IR 05000482/1988023

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Insp Rept 50-482/88-23 on 880829-0902.No Violations Noted. Major Areas Inspected:Followup to Previous Insp Findings & LERs,10CFR21 Repts & Safety Sys Outage Mod Insp
ML20195B828
Person / Time
Site: Wolf Creek 
Issue date: 10/21/1988
From: Barnes I
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20195B820 List:
References
50-482-88-23, NUDOCS 8811020229
Download: ML20195B828 (22)


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' APPENDIX

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U.S. NUCLEAR REGULATORY COMMISSION

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REGION IV

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NRC Inspection Report:

50-482/88-23 Operating License: NPF-42

Docket: 50-482

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Licensee: Wolf Creek Nuclear Operating Corporation (WCNOC)

Facility'Name: Wolf Creek Generating Station (WCGS)

Inspection At: WCGS, Burlington, Kansas Inspection Conducted: August 29 through September 2, 1988 Inspectors:

I. Barnes, Chief. Materials & Quality Programs Section J. R. Boardman, Reactor Inspector

H. F.'Bundy, Reactor Inspector D. R. Hunter, Senior Reactor Inspector i

R. C. Stewart, Reactor Inspector

f Approved:

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/ M, _f r I. Barnes, Chief, Materials and Quality Date Programs Section Division of Reactor Safety

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Inspection bunnary Irispection Conducted August 29 through September 2,1988 (Report 50-482/88-23)

i Areas Inspected: Announced special inspection of the licensee's followup to

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previousinspectionfindings,followuptolicenseeeventreports(LERs),10CFR Part 21 reports, and the safety systems outage modification inspection (SSONI).

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,esults: Within the four areas inspected, no violations were identified.

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DETAILS

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1.

Persons Contacted WCNOC Personnel

  • B. D. Withers, President
  • R. M Grant, Vice President, Quality
  • F. T. Rhodes', Vice President, Nuclear Operations
  • G. D. Boyer, Plant Manager
  • A. A. Freitag, Manager, Nuclear Plant Engineering (NPE)

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  • H. G. Williams, Manager, Plant Support
  • B. McKinney, Manager, Technical Support
  • 0. L. Maynard, Manager, Licensing
  • C. M. Estes, Manager, Operations
  • C. E. Parry, Manager, Quality Assurance (QA)
  • C. Sprout, Manager, NPE Systems
  • C. G. Patrick, Supervisor, Quality Systems

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  • R. W. Holloway, Manager, Maintenance and Modifications
  • T. Deddens, Jr., Outage Manager
  • G. J. Pendergrass, Licensing Engineer
  • L. R. Berry, Licensing Engineer
  • D. Dullum, Compliance Engineer
  • B. Norton, Supervisor, Reactor Engineering
  • R. H. Belote, Manager, Nuclear Safety Engineering NRC
  • B. L. Bartlett, Senior Resident Inspector

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The NRC inspectors also contacted other licensee personnel during the course of the faspection.

  • Denotes those persons attending the exit interview on September 2, 1988.

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Followup on Previously Identified Inspection Findings

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2.1 Violations 2.1.1 (Closed) Violation (482/860b

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Failure to verify correct surveillance procedure prior.o use.

The licensee's corrective actions were reviewed.

These actions included:

(1) reviews to ensure that the activity was performed correctly and (2) providing the violation as required reading (Form No.86-128) for the

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l operations group.

This violation is considered closed.

2.1.2 (Closed) Violation (482/8622-01):

Fire door blocked open without

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implementation of compensatory measures.

This violation involved propping a Technical Specification (TS) fire door open without j

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implementation of fire watch.

Corrective actions included remedial

training for involved personnel and the posting of all TS fire doors

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with appropriate instructions to avoid future violations.

This violation is considered closed.

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2.1.3 (Closed) Violation (482/8628-01):

Failure to comply with

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surveillance requirements.

The HRC inspector reviewed the licensee's corrective actions which included correcting the noted deficiency, i

evaluating the review process, requiring a maintenance engineer

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review of the completed surveillance, and' including the violation in l

the required reading program (Form 87-12) for the maintenance i

department.

The required reading was completed during March through

April 1987.

Improved written instructions were provided regarding review of completed work / surveillance activities.

This violation is

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considered closed.

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2.1.4 (Closed) Violation (482/8632-01):

Failure of post-test review to identify an out-of-specification value and institute proper corrective action.

The superintendent of maintenance has issued written direction which requires that an additional post-test review be performed by maintenance engineers to ensure completeness, and to

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ensure all data is within acceptable limits prior to routing the

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complete procedure to the operations surveillance coordinator.

The written response and written directive have been placed in the maintenance department required reading files.

In addition, the licensee's review of the completed test procedure (STS-MT-019, dated October 16, 1985) identified that certain average specific gravity (SG) calculations were in error.

The errors were corrected via a supplemental correction report dated March 11, 1987.

The above corrective actions were verified by the NRC inspector.

This violation is considered closed.

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2.1.5 (Closed) Violation (482/8634-01):

Failure to have an adequate procedurefordrainingthereactorcoolantsystem.

The NRC inspector reviewed the licensee s corrective actions which included revistens to the appropriate procedures to limit the "pump down" rate of the refueling pool / reactor coolant systems (RCS) with the upper vessel internals installed.

Procedure SYS EC-200, "Changin0 Level in the Fuel Pool or Refueling Pool," Revision 7, Steps 4.7.3.13 and 4.7.3.16 addressed the reduced RCS "pump down" flow rate; Procedure FHP 02-001,

"Fuel Pool Cooling," Revision 7, Steps 7.3.9.2 and 7.3.9.3.1 addressed the reduced RCS "pump down" flow rate; and Procedure GEN 00-007,

"Mode 5 RCS Orain Down," Revision 8, Step 2.15, referenced Attachment 2 to the procedure which provided RCS "pump down" flow rates vs RCS water level.

This violation is considered closed.

2.1. 6 (Closed) Violation (482/8703-01):

Failure to perform activities in accordance with established procedures.

The licensee's corrective actions regarding the installation of questionable plastic materials,

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tape, and a metal clamp were reviewed and included the initiation of a temporary modification (87-023-BG) and completion of a safety evaluation to assure that no unreviewed safety question was involved.

