IR 05000482/1987009
| ML20214S830 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 05/14/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20214E844 | List: |
| References | |
| 50-482-87-09, 50-482-87-9, NUDOCS 8706100002 | |
| Download: ML20214S830 (43) | |
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SALP BOARD REPORT U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 50-482/87-09 Wolf Creek Nuclear Operating Corporation Wolf Creek Generating Station
February 1,1986, through February 28, 1987
I 0706100002 070514 PDH ADOCK 05000402 G
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INTRODUCTION The Systematic Assessment of Licensee Performance (SALP) program is an integrated NRC staff effort to collect available observations and data on a periodic basis and to evaluate licensee performance based upon this information.
SALP is supplemental to normal regulatory processes used to ensure compliance to NRC rules and regulations.
SALD is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to the licensee's management to promote quality and safety of plant operation.
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An NRC SALP Board, composed of the staff members listed below, met on April 14, 1987, to review the collection of performance observations and data to assess the licensee performance in accordance with the guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance."
A summary of the guidance and evaluation criteria is provided in Section II of this report.
This report is the SALP Board's assessment of the licensee's safety performance at Wolf Creek Generating Station for the period February 1, 1986, through February 28, 1987.
SALP Board for Wolf Creek Generating Station:
R. E. Hall, Deputy Director, Division of Reactor Safety and Projects, Region IV (Chairman)
R. L. Bangart, Director, Division of Radiation Safety and Safeguards, Region IV J. E. Gagliardo, Chief, Reactor Projects Branch, Region IV D. R. Hunter, Chief, Project Section B, Reactor Projects Branch, Region IV J. E. Cummins, Senior Resident Inspector, WCGS P. W. O'Connor, Project Manager, Nuclear Reactor Regulation The following personnel also participated in the SALP Board meeting:
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W. C. Seidle, Chief, Technical Support Staff, Region IV B. Murray, Chief, Facilities Radiological Protection Section, Radiological and Safeguards Program Branch, Region IV L. A. Yandell, Chief, Emergency Preparedness and Safeguards Programs Section, Radiological and Safeguards Program Branch, Region IV B. L. Bartlett, Resident Inspector, WCGS R. P. Mullikin, Project Inspector, Region IV C. A. Hackney, Emergency Preparedness Analyst, Region IV J. A. F. Kelly, Senior Security Inspector, Region IV II.
CRITERIA Licensee performance was assessed in 11 selected functional areas.
Each functional area normally represents an area significant to nuclear safety and the environment.
One or more of the following evaluation criteria were used to assess each functional area.
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Management involvement and control in assuring quality.
B.
Approach to resolution of technical issues from a safety standpoint.
C.
Responsiveness to NRC initiatives.
D.
Enforcement history.
E.
Operational events.
F.
Staffing (including management).
However, the SALP Board is not limited to these criteria and others may have been used where appropriate.
Based upon the SALP Board assessment, each functional area evaluated is classified into one of three performance categories.
The definition of these performance categories is:
Category 1.
Reduced NRC attention may be appropriate.
Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample an:1 effectively used so that a high level of performance with respect to operational safety is 5eing achieved.
Category 2.
NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective so that satisfactory performance with respect to operational safety is being achieved.
Category 3.
Both NRC and licensee attention should be increased.
Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used so that minimally satisfactory performance with respect to operational safety is being achieved.
III. SUMMARY OF RESULTS Improvement was achieved in the areas of Plant Operations, Radiological Controls, and Security.
Performance in the areas of Surveillance and Quality Programs and Administrative Controls Affecting Quality has declined, in part, due to the failure of plant personnel to initially address a calculated low RCS flow adequately, and the number of cases where personnel failed to follow procedures.
The licensee's performance is summarized in the table below, along with the performance categories from the previous SALP evaluation period:
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Previous Present Performance Performance Category Category Func.t.ional Area (10/2/84 to 1/31/86)
(2/1/86 to 2/28/87)
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Plant Operations
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Radiological Controls
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Maintenance
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Surveillance
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Fire Protection
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2 G.
Security
2 H.
Outages Not Assessed
I.
Quality Programs and Administrative Controls Affecting Quality
2 J.
Licensing Activities
1 K.
Training and Qualification Effectiveness
1 The total NRC inspection effort during this SALP evaluation period consisted of 34 inspections, including resident inspector inspections and emergency exercises, for a total of 4,339 direct inspection hours.
The licensee, during this appraisal period, made the transition from Kansas Gas & Electric Company (KG&E) to the Wolf Creek Nuclear Operating Corporation (WCNOC).
The two designations will be used interchangeably throughout this report.
IV.
Performanco Analysis A.
Plant Operations 1.
Analysis This area has been inspected on a continuing basis by the NRC resident inspectors.
Operations personnel (both Ilcensed and nonlicensed) were observed to have a professional attitude towards safety, to
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maintain an attentive attitude to plant parameters, and to promptly respond to alarms and plant events. Appropriate use of procedures was always evident during both routine evolutions and response to events.
The NRC inspectors observed that licensee management and quality assurance department personnel were routinely in the plant to observe operator activities.
The shift supervisor (SS) and control room log met the minimum requirements; however, the amount of detail, especially for clarifying what happened during an event, could be improved.
Positive activities in plant operations that are ongoing or have been performed by the licensee during this assessment period included:
o The faces of main control board meters in the control room have been color coded with green and red tape to designate the acceptable and unacceptable operating regions for the parameter being monitored.
o The number of nuisance alarms in the control room has been reduced from approximately 17 to 4.
Licensee personnel are reviewing possible fixes for the remaining nuisance alarms, o
The licensee has a college degree program for operations personnel.
This program not only provides a career path for the control room operations personnel, in that the shift supervisor is also the shift technical advisor, but it also would tend to increase the overall knowledge level in the control room.
Wolf Creek Operating License NPF-42, Issued June 4,1985, Attachment 3, required, in part, that prior to restart following the first refueling outage, that the safety parameter display system (SPOS) be fully functional.
Prior to restart following the first refueling outage, the licensee informed NRC that the SPDS was fully functional.
The NRC resident inspectors have since observed that the SPDS display console in the control room appeared to have been partially nonfunctional for an excessive amount of time.
Upon questioning the licensee as to the apparent lack of activity in correcting the problem, the licensee stated that the SPOS was out of service more than desired, but that the problems had only recently surfaced.
The Itconsee also stated that technicians had been working on the problem since it appeared.
The NRC inspectors informed the licensee of their concern that the repair effort for the SPDS originally appeared to be of a lower priority than it should have been.
During system walkdowns by the resident inspectors, a number of discrepancies between the licensco's lineup checklists, piping i
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and instrumentation drawings, and component labeling were identified.
The licensee promptly initiated corrective action as required.
Nine violations were identified in this area during this assessment period. One instance of failure to follow temporary modification requirements was identified as a violation.
This involved a failure to comply with procedural requirements during the issuance of temporary modification orders (TMO).
Three violations involving failure to properly lock valves were identified.
In all three violations, the valves were in their required positions.
These violations appeared to be isolated cases; however, they point out four instances in which plant personnel failed to pay attention to detail.
One instance of a remote handswitch being in the wrong position was identified as a violation.
This violation was also documented in a licensee event report (LER).
Four instances of failure to follow procedural requirements were identified as violations.
During this SALP assessment period there were a total of ten reactor trips.
The NRC evaluation attributes a total of seven reactor trips to personnel error.
Two of the reactor trips were due to equipment failure.
The remaining reactor trip was due to a procedural error.
