IR 05000482/1989023

Insp Rept 50-482/89-23 on 890801-31.Violation Noted.Major Areas Inspected:Plant Status,Onsite Followup of Events at Operating Power Reactors,Operational Safety Verification, Monthly Surveillance & Maint Observation & Part 21 Repts

ML20247K073
Person / Time
Site:	Wolf Creek
Issue date:	09/14/1989
From:	Holler E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20247K055	List: IR 05000482/1989023 ML20247K050
References
50-482-89-23, NUDOCS 8909210061
Download: ML20247K073 (15)

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. .'p,. APPENDIX L U.S. NUCLEAR REGULATORY COMMISSION REGION IV-

, -NRC Inspection Report: 50-482/89-23 Operatin'g License: NPF-42 Docket: 50-482 i

Licensee: Wolf Creek. Nuclear Operating Corporation (WCNOC)

A P.O. Box 411'

Burlington, Kansas 66839-

. Facility Name: WolfCreekGeneratingStation(WCGS)

. Inspection At: WCGS,' Coffey County, Burlington, Kansas Inspection Conducted: August 1-31, 1989

. Inspectors:- B. L. Bartlett, Senior Resident Inspector Project Section D Division of Reactor Projects M. E. Skow, Resident Inspector Project Section D. Division of Reactor Projects D. M. Hunnicutt, Senior _ Project Engineer Project Section D, Division of Reactor Projects D. V. Pickett, Project Manager Office of Nuclear. Reactor Regulation i

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E. J. Holler, Chief Date Division of Reacti>r'fProjects Project Section D, Inspection Summary Inspection Conducted August I-31,1989 (Report 50-482/89-23)

Areas. Inspected: Routine, unannounced inspection including plant status, onsite followup of events at operating power reactors, operational safety verification, monthly surveillance observation, monthly maintenance

-' observation,10 CFR Pcrt 21 report followup, followup on previously identified NRCitems,andbalanceofplant(BOP).

Results: A violation was noted, for which a citation will not be issued, regarding a licensee reported missed surveillance requirement and failure to enter Technical Specification (TS) 3.0.3 (paragraph 3). The licensee has discovered a conservative error in reactor power indication (paragraph 4),

performance of maintenance and surveillance activities was satisfactory (paragraphs 5 and 6), the licensee's predictive maintenance program identified hot connections on the main transformers (paragraph 6), and drawing discrepancies were found during a B0P inspection (paragraph 9).

8909210061 890914 PDR ADOCK 05000482 Q PDC

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-2-l DETAILS Persons ~ Contacted Principal Licensee Personnel B. Withers, President and CEO F. T. Rhodes, Vice President, Engineering and Technical Services

• R. M. Grant, Vice President, Quality Assurance (QA)

• J. A. Bailey, Vice President, Operations

• G. D. Boyer, Plant Manager _

R. W. Holloway, Manager, Maintenance and Modifications

• 0. L. Maynard, Manager, Regulatory Services B. McKinney, Manager, Operations

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• M. G. Williams, Manager, Plant Support

• C. E. . Parry, Manager. QA, WCGS

• K. Peterson, Supervisor, Licensing G. Pendergrass, Licensing

• G. Norton, Manager, Technical . Support C. W. Fowler, Manager, Instrumentation and Control (I&C)

• R. B. Flannigan, Manager, Nuclear Safety Engineering

• R. S. Benedict, Manager, Quality Control (QC)

• W. M. Lindsay, Supervisor, QA

• J. A. Zell, Manager, Training

• R. Wright, QA Audit Supervisor t *D. Moseby, Operations Supervisor

• R. Sims, Supervisor, Equipment Engineering

• S. Walgreen Supervising Operator J. Pippin, Manager, NPE

• S. Wideman, Licensing Specialist III C. Sprout, Section Manager, NPE N. Hoadley, Manager, NPE Systems The inspectors also contacted other members of the licensee's staff during the inspection period'to discuss identified issue * Denotes those personnel in attendance at the exit meeting held on September 1, 198 . Plant Status The plant operated in Mode 1 (100 percent reactor thermal power) during the inspection period. There were no reactor or turbine trip . Onsite Followup of Events at Operating Power Reactors (93702)

The purpose of this inspection activity was to provide onsite ir.spection of events at operating power reactors. Specific inspection activities included:

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-3-p-o Observing plantistatu ?o Evaluating the significance of the events, performance ofLsafety systems, and actions taken by the license Confirming that the licensee has Fade proper notification of the

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o events and of any new developments or significant changes in plant conditions;

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-o Evaluating the need for further or continued NRC response to the

. event The following items were considered during the followup:

o~ Details regarding the~cause of the event, o : Event chronolog o Functioning of safety systems as required by plant condition ,

o Radiological' consequences and personnel exposur Proposed licensee actions to~ correct the cause of the even o -Corrective. actions taken or planned prior to resumption of facility

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operation Selected events requiring.LERs that occurred during this report period are listed,in'the table below:

Date Event * Plant Status Ca,use 8/9/89 Missed SR Mode 1 Personnel error (100 Percent)

8/30/89 CRVIS Actuation Mode 1 Spike on GK AI-3 (100 Percent)

• Event SR - TS surveillance requirement CRVIS '- Control room ventilation isolation system The inspectors will review the LERs for these events and will report any findings in a subsequent inspection repor Selected inspector observations regarding other events are discussed below:

o On July 10, 1989, the inspectors observed an entry in the shif t supervisor's log that Surveillance Test STS 1C-2118 had been missed and was overdue July 3, 1989. This is a 62-day surveillance en the

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"B" reactor trip breaker. The licensee entered TS Limiting Condition for Operation (LCO) 3.3.1, Table 3.1-1, Action Statements 9,10, and 12. The licensee promptly declared the breaker inoperable and performed the surveillance. The surveillance resulted in a finding that the brer :er functioned properly. During further review of the event, the licensee considered that they should also have entered TS LC0 3. That LCO requires that when an LC0 and its associated action statements are not met, the licensee shall initiate action within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit in a condition in which the TS does not apply. In this case, the applicable conditions would be hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The licensee then made a 1-hour notification to the NRC indicating that they should have been in TS 3.0.3. This was because the bases section of the TS for LC0 4.0.3, which describes actions on failure to perform a surveillance requirement within the specified time interval, states that action statements are entered when the surveillance requirements should have been performed rather than at the time it is discovered that the tests were not performed. The surveillance was missed due to a scheduling error in June 1989. The STS was not placed on the appropriate schedul The licensee did not identify this scheduling error until the next schedule was being prepare The inspectors reminded the licensee that Generic Letter 87-09 offers licensees an opportunity to request a change to the TS that would j change the time that equipment is considered inoperable following a missed surveillance. The generic letter change would allow equipment to be declared inoperable when it was discovered that the surveillance was missed vice the date in which it became overdue. Had this change been incorporated, the licensee would not have needed to enter TS 3.0.3. Failure to perform the surveillance test on schedule and enter TS 3.0.3 after discovery is an apparent violation. This licensee identified violation (482/8923-01) will not be cited because the criteria specified in Section V.G.1 of the General Statement of Policy and Procedure for NRC Enforcement Actions were satisfied. No written response to this violation is required.

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No other violations or deviations were identifie . Operational Safety Verification (71707)

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The purpose of this inspection area was to ensure that the facility was l being operated safely and in conformance with license and regulatory requirement It also was to ensure that the licensee's management control system was effectively discharging its responsibilities for continued safe operation. The methods used to perform this inspection included direct observation of activities and equipment, tours of the facility, interviews and discussions with licensee personnel, independent verification of safety system status and limiting conditions for operation, corrective actions, and review of facility records.

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Areas reviewed curing this inspection included, but were not limited to, l control room activities, re atine surveillance, engineered safety feature j operability, radiation pro.ection controls, fire protection, security, l plant cleanliness, instrumentation and alarms, deficiency reports, and I corrective action Routine surveillance and operating activities witnessed and/or reviewed by the inspector are listed below:

o The licensee noted that plant electric output was running about 1,-15 megawatts electric (MWe) less thu the production rate f this time last year. The licensee believes that a small leak in the 7A Feedwater Heater Baffle Plate accounts for some of the deficienc Feedwater temperatures are about 4*F cooler than at similar lake temperatures last year. However, the licensee does not believe this accounts for the entire decrease in electric output. At the end of this inspection period, the licenser. was also evaluating the possibility of venturi fouling of feed-flow detectors. The fouling would cause indicated feedwater flow to be higher than actual feedwater flow. Feedwater flow is an input into the calorimetric calculation used to verify and adjust reactor power instrument With indicated feedwater flow higher than actual flow, indicated reactor power would be higher than actual reactor powe No violations or deviations were identifie . Monthly Surveillance Observation (61726)

