IR 05000305/1983001

IE Insp Rept 50-305/83-01 on 830103-0302.Noncompliance Noted:From 820422-27,temporary Changes Made to Maint Procedure 5B-18469 W/O Review or Approval

ML20204G093
Person / Time
Site:	Kewaunee
Issue date:	04/07/1983
From:	Jackiw I, Nelson R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20204G051	List: IR 05000305/1983001 ML20204G047 ML20204G066
References
50-305-83-01, 50-305-83-1, NUDOCS 8305020356
Download: ML20204G093 (8)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-305/83-01(DPRP)

Docket No. 50-305 License No. DPR-43 Licensee: Wisconsin Public Service Corporation P. O. Box 1200 Green Bay, WI 54305 Facility Name: Kewaunee Nuclear Power Plant Inspection At: Kewaunee Site, Kewaunee, WI Inspection Conducted: January 3-7, 10-14, 17-21, 24-28, 31, February 1-4, 7-11, 14-18, 21-25, 28, March 1-2, 1983 Inspector:

5 for Resident Inspector O

Kewaunee Nuclear Power Plant bSM %-

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Approved By:

I. N. Jackiw, Chief v 63

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Reactor Projects Section 2B Inspection Summary Inspection on January 3-7, 10-14, 17-21, 24-28, 31, February 1-4, 7-11, 14-18, 21-25, 28, March 1-2, 1983 (Report No. 50-305/83-01(DPRP))

Areas Inspected: Routine unannounced inspection by resident inspector of licensee action on previous inspection findings; cperational safety; maintenance; surveillance; significant events; independent inspection; licensee events report; and design changes and modifications. The inspection involved a total of 234 inspector-hours by one inspector including 52 inspector-hours onsite during off-shifts.

Results: Of the eight areas inspected, no items of noncompliance or deviations were identified in six areas; four items of noncompliance were identified in the remaining two areas (failure to follow procedures -

Feragraph 4; use of an unreviewed procedure, requesting nonconforming materials, and failure to control nonconforming materials - Paragraph 9).

F305020356 830411 PDR ADOCK 05000305 O

PDR

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DETAILS 1.

Persons Contacted

• D. C. Hintz, Plant Manager

• M. C. Marchi, Technical Supervisor R. W. Lange, Superintendent, Maintenance

• C. R. Steinhardt, Superintendent, Operations W. J. Richmond, Plant Service Superintendent D. W. McSwain,-Assistant Superintendent, Instrument and Centrol K. h. Evers, Reactor Supervisor W. J. Truttmann, Assistant Superintendent, Operations The inspector also talked with and interviewed members of the Operations, Maintenance, Health Physics, Instrument and Control, Quality Control, and Security Groups.

• Denotes those attending one or more exit interviews.

2.

Licensee Action on Previous Inspection Findings (Closed). Noncompliance (303/32-18-01(DPRP)): Failure to perform monthly surveillance on radiation monitoring channels R-11 end 12.

The licensee discussed this event and the potential consequences with the persennel involved.

3.

Operational Safety Verification The inspector observed control room operations, reviewed applicable logs and conducted discussions with control room operators during the period of January 1 - March 2, 1983. The inspector verified the operability of selected emergency systems, reviewed tagout records and verified proper return to service of affected components. Tours of the auxiliary and turbine buildings were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks, and excessive vibrations and to verify that maintenance requests had been initiated for equipment in need of maintenance. The inspector by observation and direct interview verified that the physical security i

plan was being implemented in accordance with the station security plan.

The inspector observed plant housekeeping / cleanliness conditions and verified implementation of radiation protection controls. During the period of January 1 - March 2, 1983, the inspector walked down the accessible portions of the auxiliary feedwater, fire protection, service

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water, emergency diesel generator, high head safety injection, contain-ment spray, residual heat removal, component cooling, spent fuel pit cooling and radiation monitoring systems to verify operability.