Three of the personnel error reactor trips were due to an apparent failure to adequately control steam generator (SG) water level.
This is down from ten trips of this type in the previous SALP period.
These SG water level trips occurred during plant startup and shutdown at low power levels and part of the problem appeared to be contributable to a man-machine interface, which appears to have improved as the operators gained more experience in controlling the SG water level.
By providing additional training, changing applicable procedures, and refining the operator's control method, it appears that the licensee has been successful in reducing the number of this kind of trip.
During this SALP assessment period, significant personnel changes in the licensee's operations department management were made.
On March 12, 1986, the Superintendent of Operations became Manager, Nuclear Training, and the Operations Coordinator for Planning and Projects was promoted to Operations Superintendent.
The vacant Operations Coordinator position created by these changes was filled by a Shift Supervisor.
At the time the new Superintendent of Operations was appointed to the position, he held a senior reactor operator (SRO) license for Wolf Creek; however, since it was not required, he allowed it to lapse.
The Operations Coordinator for Operations and the Operations Coordinator for Planning and Projects, both of whom work directly under the Superintendent of Operations, hold and maintain SRO licenses, i
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Conclusions
1 Improvements have been accomplished in the area of plant t
operations, but personnel errors have caused a number of
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reportable events.
Licensee attention to detail in this area can be improved.
The ifcensee is considered to be in Performance Category 2 in this area.
3.
Board Recommendations a.
Recommended NRC Actions
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The level of NRC inspection in this functional area should
be consistent with the basic inspection program.
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b.
Recommended Licensee Actions Management attention should be given to improvements in the following areas:
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Ensure that personnel are strictly following procedures and that they pay more attention to details j
of the activities they perform.
o Improve the periodic review of procedures and system
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checklists to reduce the number of discrepancies between checklists, drawings, and as-built conditions
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identified during system walkdowns.
o Continue the effort to eliminate nuisance alarms.
o Continue efforts to reduce plant trips.
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Continue efforts to make the SPDS fully operational
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and reliable.
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Improve the amount of detail in control room logs so i
that they fully reflect ongoing activities.
B.
Radiological Controls 1.
Analysis
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Five inspections in the Radiological Controls area were performed
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during the assessment parlod by region-based radiation specialist inspectors.
These inspections included the following specific areas:
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occupational radiation safety, radioactive waste management,
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radiological ef fluent control and monitoring, and water chemistry controls.
No vioIntions or deviations were identified.
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Occupational Radiation Safety This area was inspected three times during the assessment period.
These inspections included one inspection during routine operations and two inspections during the licensee's first refueling outage.
Concerns were identified in the previous assessment regarding a heavy reliance on contractor personnel, lack of an ALARA committee, ALARA goals, and objective evidence to determine ALARA program effectiveness.
The licensee has taken actions to resolve the previous concerns, i
The licensee has established a well defined program for general employee training, radiation worker training, and training for the health physics staff. Management oversight was evident by
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the performance of comprehensive audits / reviews.
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audit / review teams have included a team member with expertise in radiation protection matters.
The health physics staff consists of an adequate number of qualified personnel.
The personnel turnover rate within the health physics group was less than
15 percent.
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The person rem exposure for 1986 was 134 as compared to an expected PWR national average of about 400 person-rem.
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and preparation for the refueling outage, internal and external i
exposure controls, surveys, and control of radioactive materials and contamination.
The licensee's responsiveness to NRC Initiatives has been timely and the resolution of issues has
been based on technically sound judgment.
Operational events i
were promptly reported and analyzed.
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Concerns noted during the assessment period included:
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of steam generator mockup training, (2) limited clerical staff, (3) lack of agreement between the FSAR and station procedures concerning staf f qualifications, and (4) lack of health physics supervisory personnel presence in the plant to oversee and
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evaluate ongoing radiation protection activities, b.
Radioactive Waste Manaacment
The licensee's program concerning the processing and onsite storage of gaseous, liquid, and solid radioactive waste was inspected once during the assessment period.
A comprehensive training and qualification program had been established for
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No problems were identified concerning operation of the radwaste i
systems.
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Radiological Effluent Control and Monitoring One inspection was conducted involving gaseous and liquid effluent controls and monitoring, offsite dose calculations and dose limits, and confirmatory measurements.
Effluent sampling and analyses activities were well defined in plant procedures to ensure compliance with the Radiological Effluent Technical Specifications.
Gaseous and liquid release permit programs were established to ensure that planned releases received the necessary review and approval prior to release.
The inspection included onsite confirmatory measurements with the NRC mobile laboratory.
The confirmatory measurement results indicated that the results were acceptable.
The following inspector observations were identified:
o Radiation effluent monitor isolation verification tests were not performed before each radioactive effluent release.
o A correlation between calculated offsite doses and the Technical Specification limits were not included in the en/tronmental reports, o
Followup on offsite contractor laboratory analytical results were not conducted when results were in disagreement with known values.
The licensee stated that the above observations would be reviewed and appropriate revisions made to improve program performance, d.
Transportation of Radioactive Materia',s This area was not inspected during the assessment period.
The previous inspection was conducted in October 1986, and the next inspection was conducted in March 1987, after this assessment period ended.
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Water Chemistry Controls lhls area was inspected once during the assessment period.
No problems were identified.
2.
Conclusions Steady improvement was noted in the Radiological Controls area.
The ifcenseecontinuedtomakeadjustmentsandrefinementswithincreased operating experience in order to improve program areas.
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The licensee is considered to be in Performance Category 2 in this area.
3.
Board Recommendations a.
Recommended NRC Actions The NRC inspection effort in this area should be consistent with the basic inspection program, b.
Recommenthd Licensee Actions Health physics supervisory personnel should spend more time in the radiation controIIed areas evaluating and observing ongoing radiation protection work activities. Management should ensure that action is taken to provide steam generator mockup training, evaluation of contractor laboratory analyses, offsite dose comparisons, and effluent monitor verification tests.
As additional operating experience is gained, adjustments and refinements should be made to improve the Radiological Controls areas.
C.
Maintenance 1.
Analysis This area was inspected by region-based NRC inspectors (including contractor personnel) and on a continuing basis by the NRC resident inspectors.
The licensee's maintenance program provides for a quality engineering review of all work requests prior to the starting of work and a second quality engineering review after the work is completed, A part of the prework review by the quality engineer is the addition of quality control inspection points and inspection criteria at appropriate steps in the work instructions to insure that quality control personnel are appropriately involved in malotenance activities.
The NRC inspectors continued ta observe that a manager from the maintenance department was in the control room at the start of the day shif t discussing curr ent maintuance activities with the shift supervisor.
This enhances communication between the departments.
There wire four violations t entified in this functional area; i
howcVer, they were isolated cases and were not indicative of a programmatic deficiency.
A region-based inspector performed an inspection of the maintenance prngram, maintenance program implementation,
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electrical maintenance, and instrumentation and control (I&C)
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maintenance.
The following observations were made:
o Maintenance management and supervision appeared to be effective.
o Procedures and work packages were up to date.
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o Technical procedures relating to maintenance appeared to be
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Maintenance training appeared good.
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Facilities and equipment appeared good for present activities, i
o Maintenance work control appeared effective.
o Maintenance quality control was well organized and staffed.
o Engineering support appeared good, i
During this assessment period the Itcensee performed a testing program for motor operated valves (MOVs) in response to NRC IE
Bulletin 85-03 and IE Notice 86-03.