The purpose of this inspection was to ascertain whether surveillance of safety-significant systems and components was being conducted in accordancewithTechnicalSpecifications(TS). Methods used to perform this inspection included direct observation of licensee activities and review of record Items inspected in this area included, but were not limited to, verification that:

o Testing was accomplished by qualified personnel in accordance with an approved test procedur o The surveillance procedure was in conformance with TS requirement o The operating system and test instrumentation was within its current calibration cycl o Required administrative approvals and clearances were obtained prior to initiating the tes o Limiting conditions for operation were met and the system was properly returned to servic ________ ___________ -

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-o The test data were accurate and complete and the test results met TS requirement Surveillance witnessed and/or reviewed by the inspectors are listed below:

o STS PE-054 Revision ~ 1, " Flow Rate Verification of Fans with Monitored Exhausts," performed August 9, 1989 o STS AC-001, Revision 5, " Main Turbine Valve Cycling Test," performed August 23, 1989 o STS IC-913, Revision 4, " Containment Hydrogen Analyzer GS-065B Calibration Test," performed August 17, 1989 o' STS IC-480A, Revision 4, " Channel Cal-CRTL RM Vent CL DET-Train 'A',"

performed August 30, 1989 o STS SP-001, Revision 9, " Process Radiation Monitoring System Source Check and Valve Stroke," performed August 31, 1989 The surveillance procedures that were observed, appeared to be performed by knowledgeable personnel in accordance with procedures. Test performers were careful to monitor the effect of STS AC-001 on plant operatio While performance of surveillance appeared satisfactory, the licensee identified a missed surveillance. This is discussed in paragraph 3 above as an onsite e,ent followu No violations or deviations were identifie . Monthly Maintenance Observation (62703)

The purpose of inspections in this area was to ascertain that maintenance activities on safety-related systems and components were conducted in accordance with approved procedures and TS. Methods used in this inspection included direct observation, personnel interviews, and records revie Items verified in this inspection included:

o Activities did not violate limiting conditions for operation and redundant components were operable, o Required administrative approvals and clearances were obtained before initiating wor o Radiological controls were properly implemente o Fire prevention controls were implemented.

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I Required alignments and surveillance to verify postmaintenance

. operability were performe o' Replacement parts and materials used were properly certifie o Craftsmen were qualified to accomplish the designated task and additional technical expertise was made available when neede o Quality' control hold points and/or checklists were used and quality control. personnel observed designated work activities, o Procedures used were. adequate.. approved, and.up to date.

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Portions of selected maintenance activities regarding the work'

requests (WRs) listed below were observed. The WRs and related documents-were reviewed by.the inspectors:

N Activity WR 05998-88 Component Cooling Water Pump C inboard seal leaking

'WR 01393-89 Valve BG V013 leaks.by WR 02045-89 Valve BG V569 leaks by WR 03321-89 Infrared scan of electrical equipment WR 02317-89 SGK05A leaking Freon at elbow fitting connection WR 03869-89 Chlorir,e Monitor GK AI-3 reads high-Selected inspector observations are discussed below:

o The inspector observed the licensee conducting an infrared scan of electrical equipment. Portions observed included the Class IE 4160v switchgear and motor control centers in the diesel generator room The scan was to look for connections, transformers, breakers, and other components that may have been operating at higher than expected temperatures. This predictive maintenance identifies areas of high temperature and provides the licensee an opportunity to anticipate equipment failures. No significant high temperatures were found on safety-related equipment. The inspector considered use of this technique a strength in the area of electrical maintenanc The infrared scan showed some hot connections on the "A" and "B" phase main transformers. The temperatures were high enough to cause the licensee to evaluate the significance of the ter.iperatu*es and what risks, if any, these temperatures posed to personnel and the transformers. The licensee subsequently has performed additional