Wolf Creek Event Report 87-15 was issued and the event was discussed during Plant Safety Review Committee (PSRC) meeting No. 255.

The matter was provided as a required reading item for the operations (87-036), maintenance (87-15)}cs(87-027) groups.

Instrumentation and Controls (I&C)

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(IC 9087006), and health phys An operations

memorandum (OP 87-0039) was issued on March 27, 1987, addressing

"systems tracking" - status.

This violation is considered closed.

2.1.7 (Closed) Violation (482/8703-02):

Failure to lock valves in accordance with procedure.

The licensee's corrective actions were reviewed and included the provision for making the violation an operations required reading item (87057/WM 87-0125) and the issuance

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of an operations memorandum (OP 87-0039) on March 27, 1987, addressing "system tracking" - status.

During the review of the

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current System Checklist (CKL) GL-121, "Auxiliary Building Heating, Ventilating,andAirConditioning(HVAC)SystemValveLineup,"

discrepancies were noted, including an incomplete page (7 of 12) - a minor documentation transfer issue, an incomplete page 12 of 12 - a minor documentation issue (temporary procedure change not included with the checklist), and a more significant issue consisting of the i

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failure to document and/or perform two steps on the checklist.

This failure to document and/or perform the two steps on the checklist were noted to the licensee (shift supervisor), referred to the NRC Senior Resident Inspector, and is documented in NRC Inspection Report 50-482/88-22 as an apparent violation.

This violation is

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considered closed.

2.1.8 (0 pen) Violation (482/8703-03):

Failure to have drawings reflect as-built status.

The licensee's corrective actions were reviewed and included the documentation associated with walkdown of all vendor-supplied HVAC skids (memorandum Freitag to Williams, dated May 27, 1987) which revealed numerous disciepancies.

The licensee issued Plant Modification Request (PMR) 02207 dated July 31, 1987, to reconcile the identified deficiencies by December 31, 1987, as committed to the NRC.

The cause of the problems appeared to have been with the i

vendor / construction /startup/ engineering interfaces.

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numerous identified discrepancies, the licensee had not evaluated the

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findings in a generic sense to determine the need for an expanded vendor skid / system walkdown with respect to other equipment; e.g.,

emergency diesel generators, etc.

This violation will remain open pending licanse) accomplishment of an evaluation of the generic aspects of this problem.

l 2.1.9 (Closed) Violation (482/8703-04):

Failure to establish adequate procedures.

The licensee's corrective actions were reviewed regarding f

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the connection of the temporary chart recorder to the normal containment sump level recorders and included the following revised procedures: OFN 00-023, "Loss of NSSS/80P Computer," Revision 3 (Action Step 4, page 1 of 5); STS 2F-001, "Containment Normal Sump Inventory and Discharge and Determination," Revision 0; and INC S-0900, "Temporary Recorder Connection on Loss of 80P Computer."

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The procedures addressed the installation and removal of the

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temporary chart recorder.

This violation is considered closed.

2.1.10 (Closed) Violation (482/8705-01):

Failure to maintain total setpoint document (TSPD) up to date.

The licensee corrective actions were reviewed and included the results of the licensee review of the setpoint changes to date (memorandum, MacTaggart to Mah, dated June 17,1987); Procedure ADM 05-103, "WCGS Total Setpoint Document,"

Revision 3; and Procedure ADM 05-102, "Setpoint Change Request,"

Revision 6.

The corrective actions appeared to be comprehensive and

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acceptable.

This violation is considered closed.

2.1.11 (Closed) Violation (482/8706-01):

Fire door blocked open without

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issuance of a fire protection impairment control permit.

The root cause of this violation appeared to be verbal instructions given to workers which were contrary to licensee procedures.

The NRC inspector reviewed safety meeting reports indicating workers had been

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retrained on the administrative procedure for fire protection impairment control (ADM 13-103, Revision 4).

This violation is considered closed.

2.1.12 (Closed) Violation (482/8715-01):

Failure to comply with TS 4.0.5.

A section of safety-related, ASME Code Class 3, piping had not been properly pressure tested after welding repair.

During this inspection, the NRC inspector observed that the licensee requested and received ter;)crary relief from ASME Section XI Code

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requirements (NRR letter dated August 26, 1987) in order to delay performing a new pressure test until the next refueling outage.

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During the August-November 1987 outage, additional repairs and piping replacements were completed on PMR-2116 and related Work Requests (WRs) 02827-87 and 03125-87.

Hydrostatic pressure testing

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j (requirement of Section XI of the ASME Code) was documented under

WR 02931-87.

In addition, the superintendent of maintenance issued an instruction (memorandum dated August 11,1987) to the maintenance l

engineering staff alerting them to the requirements of TS 4.0.5 and 10 CFR 50.55a(g)(5)(iii).

The NRC inspector reviewed the above record documents and had no further questions.

This violation is i

considered closed.

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2.1.13 (Closed) Violation (482/8715-02):

Failure to test isolation of

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containment purge valves.

The root cause of this violation was

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inadequate procedure review.

Revisions to applicable surveillance

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test procedures (STPs) inadvertently deleted demonstration of automatic pathway isolation and control room alarm annunciation on tripping of containment purge radiation monitors, as required by TS 4.3.3.11.

The NRC inspector reviewed STS GT-004, Revision 0, dated August 18, 1987, which appears to satisfy TS 4.3.3.11.

Also, ADM 07-100, Revision 32, "Preparation, Review, Approval, and Distribution of WCGS Procedures," requires the preparer to document whether a change relates to a TS surveillance requirement.

If it does, it must be reviewed by the surveillance coordinator.

This violation and LER 87-029 on the same subject (see paragraph 3.3) are considered closed.

2.1.14 (Closed) Violation (482/8720-01):

Failure to enter TS 3.03.

The licensee corrective actions were reviewed regarding the blocking open of control room doors for limited periods of time (57 hours6.597222e-4 days <br />0.0158 hours <br />9.424603e-5 weeks <br />2.16885e-5 months <br />) and included posting permanent signs on control room pressure boundary doors and providing instructions to contact the control room prior to opening the doors for extended periods of time.

Contractor, facilities and modifications (F&M), and operations personnel were provided training regarding the event.