Corrective and preventive
maintenance was performed, design differential pressures and valve and actuator design information were reviewed, torque switch bypass settings were reset, and motor operated valve and testing (M0 VATS) was used to identify and correct problems in verifying the proper setup of valves following maintenance.
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The qualification of components and wiring in valve operators
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was inspected by a region-based inspector and a followup of identifled problems and equipment operability was performed by i
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NRC resident inspectors.
The purpose of the inspection was to
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sample control wiring used in Limitorque valve operators to
determine qualification status and to review the licensec's actions relative to ins 83-72 and 86 03 which had identified specific operator problems.
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The licensee had inspected most of the operators and in response to ins 83-72 and 86-03 had replaced unquallffed wiring and terminal blocks in several operators; however, several items i
were identified for which the licensee had failed to identify
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deficiencies, failed to take adequate corrective action, or t
failed to adequately document qualification of certain items.
Those areas are summarized below:
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During the licensee inspection of Limitorque wiring, unidentified wiring was found in one operator and there was i
no documentation to show that the wires were either
replaced or were qualified.
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o The licensee had found several terminal blocks in the
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operators which were unidentifiable and there was no documentation to show that they had been replaced or were qualifled.
o Equipment qualification documentation for Limitorque operators neither discussed nor referenced certain parts
identified during licensee walkdown; thcrefore, no trail
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existed for making a determination of the qualification
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status of the items.
This deviated from established EQ l
procedures.
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Qualification test reports were not available for certain
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wiring which was determined by the licensee to be i
qualifled.
There were no reactor trips during this SALP period that were
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attributed to improper maintenance activities.
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i During this SALP assessment period, the licensee had three inadvertent engineered safety features (ESF) actuations that were caused by maintenance personnel errors, two more ESF actuations were caused by offsite personnel working in the switchyard, and one ESF actuation was caused by an inadequate
procedure.
The NRC inspectors observed that maintenance activities were
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appilcable drawings and procedures.
2.
Conclusions The maintenance department appears to have effective programs and staff to accompIlsh their assigned task.
i The IIconsee Initiated a program and partially carried out the
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actions in response to the ins which identified certain
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Limitorque operator problems.
There were weaknesses in certain areas; however, immediate action was taken to correct possible i
j operability problems, including going into an TS LCO.
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The licensee is considered to be in Performance Category 1 in
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this area.
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3.
Board Reconsnendations a.
Recommended NRC Actions l
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The NRC should consider reduced inspection effort in this
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Reconminded Licensee Actions l
i Licensee management is encouraged to continue the strong i
maintenance program, including the effective communications
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between the control room and the maintenance staff, so that
the maintenance of cornponents important to the safe
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operation of the plant get top priority.
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D.
Surveillance l
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Analysis
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This area was inspected by region-based NRC inspectors and on a
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continuing basis by the NRC resident inspectors. Of the large l
number of surveillances perfonned by the licensee, few were found
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to be inadequate.
However, these few examples did indicate areas
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of concern.
I During the perfonnance of a TS required surveillance test on January 14, 1987, the test perfunner calculated a final RCS flow rate below the acceptatico critoria. The test performer did not i
believe the results were valid based on reasons, which after weeks of effort, were verified to be true. The test perfonner infonned his inanagernent but failed to inform the SS as required i
by the licensee's procedure.
If the test perfonner's reasons for not believing his compluted surveillance had been incorrect, then
the SS would not have received timely nottficotton that the plant l
was operating in a degraded mode.
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Review of the LERs submitted by the licensee, during this SALP l
appraisal portod, shows approximatuly five examples of TS rulated
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surveillances not being perfonned properly and causing ESF f
actuations.
The Inost serious of these occurred when an unusual
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event had to be declared due to a reactor trip and a safety injection actuottori which were caused when the wrong steam pressure transmitter was isolated for a surycillance related
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calibration. During this SALP assesstnent portod, the licensee (
identified three examples of surveillance procedures which did t
not adequately implenent TS surveillarice requircinents.
The first
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example involved on incorrect test voltage for verifying the l
boron dilution alarm setpoint due to ari error in the vendor manual.
The second example involved a failure to verify fire dampur actuation during halori system surveillance testing. A i
similar example of a procedure failing to iteet a f tre protection TS surveillance requirement was previously identified in a NRC
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violation.
The corrective action by the licensee to that NRC
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violation was apparently inadequate since the licensee's QA organization had a similar finding after the corrective action was completed.
The third example involved a failure to verify that the proper dampers be positioned within the proper time frame on a high chlorine signal in the control room emergency ventilation system.
The licensee's program, utilizing a computerized tracking system and staff personnel dedicated full time to the program, appears to be of fectively getting required surveillances accomplished on schedule.
l Six violations were identified in this area during this assessment period.
Three instances of failure to comply with procedural requirements were identified as violations.
One violation involving failure to verify the proper revision of a procedure prior to use was identified, which involved the
failure to actually use the correct procedure and revision. One
violation of a failure to identify an out of specification value recorded during the performance of a survolI1ance test was identified. One example of a missed fire suppression system surveillance was identified.
Of the ten reactor trips which occurred during this SALP
assessment period, four were the result of surveillance activities and one of these was caused by offsite personnel working in the switchyard, t
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Conclusion Except for the examples cited above, the N rveillance program as a whole, was found to be sound and well implemented.
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the performance of certain Individual survelliances was
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inadequate based on a failure to follow procedures and pay attention to detall.
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The licensee showed consistent evidence of prior planning and
assignment of priorities with stated controls, and an expIlcit
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procedure for control of inservice inspection activltion has
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been implemented.
Staffing positions for the inservice i
inspection program are identified, with authorities and t
responsibilities well (efined.
l The licensee in M nsidered to be in Performance Category 2 in this area.
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Iloard_Rocommendationg a.
R_ecommendod NRC_ Actions i
The level of NRC Inspection in this functional area should
be consistent with the basic inspection program, t
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b.
Recommended Licensee Actions The licensee should ensure that surveillances meet all TS requirements.
In addition, more careful planning of surveillance performance needs to be done to help eliminate inadvertent reactor trips.
The licensee should also pay more attention to detail in the review of completed surveillance tests and in response to indicated test results.
E.
Fire Protection 1.
Analysis This area was inspected by a region-based inspector and on a continuing basis by the NRC resident inspectors.
The licensee has a competent and dedicated staff in their fire protection / prevention organization. This staf f consists of a full time fire protection specialist, a training coordinator, and a clerk.
The concerns identified during the assessment period were those associated with the implementation of the fire protection program and not with the program itself.
The following observations were made:
o The licenseo showed a weakness in the administrative controls for fire barrier penetrations and openings.
There were three violations and several LERs associated with fire barriers.
These resulted in fire watches being delayed or missed, o
Control of transient combustibles has been effective.
The two violations identified did not appear to indicato a programmatic breakdown, o
The fire brigado/ watch training continued to be outstanding.
The formal training, drills, and hands on practice in actual fire conditions provided a well tralned and organized fire fighting unit.
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Conclusions The ifcensee has not shown significant improvement in their fire protection /provention program, llowever management interest and involvementcontinuedtoimprove,aswellasfirefighting training.
The one area that Indicates a minor programmatic deficiency is in the area of adecuate administrative controls for fire barrier penetrations ont openings.
The Ilconsee is considered to be in Performance Category 2 in this are _
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Board Recommendations a.
Recomended NRC Actions l
l The level of NRC inspection in this functional area should j
be consistent with the basic inspection program, b.
