IR 05000482/1989018
| ML20247J945 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 07/17/1989 |
| From: | Boardman J, Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20247J944 | List: |
| References | |
| 50-482-89-18, NUDOCS 8907310389 | |
| Download: ML20247J945 (15) | |
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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: 50-482/89-18 Operating License: NPF-42
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, Docket: 50-482
' Licensee: Wolf. Creek Nuclear Operating Corporation (WCNOC).
P.O..: Box 411 -
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Burlington, Kansas 66839
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Facility Name: Wolf. Creek Generating. Station (WCGS).
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J Inspection At: E WCGS, Burlington, Kansas Inspection Conducted: June.26-30, 1989 b-
~7[7/89 Inspector:
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-A-J.'R.~B6aTaman. Reactor Inspector..P1 ant Ddte Systems Section, Division of Reactor Safety-h-
Approved:
UM r/s7/sf T. F. Ttetka, Chief, Plant Systems Section D6te' ~
Division of Reactor Safety
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Inspection Summary
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Inspection Conducted June 26-50. 1989 (50-482/89-18)
Areas Inspected: Routine, announced inspection of the storage of emergency diesel-generator.(EDG) fuel oil (F0), containment building temperature profiles. Licensee Event Reports (LERs), the Justification for Continued
Operation (JCO) for~ Target Rock Valves, and action on previously identified
. inspection findings.
Results: Within the areas ~ inspected, no violations or' deviations were-p icentified. The licensee's present program for the control of EDG F0 appeared
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to meet regulatory requirements. Containment building temperatures appeared to be acceptable. The JC0 for the Target Rock solenoid valves was acceptable and provided ample justification' for facility operation.
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8907310389 890710 I
PDR ADOCK 05000482 g
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Persons Contacted-WCNOC-
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- F. T. Rhodes Vice: President, Engineering and Technical Services
- R. M.-Grant, Vice President, Quality Assurance (0A)
- J.'A. Bailey, Vice President, Operations G..D.'Boyer, Plant' Manager
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- R. W. Holloway, Manager, Maintenance and Modifications
- *0 L..Maynard, Manager of Regulatory Services
- B. McKinney, Manager, Operations
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- M. G. Williams, Manager, Plant Support
- K Peterson -Supervisor, Licensing t
- W. B. Norton, Manager, Technical Support
. C. W. Fowler, Manager, Instrumentation and Control (I&C)
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R. B. Flannigan' Manager, Nuclear Safety Engineering
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W. M. Lindsay, Manager', QA
'*R. S. Benedict, Manager,10uality Control (QC)
C. E. Parry, Manager Site Quality
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'.*W M. Lindsay, Supervisor, CA
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- J. A. Zell, Training Manager
- J. Pippin, Manaoer, Nuclear Plant Engineering (NPE)
A. Critchley, Supc Visor, Corporate Policies and Procedures
- S..Wideman, Licensing Specialist III"
- H. L. Stubby,' Supervisor Technical Training
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- T. F. Deddens, Jr..,0utage Manager
- J. H. Ziesenis, Supervisor, Chemistry:
- D. ' G. Moseby, Shift Supervisor, Operations '
- C. L. Palmer, Supervisor, Chemistry
' *J. Weeks, Shift Supervisor, Operations
- C. Sprout. Section Manager, NPE
- N. Hoadley, Manager NPE Systems
- R. L. Logsdon, Manager, Chemistry NRC Region IV Personnel
- T. F. Stetka, Chief Plant Systems Section
- B. Bartlett, Senior Resident Inspector
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- H. F. Bundy, Reactor Inspector The NRC inspe' tor also interviewed other licensee personnel during the c
inspection.
- Denotes'those persons attending the exit interview on June 30, 1989.
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?.- 'FollokuponPrevious'InspectionFindings (92701 and 92702)
a '. - '.(Closed) Violation (482/8821-02): This violation dealt with the
. failure of the licensee's personnel to. implement procedures. The NRC inspector reviewed the licensee's actions taken=to accomplish the'
i connitments made in response to this violation and found them to be acceptable.