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' scans of the connections and begun to trend these temperatures. The temperatures have been fairly stable with some daily fluctuation If the temperatures begin an upward trend, the licensee plans to enter an outage to make repair The other observed maintenance activities were corrective maintenance. These activities were performed in accordance with procedure, appropriate fire impairment permits, radiological controls, and work control No violations or deviations were identifie . 10 CFR Part 21 Report Followup (36100)

(Closed) 10 CFR Part 21, "HFA Auxiliary Relays - Latch Engagement Was Less Than the Recommended Minimum" - Three models (HFA1518, HFA154B, and HFA154E) of the "HFA" auxiliary relays manufactured and qualified to Institute of Electrical and Electronics Engineers, Inc., (IEEE) IEEE-323 (IEEE Standard for Qualifying Class IE Equipment for Nuclear Power Generating Stations) by General Electric Company (GE) were reported to provide insufficient latch engagement. The manufacturer indicated to the licensee (Relay and Accessory Service Letter, No.190.1, November 16, 1987) that some of these "HFA" relays, when continuously energized for

- long periods, have failed to change contact state when subsequently deenergized. The manufacturer's letter stated that if there was insufficient clearance between the top of the relay armature and the top ,

of the molded moving contact carrier, the mechanical latch could be prevented from reaching the minimum 1/32-inch engagement. Also, insufficient tension by the formed leaf spring that rotates the latch to its fully engaged position could permit the spring to relax before full engagement between the latch and armsture was achieve The licensee's investigation determined that the plant has five Model N HFA151A2H nonsafety-related relays and (non-Class 1E)one Model No.One applications. 12HFA65D62H relay relay (installed in12HF used as a spare in Charger NK25 and is not normally energized; however, NK25 has the potential to be placed in service at any time and, therefore, was included in the list. Three relays (12HFA151A2H) are not presently utilized. One relay (12HFA151A2H) is used as a permissive in the closing circuit of a breaker control scheme for certain tie breakers. One relay (12HFA65D62H) provides undervoltage annunciation input for certain DC buse In addition, Spare Parts Purchase Orders SPE-017(Q) and SPE-020/053(Q) were reviewed by licensee engineering and found to include HFA relays purchased from GE. Eight spare "HFA" relays were located in the warehouse stock. These eight relays were identified by specification, vendor, material code, purchase order number, and part number. None of these eight GE "HFA" relays were designated for use in safety-related (Class 1E applications) systems. The licensee has not stored any GE "HFA" relays in the warehouse that require action or replacement due to this 10 CFR Part 21 repor r ,

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No violations or deviations were identified. The inspector's review of'

' the licensee's actions indicated appropriate corrective actions had been

'taken.: This item is. close . Followup on Previously Identified NRC Items Open Items and Unresolved Items (92701)~

(Closed)OpenItem(482/8813-03): Emergency Lighting - Local battery operated lights were not available in necessary areas (e.g., mezzanine levels of north / south mechanical penetration room, purge valves, and auxiliary feedwater (AFW) isolation valves area of Area 5). The licensee procured six battery operated lights for operator us The inspector observed that two of the light units were available in each of the following: (1) the AFW pump room emergenc (2) auxiliary shutdown panel emergency locker, andcontrol (3)y locker, room ventilation Room "B" emergency locker. These lights were added to the appropriate inventory sheet in Procedure STN GP-009, " Emergency Radio and Equipment Check and Inventory," Revision 8.. In addition, a glow-type paint was applied to the outside purge valve position indicators. " Paint glow" enhances the operator's ability to locate the position indicators. This item is close (Closed)UnresolvedItem(482/8807-31): Temporary Modification (TMO)87-120 GK - This modification clamped the Train "A" control room emergency ventilation system (CREVS) supply damper in the open, actuated position in response to several failures

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of the actuating linkage. The CREVS is designed to control the level l

of airborne contamination in the control room atmosphere and to control the temperature and humidity for personnel safety and comfort. The safety systems outage modifications inspection (SSOMI)

team determined that the licensee had not adequately determined whether the system remained operable and capable of pressurizing the control room as required by TS 3/4. The inspector determined that the licensee had completed the following: (NOTE: For clarification, each SSOMI concern is stated above the corresponding licensee's corrective actions description.)

o The licensee had not performed a calculation or a functional test to demonstrate the ability of the Train "B" CRVIS to maintain the required control room pressure in this degraded mod The licensee performed a review of USAR Chapter 15 analysis to demonstrate the ability of the Train "B" CRVIS to maintain the required control room pressure with the CREVS supply damper clamped in the open position. The review verified that no bypass pathways exist for unfiltered air to enter the control room. The licensee determined that preventing a damper to go