Recommended Licensee Actions Licensee management should continue the level of attention in the fire protection / prevention program and effectively implement administrative controls for establishing and maintaining fire barrier penetrations and openings.
Especially important is the need for all licensee personnel and contractors to recognize the safety significance of all fire barriers (doors, dampers, or penetration seals).
F.
Emeranncy Preparedness
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Analysis This area was inspected on a periodic basis by NRC region-based inspectors and contract personnel.
During the assessment period, three emergency preparedness inspections were conducted.
l These inspections encompassed the following specific areas:
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changes to the emergency preparedness program, knowledge and performance of dulles, review of the emergency plan and emergency plan implementing procedures, emergency detection and classification, protective action decision making, dose calculations and assessment, notifications and communications, shift staffing and augmentation, licensee audits and quality assurance, and evaluation of the annual emergency exercise.
During this assessment period, NRC Inspectors determined that certain emergency action levels had not been included in the emergency implementing procedures.
The results of the omission became evident during shift supervisor / operator interviews and walkthroughs.
Emergency classifications were inconsistent, and operators had difficulty in developing protective action
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recommendations.
Some of the emergency action levels were not compatibic with the guidance provided in NUREG 0654.
The licensee developed a bimonthly growl test for the strens used for the prompt public notification system; however, maintenance procedures had not been developed for documenting information pertaining to system reliability, siren location, and maintenance performed.
The station training program had been identified in the previous SALP assessment period as an area needing improvement.
Requirements were inconsistent as to training intervals.
Some
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operations personnel could go for 23 months without receiving any emergency preparedness training.
Personnel training records were kept in a manner that made it difficult to identify training requirements, and to identify those personnel that had met the training requirements.
Some of the training provided was insufficient to enable some members of the emergency response organization to adequately perform their tasks during the annual exercise.
The licensee made the transition from Kansas Gas & Electric Company to the Wolf Creek Nuclear Operating Corporation (WCNOC)
in an expeditious manner that did not appear to impact the WCGS emergency response capability.
However, several changes were made to the onsite emergency planning administrator (EPA)
l position, and the replacement EPAs have had little previous
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experience in this area.
That type of turnover could have a degrading effect on the emergency response program if it continues.
The Quality Assurance (QA) department conducted an excellent emergency program review during this assessment period.
The QA department sent representatives to emergency preparedness training seminars and developed and implemented an internal QA training program for conducting emergency plan reviews.
The licensee conducted a joint emergency response exercise with NRC, state, and county participation.
The results of this
,
inspection indicated that there was reasonable assurance that i
the licensee could adequately protect the health and safety of the public during an emergency.
Five deficiencies were
"
identified by the NRC inspectors in the areas of communications, dose assessment, inadequate capability to measure radiofodine under adverse radiological conditions, communicator training, and delayed protective action decision making in the Emergency
<
Operations Facility.
'
Fifteen open items and three deficiencies were closed during this assessment period.
Resolution of the emergency action j
level /cmergency classification issue is still open; however, I
Ilcensee management has been responsive to NRC initiatives.
)
The licensee has maintained sufficient depth in the emergency response organization.
During this reporting period, the licensee exercised several different emergency response teams.
,
i 2.
Conclusion 3
!
The findings of the NRC inspections conducted during the
!
evaluation period Indicate that, overall, the licensee's
,
emergency preparedness program is adequate to protect the health and safety of the public.
Corporate management has been t
.
.
.
.
. _
_-
--
_
. _ _
.
.
involved in site activities and the QA department has conducted thorough emergency program reviews.
The licensee has been responsive to NRC initiatives, with a good understanding of the issues generally apparent.
The licensee had an excellent enforcement history this assessment period.
The training program continued to be inconsistent as to frequency and depth of instruction.
The licensee is considered to be in Performance Category 2 in this area.
3.
Board Recommendations
]
'
a.
Recommended NRC Actions The level of NRC inspection in this functional area should be consistent with the basic inspection program.
b.
Recommended Licensee Actions The licensee should review and update emergency action levels / emergency classifications for consistency with the guidance of NUREG 0654.
The licensee should evaluate the emergency preparedness initial training and retraining programs as to training frequencies and scope and depth of instruction for all emergency response personnel.
Attention should be given to correcting the deficiencies identified during the annual emergency preparedness i
exercise.
G.
Security 1.
Analysis This area was inspected on a continuing basis by the NRC resident inspectors and on a periodic basis by NRC region-based inspectors.
Four inspections were conducted by region-based NRC physical security inspectors during the assessment period.
j-Seven violations were identified, and Notices issued, during this period.
One of these violations was later withdrawn based upon an explanation provided by the licensee.
There was evidence of prior planning and assignment of priorities.
Policies and procedures were well stated, appropriately
disseminated, and understandable.
Decision making was usually at a level that ensures adequate management review.
The licensee has reordered the corporate structure.
Currently, it is difficult to determine the pattern that will be established by the new corporate structure to maintain an independent and j
effective oversight of security-related matters. Management reviews of security matters were timely, thorough, and
!,
-
.
.
technically sound. Security incident analysis was sometimes performed without a sufficient data base.
Records were generally complete, well maintained, and available.
Procedures and policies are generally followed. Corrective action was effective, except in unusual cases, as indicated by lack of repeat occurrences to that specific set of circumstances.
A clear understanding of security issues was demonstrated and conservatism was routinely exhibited when the potential for a security risk existed. The approaches to the resolution of protection issues were technically sound, thorough, and timely in almost all cases.
The licensee was responsive to NRC initiatives and there are few long-standing regulatory issues attributable to the licensee.
Technically sound and acceptable resolutions were proposed initially in most cases.
Major violations, directly attributed to the security organization, were rare. A number of minor procedural mistakes by security personnel have occurred, but were not repetitive.
These mistakes appear to be indicative of a minor programmatic deficiency, but corrective action was timely and effective in most cases.
Occasional significant computer related events, construction error holdovers, personnel safety considerations, and maintenance activities were attributable causes under the licensee's control that have adversely impacted the planned security program. These events were identified and reported in a timely manner. HoWever, some information may have been missed due to the lack of a proceduralized information gathering
-
technique for use in the routine incident analysis. This situation has been addressed and an instruction memo issued.
Particular events were sometimes isolated for special study and dnalysis. These studies were excellent.
Security organization positions were identified, and authorities and responsibilities were defined.
Key positions were usually filled in a reasonable time utilizing the expertise within this proprietary staff. Staffing w'as adequate and, midway in this rating period, the squad manning structure was reorganized to reduce problems of occasional, excessive overtime. The experience levels of the key personnel in the security organization, and those groups that support security, met commitments made by the licensee at the time of licensing. At the very end of this assessment period, major personnel losses occurred in the critical area of computer maintenance which has the potential for decreased computer reliabilit __
_
-_
_ _ - _ _ _ _
.
2.
Conclusion The licensee has an ample number of qualified and dedicated personnel assigned to the security organization to implement the several security plans.
Some minor procedural errors by security personnel, and others impacting security, persisted and thus detracted from the otherwise high level of protective performance.
Licensee management attention and involvement was evident and was concerned with nuclear security.
Licensee resources were adequate and reasonably effective so that satisfactory performance with respect to site security and safeguards was achieved.
The licensee is considered to be in Performance Category 2 in this area.
3.
Board Recommendations a.
Recommended NRC Actions The NRC inspection level should be consistent with the basic inspection program.
b.
Recommended Licensee Actions The licensee should review the causative factors of security events for broader implications, such as weaknesses in elementary training, disciplinary actions, and in the incident analysis proce:s.