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-(Closed) Violation.(482/8821-04): This violation dealt with the failure of the licensee's personnel to implement adequate corrective action. ' The specific example related to multiple actuations of the auxiliary feedwater system (AFW). The NRC inspector reviewed the licenwe's actions taken to accomplish the commitments made in response to this violation and found them to be
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' acceptable.
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(0 pen) Violation (482/8827-04): :This violation dealt with the failure of the licensee to include the compressed air system (CAS)
~ heck valves in'the WCGS check valve test program,- The licensee's c
connitment to incorporate the nitrogen and. instrument air check valves in'a testing program was verified. The 'icensee connitted to review similar components in other systems by December 29, 1989.
This item remains open pending the completion and NRC' verification of the licensee's remaining corrective actions.
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-(ClosediViolation(482/8817-02): This violation dealt with the failure of the licensee's personnel to maintain adequate records of postmodification testing (PMT). NRC inspection' report (IR) (50-482/88-23),
paragraph 2.1.21 reported that the licensee's corrective actions were acceptable. That report'left the violation.open pending the results
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of,the NRC maintenance team inspection. -The results of the team inspection,documentedinNRC1R(50-482/88-27), found the PMT
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. program to be acceptable.
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Based en the reviews discussed in NRC irs (50-482/88-23 and 50-482/88-27), this item is considered closed.
(0 pen)Violatio'n(482/8817-03): This violation dealt with the e.
failure of the licensee's personnel to take adequate and timely corrective actions for problems identified with the 'ontainment c
hydrogen analyzers. The licensee connitted to resolve the hardware problems by Refuel 4, which is tentatively scheduled for spring 1990.
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In addition, trending for surveillance activities was committed to be fully implemented by September 1989. While the licensee has made
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progress with respect to trending of surveillance activities, the activity is'not yet complete. This violation remains open pending completion and NRC verification of the licensee's corrective actions, f.
(Closed) Open Item (482/8827-03): This item addressed the establishment of a root cause task group by the licensee. Since this
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item was opened, the licensee has issued Procedure KGP 1212,
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Revision 0, " Hardware Failure Analysis Program" dated March 14, 1989.
Implementation of this procedure addresses the concerns of this item.
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(Closed) Violation (482/8824-01): This violation dealt with the failure of the licensee to take prompt corrective action. The specific examples dealt with failure of the licensee to identify the root cause of a feedwater valve failure, and to promptly~ change an operational procedure. The NRC inspector reviewed the licensee't actions taken to accomplish the corrective actions stated in response to this violation. Action on this item is considered to be i
complete.
(Closed)OpenItem(482/8827-05): This item related to the inclusion h..
of instrument. air sampling in 'the preventive maintenance (FM)
pregram. The licensee has issued Procedure.STN KA-001, " Air Quality Tt. sting," dated March 17, 1989, to incorporate air sampling in the
' surveillance program in lieu of the PM program. Action on inis item
is considered to.be complete.
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L(Closed)OpenItem'(432/8827-06): This item was open pending completion 'of a determination by the' licensee that the failure to use adequate electrical grounding during the performance of maintenance was an isolated instance..The licensee's determination concluded that the instance was limited to a single individual ano therefore was considered to be an isolated case.
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(0 pen)OpenItem(482/8827-07)': This item related to the issuance of aidance for the selection of electrical grounding devices. Such
guidance has not yet been issued. The licensee will issue this guidance by December 31.1989. - This item remains open pending issuance of tnis guidance.
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(Closed)OpenItem(482/8821-03): This item dealt with the lack of overall ~ controls for a required reading program for nonlicensed staff personnel. Subsequently, the licensee issued Procedure ADM 01-226
" Guidelines for Required Reading Programs," dated June 23, 1989.
Action on this item is considered to be complete.
3.