This violation is considered closed.

2.1.15 (Closed) Violation (482/8722-01):

Failure tc, perform surveillance in accordance with procedures.

The licensee's corrective actions were reviewed regarding the failure to perform Surveillance Test STS FP-602, "Electric Motor Driven Fire Pump 1FP01PA - Monthly Operation," as required, and included the rercheduling of the surveillance to be performed on the fifteenth of the month.

The electric fire pump is required to be started alternately from the contro! room and the local panel.

This violation is considered closed.

2.1.16 (Closed) Violation (482/8801-01):

Failure to comply with plant change procedure.

Steel test flanges were found hanging by electrical cable wraps from residual heat removal (RHR) valves.

No seismic loading evaluation was performed.

WCNOC operations personnel removed temporary test flanges and verified that no other such flanges were tied to any safety-related equipment or supports.

A Wolf Creek Event Report 88-05 was written to alert management and the PSRC of the event.

An engineering e,aluation (EER-88-XX-12 dated February 29,1988)

indicates that the structural integrity of the subject valves was not impaired and would not have prevented the piping system from performing its function.

The flanges are required only for testing during plant cold shutdown mode and are now stored in a tool box.

This violation is considered close.

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2.1.17 (0 pen) Violation (482/8806-01):

Failure to have appropriate procedure for venting reactor vessel and startup of an RHR train.

When starting up RHR Train A component ccoling water (CCW), a water hammer event ensued.

The NRC inspector reviewed Procedure STS EJ-120, Revision 10, which was revised to preclude inadvertent closure of Valve EG-HV-101.

The NRC inspector also reviewed an internal memorandum dated February 23, 1988, indicating that all system operating procedures had been reviewed to ensure inclusion of appropriate valve adjustment limitations.

The disposition of Engineering Evaluation Request (EER) 88-XX-09 confirmed continued operability of RHR Train A.

Technicians discovered that the reactor vessel (RV) head had not been properly vented when they disconnected a "conoseal." Also, reactor coolant system (RCS) level deviations were indicated on the tygon hose.

The NRC inspector reviewed Tem orary Procedure Change MA-051 toProcedureGEN-00-007, Revision 8,p' Mode 5-RCSDrainDown,"which requires head venting through the reactor vessel level indication system (RVLIS) connection in conjunction with the head vent.

This change was implemented because the reason for failure to obtain adequate venting was not determined.

The added flow path should provide reasonable assurance of adequate venting.

The licensee's evaluation of the RVLIS indicated that during drain down to 1/2 loop level, there was no redundant indication between the bottom of ths

pressurizer and the top of the loop to the tygon hose level indicator.

The NRC inspector reviewed records indicating a job authorization was approved on April 14, 1988, to adjust existing Level Transmitter (LT) 462 to cover this range.

LT 462 will send a signal to Level Indicator (LI) 462 on the main control board.

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the job authorization provides a duplicate indicator to LI 462 in

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containment.

This violation will remain open pending installation of j

this additional RV level indication.

2.1.18 (Closed) Violation (482/8807-38):

Failure to fbilow procedures for performing various maintenance and modification activities.

The root

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cause of this violation was inattention to detail in following

procedures, involved personnel in the three examples cited were t

counselled by licensee management.

The NRC inspector reviewed

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"Minutes for PSRC Meeting 320," which documented discussion of this

violation.

These minutes were distributed to plant management.

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violation is considered closed.

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Failure to make entries in the f

l pump and valve events log.

ADM-02-301, "ASME Code Testing of Pumps

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and Valves," has been revised to clarify the use of the pump and

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valve events log.

In addition, operations supervision has discussed this event with the personnel currently responsible for the pump and i

valve log.

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During this inspection, the NRC inspector verified the corrective

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action taken.

This violation is considered closed.

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2.1.20 (Closed) Violation (482/8817-01):

Failure to have appropriate procedure for performing daily surveillance of loose parts monitoring system.

This violation involved a failure to perform audio monitoring of the loose parts monitoring system for almost 3 years, because of a procedure inadequacy.

The NRC inspector reviewed STS CR-001, Revision 8, which now includes a requirement to listen to the audio signal from each channel.

The NRC inspector also reviewed Program Deficiency Report (PDR) OP 88-016 which was closed on June 16, 1988.

This PDR documented completion of a review of TS bases to determine satisfaction of all surveillance requirements.

This violation is considered closed.

2.1.21 (0 pen) Violation (482/8817-02):

Failure to maintain adequate and complete test records.

The NRC inspector reviewed documentation of appropriate tests related to testing following the plant modification requests (PMRs) cited in the violation.

Administrative Procedure (ADM)01-057, Revision 12, dated September 8, 1987, "Work Request," appears to con *,ain appropriate instructions to assure adequate testing is delineated and accomplished for plant components having test requirements.

The NRC inspector also reviewed training records indicating that involved personnel had received training on the revised ADM 01-057.

In that post-maintenance testing practices will be addressed during a forthcoming NRC maintenance team inspection this violation will

remain open pending the results of the team s findings.

2.2 Unresplved Items 2.2.1 (Closed) Unresolved Item (482/8710-01):

TS changes pending NRC approval.

During this inspection, the NRC inspector verified that TS changes, the revisions to Table 3.3-5, eigineering safety feature response times, have been incorporated in Amendment 9 to facility operating license NPF-42, NRR letter dated August 4, 1987.

This item is closed.

2.2.2 (Closed) Unresolved item (482/8715-04, 482/8720-02):

Operability of ASME Code components which are established to not be in full compliance with ASME Code requirements.

These unresolved items pertained to licensee actions related to operation of the emergency service water (ESW) system af ter identification in February 1987 that erosion / corrosion had locally reduced pipe wall thickness below ASME Code design minimum wall.

The NRC inspector reviewen the current WCNOC position on Code compliance versus operability.

This position references the TS 1.18 definition of operability which bases operability on the ability of the item to perform its specified function.

For a Code noncompliance, the position states that Nuclear Plant Engineering (NPE) will evaluate to determine whether the noncompliance would preclude the component from performing its

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specified safety function.

Code limits, when applicable, will be

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used as the criteria for operability decisions. With respect to the

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subject type of problem, erosion of ASME Code pipe below manufacturing minimum wall thickness would be evalueiM by NPE to i

determine the maximum stress fn that section of pipe.

