IR 05000482/1989007
| ML20247A795 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 03/07/1989 |
| From: | Hunter D, Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20247A761 | List: |
| References | |
| 50-482-89-07, 50-482-89-7, NUDOCS 8903290193 | |
| Download: ML20247A795 (9) | |
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APPENDIX B.
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U.S.' NUCLEAR REGULATORY COMMISSION-
-REGION IV
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-NRC-' Inspection Report: 50-482/89-07 Operating. License:'NPF-42
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Docket: 50-482 Licensee:' Wolf Creek Nuclear' Operating Corporation (WCNOC)
P O.; Box;411 Bolington. : Kansas 66839
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Facility Name: Wolf Creek Generating Station (WCGS)
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. Inspection At: WCGS, Burlington, Kansas Inspection Corducted:
February 13-17,1989 Inspector:-
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WriIt n R. HgMter, Senior Reactor Inspector.
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Operations Program Section. Division of Reactor Safety
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Approved:
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3/7/# 7
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-William C. Seple, Chief, Test Programs Date Section, Division of Reactor Safety'
Inspection Summary Inspection' Conducted February 13-17, 1989 (Report 50882/89-07).
Areas Inspected:
Routine, unannounced inspection of the areas of facility
~ modifications and offsite technical support staff.
m Results: Within the two areas inspected, two violations were identified (failuretoprovidewrittensafetyevaluationpursuantto'10CFR50.59(b)(1),
paragraph 2.4.2;-and inadequate PSRC review of4 temporary modifications, paragraph 2.4.3).
The licensee program and implementation of facility
, modifications appeared to have Limproved significantly, including the routine
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attendance by nuclear. plant" engineering (NPE) in PSRC meetings.
Further
&Qs improvements regarding temporary modification activities appear to be-warranted, including the increased involvement of NPE in temporary modifications.
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8903290193 890315 PDR ADOCK 05000482
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DETAILS c_
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1.; : Persons Contacted WCNOC-
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- G.-D. Boyer P1 ant Manageri
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- R. M. Grants Vice President Quality
- C. Sprout : Section Manager, NPE Systems
- C. E.: Parry, Manager, Site Quality
- A. A. Freitag, Manager, NPE-
- 0.'L. Maynard, Manager, Licensing.
'*M.' G. Williams, Manager, Plant. Support 1*R. W. Holloway,. Manager, Maintenance and Modifications
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- B.'.T. McKinney. Manager,< Operations
- W. B. Norton, Manager, Technical Support
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- J..F.-Deddens,-Outage Manager T.:L.. Foster Manager, Facilities and Modifications W. M. Lindsay, Manager, Quality Assurance Evaluation f
.B. L. Novak, NPE-
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Z. S. Bostros NPE
'*JE D. Stamm, Lead Engineer, NPE
- T. L. Ottcarn,.NPE-
- V. J. MacTaggart, Supervisor, Results Engineering
- R. L. Reitmann, Results Engineer
'*D. A..Glozowski, Maintenance Engineer
- S.:W. Lewis, Results Engineer
- S. F. Hatch, Supervisor, Quality' Systems
- S.:Wideman, Licensing Specialist
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- C. J. Hoch, QA' Technologist
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< *R. D., Flannigan, Supervisor, Plant Support J.-R.-Myer Engineer, Plant Support D. N. Dallum,' Engineer, Plant Support >
The NRC inspector contacted other operations, technical, and administrative personnel.
NRC
- B. L. Bartlett, Senf 9r Res ident Inspector M. E. Skow, Reside'
Inspe : tor
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- Denotes persmnel attending the exit interview.
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x 2.
Facility Modifications
'Seleczed modification program policies, procedures, and modifications were
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' reviewed to determine that the' changes were completed in conformance with-the requirements / commitments set forth in.10 CFR 50.59. Technical-Specifications (TS), USAR, Codes, and Standards.
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i 2.1 Documents Reviewed Refer to Attachment 1.