Storage of Emergency Diesel Generator Fuel Oil (25100)
The purpose of this inspection was to verify that the licensee had an adequate quality control program for emergency diesel generator fuel oil (EDG FO) that was maintained.onsite.
The specific attributes-reviewed included the following for which the responses are contained in Attachment 1:
The scope of the licensee's review of NRC Information
. Notice (IN) 87-04, ". Diesel Generator fails Test Because of Degraded fuel";
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The existence of a permanent EDG F0 storage tank recirculating
filtration system; The periodic cleaning of EDG F0 storage tanks; The use of fuel oil antioxidation and bacteriostatic additives;
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The tests performed for such contamination as presence of water,
oxidation products, and bacterial growth; The prompt removal of.. identified water contamination;
The periodic cleaning of strainers anc filters;
.The monitoring of fouling'and contamination;
The scmpling and testing of EDG F0; The use of duplex filters and strainers; and
The use of differential pressure indication for determination of
filter and strainer fouling.
Summary The :nspector*s review of this program included a review of Licensee Event Report (LER1 89-006-00. This LER identified a failure in the licensee's EDG F0 sample program to verify the cloud point in fuel oil semples as required by TS. 'The programmatic failure existed from April 14, 1986, to March 9, 1989, and was not identified during the licensee's review of NRC
I IN 87-04. The NRC inspector determined that the tests were performed by an outside laboratory prior to April 1986, however the licensee did not verify that these tests complied with TS. This issue will be followed by thc resident inspector as part of the close-out action for LER 89-006-00.
j The NRC insoector reviewed the licensee's problems-of high particulate in EDG F0. This review indicated that a similar problem had occurred at the Callaway Nuclear Plant. During April-May 1989, the NRC issued Inspection
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Report (IR) 50-482/89-09 for the Callaway Plant. This 1R states that "The historical sampling [of EDG F0] has shown that fuel begins to have a high particulate content within a two year time frame." The report indicated that Callaway empties and inspects the EDG F0 tanks during each refueling outage and that the EDG F0 is replaced at that time.
l Tne NRC inspector attempted to determine the different in EDG F0 particulate contamination between Callaway and WCGS.
icensee personnel stated that WCGS had experienced similar problems with particulate. By reducing the sample of EDG F0 tested f rom a quantity of approximately 1 gallon to'a quantity of I liter, the tests became acceptable. This sampling method is not prohibited by the ASTM standard or facility TS.
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The-licensee's procedures relating to the EDG F0 storage which were reviewed included the following:
- Title Document No.
Revision-Date I
Sampling of the
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Diesel: Fuel Tanker CHM 01-198
05/05/89 Emergency Diesel New Fuel STS CH-015
04/06/89 Emergency Diesel fuel Storage Tank STS CH-008A & B
03/28/89 n
Diesel Generator NE01 Day Tank Water Removal STS JE-003A
07/30/85
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Diesel Generator NE02 Day Tank Water Removal STS JE-003B
07/30/85 Standby Diesel Storage Tanks Drain and Clean STS MT-017
07/28/88 Diesel Fuel Particulate Analysis CHM 02-425
03/17/88 Determination of Water and Sediment in Oil (Centrifuge Method)
CHM 02-421
03/13/87 Determination of Flash Point CHM 02-424
03/13/87 Determination of Kinematic Viscosity of Liquid Petroleum Products CHM 02-440
02/08/89 Clear and Bright CHM 02-423
03/13/87 The licensee's present program for EDG F0 appears to meet NRC regulations and commitments.
i No violations or devios. ions were identified.
4.
Information on Containment Temperature (TI 2515/98)
The purpose of this inspection was to obtain containment average ambient operating temperature profiles for WCGS to detemine its effect on the environmental qualification of equipment, and in particular, electrical I
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The' catalyst component of the 2-part silicone potting compound.
- N The. failure mode was independent-of the environment. Failure had occurred
"in valves and assemblies installed in plants and stored in warehouses.