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calculated maximum strecs w aeded the Code allowable wress,

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Operations would declare h pipe inoperable based upon the NPE evaluation.

If the calcuMed stress was below the ASME Code stress limits, the pipe would be considered to be still operable.

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NRC inspector verified (Mt the appropriate provisions of the current WCN00 position on Code cumpliance versus operability were

contained ir, Procedures ADM 08-212, "Erosion / Corrosion Monitoring Program," Revision 1, and KPN-E-314, "Disposition of Field Change Documents," Revision 7.

Required NRC actions in regard to the specifics of the 1987 ESW system operability issue will be determined during followup of NRC Inspection Report 50-482/88-200 (Quality Verification Function Inspection).

These items are closed.

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2.2.3 (Closed) Unresolved Item (482/9727-01):

Contamination of two

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I workers while working on a portable self-contained water processing i

system.

This item was included in Item A, Notice of

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Violation 50-482/87-31, and is accordingly closed as an unresolved

item.

2.2.4 (Closed) Unresolved Item (482/8727-02):

Pressurizer hydrogen burn

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during welding of an isolation valve to a pressurizer oressure level l

j instrument sensing line.

This item was included in Item B. Notice of

Violation 50-482/87-31, and is accordingly closed as an unresolved

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item, 2.3 Open I. ems

2.3.1 (Closed) Open Item (482/8615-01):

Hazardous maintenance material i

storage and control.

This finding dealt with the lack of licensee l

l procedures for storage and control of hazardous material.

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j primary concern was danger to personnel.

The licensee could not i

j provide the NRC inspector with a copy of selected Material Safety

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i Data Sheets (MSDS) for hazardous materials on site.

The licensee subsequently had issued the following procedures

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defining controls for and handling of hazardous material:

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l ADM 01-118 "Use of Plant Chemicals and Cleaning Agents,"

Revision 1, dated December 16, 1986 j

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KPG-1260, "Hazardous Waste Management," Revision 1, dated

i Jaruary 29, 1987 i

The November 1987 revision of the WCNOC General Employee

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Training (GET) Orientation handbook contains instructions on use of potentially hazardous materials and hazardous waste.

The licensee's I

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computerized chemical control system (CCS) lists all approved site cheinicals and their MSD'

This data is available from the WCNOC Safety Services'organizar. ion.

This item is considered closed.

2.3.2 (Closed) Open Item (482/8615-02):

Inadequacy of licensee Surveillance Procedure ST3 IC-243, "Analog Channel Operation Test Nuclear Instrumentation Power Range N1-3 Protection Set II,"

Revision 1, dated May 2, 1985.

Thi, finding dealt with licensee personnel stating that performance of the surveillance necessitated repositioning a milliamp range switch.

This repositioning was not included in the procedure.

inSection5.7.2 stating: vision 2,datedApril The sublect procedure Re 30, 1987, added a note

"At power levels below 50 percent it may

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be necessary to change the Range Milliamps Switch on N43B Det. B to the 1 position." This item is closed.

2.3.3 (Closed) Open Item (482/8615-03):

Replacement of Agastat relays to assure component qualification and compliance with plant licensed design base.

The concern dealt with assurance that components and components parts would be capable of performing their safety-related functions for the design life of the facility.

The specific concern

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l was that components might not be replaced prior to exceeding their design life.

l Complince with 10 CFR 50.49 and NRC Generic Letter 83-28,

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Section 2.2.2, contain the framework to assure accomplishment of such

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requirements and are the basis for closure of this item.

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2.3.4 (Closed) Open Item (482/8720-03):

Temperatures of individual comparttuents inside containment could not be determined.

The licensee installed 14 temporary resistance temperature detectors (RTDs) in specific compartments within containment under PMR 01975.

During this inspection, the NRC inspector reviewed data acquisition system (OAS) temperature data recorded during the period January through June 1988.

The 14 RTDs indicated temperature readings of 55*F to 124*F.

The NRC irspector had no further questions regarding this matter.

This item is considered closed.

3.

Followup to Licensee Event Reports (LER )

3.1 (Closed) LER 87-019:

Containment purge isolation signal (CPIS) and control room ventilation isolation signal (CRVIS) caused by signal spike on radiation monitor (RM) resulting from faulty cable.

The CPIS and CRVIS occurred when the door to Containment Purge Exhaust Radiation Monit.or GT-RE-33 was opened.

Subsequently, the event was recreated with Monitor GT-RE-33 in bypass by opening the cabinet door.

This led to discovery of a broken shield on the coaxial cable connector to Monitor GT-RE-33, which caused a noise spike.

The cable connector was replaced and no further events were experienced.

Because no similar failures had been experienceu, similar coaxial cable connectors are being

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i tested during the routine surveillance program.

This LER is considered closed.

3.2 (Closed) LER 87-021:

Failure to perform reluired hourly fire watch for impairment.

A fire watch person inadvertently missed an inspection on the fire watch impairment log.

The error was self-discovered and the inspection was made late by the person performing the subsequent tour.

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The licensee's corrective actions beluded improving the impairment descriptions on the log requiring a sign-off at the end of each tour verifying that all impairments had been inspected, and labeling fire doors with engraved permanent labels.

The NRC inspector observed completed i

revised logs, newly labeled doors, and remedial training records for the

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LER.

These actions appear responsive to the problem.

This LER is l

l considered closed.

3.3 (Closed) LER 87-029:

Failure to test isolation of containment purge j

i valves.

Closure of this item is discussed in paragraph 2.1.13 of this report.

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i 3.4 (Closed) LER 87-034:

Propped open door breaches control room pressure boundary.

This event resulted from inadequate communications between

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operations personnel, and facilities and modifications (F&M) personnel

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performing work on fire barrier penetrations.

The F&M personnel propped

open a control room pressure boundary door to facilitate their work.

The licensee's corrective actions included posting permanent signs on the

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involved and two similar doors, with instructions to contact the control l

room prior to opening these doors for extended periods of time.

Also, F&M

and operations personnel were receiving training on maintaining pressure boundaries.

This LER is considered closed.

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3.5 (Closed) LER 87-044:

Missed snubber visual inspection because of

'i exclusion from procedure.