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closed upon occurrence of an_ active failure did not put the system outside of previously analyzed system failure ,

o Even though the operator actions did not meet single failure

' design requirements, the specified operator actions would not be sufficiently responsive when considering the design requiremen of the CRVIS to maintain a positive pressure in the control room in the event of radiation or gas in the air intake The capability of. maintaining the control room with a positive pressure of 1/4-inch water gage was not degraded by having the isolation damper blocked open. This is-the normal position of this damper during CRVIS actuation. If the CREVS becomes inoperable during a CRVIS, operator action must be taken to manually'close the damper to ensure that a positive pressure of at least 1/4-inch water gage is achieved. Removal of the power to the damper's operator and blocking the damper _ open does not compromise the capability to perform the necessary operator action. Therefore, the necessary operator actions would be sufficiently responsive when 16:e design requirements of the CRVIS are considered.

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o The licensee failed to recognize that additional testing or calculations were necessary to verify that the system remained

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operable with the temporary modification implemente The licensee detemined that preventing a damper to go closed upon occurrence of an active failure did not put the system outside of previously analyzed system failures because other limiting failures would exist. The condition described in the 10 CFR 50.59 safety evaluation was not deficient in that the candition described in the evaluation was bounded by the analysis presented in USAR Chapter 15. Damper replacement parts were installed and the CRVIS system was restored to normal operation on November 26, 198 o Appropriate corrective action in preventing repeated damper failure was not take The licensee has evaluated the identified damper failures, mechanical problems and maintenance work, and rework associated with the dampers. This review identified that four dampers / actuators were reworked (some machining on couplings)

during 1984. Two dampers / actuators were replaced in 1985 due to the actuators being jammed. In 1987, three failures occurred which required replacement of the actuators. The licensee had discussions with the vendor representative. The representative indicated that these f ailures could be attributed to a misalignment of the coupling and the saddle when blocking the I

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-11-dampers open or closed. The vendor subsequently provided appropriate tolerances and coupling clearances to ensure proper coupling alignmen o The licensee had not identified the above failure as potentially reportable nor evaluated the failures for deportabilit The licensee initiated Defect Deficiency Report (DDR)87-122 on November 17, 1987, and performed an evaluation of deportability pursuant to 10 CFR Part 21. The licensee concluded that this deficiency was not reportable under the requirements stated in 10 CFR Part 21 because no deviation existed and no condition or circumstance that could contribute to exceeding TS because of a '

failure of the control room heating, ventilation, and air conditioning (HVAC) damper was identifie The licensee had adequately addressed each of the above. The inspector had no questions. Five of the six items comprising this unresolved item are closed. The remaining item is assigned a new tracking numbe (0 pen) Unresolved Item (482/8923-01): TM0 87-120 GK - The need for operator action to meet single failure design of a safety system does not conform to the requirements of 10 CFR Part 50, Appendix A. The second of the six items that comprised Unresolved Item 482/8907-31 remains unresolved pending further review by the inspector and has been assigned a new tracking number. (482/8923-01)

b. Violations and Deviations (92702)

(Closed) Viclation (482/8819-01): Fire Doors Inoperable - Fire Doors 13261 and 13281 were observed to be standing open. Neither fire protection impairment control permits nor log entries had been completed for the door The licensee's corrective actions included: (1) revising Procedure ADM 13-103, " Fire Protection Impairment Control." to clearly identify the requirement for obtaining a fire impairment permit any time a fire door is to be left open; (2) the procedure change to ADM 13-103 was placed in operations as required Reading Entry No.88-160; and (3) the operations supervisor instructed all operations personnel by interoffice correspondence (OP 88-0145,

" Impairments On Open Doors," July 12,1988) of the requirement to issue a fire impairment and establish a fire watch, as required, vnenever any fire door is left open for any reason, except normal passage. The inspector reviewed the licensee's corrective actions and determined that these actions were adequate. This item is closed.

l (Closed) Violation (482/8830-01): Failure to Comply With TS Action Statement - With the plant in Mode 6 and less than 23 feet of water f