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An additional' problem, reported as being minor, was the~ cracking of' valve wiring teminal blocks, apparently from the overtightening of terminal lugs..
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K These problems are discusse' in a Nuclear Utility Group on equipment d-
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Qualification.(NUGEQ) memorandum dated March 29, 1989. Neither this L.., *.
-conditions are safety concerns. Modification kits have been assembled to memorandum, nor TR technical data, indicated that the. identified-correct the cracking of. insulation cnd terminal blocks, g
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The bases for the lC0 were:
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There were no examples of cracked silicone insulation at WCGS. This
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activities and of spare assemblies in the warehouse.
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included examination of installed valves during maintenance
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0f-the 20 valves, none are considered for accident mitigation in the
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. Updated Safety Analysis Report (USAR).
Fourteen valves are
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referenced in.the WCGS Emergency Operating Procedures (EOPs), however ul'
'their failure will not prevent mitigation of an accident situation.
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The valves are sealed with.CONAX seals to prevent postaccident moisture intrusion. As a result, cracked insulation or terminal blocks, should
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.not affect valve operation.
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Refurbishment kits to correct the identified problems will be
installed in affected valves during the next refueling outage. The kits will contain the following parts:
Solenoid and reed switch assemblies having Kapton insulated lead
wires;
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Kulka terminaf blocks, and
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Bonnet 0-ring and solenoid cover gasket.
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This item will be reviewed following refurbishment of the valves.
' Inspector Followup Item (482/8918-01): Review the completed refurbishment
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of these valves.
7.
Review of 10 CFR Part 21 Reports (30100)
The NRC inspector reviewed evaluations performed by the licensee for deviations, conoitions, or circumstances identified by users, vendors. or suppliers as required by 10 CFR Part 21. The evaluations were performed l
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'to determine the applicability of the identified problem to the safe
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operation of the facility. The evaluations reviewed by the NkC inspector are listed below.
Part 21 Report 86-07. This Part 21 report covered a September 17, 1986,' letter from Validyne Engineering relating to transducers.
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Validyne Engineering issued a supplemental letter on the same subject.
dated October 16, 1986. This~ letter became WCGS Part 21 Report P7-010.
WCGS Part 21 87-010 was closed in NRC.IR 88-19.
Based on the closure of Part 21 Report 87.-010. Part 21 Report 86-07 is considered closed.
l Part 21 Report 86-09. This Part 21 report dealt with the failure of springs in Valcor solenoid valves. The licensee's Plant Modification Request (PMR) 1844 has replaced all required springs in affected Valcor valves during the last regularly scheduled PM for each valve.
Part 21 Report 86-09 is considered closed.
The NRC inspector reviewed the actions taken by the licensee in response to the notifications provided by the vendors. Based on tris review, it appeared that the licensee had taken appropriate actions.
No violations or deviations were identified.
8.
Exit Interview An exit meeting was held on June 30. 1989, with those individuals denoted
,in paragraph 1.of this report. At this meeting, the scope of the inspection and the findings were summarized. The licensee did not identify as proprietary any of the information provided to, or reviewed by the NRC inspector.
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' ATTACHMENT l'
. SURVEY.-OF LICENSEE'S RESULTS TO
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SELECTED EDG F0 ISSUES iPl' nt.'Name:
- Wolf Creek Generating St' tion (WCGS)
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Docket Number:
50-482
? Inspector:
J. R. Boardman
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Hitsthelicenseeadequatelyreviewedandevaluated'NRCInformation Notice (IN) 87-04, issued on-January 16, 1987, as a result'of,the ANO Unit
'2. Emergency Diesel Generator l(EDG) fuel oil-(F0) starvation event which occurred on June 27, 19867.'
H Review of IN 87-04'is documented'in the licensee's Industry-Technical-
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Information Review and Evaluation (ITIP):00250, dated February 9,1987.
This ITIP adequately ad6resses the' cleaning of the installed <EDG F0 system
. filters. The ITIP also addresses periodic sampling'of the EDG F0 storage.