Corrective measures should have a strong relationship to.those precipitating factors as identified by the event evaluation.
The matter concerning the computer support personnel should be addressed quickly to avoid related maintenance difficulties in the security system.
11.
Outages 1.
Analysis This area includes all licensee and contractor activities associated with major outages.
Thus, it also includes refueling, outage management, major plant modifications, repairs of major components, and post-outage startup testing.
During this assessment period, the licensee performed the first refueling outage for this plant.
This area was inspected by region-based inspectors and on a continuing basis by the NRC resident inspectors.
Routine inspections conducted by the NRC resident inspectors included preparation for refueling, refueling activities, housekeeping,
)
_ _ _ _ _ _ _ _ _ _ _ _ _
..
.
o 20'
.
spent fuel pool activities, plant startup following refueling, and startup physics testing following refueling.
~
During the first refueling outage the licensee airbound their
>
residual heat removal (RHR) pumps on three separate occasions.
The multiple occurrence of this event was identified as a violation.
The licensee.airbound their RHR pumps once at the beginning of the outage while the reactor vessel water level was at half loop and twice near the end of the outage while lowering the water level in preparation for setting the reactor vessel head.
None of these air bindings resulted in a significant increase in RCS temperature; however, this method of common mode failure had been identified previously to the licensee in NRC and industry notices.
Extensive planning and preparation for the refueling outage by the licensee was evident. There was a well organized outage management system, using temporary assignments of personnel to key positions such as outage coordinator, and various project coordinators.
Maintenance and design change activities were-planned in advance, prioritized, and coordinated against each other and with plant system conditions.
Licensee personnel resources were supplemented with contractor personnel, as needed, during the outages.
2.
Conclusion In most activities, a high level of management involvement in the outage was evident _with the exception of the RHR pump air binding event.
Also, additional experienced personnel were added, as needed, during the refueling outage.
The licensee is considered to be in Performance Category 2 in this area.
3.
Board Recommendations a.
Recommended NRC Actions The level of NRC inspection in this functional area should be consistent with the basic inspection program.
b.
Recommended Licensee Actions The licensee should pay more attention to detail during future refueling outages, especially those evolutions that will be performed for the first time or that are infrequently performe.
I.
Quality Programs and Administrative Controls Affecting Quality 1.
Analysis Activities under this functional area were inspected by region-based NRC inspectors and by the NRC resident inspectors.
This functional area includes all verification and oversight activities which affect or ensure the quality of plant activities, structures, systems, and components.
This area may be viewad as a comprehensive management system for controlling the quality of work performed and for centrolling the quality of verification activities that are intended to confirm that the work was performed correctly.
Appraisal in this area was based on the results of management actions to ensure that the necessary people, procedures, facilities, and materials are provided and used during the operation of the plant.
Emphasis in the appraisal of this area was placed on the effectiveness and involvement of management in establishing and ensuring the implementation of the quality assurance program.
Also considered in this area was the licensee's performance in the areas of committee activities, design and procurement control, control of design change processes, inspections, audits, corrective action systems, and records.
The licensee's organization underwent a major change during this assessment period.
On January 1, 1987, after the appropriate regulatory approval had been received, the Wolf Creek Operating License and Appendix A to the operating license were revised to allow licensed activities to be under the control of the Wolf Creek Nuclear Operating Corporation (WCNOC). WCNOC is a new corporation jointly established by the Wolf Creek owners.
The Kansas Gas and Electric (KG&E) Director of Nuclear Operations, Director of Engineering and Technical Services, and the Director of Quality became vice presidents of WCNOC.
The three vice presidents report to the President and Chief Executive Officer (CEO) of WCNOC, Bart D. Withers, who reported on site in November 1986, and became CEO on January 1, 1987.
Since WCNOC is a jointly-owned subsidiary of KG&E, KCP&L, and KEPC0, there is no substantive difference in the operation of Wolf Creek under the newly established company.
On January 14, 1987, a surveillance was performed to verify that reactor coolant system (RCS) flow was above the TS minimum. The results of this surveillance indicated that RCS flow was below the TS minimum.
The surveillance performer failed to inform the SS as required by procedure; however, he did inform the plant manager and the superintendent of operations.
Due to suspected test inaccuracies the decision was made to not enter the TS
_-
,_
.
-
.
..
,
.
action statement, but to pursue and correct the suspected inaccuracies.
As a part of the ensuing troubleshooting, reactor power was increased from approximately 75 percent power.to full power.
On February 4, 1987,.in discussions with licensee personnel, the NRC inspectors were made aware that the licensee had spent approximately 3 weeks evaluating whether or not a calculated low reactor coolant system flow was due to instrument inaccuracies or if the calculated value indicated actual flow.
The licensee did discover and correct instrumentation
inaccuracies which showed that RCS flow, even though lower than the first cycle flow, was actually above the TS limit; however,
'
these same inaccuracies allowed the licensed full power limit to be exceeded, by less than one percent, during the troubleshooting process.
The decision making process in this instance was nonconservative.
During this assessment period, discrepancies identified in the area of equipment qualification created the need for a great deal of management attention.and work by the staff. On May 2, 1986, the licensee determined that terminations in safety-related pressure transmitters were made using terminal blocks rather than the required splices.
Based on this finding, the licensee inspected other safety-related environmentally qualified instrument terminations located in harsh environments, and identified the following additional discrepancies:
o Connection boxes for 16 level instruments were not filled with silicone fluid as required by the applicable installation drawing.
o Connection box terminations for four containment cooler temperature elements did not have potting compound applied, as required by the installation drawing.
The two new discrepancies appeared to be unique and isolated cases that were different from the splice versus terminal block discrepancy originally identified; however, the licensee again expanded the scope of this inspection to include a sample of all terminations located in harsh environments that had special environmental qualification requirements.
This expanded inspection did not identify any discrepancies.
,
In an unrelated NRC inspection (conducted May 12-16, 1987) of qualification of Limitorque valve operator wiring, the NRC inspector identified five potential violations and one deviation from a commitment to the NRC.
The licensee, based on these findings and additional licensee findings during the followup inspection and rework process, replaced the internal wiring in 156 Limitorque operators and unqualified terminal boards in two operators.
,
l
,_ -,
. - - - - --
-
.
,.
-,,
-,.
.
During this evolution of inspections and rework, licensee management, in a timely manner, took the initiative in expanding the scope of the inspections and in taking appropriate corrective action to return the components to a qualified status.
Licensee management was conservative in considering plant safety during these activities and shut the plant down to Mode 3 for approximately 7 days while the Limitorque valve operator work (rewiring and relugging) was performed.
The licensee's quality assurance staff is motivated, properly supported, and highly competent. Members of the QA staff, including management, are frequently observed in the plant.
The NRC considers the licensee to have an effective and well managed QA organization. The QA audits and surveillances reviewed by the NRC have been of exceptional quality.
The plant experienced one reactor trip and two ESF actuations due to non-nuclear technicians performing work in the switchyard. These caused unnecessary challenges to the plant's safety systems.
There were four violations issued in this functional area; however, they were considered isolated cases and did not appear to be indicative of a programmatic breakdown.
2.
Conclusion The licensee's QA program and staff was observed to maintain high standards; however, the type and numbers of NRC violations and licensee LERs issued for failure to follow procedures indicated that an increased awareness of attention to details at all levels of the licensee's staff is needed to reduce these occurrences.
Overall, all levels of the licensee's staff are very open with the NRC and are responsive to NRC inquiries and inspection activities.