No items of noncompliance or deviations were identified.

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4.

Monthly Maintenance Observation Station maintenance activities of safety related systems and com-ponents listed below were observed / reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides and industry codes or standards and in conformance with technical specifications.

The following items were considered during this review:

the. limiting

.onditions for operation were met while components or systems were removed frnr service; approvals were obtained prior to initiating the work; activitits were accompliched using approved procedures and were inspected as appli;cble; functional testing and/or calibrations uere

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performed prior to returning components or sy. stems to service; quality control recorde were maintsined; activities were accomplished by qualitied personnel; parts and materials used were properly cert ifind; radiolegical controls were implemented; and, fire prevention controls were implemented.

Work requests were reviewed tc detcrmine status of outstanding jobs and to assure that priority is Ossigned to safety related equipment maintenance which may affect system. performance.

The following aaiutenance cctivities were observed / reviewed:

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MWR No.

t.ctivi;y 42-21424 Diesel Generator I A Start Selec tor Switch -

Cleaned, tightened connections, and lubricated 06-21535 Steam Generator Blowdown Isolation Valve -

Adjusted limit switches 25-21625 Control Room A/C Failure to Start -

Reset service water temperature controller to a lower setpoint 02-21056 Spent Fuel Pit HX Service Water Valve Leak Adjusted valve packing 10-21622 ESF Sequencing Relay -

Readjusted timer

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35-21465 Boric Acid Heat Trace Circuit #1 Low Temperature Recalibrated controller 10-21216 Erratic Temperature Indication on Emergency Diesel 1A Exhaust

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Tightened loose pyrometer connections l

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On February 14, 1983, the inspector noted that containment pressure transmitter (PT-21122) had been disconnected from its sensing lines, the transmitters isolation valves were found to be shut, but not tagged to warn of an unusual condition.

The transmitter, when con-nected, serves as an extension of the containment boundary. Adminis-trative Control Directive 4.3, Section 3.3.3, states, " Danger cards shall be used to protect equipment or to warn of unusual or dangerous conditions". At approximately 12:05 p.m. on February 16, 1983, the inspector noted that the control switch for component cooling water pump 1A was in the " pull-out" position.

In response to the inquiry as to the status of the pump, the Duty Shift Supervisor and a shift Coatrol Operator stated that the pump's circuit breaker had been released for preventative maintenance, and tag cut control was not necessary because the maintenance personnel had not requested tagging.

The inspector reviewed the applicable Preventative Meintenance Procedure (PMP)40-107 "480 Volt Supply and Distribution Sapply Breaker Maintenance for Component Cooling Pumps", and ACD 4.3 "Tagout Control". PMP 40-107,

Section 3, clearly indicates that to isolate the bre aker for maintenance the cont rol switch was required to be tagged in the " pull-out" position.

ACD 4.3, Section 3.3.3, states, " Danger cards shall be used to protect equipnent or to warn of unusual or dangerous conditions". The results of the review hsd been communicated to the Duty Shift Supervisor, Assistant Superintencent of Operations, and Superintendent of Mainten-ance by 12:30 p.m.

A tag was placed on the control switch at 1:38 p.m.

Technical Specification 6.8.1 states, " Written procedures and adminis-trative policies shall be established, implemented and maintained that

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meet the' requirements of Section 5.1 and 5.3 of ANSI N18.7-1972".

Failure to place tegs as required by prr>cedures fu a violation of Technical Specification 6.E.1 (305/83-01-01(DPRD)).

No other items of noncompliance or deviations were identified.

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Monthly Surveillance Observation The inspector reviewed / observed the following Technical Specification required surveillance testing:

Surveillance Procedure Test 48-003 Nuclear Power Ranges47-010 Reactor Coolant Temperatures36-013 Reactor Coolant Flow 06-033 Steam Generator Flow Mismatch 18-043 Containment Pressure 04-157 Circulating Water Temperatures

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The following items were considered during the inspection: that testing was performed in accordance with adequate procedures, that test' instrumentation was calibrated, that test results conformed with technical specifications and procedure requirements were re-viewed by personnel other than the individual directing the test, and.that any deficiencies identified during the testing were reviewed and resolved by appropriate management personnel.