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tar,ks.
2.
Does the licensee have a permanent F0 storage tank recirculation system-
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- refueling outage.to remove' accumulated particulate?
No'.
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Are all F0 storage tanks being cleaned and inspected at a minimum of
10-year: intervals in accordance with Regulatory Guide 1.1377 l
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Technical Specification (TS) 4.8.1.1.2.1. requires the draining, cleaning, l
and testing of the storage tanks at least once every 10 years. The first
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10-year interval 4has not been completed, i
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Does the licensee's F0 program include a regular analysis of F0 semples and bottom testing for accumulated water, at the lowest point in the F0 day tanks and F0 storage tanks?
TS 4.8.1.1.2.b. requires that at least once every 31 days and after each
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operation of the diesel where the period of operation'is greater than, or
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equal to, I bour a check be made of the diesel oil feed tanks.for water. Accumulated water shall be removed. In addition TS 4.8.1.1.2.c.
requires that at?least once every 31 days the F0 storage tanks be
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checked for accumulated water, and that the water be' removed.,
j LER 89-008-00 documents a one-time failure to make a check of a EDG day tank following EDG operation longer than an hour. The failure resulted
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operator. error. The corrective action included procedure revisions and written management emphasis.
5.
Is a fuel additive being used as a fuel stabilizer which will function to prevent oxidation and bacterial growth?
No, nor are such additives specified in the purchase order for EDG F0.
6.
Does the licensee effectively ensure that periodic F0 bottom sampling and l
analysis are being performed to detect high particulate concentrations in
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the F0 supply which occurs over long-term storage due to the effects of oxidation, and biological contamination in accordance with ASTM D270-19757 No. The licensee's sampling complies with TS 4.8.1.1.2.e.
This requires at least once every 31 days that a F0 sample be obtained in accordance with ASTM-D2276-78. The sample shall be tested in accordance with ASTM-D2276-78, Methed A, to verify that the total particulate contamination is less than 10mg/lfter.
7.
Are. day tanks and integral tanks being checked for. water monthly, as a minimum, ano after each operation of the diesel where the period of operation was I hour or longer?
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P16ase see the response to 4. above.
8.
Is accumulated water removed immediately if it is determined that water is present in the storage, integral, or day tanks?
The removal of water is in the licensee's procedures.
Please see the response to 4. above.
9.
Is the licensee replacing F0 in a short period of time (about a week), if it is determined that the F0 does not meet the applicable specifications?
No. There is no TS which requires initiation of corrective action within a specified time to return the fuel supply to acceptable limits.
The licensee's personnel stated that no stored EDG FO has been determined to be non-conforming, except for the following cases:
Licensee Event Report (LER) 50-482/8906-00, dated March 8, 1989,
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identified that the licensee had failed to perform, or have performed, the cloud point analysis required by TS 4.8.1.1.2.d.2.
from April 14, 1986, to March 9, 1989. The licensee performed the cloud point test and declared the EDG F0 acceptable.
The periodic tests for particulate performed on the fuel storage tank for EDG B, were determined to be unacceptably high on May 19, 1988, and June 19, 1988. The licensee's personnel stated that, in each case, they recirculated the FO back to the EDG F0 storage tank until an acceptable level of particulate was obtained.
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F0 purification resulted from the_ F0 passing through the in-line strainers between;the F0 storage tank and the day tank during recirculation.
n 10. Are F0 components which may be prone to fouling being routinely monitored for indications'of fouling?
High differential pressures (DPs) for the EDG F0 system parallel strainers
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between the EDG F0 storage tank and the day, tank, are alarmed in the control room with their own indication. They also have local indication.
The FO duplex strainer and filter provided'with the EDG, have high,DPs as an input to'the Master Diesel Generator Trouble Alarm in the control room.
These signals also have local indication.
.11.. Are F0 filters and strainers being cleaned and inspected on a periodic basis per the vendor recommendations?