Snubber AE04-R005 was not visually inspected during the first refueling outage because it had been inadvertently removed from the procedure subsequent to the preservice inspection.

The j

NRC inspector reviewed an inspection record for Snubber AE04-R005

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i completed during the second refueling outage.

Also, the current procedure I

includes Snubber AE04-R005.

A record of a licensee review of all snubbers i

requiring inspections indicated there were no further omissions.

This LER is considered closed.

4.

Followup to 10 CFR Part 21 Reports The NRC inspector reviewed three evaluations performed by the licensee of 10 CFR Part 21 reports made by other licensees and equipment suppliers and

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vendors.

The evaluation were performed to determine the applicability of the identified problem to the sa's operation of WCGS.

The evaluations

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reviewed by the NRC inspector ar

'isted below.

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NRC User, Vendor Identification or Supplier Subject P21-87-83 Morrison-Knudsen Failure of Basler Electric saturable core transformer due to inadequate insulation between windings P21-87-51 Static 0-Ring Inc.

Pressure switch setpoint drift resulting from gas bubble formation in sensing element P21-87-74 Northern States Abrasion damage to motor lead wire Power insulation on Limitorque SM8-00 motor operators The NRC inspector concluded that the licensee's evaluations were satisfactory.

No violations or deviations were identified in the review of this program area.

5.

Followup to Safety Systems Outage Modifications Inspection (SSOMI)

5.1 (Closed) Unresolved item (482/8807-01):

Battery charger AC alarm setpoint.

The licensee's overall evaluation and assessments of the finding appeared reasonable; however, document review revealed that no post-modification testing wa: required following the transformer tap change activity (PMR 1345) performed in 1985.

As a result, low voltage alarms occurred and the alarm setpoint was reset from 94 percent to 90 percent of 480V AC to prevent the "nuisance" alarms.

Interviews revealed that the battery chargers normal input AC voltage should be 480V 110 percent.

The low voltage alarm may occur at the lower band of normal input AC voltage.

5.2 (Closed) Unresolvtd Item (482/8807-02):

PMR 899 accumulator level transmitters.

As a result of this PMR, a smaller volume of nitrogen gas remained in the accumulator tank te provide for water injection into the primary system in the event of a loss of coolant accident (LOCA).

The new sensor connections to the referer.ce leg were five feet higher, which provided an additional 41.36 cubic feet of water in the tank at the minimum level setpoint than designed.

As a result, a smaller volume of n'trogen gas remained in the Accumulator Tank to provide for water injection into the primary system in the event of a LOCA.

The TS require that a minimum of 818 cubic feet of water be injected from the tank into the primary system in the event of a LOCA, The actual tank pressure required with the new volum2 of water was not determined.

The design nitrogen gas pressure of 585 psig had some allowance for conservatism, however this allowance was also unknown.

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Duringthisinspection,thesubjectfindingwasclosedbasedon discussions with licensee personnel and the following data:

The design modification stipulated in PMR 899 called for utilization of the same tank taps, standpipe taps, and diaphragm seal locations as the original installation.

The replacement Rosemount transmitters were relocated to a lower elevation than the Bartons (approximately 5 feet to 17 feet difference depending on transmitter) and are now placed at the midpoint between the diaphragm seals rather '.han abova

the upper seal.

Since the tap connections and diaphragm seal locations were j

unchanged, the original tank level setpoint calculations remain

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valid.

The replacement of a transmitter as well as its relocation j

from above the upper diaphragm seal to the seal midpoint would result in the need for calibration.

This was performed by Instrumentation i

and Controls personnel for PMR 899 in accordance with STS IC-908A,

"Channel Calibration Accumulator Level Transmitters." These actions

result in the tank water content remaining the same as prior to the modification and being within the TS bounds.

No engineering reanalysis of the effect of increased water content was necessary.

5.3 (Closed) Unresolved Item (482/8807-03):

PMR 899 accumulator level transmitters.

Although a significant amount of data existed to justify this PMR, it was not communicated within the organization.

A root cause j

analysis for changing the level transmitters was not performed.

The licensee provided the following information in the written response to this item.

Many letters were written as a result of the Barton instrument problems identified at WCGS.

The responsible engineer's correspondence

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file on the subject was turned over to the SSOMI team for review.

Although this file did not contain all the project correspondence, it did include the minutes of a meeting held at Wolf Creek on January 25, 1984, with representatives in attendance from KG&E (including the Project

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Director), Union Electric, Westinghouse, ITT Barton, and Nuclear Projects Incorporated.

During this meeting, KG&E/UE failures were discussed, l

including failure modes, and action plans were established.

The I

January 25, 1984, meeting minutes and other correspondence such as a January 27, 1984, letter from John Bailey of the Wolf Creek project to i

Kent Brown, KG&E Vice president (subject-Barton Transmitter problems and

intended solutions) clearly show that management and the project, as a whole, were being informed of the Barton transmitter problem, i

i During this inspection, the NRC inspectors reviewed other licensee records and correspondence.

These documented the root cause of the level i

transmitter replacement, and dissemination of information within the licensee's organization as appropriate.

This documentation included:

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Union Electric Company Letter VLB-460, dated December 31, 1983

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  • Nuclear Operations & Maintenance Information Service Report 2931A, Request 83-7-51, dated July 18, 1983

KG&E Interoffice Correspondence KNPLKWPD 84-12, PR M001-771 Corr, J. A. Bailey to F. Duddy, dated March 26, 1984

KG&E Interoffice Correspondence KWOLKWO 83-762, TS-35, from G. D. Boyer to F, T. Rhodes, dated December 14, 1983

KG&E Interoffice Correspondence KNWLKWO 85-007, A. Freitag to F. Rhodes, dated May 7, 1985

KG&E Interoffice Correspondence, B. McKinney to G. Boyer, dated November 23, 1983

KG&E Interoffice Correspondence KWOLKWO 83-798, TS 84-3, G. D. Boyer to J. A. Bailey, dated January 4,1984 Based on documentation reviewed, this item is closed.

5.4 (Closed) Unresolved Item (482/8807-04):

The work package for replacement of accumulator transmitters, PMR 899, as reviewed by the NRC inspector, failed to have the Q-list for safety-related equipment included in the modification.

