0-415 inches water column (INWC)
instrument to be used for calibration where an 0-830 INWC was used.
As stated previously, this does not ensure that necessary instrument
sensitivities are met.
Another example was seen in CIWA-025448
(item b. above) where a 0-100 psi Heise test gauge and Fluke 8600A
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DVM were identified for use as test equipment.
Instead of using the
identified equipment, a Helicoid 0-100 psi gauge and a Triplet meter
were used.
The second weakness identified during review by the NRC inspector was
that there appeared to be inconsistencies in the document review
process.
In CIWA 025719 (item d. above) Section D (corrective
maintenance control section) was not filled out.
CIWA 025913
(item e. above) identified one of the test instruments by
manufacturer's name and not by its control number.
This does not
permit easy traceability.
A third weakness was incomplete reviews as identified in CIWA 022177
(item f. above). On CIWA 022177, addendum page 11, it was indicated
that plant engineering was to evaluate the acceptability of the
switches used for initiating the alarm.
It was not apparent that the
review had been performed.
No other weaknesses were noted during the
review of these maintenance documents.
These concerns will be an
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open item (382/8628-03) to be reviewed generically during a
subsequent inspection.
7.
Licensee Electrical Maintenance Program
The NRC inspector performed an inspection of the Maintenance Program in
the electrical area.
Maintenance history, work item tracking forms,
maintenance work requests, qualification records, document control
procedures, and replacement part control records were obtained and
reviewed.
Selected Electrical Maintenance Organization personnel
(electrical supervisors and electricians) were interviewed to determine
their areas of responsibilities, functions, and qualifications.
Three maintenance action items were witnessed to ensure that the
electricians performin0 the maintenance tasks followed the appropriate
maintenance procedures.
All three items involved the testing of HPCI
Pump AB relays.
Testing was performed in accordance with the following
procedures:
a.
ME-7-035, Revision 1, G.E. Auxiliary Relays, Models HGA11A through
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HGA11X
b.
ME-7-030, Revision 1
G.E. Auxiliary Relays Models HGA17A through
HGA17T
c.
ME-7-033, Revision 1, G.E. Auxiliary Relay HGA14
The NRC inspector identified two areas of concern.
The first concern
involved test equipment.
In maintenance procedure ME-7-035, Step 6.2.1,
Doble equipment, or equivalent, was identified to be used to perform the
testing.
The technicians performing the job used Multiamp equipment.
Equivalency was not determined.
As stated previously, not determining
equivalency or having an established equivalency list in advance fails to
ensure that instrument sensitivities are acceptable.
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The second concern related to the adequacy of the procedures.
Step 7.0 of
maintenance procedure ME-7-033 indicated that the acceptance criterion was
for the relay to pick up at rated power.
The rated power was not included
as part of the documentation but was determined by the technician from
memory. This practice does not assure that the testing is acceptable.
Another example was seen in Step 8.3.1.1 of ME-7-033, where terminals 1
and 7 were to be used for continuity verification when the relay was
energized.
These terminals were connected to spare contacts.
The
procedure did not provide for checking contacts actually in use.
This
practice does not provide assurance that the relay will provide the
protection intended.
No other concerns were identified during work observations.
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Procedures and other documentation associated with the following 11
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completed electrical maintenance activities were reviewed:
a.
CIWA 027805, wet cooling tower fan 6A breaker (ACC-EBTR-315A12MS)
replacement.
b.
CIWA 027484, dry cooling tower fan 58 motor (CC-EMTR-315B-3F) lug
repair.
c.
CIWA 006299, diesel generator feeder breaker (EBKR-3A145) spring
release interlock support repair.
d.
CIWA 021284, flow transmitters CC-IF-5570AS and BS hydro-test
validation.
e.
CIWA 004376, static uninterruptable power supply (SUPS) 3B-5 bypass
,
transformer firing board (ID-IDEN-PSM85) temporary modification.
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f.
CIWA 004392, SUPS 3B-S Bypass transformer firing board
(ID-IDEN-PSM85) testing,
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g.
CIWA 005619, MCC 38213 and 38311 missing grommets (MCC-CABLE-GR0MS)
evaluation and repair.
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CIWA 009388, all safety related motor operated valves inspection and
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heater operation verification.
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CIWA 025125, reactor building purge exhaust fan E22 motor
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(HVRE-MTR-3A7AS) polarization index procedure revision.
j.
CIWA 027249, cabinet C-24 temperature control (IC-ITC-3024) burnt
wire repairs,
k.
CIWA 023669, fuel handling building flitration unit B heater
(HVFIHPL51148) troubleshooting and repair.
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During the review of completed maintenance packages by the NRC inspector,
one concern was identified.
This involved document completion and review.
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In CIWAs (025125, 02749, 023669, and 006299), Section D (Corrective
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Maintenance Controls Section) of the first page was not completed, or was
filled out incorrectly.
These deficiencies in themselves were not highly
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significant, however, they demonstrated a weakness in the final document
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review process.
Three additional items were reviewed during review of the licensee's
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electrical maintenance program as follows:
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The first item was the overcurrent testing of breakers important to
safety.
This involved the concern that some breaker manufacturers
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have specified that alternating current (AC) overcurrent testing be
performed only once in the lifetime of a circuit breaker, with
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subsequent testing to be done using direct current (DC).
The
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licensee response to their concern indicated that it was applicable
to one type of circuit breaker at Waterford.
The breakers in
question were tested using an AC test source, filtering the output
through a rectifier bank when testing the breaker.
The testing
method adequately addressed the concern.
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The second item was the replacement of Agastat time delay relays in
emergency diesel generator sequencing circuits.
The licensee was
questioned about the use of qualified replacement relays.
Procedures
governing relay replacement were reviewed and found acceptable.
The third item was the meggering (high voltage insulation test) for
long installed runs of cables.
The licensee's current practice is to
megger cables at the circuit breakers.
This practice is acceptable
when cable runs are short.
When the cable runs are long, the voltage
drop in the cable could prevent a valid test of insulation breakdown
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resistance.
The licensee committed to reviewing this concern.
This
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will remain an open item (382/8628-04) to be reviewed during a
subsequent inspection.
8.
Exit Interview
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The NRC inspector met with the NRC senior resident inspector and the
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licensee representatives identified in paragraph 1 at the conclusion of
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the inspection on November 21, 1986.
The NRC inspector summarized the
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scope and findings of the inspection.
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