2.2 Modification Controls The review of Policy III.25.0, " Configuration' Management Policy," and Procedure KGP-1131, " Plant Modification Process," by the NRC inspector, revealed an apparent inconsistency between the policy and the procedure-regarding the scope of the modification controls.
Policy III.25.0, Step 25.2,. stated that " partial divider walls... outside the power block,... are exempt"; however, KGP-1131, Step 2.1, stated that "inside
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the power block... divider walls which do not span from floor to ceiling... are outside the scope of this procedure...." This apparent procedural discrepancy was discussed with licensee representatives.
It was determined that only walls within offices located inside the power block were considered to be exempt, and the licensee representatives indicated that any changes, which had been made to the walls within the
- power block," were accomplished in accordance with the program. The NRC inspector had no further questions regarding this matter.
2.3 Modification Requests Selected plant modification requests (PMRs) were reviewed by the NRC inspector. Regarding PMR 00931, " Hanger on Steam Generator Plowdown Piping - Spacing / Binding," document review and interviews revealed that the hanger was designed for seismic restraint (vertical) and allowed unrestrained thermal growth in the horizontal direction. The licensee's reviews associated with the PMR determined that the minor binding (wedge / spacer installed during construction-activities) discovered during initial plant heatup activities caused no unacceptable stresses on the pipe. The construction wedge was removed to allow free pipe movements.
The NRC inspector had no further questions regarding this matter.
2.4 Temporary Modifications The NRC inspector reviewed Administrative Procedure ADM 02-001, " Temporary Modifications," and selected three safety-related, temporary modifications (88-117-NK, 86-65-GK, and 87-006-BB) for evaluation to ensure that the changes were made in accordance with the licensee and TS.
2.4.1 The review of ADM 02-001 revealed that temporary change modifications (changes) were authorized on safety-related equipment provided the appropriate group leader (or designee) prepared and approved by the 10 CFR 50.59 applicability review was in advance of the work being performed, and the changes were determined to not change the facility as described in the USAR.
Step 2.3 of Procedure ADM 02-001 required that the duty shift supervisor shall approve the installation, restoration, and ensure the temporary modification order (TM0) and the 10 CFR 50.59 environmental applicability review have been properly
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completed. Additionally', the PSRC was required to review all 50.59 and environmental applicability reviews within 2 weeks of the-installation or at the end of an outage and prior to entry into=
Mode'4-(Steps 2.4and6.1.3.2). The PSRC review of all the applicability reviews (changes implemented) within a specific period of time appeared to be conservative. The NRC inspector had no further questions regarding this matter.
A review of the administrative procedure by the.NRC inspector identified an apparent program and procedure weakness regarding the lack
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of immediate involvement of the NPE group in the modifications. to ensure the quality.of the' design activity. The. licensee
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representative indicated that the controlling procedure for the TMOs u
was being evaluated and the more timely involvement of NPE was being i
considered, including providing NPE with copies of temporary i
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modifications and the associated maintenance orders.
2.4.2.
The NRC inspector's review of-TMO 88-117-NK (Safety Evaluation 88-AR-096),
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" Jumper Cell 10 of Battery NK12," revealed that the safety-related i
TM0 had been installed on November 11. 1988. The 10 CFR 50.59
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-applicability review was completed, and the five questions were
answered "No," including the question "Does this change the facility l
or procedures from their description in the USAR?" The TM0 resulted in the imbalance alarm associated with Battery NK12 (Annuciator.
Window 26C) to be illuminated continuously. The alarm is addressed in Section 8.3.2.2 of the USAR (page 8.3-44), " Analysis," as part of the control room summary annunciator and is part of the -
instrumentation provided to monitor each DC subsystem.
i The licensee representatives stated that the jumpering of one cell of
the. safety-related battery did not reduce the battery capacity below.
j that required to meet the accident analysis; however, the analysis to
support the conclusion was not documented, j
Document review by the NRC inspector revealed that the TMO, which had been implemented on November 11, 1988, was reviewed by the PSRC,
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after-the-fact, on November 22, 1988. Additionally, document review and discussions revealed that NPE was in attendance at the PSRC
meeting (No. 345) when the TM0 was discussed. The TM0 remained in
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effect at the time of the inspection and no documented safety l
evaluation was required.