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No items of noncompliance or deviations were identified.

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6.

Significant Event Followup

On January 5, 1983, during full power operation, an electrician pulled a fuse to deenergize and repair an indicator light holder associated with a normally shut caustic additive valve to the containment spray pumps. The fuse also supplied power to the valve's normally energized actuation solenoid valve, deenergizing the solenoid caused the additive

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valve to fail open, as designed, allowing the caustic standpipe to drain into the spray pumps suction line. The standpipe level fell below the Technical Specification level of 96%. As required by the Technical Specification, the licensee commenced going to Hot Shutdown.

Standpipe level was restored and the unit was returned to full power.

Design Change Requert No. 942 has been initiated to make the additive valves fail shut to prevent recurrence.

On February 21, 1983, the "B" train of the containmert spr&y system-was inadvertantly actuated. The cctuation ocenrred while an I 6 C Technician was performing a non-routine testing of circuit continuity indicating lights for the train. The pump.was secured by a shift control operator within 15 seconds. The licensee estimates that less than 50 gallons of watcr was sprayed into the containment. Chemistry

. testing of the water indicated that the sprayed water did not contain sodium hydroxide. An inspection of the containment did not reveal any conditions that would preclude continued operation at normal power levels.

Investigation into the cause revealed that current limiting resistors in series with the light circuitry had not been installed per the circuitry drawing. This item will remain open pending further review (0 pen Item 305/83-01-02(DPRP)).

No items of noncompliance or deviations were identified.

7.

Independent Inspection The inspector conducted a general inspection of operations, maintenance, health physics, security, quality assurance, and administrative activities.

On February 14, 1983, the inspector noted that the containment vacuum indicator in the control ~ room was inoperable, but an out-of-service sticker had not been placed on the indicator. Administrative Control Directive (ACD) 4.5 " Shift Operations and Turnover", Section 5.2.10.1, o

states, "When a meter, controller, recorder, or annunciator is out-of-service, an OUT-OF-SERVICE sticker shall be attached to the instrument

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to indicate that the instrument is not to be used for operating the plant.

If there is an associated MWR, write the MWR number on the sticker". When the above was brought to the licensee's attention, their response indicated that the ACD requirements were not applicable to the indicator because it was not considered a safety-related indicator.

During the exit meeting on March 2, 1983, the licensee informed the inspector that henceforth ACD 4.5, Section 5.2.10.1, shall apply to safety-related, and non-safety-related components.

No items of noncompliance or deviations were identified.

8.

Licensee Event Reports Followup Through direct observations, discussions with licensee perr.onnel, and review of records, the following event reports were reviet;ed to determine that reportability requirements were fulfilled, immediate ccrrective

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action was accomplished as required, and corrective action to prevent

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recurrence had been accomplished or initiated.

82-036/03L Condensate storage tank 'below Technical Specification required level (Technical Specificatica change requested to decrease the required level)

9.

Design Changes and Modifications The inspector reviewed three completed Design Changs Requests to ascertain if the changee were made in conformance with the Kewaunee Operational Quality Assurance Program, Technical Specification ANSI N18.7-1976, und 10 CFR 50, Appendix B.

The findings arc as follows.

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Design Change Request Nc. 1039 - The design change was initiated to provide different trains of safeguards power to Auxiliary Feedwater valves 10A and 10B.

Implementation of the change was prescribed by Maintenance Work Request No. 18469 and the accom-a panying Maintenance Procedure No. 5B-18469. The completed maintenance procedure indicates that temporary changes were made to the procedural steps 4.6.1, 4.6.2 and 4.6.3.