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-12-above the reactor vessel flange, one diesel was not' maintained L, operable as required by TS. With the "A" diesel inoperable, the licensee initiated maintenance on the 'B" diesel which rendered it inoperable. The maintenance was performed on equipment which was not required for the emergency function of the diese The licensee's corrective actions included issuance of Standing Order No.13 " Discussion of General Operation Philosophy Regarding Plant Evolutions," Revision 1, dated January 6,1989, to operations personnel. The plant manager issued guidance (Interoffice Correspondence, " Guidelines for Entry Into Tech Spec Action Statements," dated January 6,1989), to the " Call Superintendents" requiring contact with the NRC before voluntarily entering a TS action statement which requires immediate action to restore. The inspector reviewed the licensee's corrective actions and determined that these actions were adequate. This item is close (Closed) Violation (482/8837-01): Failure to Maintain One Boron Flow Path Operable - This item was also reported by the licensee as Licensee Event Report (LER)88-025. The LER was closed in NRC Inspection Report 50-482/89-015. Both the LER and the corrective action discussed in the licensee's response to the violation in a letter to the NRC dated January 23, 1989, were similar. In those documents, the licensee stated that a checklist that specifies a-list of major equipment relied'upon to maintain an operable boron flow path was developed. The special plant configuration checklists were found in the control room. The licensee further stated in the LER and violation response that the checklist ". . . will be used by operations personnel as an aid in verifying . . ." TS complianc However, Procedure ADM 02-312, Revision 4, " Mode Change Checklist and Surveillance Tracking Program," states that the checklists ". . . are available for use by'the shift supervisor, if desired, as an aid for ensuring proper equipment availability . . . ." When this was discussed with the licensee, a change to ADM 02-312 was promptly issued that deleted the words "if desired." This violation is close !

(Closed) Violation (482/8837-02): Failure to Follow a Temporary Procedure for Refill of'the Refueling Cavity - The operator fully openea Accumulator Isolation Valve EP HIS-8808B from the control room instead of closing the valve as required by Temporary l Procedure TPOP-126, " Refill of Refueling Cavity, Fuel Off Loaded,"

' Revision 0, Step 4.2. (NOTE: There was no irradiated fuel in the l reactor vessel when this error occurred).

The licensee assigned an incident investigation team to review and evaluate the improper operation of Valve EP HIS-8808B. The team determined (Final Report on Containment Event of November 21, 1988,

-Incident Investigation 88-02) that the operating crew had not fully

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-13-complied with the appropriate procedural steps. The team also identified a weakness in the procedure and a need for additional

- training on the reading of control. room drawing The licensee's corrective actions included: (1) a review and

revision (No. 38, to provide more specific guidance on writing

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temporary procedures and to require an independent review of temporary procedures prior to approval) of Procedure ADM 07-100,

" Preparation, Review, Approval, and Distribution of WCGS Procedures;"

(2) the operating crew was counseled; (3) meetings were held with operations personnel to discuss the event and reiterate the need for a more conservative approach to problem solving in day-to-day operations; (4) Standing Order No.13. " Discussion of General Operating Philosophies Regarding Plant Evolutions," Revision 1, was issued to emphasize management's philosophies regarding plant evolutions, particularly inf regoently performed evolutions; and (5) training was provided on reading of control room drawings (trainingidentification-No. 1610201, " Electrical Print Reading,"

Revision 00). The inspector reviewed the licensee's corrective actions and determined that these actions were adequate. This item is close (Closed) Violation (482/8837-03): Failure to Implement Fire Impairment Procedure Controls - On November 2,1988, Fire Door 32091 was propped open and d fire protection impainnent control permit was not completed for this doo The licensee could not determine the person or persons who propped open the door. The licensee issued a letter (WO 88-0295, dated December 23,1988) to all station personnel re-emphasizing the need to properly obtain a fire protection impairment control permit and, '

when passing by doors in the plant, to check any doors noted open for a proper impairment control permit. The inspector determined that the licensee's actions were appropriate. This item is close (Closed) Violation (482/8905-01): Inoperable Fire Barrier - TS 6. requires that written procedures be established, implemented, and maintained for, among other things, the fire protection progra Procedure ADM 13-13. " Fire Protection Impairment Control,"