The TM0 did change the facility as described in the USAR by reducing the tested battery capacity and by changing the continuous alarm
system associated with the battery. The failure to provide a written
safety evaluation, which provided the bases for the determination i
that the change did not involve an unreviewed safety question, is a violationof10CFR50.59(b)(1).
(482/8907-01)
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-5-2.4.3 The NRC inspector's review of TM0 86-65-GK, " Compressor Heat Exchanger SK0AA Gasket Material," and TM0 87-006-BB, " Increase of the Instantaneous Trip) Setting on MCC Breakers NG01BBR3 and NG02DDF1-(PORV Block Valves," revealed that the TMOs included documented 10 CFR 50.59 safety evaluations - TM0 86-65-GK (86-SE-87) and TM0 87-006-BB (87-SE-003); however, the PSRC review was provided using the "PSRC Serial Review Sheet." The PSRC review regarding TM0 86-65-GK (86-SE-87) was completed on June 20, 1986, as a
" walk-around" review (four PSRC members and the PSRC chairman). The PSRC review regarding TM0 87-006-BB was completed on November 1, 1987, as a " telephone survey" of.five PSRC members and the acting PSRC chairman.
Technical Specification, Section 6.5.1 requires that the PSRC meet to perform its functions.
Procedure ADM 01-002, " Plant Safety Review Committee," Step 5.2.6, states, that, "A meeting does not require the physical presence of.the quorum at one location.
It shall only.
require communication among the quorum." This would be acceptable if a PSRC member joined the meeting by telephone, for the Technical Specifications clearly require a meeting. Actual practices included the review of some individual issues by members of the PSRt,.id.
approval by the plant manager utilizing the."PSRC Serial Review Sheets." The review of the two TM0s by the individual PSRC members and chairman prior to the implementation of the modification was
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accomplished outside of a formal PSRC meeting. The failure to review the safety evaluations by a quorum of PSRC members convened by the PSRC chairman is a violation of Technical Specification 6.5.1.
-(482/8907-02)
2.5 Audits The NRC inspector reviewed selected audit reports associated with the control and implementation of plant modifications.
The NRC inspector. discussed with the licensee the post modification and maintenance testing activities identified in a recent audit (TE: 50140-K196,
" Work Control"). The matter had been previously identified by the licensee and the NRC. Discussions revealed that the matter was being maintained open and active by QA pending verification of corrective actions taken.
The NRC inspector had no further questions regarding this matter.
2.6 Surveillance The NRC inspector reviewed selected surveillance reports associated with the control and implementation of plant modifications.
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-6-The NRC inspector noted that the control of drawings (" red lining")
associated with the control room and the maintenance of fully accurate control room drawings, including temporary modification, had been identified by the licensee in Surveillance TE:
53359-S-1659 in August 1988. Corrective actions were continuing on the licensee identified findings at the time of the inspection.
The NRC inspector had no further questions regarding this matter.
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Offsite Technical Support Staff Selected program policies and procedures were reviewed to determine that the control of the activities were in accordance with the quality program requirements.
3.1 Documents Reviewed Refer to Attachment 2.
3.2 Program Policies and Procedures Selected program policies and procedures were reviewed by the NRC inspector regarding materials and services control, procurement, maintenance, and review activities.
3.3 Audits The NRC inspector reviewed selected audit reports associated with certain plant support activities including procurement, materials and parts controls, and the industry technical infonnation program (ITIP).
3.4 Surveillance The NRC inspector reviewed selected surveillance reports associated with support activities, including control of maintenance parts and certain plant testing.
L'o violations or deviations were identified in this program area.
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Exit Interview The NRC inspector met with the licensee personnel denoted in paragraph 1 on February 17, 1989. The NPC inspector summarized the findings of the inspection and discussed the findings identified in paragraph 2.4 regarding the failure to provide a written safety evaluation and the PSRC serial review practice. The licensee did not identify, as proprietary, any of the information provided for review by the NRC inspector.