However, during the licensee's resolution of the RCS flow rate problem described above, the NRC feels that in light of the potential consequences of a problem of this type that the NRC should have been made aware of all aspects of the problem in a more timely manner.
The licensee is considered to be in Performance Category 2 in this area.
3.
Board Recommendations a.
Recommended NRC Actions The level of NRC inspection in this functional area should be consistent with the basic inspection program with
.
increased emphasis on the management decision making
'
process.
b.
Recommended Licensee Actions
~
The licensee should review its decision making process to ensure that problems of the type described above do not reoccur. Also, the licensee should maintain control of work activities in the switchyard to preclude challenges to the plant's safety systems.
The licensee is encouraged to maintain an attitude of complete openess with the NRC and bring any problems that have any potential for escalating into safety issues to the attention of the NRC in a timely manner.
J.
Licensing Activities 1.
Analysis During the present rating period the licensee's management demonstrated active participation in licensing activities and kept abreast of all current and anticipated licensing actions.
In addition, the management's involvement in licensing activities assured timely response to the requirements of the Commission's requirements related to Generic Letter 83-28.
The implementation schedules for compliance with Generic Letter 83-28 have been met by the licensee and their submittals have generally been of high quality and have not required significant rework to satisfy staff requirements.
Management involvement related to the iodine filter exemption request was extensive and included a special audit of the vendor's manufacturing activities and acceptance testing activities to assure that regulatory requirements were being satisfied.
The KG&E management has been.an active participant in Owners Group activities intended to delete unnecessary issues from the technical specifications. In particular Wolf Creek has volunteered to serve as a lead plant in the area of fire protection program changes to the standard technical specifications.
The licensee's management and its staff have demonstrated sound technical understanding of issues involving licensing actions. Their approach to resolution of technical issues has demonstrated extensive technical expertise in all technical areas involving licensing actions.
The decisions related to licensing issues have routinely exhibited conservatism in relation to significant safety matters.
The licensee's clear understanding of the staff's concerns assured sound technical discussions regarding resolution of safety issue,
In the review of Generic Letter 83-28, the staff noted that KG&E's approach was direct and enabled ready verification of the acceptability of their program.
Their submittals indicated an understanding of the safety issues that were involved and permitted the staff to resolve the issue without requiring significant additional information.
In the review of flow induced anomalous flux variations detected at a similar facility, Wolf Creek staff exhibited a prompt and technically sound response to NRC concerns related to identifying the cause of the anomalous behavior. KG&E agreed to monitor the flux and flow variations and kept NRC aware of the results of their investigations. This cooperation with the staff was very helpful in allowing the staff to assess the safety significance of this phenomena.
A unique aspect of KG&E's approach to resolution of technical issues has been their interaction with Callaway, the other SNUPPS standard plant.
Continued observation of problems and participation in the development of solutions at Callaway has permitted KG&E to preplan their approach to problems that are common to both plants.
KG&E has been responsive to NRC requirements and requests.
In most cases they have provided the information that the staff has requested in a timely manner.
Their responses have generally been complete so that the staff has not been required to make additional requests to obtain the information originally requested.
The licensee was particularly responsive in providing additional information to assist the staff's review of the iodine filter exemption request.
The licensee reported 53 non-security events to the NRC Operations Center and submitted approximately 68 non-security licensee event reports (LERs) during the report period.
There were no events significant enough to be presented at the Operating Reactors Briefing.
None of the events reported during this period are considered to be significant.
All LERs were submitted within the time requirements of 10 CFR 50.73. Many of these reports were received well ahead of the deadline.
The reports were generally complete and easily understood. Three of the 10 CFR 50.72 reports were late by from 2 to 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />.
The licensee reported 45 events under sections
,
of 10 CFR 50.73 which also required 10 CFR 50.72 reports. All but one of the required 45 10 CFR 50.72 reports were made.
The plant experienced 7 unplanned scrams through January of 1987.
This corresponds to a trip rate of 1.09 per 1000 critical hours.
This is slightly over the Westinghouse average of 1.04 per 1000 critical hours.
.
- _ - - _ - _ _ - _ - _ _ _ - _ _ _ _ _ _ _ _ _
.
,
2.
Conclusion The licensee has been responsive and technically competent in pursuing its licensing activity during this SALP rating period.
The licensee is considerd to be in Performance Category 1 in this area.
3.
Board Recommendation a.
Recommended NRC Actions None.
b.
Recommended Licensee Actions The licensee should address license conditions and other licensing activity, as well as any future licensing activity with a high level of management attention to detail to assure that the staff's requirements are addressed on all licensing issues.
K.
Training and Qualification Effectiveness 1.
Analysis This functional area was inspected by NRC region-based and resident inspectors.
During this assessment period, the licensee received the Institute of Nuclear Power Operations' accreditation in the areasofgeneralemployeetraining-rajiationworker,nonlicensed operator, health physics technician,. licensed operator, licensed senior operator, and shift technical tidvisor.
In November 1986, the licensee submiti,ed accreditation self evaluation reports in the areas of chumistry technician, instrument and control technician, mef:hanical maintenance personnel, electrical maintenance perhonnel, and onsite technical staff and managers.
,
The licensee promptly responded to and corrected any NRC
}
identified concerns.
During the assessment period, hot license examinations were administered to five applicants for operator licenses during the week bf Octobdr 6, 1986.
All applicants successfully passed the examinations and the appropriate licenses were issued.
The licensee also voluntarily participated in a proposed requalification program pilot exercise to evaluate the WCGS requalification program.
This exercise consisted basically of an NRC review of a facility developed written examination
. _. _ -
_
'._
administration and grading, as well as evaluation of facility administered operating examinations.
Based on this effort, the WCGS requalification program was evaluated to be satisfactory.
A favorable recommendation was also forwarded to headquarters'
Operating Licensing Branch concerning the pilot requalification program.
There were no generic weaknesses noted during the administration of the October 1986 examinations.
2.
Conclusion The licensee has made a large commitment to training, as evidenced by the.large experienced staff dedicated to training and the modern, spacious training center.
The licensee is considered to be in Performance Category 1 in this area.
3.
Board Recommendations a.
Recommended NRC Actions The level of NRC inspection in this functional area should be consistent with the basic inspection program.
b.
Recommended Licensee Actions The licensee should continue to ensure that all employees receive adequate training.
V.
SUPPORTING DATA AND SUMMARIES
.
A.
Licensee Activities 1.
Major Outages The unit was shut down from April 8-25, 1986.
The cause was an
,
inadvertent trip due to testing activities in the Wolf Creek
substation switchyard.
The outage was extended to allow the repair of a pressurizer spray control valve and to conduct some 18-month surveillance tests.
.
The unit was shut down from June 4-11, 1986, to allow the correction of Limitorque valve operator wiring discrepancies.
?
l The unit was shut down from October 16 through December 20,
1986, for the first refueling outage.
2.
Power Limitations None
A
.
3.
Significant Modifications None.
B.
Inspection Activities 1.
Violations See Tables I and II.
2.
Major Inspections There was a maintenance program review conducted in June 1986 (86-15) with a region-based inspector and contractor personnel.
C.
Investigations and Allegations Review There were four allegations reviewed during this assessment period.
Three were closed due to not having safety significance.
One was referred to the licensee for review. The licensee's results will be reviewed by the NRC.
One major investigative activity was conducted.
The results have not been made public yet.
D.
Escalated Enforcement Actions 1.
Civil Penalties A Notice of Violation and Proposed Imposition of Civil Penalty was issued on July 7,1986.