The licensee response, and discussion during the inspection between the NRC inspector and the cognizant engineer for PMR 899, indicated that the required identification of Q-list material was made as follows:

Licensee Procedure KPN-0-311. "Q-List," Revision 2, dated

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November 19, 1985, governs changes to the Q-list.

The required form KEF-D-311-2 was prepared April 23, 1986, and released July 3, 1986, by Document Control Release DC-22.

Revision 004 of the System-EP Accumulator Safety Inspection System Q-list has PMR 899 and Q-list Change Notice (QL-EP-03-Z) identified on the covee as an unincorporated change.

This change notice is scheduled to be incorporated at the time of final closure of PMR 899.

This item is considered closed based on the above data.

5.5 (Closed) Unresolved Item (482/8807-05):

Electrical equipment room No. 1403 cooler.

The licensee's corrective actions appeared to be acceptable.

The concerns noted by the NRC were clarified and documented prior to placing the equipment into operation, including the design bases of the room and control rod drive cabinets, the installation of an area thermometer, and once per-shift checks and temperature recording by the auxiliary operator.

A local temperature of approximately 72*F was noted and recorded during the period of July 1-12, 1988 (CFL ZL-001).

No further control rod cabinet temperature problems were noted following the

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completion of the design change.

The licensee plans to install the temperature indicator controller and automatic chiller water control valve during the upcoming refueling outage (end of 1988).

This item is considered closed.

5.6 (Closed) Unresolved Item (482/8807-06):

PMR 1634 Reactor coolant drain tank (RCDT) isolation valve.

This PMR installed an isolation valve upstream of Relief Valve HB-7160 to simplify inspection and repair of the relief valve.

Previously, repair or replacement of the relief valve required a plant shutdown.

The Results Engineering Group issued Temporary Modification 86-24-HB in March 1986, to gag RCOT Relief Valve HBV-7160.

The 10 CFR 50.59 Safety Evaluation performed indicated that his modification did not affect the tank's overpressure protection because the tank was protected by Relief Valve HBV-7169.

Although Valve HBV-7169 had a larger spring to accommodate a higher set pressure, the evaluation indicated that the setpoint was below the design pressure of the relief tank and therefore provided adequate overpressure protection.

However, the Safety Evaluation did not evaluate the required flow rate, the relative flow rates of the two valves at 110 percent of the tank design pressure (110 psi) and the differences in configuration.

Therefore, the evaluation did not demonstrate that the second relief valve provided equivalent or adequate protection for the tank.

The licensee response stated:

The Safety Evaluation clearly stated that the two relief valves were supplied by the same manufacturer and are identical in f ie, style, type, assembly number, and material specifications.

Addition ly, it stated that the ASME Code relief requirebents for the tank we'

maintained.

The evaluation did not state that after full accumulation if the relief valve, the relief capacity is a function of the valves' orifice size and that the orifice sizes of the two valves were identical.

The root cause of this finding was an inadequately documented review to support the subsequent evaluation conclusions.

In the two years since this evaluation, significant experience and program development has occurred.

The Results Engineering 10 CFR 50.59 guidance has been augmented to include in each Safety Evaluation the design bases or function of a component and fully describe how this component and its system are affected by the change or modification.

Relief valves which appear identical and have different setpoints have dif ferent springs, but at full accumulation are, in fact, identical.

This should be documented when identical relief valves are discussed.

This item is closed.

5.7 (Closed) Unresolved Item (482/8807-07):

PMR 1634 RCDT isolation valve.

The new isolation valve added by PMR 1634 had less flow area than the relief valve inlet (Valve H-7160).

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The licensee response stated:

During the design process of PMR 1634, a review of ASME B&PV Code,Section VIII, paragraph UG-135 and Appendix M was made.

Engineering made the interpretation that "full area stop valve" meant and was intended to mean that the isolation valve between a pressure vessel and its pressure relieving device was to be of the identical line size as the piping and relief valve.

Subsequent to the concern expressed by the NRC, engineering discovered that an interpretation had been made by the ASME (Interpretation VIII-1-83-338) for the definition of a "full area stop valve" that confirmed that the minimum flow area within the stop valve should be at least equal to the inlet area of the pressure relief device.

The intended stop valve had a minimum flow area of 2.64 square inches versus 3.14 square inches for the pressure relief valve A technical evaluation of the stop valve indicated that no actual reduction capacity of the pressure reducing device would occur (i.e., design function would not have been affected).

Subsequent to the review of the ASME Code Interpretation VIII-1-83-338, PMR 1634 was withdrawn from implementation status.

Based on current system performance without the modification, this design change is not presently deemed necessary, the system was restored on December 9, 1986.

Even if the proposed modification had been implemented, the modification would not have affected the original relief capacity of the valve.

This item is considered closed.

5.8 (Closed) Unresolved Item (482/8807-08):

PMR 1634 RCOT isolation valve.

Instrumentation was not installed at the new isolation valve to enable appropriate emergency actions if the tank became overpressurized.

The isolation valve was installed to permit maintenance on Relief Valve H-7160 without shutting down the plant.

During this inspection, the NRC inspector reviewed licensee's documentation related to this item and discussed the item with licensee personnel with the following findings:

There is no regulatory requirement for instrumentation to be included

in PMR 1634.

The requested scope of PMR 1634 did not include instrumentation.

  • Pressure monitoring was considered to be within the scope of maintenance and operations, and could be accomplished using existing instrumentation and communication systems.

Similarly, the required spool piece to replace the relief valve

during maintenance was not included in PMR 1634.

This also was considered to be a maintenance responsibilit _____________ - __________________ -_ ____-_ _ _.

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PMR 1634 was cancelled.

This item is considered closed based on the findings of the inspection.

5.9 (Closed) Unresolved Item (482/8807-09):

Valve packing chamber leak-off line modification.

This finding dealt with the installation of leak-off line metal flexible hoses with shut-off valves.

The concern was that closing a shut-off valve could result in pressurizing a flexible hose to reactor coolant pressure, which was greater than the manufacturer's hose pressure rating.

During this inspection, the NRC inspector noted the following:

The shut-off valves were installed only to isolate a drain line hose during packing chamber maintenance.