EDG F0 filters.and. strainers supplied by the EDG manufacturer are cleaned (or the elements replaced) and inspected annually. The vendor recommendations for cleaning, or element replacement are based on values-of DP;across the filters or strainers.- Licensee personnel stated-that these DPs are checked during each operation of the EDGs, and that the appropriate maintenance would be performed before DPs exceeded the manufacturer's values given in the EDG technical manual (TM). Other strainers are located between the F0 storage tanks and the day tanks.
These strainers are cleaned during every refueling outage. All filters and strainers are ' duplex, or are in pairs, and arranged so that only one filter,:or strainer, is on-line at a time. The other strainer is in reserve and isolated.
12._ Does the F0 system utilize dual element filters and strainers which permits on line cleaning of the elements, in the event of fouling, to allow continuous operation of the EDG7 Yes. See 11. above. The duplex filters and strainers cannot be improperly aligned by valve manipulation to place both units in an assembly in operation at the same time.
j 13.
Is there a differential pressure indicator'for each duplex filter strainer for indication of fouling in accordance with ANSI N195-19767 Triere is differential pressure indication as discussed in q)uestion 10 above. Based on the Unpdated Safety Analysis Report (USAR Table 9.5.4.3, and discussions with the licensee's personnel, ANSI N195-1976 is incorpo ated in the design of the EDG F0 system and associated systems.
14. Are F0 alarms annunciated in the main control room or incorporated into a general control room trouble alarm with local individual alarms,-in accordance with ANSI N195-19767
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See question 10 above for local and remote indications. The licensee's -
personnel confirmed compliance with ANSI N195-1976.
15. Are any of the instruments that perform a control function and provide an alarm seismically qualified in accordance with the IEEE Recommended Practices for seismic qualification of Class 1E Equipment for Nuclear Power Generating Stations, IEEE 344-19757 The licensee's personnel stated that the instruments are seismically qualified.
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ATTACHMENT 2 i-1.
Plant Name:
Wolf Creek Generating Station 2.-
Docket Number:
50-482 3.
What are the average containment temperatures during power operation as recorded by the licensee?
The following data are the average of the Reactor Containment Building (RCB)
temperature readings (in degrees Fahrenheit) (*F) made during the summer of 1987 at the inlet of the containment cooling units to determine compliance with the Technical Specifications (TS). Thir data is based on readings for the highest 3 days of each month:
1987 April May June July August September 91.4 97.7 98.4 101 102.6 93.7 4.
Containment temperature at which the plant is licensed to operate (i.e.,
operating temperature specified in the FSAR),
Based on the WCGS Updated Safety Analysis Report (USAR), Table 3.11(B)-1, and TS 3.6.1.5, the containment temperature at which the plant is licensed to operate is 120 F average, with 150 F.in the reactor cavity.
5.
Review the temperature readirgs and provide your assessment as to whether nr not you believe the average temperature readings accurately reflect containment conditions, or if there is a significant difference, due to sensor location or stratification of containment atmosphere which could produce hot spots.
l The temperature readings are as prescribed by TS 3.6.1.5., which states that the containment air temperature, as measured at the inlet to the containment air coolers shall not exceed 120 F.
Without knowing the flow of. containment cooling air throughout the containment, and localized heat sources, determination of a comprehensive containment I
temperature profile does not appear to be practical without the use of thermography.
6.
What temperature (s) is used by the licensee in its equipment environmental qualification program when calculating the remaining qualified lifetime for all equipment inside containment, and are these temperatures j
consistent with temperatures being experienced?
l The temperature used is 120 F.
The temperatures recorded to date have I
been less than this value (see answer to question 3).
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A' administrative temperature limit for the containment, if no technical l
specification limit exists?
Not applicable.. There is a TS limit.
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Recent history of temperatures inside containment. Provide containment
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average air temperature in addition to the containment air temperatures used to compute the average air temperatures for the morths of April, May, June, July, August, and September 1987.
See the response to questior. 3. abovt.
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