Revision 5, implements procedures for impaired fire protection equipment including degraded fire barriers. On February 25, 1989, the inspectors identified an open, unsealed, 3/4-inch conduit located i between Room 1326 (Fire Area A-14) and Room 1329 (Fire Area A-33) for which no fire impairment had been issue The licensee's investigation into the reason this conduit penetration ,

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was not sealed revealed that the original embedded conduit had been forced out of level during construction. This made the embedded  ;

conduit undesirable es an electrical cable raceway. The conduit was l abandoned and subsequently overlooked during penetration sealing activities. This penetration had not previously been identified in

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-14- d the turnover exception item list. The failure to seal this conduit penetration was due to personnel oversight at the time of i construction turnove The licensee issued a fire impairment control permit and established an hourly fire watch on February 28, 1989. The impairment permit and ,

fire watch located were maintained between until Area Room 1326 (Fire sealing of the A-14) and 3/4-inch Room 1329p(enetration Fire Area A-33) was completed in accordance with WR No. 01066-89 and Work Package No. 01066-89-01 on Harch 17, 198 The inspector reviewed the licensee's investigation report end corrective actions. The records indicated appropriate sealing of the penetration opening and verification that the sealing was leak tigh This item is close (Closed) Violation (482/8907-02): PSRC Quorum - TS 6.5.1 requires that a quorum of plant safety review committee (PSRC) members shall meet as convened by the PSRC chairman to advise the plant manager on all matters related to nuclear safet The licensee made two changes to the facility, TM0 86-65-GK (86-SE-87)

(installed on June 20, 1986) and TM0 87-006-BB (87-SE-003) (installed on November 1, 1987), without the benefit of a meeting by a quorum of PSRC members convened by the PSRC chairma Instead, the review of the two TM0s and associated safety evaluations was conducted utilizing a " series review" sheet (walk around and telephone calls) by members of the PSRC and the PSRC chairman prior to the installation of these two TM0 The licensee's corrective actions included elimination of the serial review process by the PSRC and Administrative Procedure ADM 01-002,

" Plant Safety Review Comittee," was revised (Revision 20, paragraph 5.2.6) to clarify that the physical presence of the quorum l

is not required at one location and that safety evaluations (SE)

should not normally be conference call reviewed. However, if an SE l

review is performed by conference call, the SE should be reviewed at the next regularly scheduled PSRC meeting by the PSRC committee. The inspector determined that the licensee's corrective actions met the procedure requirements. This item is closed.

1 No violations or deviations were identified in this area of the inspection.

l Balance of Plant (BOP) (71500)

The purpose of this inspection was to determine the adequacy of modifications made to 80P systems, the edequacy of B0P operating procedures, and the effectiveness of management attention to the correction of B0P problems.

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c-15-The inspectors reviewed selected plant modification requests (PMRs), WRs, and procedures; performed walkdowns of. selected systems; and interviewed selected personne .

Selected inspector observations are discussed belo The following discrepancies were noted during a review of procedures, drawings, and equipment:

o System drawings showed locked valves while the valve lineup checklist did not require locked valves. Most of the valves shown on the system drawing as locked were found with locking devices in use. The shift supervisor's. list of locked valves did not include many of these valves. Two valves were found with locking devices for which no document appeared to require the lock o The arrangement of skid mounted equipment was not accurately reflected on: the system drawing o Apparent modifications were not found on system drawings. These included two storage tank bottom sample points and an addition to a

. pipe suppor '

.These items were discussed with the licensee. The skid mounted equipment drawings discrepancy is similar to a discrepancy noted in NRC Inspection Report 50-482/89-10. The licensee stated that a review and evaluation of drawings of vendor skid mounted equipment has been proposed for next year's budget. With regard to the apparent modifications, the licensee

' determined that they were not documented as either temporary or as permanent parts of the system. There were no open PMRs on the syste In addition to the previous inspection report, findings concerning the quality of secondary drawings have been identified in licensee QA Surveillance Reports 1659, dated October 5,1988, and 1737, dated June 2, 1989. Together, the findings indicated that the licensee appears to place less emphasis on quality for B0P as it does for the primary safety-related side of the plan . Exit Meeting (30703)

The inspectors met with licensee personnel (denoted in paragraph 1) on September 1, 1989. The inspectors summarized the scope and findings of the inspection. The licensee did not identify as proprietary any of the information provided to, or reviewed by, the inspectors.

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