This was to prevent back flow from other leak-off lines through a common discharge header, or from the RCOT.

  • When a shut-off valve was closed, the hose would not be pressurized.
  • The metal flexible hoses have a manufacturer's nominal design burst pressure of 4765 psig at 600 F.

This should protect the hose from failure if a shut-off valve were improperly closed.

  • Installation of the hoses does not appear to deviate from any defined USAR parameter.
  • Failure of the hoses would not affect plant operability.

This item is considered closed based on the findings of the inspection.

5.10 (Closed) Unresolved Item (482/8807-13):

Root cause analysis of containment cooling fan damage.

This item reflected concern that the licensee did not perform a root cause analysis of the fan failure.

The licensee's response of April 28, 1988, indicates that the licensee did perform a root cause analysis, with inconclusive results.

It would have been beneficial for the licensee to have documented this analysis in the PMR for future reference, even though no root cause could be established.

The licensee's actions to present similar failures, by inspections of blade tip angles torque checks of the blade attachment nuts, vibration checks,andlubrlcationofmotorbearings,appearreasonable.

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is considered closed.

5.11 (Closed) Unresolved Item (482/8807-14):

Appendix J leak test requirements.

It was noted that further NRC action was necessary to clarify the containment boundary and leak testing rcquirements with respect to certain valves.

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l During this inspection, the NRC inspector reviewed the licensee response to this item dated April 28, 1988.

As pointed out by the licensee, the

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valves identified in PMRs 1143 and 2109, are feedwater and feedwater chemical addition isolation valves associated with the main feedwater line penetrations.

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The valves associated with the piping connected to the secondary side of the steam generators, isolate the steam generators and are not considered

containment isolation valves and are, therefore, not leak tested under l

Appendix J leak test requirements, j

All portions of the secondary side of the steam generators are considered l

an extension of the containment.

(USAR Section 6.2.4.3) This item is considered closed.

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r 5.12 (Closed) Unresolved Item (482/8807-19):

DC system low voltage alarms.

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The licensee's corrective actions were reviewed regarding the DC low i

i voltage condition and it revealed that the licensee had written a new i

procedure (MPE E051 Q-03, Supply Power to the NK Buses During NB Outage

or Charger PMs, Revision 0).

The annunciator procedures were reviewed to j

ensure the.t actions were appropriate.

The procedures were not consistent, in that the alarm setpoints were not included in all the procedures.

This

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item was discussed with shift personnel who noted that the setpoints were j

to be added as needed during the routine biennial review of procedures.

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i It appeared that during normal operating conditions and during the periods

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when alternate power is being supplied to the NK bus, the low DC voltage alarms (123V DC, 112.5V DC, 86V DC, and 82.5V DC) should provide adequate i

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i warning to the operators.

This item is considered closed.

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I 5.13(Closed)UnresolvedItem(482/8807-21):

Deficiencies in wiring i

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installation for valve motor-operators.

This item involved unauthorized i

j use of tape to protect conductors, failure to install protective end caps L

on conductors, and minor conductor damage associated with two motor

operators.

The NRC inspector reviewed completed WRs 04953-87 and 04954-87

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which satisfactorily corrected identified deficiencies.

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deficiencies resulted from noncompliance with installation specifications

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and procedures.

NRC Inspection Report 50-482/88-07 and the licensee's

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i response, dated April 28, 1988, indicated that these were isolated l

deficiencies and that the workmanship observed was generally good.

This

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item is considered closed.

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5.14 (Closed) Unresolved Item (482/8807-23):

Rejection of Engineering

Evaluation Request (EER) 87-KC-08 to relabel wires with duplicate ntitbers I

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in vendor equipment.

In responding to this item, the licensee correctly l

observed that the instruction manual for the equipment shown on the L

subject vendor wiring diagram includes information that eliminates the

confusion regarding the duplicate wire numbers.

Criterion 15.N. of Bechtel

Orawing E-01016 "Electrical As-Built Drawing Criteria," states that i

internal vendor wiring inconsistencies, that do not affect the circuit i

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This criterion was correctly applied in dispositioning the EER.

This item is considered closed.

5.15 (Closed) Unresolved Item (482/8807-24):

PMR 2018 ASCO solenoid valve replacement.

The SSOMI team review of PMR 2018 Asco Solenoid Valvo Replaceme,.t identified a concern with the 10 CFR 50.59 Safety Evaluation.

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The new model solenoids were originally procured as replacements for the solenoid valves.

The spare parts had been purchased in

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accordance with the original Westinghouse Purchase Order which included seismic and environmental qualification requirements.

In addition, the Material Received Report (MRR) includes a certificate of conformance documenting the compliance with Westinghouse Purchase Order and the applicable Codes and Standards.

Based on this, the seismic and environmental equivalency of the replacement parts were considered during the procurement process; therefore, no hardware deficiency had been identified.

However, reference to this equivalency should have been documented on the 10 CFR 50.59 Safety Evaluation.

The licensee acknowledged that the 10 CFR 50.59 Safety Evaluation for PMR 2018, Asco Solenoid Valve Replacement should have identified the reference to equivalency and suitability of the replccement solenoids.

In order to preclude further omissions of this nature, the subject deficiency will be brought to the attention of those personnel performing safety evaluations throtgh review of the SSOMI team audit findings and the WCNOC response.

No further action is warranted at this time.

This item is closed.

5.16 (Closed) Unresolved item (482/8807-25):

The air supply line for Asco Solenoid Valve EJHCV-8890B appeared to have inadequate seismic support.

The subject line is in the instrument air system.

j During this inspection, the NRC inspector determined the following bases y

for closure of cor.cern:

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Valve EJ-HCV-88908 is by design a normally closed, fail closed

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application.

Functionally, the loss or failure of the instrument air line should not affect reactor safety.

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The instrument air line is not by design required to be seismic.

The absence of adequate seismic support is not a deficiency.

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The licensee state that the nonseismic instrument air line resulted i

in no seismic II/I considerations.

Connection between the i

seismically qualified valve and the sei3mically unqualified i

instrument air system is by hose to preclude seismic loading of the valve support, i

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5.17 (Closed) Unresolved Item (482/8807-29):

PMR 1828 ESW building cable l

replacement.

This PMR was issued to pull new cables to the ESW building.