A $40,000 civil penalty was proposed for a Severity Level II violation involving multiple uncontrolled access paths from the Owner Controlled Area into the Protected Area and in two instances into Vital Areas. This violation was discovered during an inspection conducted during
the previous SALP assessment period.
(
A Notice of Violation was issued on September 16, 1986, for a i
Severity Level III violation involving two separate occurrences l
in which security personnel knowingly falsified security tour reports.
No Civil Penalty was issued.
-
2.
Enforcement Orders None, r
l l
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_
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--
_ - = _ = -
.
.- --
_-
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- ___
__
-
-.
,
.
E.
Management Conferences Held During Assessment Period Conferences A management meeting was held on October 27, 1986, to discuss a security issue (control room access).
An enforcement conference was held on February 20, 1987, to discuss the licensee's failure to take action specified by the Technical Specifications when calculated RCS flow was less than allowed.
- F.
Confirmation of Action Letters (CALs)
,
None.
G.
Review of Licensee Event Reports and 10 CFR Part 21 Reports Submitted by the Licensee
1.
Licensee Event Reports (LERs)
During this assessment period, a review was conducted of LERs submitted during the period February 1, 1986, through February 28, 1987.
This review included LERs 86-04 through 87-11..The technical content of LERs was greatly improved during this assessment period.
See Table III for a list of all LERs issued during this assessment period.
An additional evaluation of the content and quality of a representative sample of the LERs submitted between February 1, 1986, and February 28, 1987, was performed by the NRC Office of
'
Analysis and Evaluation of Operational Data (AE00).
This, the i.
first evaluation of the licensee using AE0D's methodology, resulted in an overall score of 9.1 out of a possible 10 points.
The current industry average is 8.2.
The principal weakness identified in the Wolf Creek LERs involved the requirement to identify failed components in the text.
Strong points were the discussions of the root cause, the failure mode, mechanism, and effect of failed component, and personnel and/or procedural errors.
2.
Part 21 Reports None.
,
4 i
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,..__._s._
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_ _ _,
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,, _.,. _ _. _ _ _. _.,. _ _. _. _ _.. _. _, _ _ _, _. _ _ _.., _,, _ _ _. _
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.
TABLE-I ENFORCEMENT ACTIVITY TABULATION OF VIOLATIONS AND DEVIATIONS
,
BY
,
PERFORMANCE CATEGORY A.
Plant Operations Violations Failure to maintain control room HVAC in required state of operability (Severity Level IV, 8604)
Failure to document the performance of a surveillance test in accordance with the procedure (Severity Level V, 8605)
.
{.
Failure to verify correct revision of a surveillance procedure
'
prior to use (Severity Level IV, 8608)
Failure to properly document a completed portion of a surveillance test (Severity Level V, 8613)
- Failure to comply with licensee's temporary modification procedure (Severity Level IV, 8618)
l-Failure to lock valve in accordance with procedure (Severity Level IV, 8618)
Failure to lock valves in accordance with procedures (Severity
'
Level IV, 8624)
Failure to have an adequate procedure for draining the reactor
.
coolant system (Severity Level IV, 8634)
!
Failure to lock valves in accordance with procedures (Severity
[
Level IV, 8703)
_
Deviations No deviations were identified in this functional area.
B.
Radiological Controls i
Violations No violations or deviations were identified in this functional area.
l
'
i
... - - -,
, _.
.
_. - _ - _ _ _,.. _ _ _ _., _ _., - _
_ _ -. _, _ _.....,,.. _ _.. _
-
,... _ _.., _ _ _. - _ -. _ -
.-...- -- -..
- -.
.. -..- - -.
- _-
-
...
+,
,
C.
Maintenance Violations Failure to adequately perform TS surveillance requirements (Severity Level IV, 8608)
-
,
Data was not recorded on a work request as required by procedure
-
(Severity Level V, 8613)
- Failure to adequately isolate safety-related equipment prior to maintenance (Severity Level IV, 8616)
!
Failure to perform activities in accordance with established procedures (Severity Level IV, 8703)
'
Deviations
,
!
No deviations were identified in this functional area.
'
D.
' Surveillance
!
!
Violations Failure to comply with surveillance procedure instructions (Severity Level IV, 8604)
Failure to perform activities in accordance with specified
,
procedure (Severity Level V, 8617)
'
Failure to comply with surveillance procedure requirements (Severity Level V, 8628)
i
Failure of post-test review to identify an out-of-specification i
value and institute proper corrective action (Severity Level IV, 8632)
Violation of Technical Specification - fire suppression system
,
surveillance missed (Severity Level IV, 8634)
Failure to perform activities in accordance with established i
procedures (Severity Level IV, 8705)
Deviations i
No deviations were identified in this functional area.
,
-
- - -
..
_,. _,
..,.. _.-
m,.-__,
.,.. _ _ _ _, _,_. _,.,. _
e.._.
. _.- _,
..,.,,__
.,,.,,._ -,.-_.... - -.__, - -_... - _,.
_
-.. -...
-
.,.
E.
Fire Protection Violations
Fireproofing removed from support beam (Severity Level IV, 8604)
Failure to maintain auxiliary building buttress penetrations in accordance with fire hazards analysis (Severity Level IV, 8608)
Cardboard containers stored in the auxiliary building contrary to procedure (Severity Level IV, 8613)
Technical Specification (TS) violation - fire door blocked open without a permit (Severity Level IV, 8622)
Failure to control combustible materials in accordance with procedures (Severity Level IV, 8624)
Fire damper not operable as required by Technical Specifications (TS) (Severity Level IV, 8701)
Deviations No deviations were identified in this functional area.
F.
Emergency Preparedness Violations No violations or deviations were identified in this functional area.
!
G.
Security Violations
'
!
Failure to strictly control access to vital sectors on a work need basis (Severity Level IV, 8607)
Altered records (Severity Level III, 8612)
,
l
Safeguards contingency plan response (Severity Level IV, 8619)
Locks, keys and combinations (Severity Level IV, 8619)
- Failure to control documents marked as safeguards information i
(Severity Level IV, 8622)
Failure to follow compensatory measures (Severity Level IV, 8633)
,
i
!
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i
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_ _. -,. _ _ _. _ _... _ _ _ _ _ _, _ _. _. _ _ _. _ _ _ _ _.
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.
.
. _ _ _
. _ _ _ _ _ - _ - _ - _ _ - _ - _ _ _ _ - - _ _ - - _ _ _ _ _ _ - - _.
_
_ _ _ _ _ - _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.
_ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
- ,
-
.
.
c
,
i
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Deviations i
No deviations were identified in this functional area.
'
H.
Outages
,
,
.
'
Violations
No violations or deviations were identified in this functional area.
I, Quality Programs and Administrative Controls Affecting Quality I
Violations
Remote alarm response procedures were out of date (Severity i
Level IV, 8604)
Lack of EQ documentation-wiring (Potential violation, 8614)
!
Lack of EQ documentation-terminal blocks (Potential violation, 8614)
Lack of EQ test report for GE Vulkene wiring (Potential violation,8614)
l
'
Lack of EQ test report for Techbestos wire (Potential violation,
-
l 8614)
!
Lack of EQ test report for Kulka terminal blocks (Potential
'
violation, 8614)
i
!
!
Failure to have drawings reflect as-built status (Severity
.
'
j Level V, 8703)
i Failure to establish adequate procedures (Severity Level IV,
8703)
,
(
Failure to maintain total setpoint document up-to-date (Severity
Level IV 8705)
'
Deviations Failure to describe and summarize the qualification details of
l wiring and terminal blocks used in Limitorque valve operators (8614)
J.