These temporary changes were made without initialing the change or review by the Plant Operational Review Committee.

l Technical Specification 6.8.1, states, in part, " Written procedures shall be established and implemented that meet requirements and recommendations of Section 5.1 of AN.il N18.7-1972".

ANSI N18.7-1972, Section 5.1.2, states, in part, " Rules shall be established that provide methods by which temporary changes to approved procedures can be made".

Administrative Control Directive 5.2 " Maintenance Procedures", Section 5.6, states, in part, " Prior to implementation,

-the temporary [ change to] Mair.tenance Procedure shall be reviewed and initialed by two mambers of plant management staff, at least one of which holds a Senior Reactor Operator's License." Failure to initial or review the temporary change is a violation of Technical l

Specification 6.8.1 (305/83-01-03(DPEF)).

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b.

Design Change Request No. 1132 - The design change was initiated to replace six safety-related containment pressure transmitters, that were not environmentally qualified, with qualified trans-mitters. Maintenance Work Request No. 19261 indicates that the task was to be performed in conformance with QA Type 1 require-ments. Material Request No. 82-2966, dated April 12, 1982, indi-cates that QA Type 2 material was requested for Maintenance Work Request No. 19261.

10 CFR 50, Appendix B, Criterion.V, states, in part, " Activities affecting quality shall be prescribed by documented instructions of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions".

ANSI N18.7-1976, Section 5.2.7, states, in part, " Maintenance or modifications which may affect functioning of safety-related structures, systems or components shall be performed in a manner to ensure quality at least equivalent to that specified in original design bases ard requirements, material specifications and inspection requirements". Administrative Control Directive 3.2 " Material Request" states, in part, "The requesting supervisor, for each part, component, er material need, will mark the request with the QA Type 1, 2, or 3 from the Bill cf Materials report, informational retrieval list er the QC Supervisor." Request-ing nonconforming material is a violation of 10 CFR 50, Appendix B, Criterion V (305/83-01-04(DPRP)).

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Design Change Request No. 1160 - The design change was initiated to increase the ratings of heaters in safety-related circuit

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breaker overload current trip devices, thereby decreasing the probability of tripping on overcurrent while operating at reduced source bus voltage. Twc sets of QA Type 1 hesters were ordered by Purchase Order No. 51565. The purchase order, QA Type 1 require-ment, requires that conformance documentation be available at the plant prior to releasing the item for use.

The heaters were received, as indicated by Receiving Report No. 22175, on May 11,

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1982, without a Certificate of Conformance. The required receiv-ing inspection / test, as stated on the purchase order, was not performed prior to releasing the heaters for installation. The heaters were installed in safety-related overloads during the period of May 11-17, 1982.

10 CFR 50, Appendix B, Criterion VII, states, in part, " Measures shall be established to assure that purchased material conform to the procurement documents". ANSI N18.7-1976, Section 5.2.13.2, states, in part, "Where required by code, regulation, or contract requirements, documentary evidence that items conform to procurement requirements shall be available at the nuclear power plant site prior

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to installation or use of such items".

Use of nonconforming materials is.a violation of 10 CFR 50, Appendix B, Criterion VII (305/83-01-05 (DPRP)).

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On March 2, 1983, the licensee was required to provide information and documentation, prior to close-of-business on March 2, 1983, that the components affected by the nonconforming actions, as specified in paragraphs 9.b and 9.c, were of the quality necessary to perform their intended function. Sufficient information and documentation was pro-vided to the inspector for him to determine that the affected components would perform their design function. On March 4, 1983, a meeting was held with the Plant Manager, QC Supervisor, and Technical Super-visor. Additional information and documentation was presented to the inspector, which further verified and substantiated the preliminary information.

No other items of noncompliance or deviations were identified.

10.

Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1) throughout the period of January 1 - March 2, 1983 and at the conclusion of the inspection on March 2, 1983 and summarized the scope and findings of the inspection activities. The licensee acknowledged the inspector's statements with respect to the items of noncompliance.

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