The licensee performed an evaluation of the damaged cables; however, an

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additional evaluation to determine the root cause of the failure in the original safety-related cables routed to tne ESW building was not performed.

The SS0MI was concerned that the conditions associatsd with

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the original cable pulls were not evaluated to provide assurancs that the

cable failures were not the result of a generic condition.

The licensee response stated:

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The original revision of PMR 1828 provided a design for replacement of control cables in both safety-related trains.

After romoval of

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the damaged Train A control cables information was available to

justify revision of the PMR to exclude the other train of control cables.

The justification for concluding that the failures were not

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indicative of a generic condition involved the following facets:

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(a) During the design development of PMR 1828, detailed cable

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pulling calculations were performed in order to add the maximum number of spare control cables possible.

These calculations

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represented a limiting case (more severe than the original i

design) which established that the original ductbank design (e.g., distance between manholes, slope of the ducts, etc.)

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provided for a safe pulling length for the original control i

cable installed.

Therefore, the ductbank design was eliminated

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as a potential root cause for the control cable failures, i

(b) A review of the number of control cable failures and their

physical routing within the ductbank was accomplished.

This review revealed that seven conductors had failed in the A train

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and one conductor had failed in the B train.

In addition, the A l

train conductors had the same physical routing within the

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ductbank.

(c) An evaluation of the damaged cables removed during the Train A i

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cable pull revealed damage to the outer jackets as well as conductor insulation damage at various locations.

Based on

discussions as well as visual observations of the cable (exposed i

copper was not corroded), some of the damage to the cable

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occurred during removal from the ductbank.

However, some damage occurred prior to removal based on visual observation of copper

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i corrosion found on the exposed conductor (in one case the

conductor had completely corro$d away).

This damage is judged i

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to be the leading contributor to the control cable failures that probably occurred during the initial installation.

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(d) The available spare control cables we,e assessed for future

contingencies.

In order to maximize the available spare i

conductors, auxiliary relays were sdded to Train B control

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circuits to provide two additional Train B control conductors.

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(e) The fact that only one control cable has failed in Train B provides evidence that the control cables were not damaged during installation as indicated by the large number of failures in Train A.

This conclusion is based on the premise that cables that have a common failure mode should have approximately the same average time to failure under the same conditions.

Therefore, if any other control cables in Train B are affected, additional failures in Train B should have been identified.

Based on these considerations, adequate justification existed to conclude that the failure mechanisms were isolated to Train A only.

Based on this cor.clusion, PMR 1828 was revised to eliminate the l

train B control cable replacement.

L This item is considered closed based on the review during this inspection

l of the licensee response as well as discussion with licensee 3ersonnel.

Licensee personnel stated that cable damage appeared to have )een caused t

by foreign objects cutting the cable jacket.

Original cable pulling

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records were not reviewed by the NRC inspector.

Apparently a licensee

root cause determination had been performed, but not documented.

The

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licensee identified to the NRC in their letter of August 19, 1988,

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Serial WM 88-0207, from B. D. Withers to R. D. Martin, on page 14 that the

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WCNOC Quality Department is currently performin0 research to develop a

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corporate program for root cause analysis.

5.18 (Closed) Unresolved Item (482/8807-30):

Concern regarding lack of detail in surveillance test procedure.

The NRC ins)ector observed that

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Procedure STS-IC-433 could not be performed )y the technician without i

additional information.

The technician suspended the test, obtaineo the necessary information, and incorporated it into the procedure via a temporary procedure change (TPC).

The test performance was valid.

The

licensee states in his response dated April 28, 1988, that an ongoing

review of procedures is providing a high level of confidence and that test i

objectives and TSs are met.

This item is considered closed.

5.19 (Closed) Unresolved Item (482/8807-34):

EF-V090, EF-V058, EF-V47, and EF-V48 hard surfacing.

The NRC inspector reviewed the licensee's

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corrective actions, associated with the concerns related to possible I

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over pressurization of adjacent systems /componente, including the revision

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made to the work order (WR 02931-87) and clearance arder (87-1228-EF) to protect adjacent systems prior to performance of the hydrostatic test.

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Additionally, the NRC inspector reviewed the revision made to

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Procedure MGM M00-01 "Hydro natic and Pneumatic Testieg," Revision 1.

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June 30, 1988, to address protection of adjacent systems during the i

performance of future hydrostatic testing.

This item is considered l

closed.

5.20 (Closed) Unresolved Item (482/8807-35):

Essential service water check I

valves.

The licensee's corrective actions reviewed included the Operations Special Order 7, "Safety Tagging for Personnel Authorized to

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Performing Tagging Activities" and the provision of a signature / initial

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i listing to provide a more efficient method of determining the individual signing of on a quality-related activity, such as independent inspections / verifications.

This item is considered closed.

5.21 (Closed) Unresolved Item (482/8807-36):

Charging pump control valve cavitation damage.

The licensee's corrective actions reviewed, associated with the concern regarding the failure to cross-reference the PMRs in the WR 4430-86, included the technical manual, the PMRs, and the associated WRs.

The Section XI work instruction associated with WR 04430-86 included the step to "repack the valve in accordance with the technical manual" and the step was followed by an asterisk, which noted 12 rings of packing were loosely installed in the stuffing box.

The e.uthor apparently knew the situation; however, the instructions and the technical manual associated should have been more closely controlled.

Discussion revealed that a document control system is implemented to ensure that changes were appropriately addressed by the author of the work package.

This item is considered closed.

5.22 (Closed) Unresolved Item (482/8807-37):

Test procedure and implementation for pressurizer safety valve testing were inadequate.

During this inspection, documented information provided by the licensee indicates that the anomalies found in the methods listed in bench testing pressurizer safety valves were corrected.

Items of concern expressed by the NRC inspector were resolved on WRs 91050-87, 04300-87, and 03999-87. Test Procedure STS-MT-005, "Pressurizer Safety Valve Operability," was completely rewritten and issued May 26, 1988.

This item is considered closed.

6.

Exit Interview An exit interview was conducted on September 2, 1988, with the licensee personnel denoted in paragraph 1, during which the scope and findings of the inspection were summarized.

The team leader informed licensee personnel that enforcement actions may be taken with respect to 550MI findings following additional Region IV review.