Licensing Activities
'
Violations
<
No violations or deviations were identified in this functional area.
.
.. -. _.,,.
,
.
_ _.. _ _. _,.,_ _ _ _ _ _ _ _ _,_,.._ _, - _, _,__ _ _ _ _ _ _ - _ _ _ _,,._, _. _ _
-
.
K.
Training and Qualification Effectiveness Violations No violations or deviations were identified in this functional area, i
l l
,
l
_
'
.
TABLE II ENFORCEMENT ACTIVITY SUMMARY WOLF CREEK FUNCTIONAL N0. OF VIOLATIONS IN EACH SEVERITY LEVEL AREA V
IV III II I
PENDING DEVIATIONS A.
Plant Operations
7 B.
Radiological Controls C.
Maintenance
3 D.
Surveillance
4 E.
Fire Protection
F.
Secucity
1 H.
Outages I.
Quality Programs and Administrative Controls Affecting
,
Quality
3
1 J.
Licensing Activities K.
Training and Qualification Effectiveness TOTAL
28
0
5
- These are five potential violations concerning equipment qualification (Limitorque wiring and terminations).
-
.___
_ _ _.. _ _
__
.
. _ _
_
. _..
__
..
=
,
.
TABLE III TABULATION OF LICENSEE EVENT REPORTS BY PERFORMANCE CATEGORY A.
Plant Operations Thirty four LERs involved activities in the functional area of plant operations.
- Delay in surveillance required manual CRVIS to satisfy TS. (86-06 and 86-09)
Reactor trip and engineered safety features actuation due to failure of EHC card. (86-07)
Personnel error resulted in an inadvertent auxiliary feedwater actuation. (86-08 and 86-12)
Personnel error resulted in the failure to establish a fire watch.
(86-10)
Technical Specification violation due to personnel error.
Containment depressurization commenced while a containment radiation monitor was put in bypass. (86-13)
Automatic actuation of engineered safety features actuation (CRVIS)
including electrical spikes, spurious alarms,.and equipment problems.
(86-l'5, 86-22, 86-41, 86-63, 86-65, 86-71, and 87-08)
Shutdown due to unidentified RCS leakage. (86-19)
Reactor protection system and engineered safety features actuation signals due to low-low steam generator level. (86-20)
Personnel error resulted in both control room intake chlorine monitors inadvertently left in bypass. (86-23)
, _ _ _
_ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ -
__-_____-_ _ - ____ ___ - -- __ _____________ __________ -__ ____ - _______ ________ _________ ___.
,
a
Personnel error resulted in feedwater isolation signal. (86-24)
Personnel error resulted in the closure of an accumulator valve.
(86-25)
Inadequate procedure resulted in a residual heat removal valve being closed, which had not been analyzed. (86-28)
Inadequate procedure resulted in a feedwater isolation signal.
(86-30)
Personnel error resulted in the failure to stroke test containment isolation valves. (86-32)
Inadequate procedure resulted in a reactor trip and engineered safety features actuation. (86-37)
Reactor trip due to low-low steam generator level. (86-42)
Leaking drain valve in waste gas decay tank. (86-47)
Personnel error resulted in a CRVIS by a control room radiation monitor being removed from bypass during a surveillance test. (86-57)
Excess check valve leakage. (86-66)
Reactor trip caused by steam generator water level swings. (86-68)
,
Reactor trip caused by failed main feedwater transmitter. (86-69)
Inadequate procedure resulted in a feedwater isolation signal during main turbine vibration. (86-70)
High main turbine vibration resulted in a reactor trip and engineered safety features actuation. (87-04 and 87-05)
,
{
,
.
,
., - _ _ - _, - - - _. - _. _,
. _... _ _.
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_.. - -, - - -
. _ _ _ _. _ _ _,
. _ - -. - _
_ _ _ _ _ _ _ _
.
.
.
I'
I i
Personnel error resulted in a failure to log axial flux difference values. (87-07)
'
i
Operation above 100% rated thermal power. (87-11)
l
B.
Radiological Controls
.
'
One LER involved activities in the functional area of radiological controls.
- j Personnel error resulted in a failure to test sealed sources. (86-29)
i
C.
Maintenance
!
!
Four LERs involved activities in the functional area of maintenance.
!
Engineered safety features actuation due to power supply failure.
(86-16)
i
Personnel error resulted in an inoperable containment isolation valve. (86-34)
!
Personnel error resulted in an engineered safety features actuation,
.,
i (86-35)
!
Personnel error resulted in a CRVIS due to power being removed from
chlorine monitor. (86-62)
!
D.
Surveillance
!
l Twelve LERs involved activities in the functional area of surveillance, i
Inadequate procedure resulted in a containment purge isolation and CRVIS. (86-21)
i i
Personnel error resulted in surveillance interval exceeded. (86-26)
!
f
.
.
.
Personnel error resulted in late verification of fuel oil properties.
(86-33)
Personnel error resulted in a reactor trip and engineered safety features actuation. (86-38)
Personnel error during surveillance testing resulted in a CRVIS.
(86-40 and 86-46)
Inadequate procedure resulted in misadjustment of spent fuel pool crane. (86-51)
Inadequate procedure resulted in improper method for verifying flux doubling setpoint. (86-56)
Personnel error resulted in a missed fire suppression system surveillance. (86-67)
Personnel error resulted in a reactor trip and safety injection.
(87-02)
Inadequate procedure resulted in an engineered safety features actuation signal. (87-03)
Control room ventilation system inoperable due to failure of door to seal properly. (87-09)
E.
Fire Protection Thirteen LERS involved activities in the functional area of fire protection.
- Personnel error resulted in missed fire watches. (86-04, 86-05, 86-14, 86-27, 86-39, 86-48, 86-50, 86-53, 86-58, 87-01, 87-06, and 87-10)
Fire barrier inoperable due to design oversight. (86-17)
.
_
_ _ _ _
_-_ _ _ _ - _ _ _
_
__
._
_
_ _ _ _ _.. _ _ _ _ _ _ _ _ _ _ _ _ -
__
.
-
.
F.
Emergency Preparedness No LERS were issued in this functional area.
G.
Security i
Six LERs involved activities in the functional area of security. (86-31, 86-45,86-49,86-52,86-54,86-55)
'
i H.
Outages
,
l Four LERs involved activities in the functional area of outages.
- Personnel error resulted in containment atmosphere radiation monitors bypassed while purge valves open. (86-59)
Inadequate procedure resulted in sampling not performed correctly
<
with radiation monitors inoperable. (86-60)
"
Personnel error resulted in core alteration being performed with both
charging pumps out of service. (86-61)
'
Personnel error resulted in containment isolation valve opened during maintenance. (86-64)
i I
I, Quality Programs And Administrative Controls Affecting Quality
'
Five LERs involved activities in the functional area of quality programs and administrative controls affecting quality.
Personnel error resulted in partial loss of offsite power. (86-11,
86-36, and 86-44)
>
Inadequate procedure resulted in a reactor trip during surveillance
,
testing. (86-18)
I Indeterminate wire in Limitorque valve operators. (86-43)
l
-
-. - _
..
.,
.
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- - - - - - - - - - - _ - - _ - - _ - -
---
%
.
J.
Licensing Activities No LERs were issued in this functional area.
K.
Training And Qualification Effectiveness
No LERs were issued in this functional area.
l
_ _ _ _ _ _
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