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ATTACHMENT 1 Documents Reviewed Policy II.11.0, " Management Systems," Revision 2 Policy 111.25.0, " Configuration Management Policy," Revision 3 KGP-1131, " Plant Modification Process," Revision 6 PCN 2, September 15, 1988 (cancelled PCN 1)
PCN 3, November 14. 1988 KGP-1132, " Configuration Identification," Revision 3 KGP-1135, " Configuration Verification," Revision 4~
(Voided and incorporated in Procedure KP-1011)
ADM 01-42, " Plant Modification Request Implementation," Revision 12 ADM 01-002, " Plant Safety. Review Comittee," Revision 19 i
ADM 02-101, " Temporary Modifications," Revision 18 TPC MA 87-447, November 10, 1987-TPC MA 87-524, December 15, 1987
'ADM 01-053, " Engineering Evaluation Request," Revision 6
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' ADM 08-201, " Control of Maintenance and Modifications," Revision 4 KPN-D-304, " Licensing Review and Safety Evaluation," Revision 2 Plant Modification: Request (PMR) 00931, " Hanger on Steam Generator Blown
= Piping - Spacing / Binding," Revision 1
~PMR 01666, " Steam Tunnel Fire Detectors Replacement," Revision 0 PMR 01952, " Safety Injection and Centrifugal Charging Pump Lube Oil Filter Gasket Material," Revision 0 PMR 0975, " Containment Temperature Monitoring System," Revisions 0 and 1 PMR 02391, " Exposure of Electrical Cables to Liquid Fluid," Revision 0-PMR 022343, " Main Steam Line Drains High Vibration," Revision 0 Temporary Modification Orders (TMO) 88-117-NK, " Jumper Cell 10 of Battery NK12" TM0 86-65-GK, " Compressor Heat Exchanger SK04A Gasket Material"
.TM0 87-006-BB, " Increase of the Instantaneous Trip Setting on MV Breakers NG01BBR3 and NG02DDF1 (PORV Block Valves)"
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Audit Report, TE:
50140-K211. " Modifications" (May 1988)-
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. Audit' Report, TE:
50140-K196, " Work Control" (March 1988)
' Audit Report,'TE: 50140-K222. " Plant Maintenance" (August 1988)
Surveillance Report, TE: 53359-S-1659, "' Redlining' Control Room Drawins."
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Surveillance Report, TE: 53359-S-1629, " Plant Modification Requests (PMRs)"
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Operations-Memo (OP 89-0029), "PORV-' Block Valves " dated February 14, 1989:
Plant Review Committee Meeting Minutes (No. 345, dated November 22,1988)
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ATTACHMENT 2'
' Documents-Reviewed
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M Policy.III.37.0, " Materials and Services Control," Revision:2
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. KGP-1250,1" Procurement," Revision 3 PCN 1 September 27, 1987
- PCN 2,. August 30, 1988 KP-2124 " Material Issue,"' Revision 1
..PCN 1, May 13, 1988
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.KP-2140, " Material.and Services Procurement," Revision 2 PCN 1. May.19, 1988.
PCN 2 July 6.-1988 PCN 3 August 24,-1988'
.ADM 01-048, " Material / Service Requisition," Revision 5-Au'dit Report, TE: ' 50140-K223,,' Procurement" (August 1988)1
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Audit Report. TE:
50140-K202, " Industry Technical Information Program (ITIP)"
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Audit Report. TE:
50140-K226,"MaterialsandParts"(September 1988)
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Surveillance Report, TE:- 53359-S-1708, "SGN01B Containment Cooler, Repair"
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Surveillance' Report,'TE:
53359-S-1682, "RHR HX 1A Gasket Replacement"
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(October 1988)
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Surveillance Report. TE:
53359-S-1674, "MFIV Rebuild EQ" (October'1988)
Surveillance Report, TE:
53359-8-1669, " Containment Integrated Leak Rate Test (CILP,T)" (October 1988)
IT1P Monthly Report for January 1989 (PS 89-0040)
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