IR 05000482/1990009
| ML20042G114 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 04/30/1990 |
| From: | Kelley D, Murphy M, Seidle W, Singh A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20042G113 | List: |
| References | |
| 50-482-90-09, 50-482-90-9, NUDOCS 9005110108 | |
| Download: ML20042G114 (11) | |
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APPENDIX e--
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U.S. flVCLEAR REGULATORY ^!T *:W:!0H
REGION IV
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HP,C Inspection' Report: 50-482/90-09
.0perating License: f1PF-42:
' Docket:
50-482
Licensee: Wolf Creek Nuclear Operating Corporation (WCNOC)
.P.O. Box 411
Burlington, Kansas 66839 L
facility Name: Wolf Creek Generating Station (WCGS)
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i Inspection At: WCGS, Coffey County, Burlington, Kansas j
Inspection Conducted: April 9-13, 1990 j
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. Inspectors:
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M.
E'. Murphy,' ReRtor/ Inspector, Ti~si Programs Date '
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Section, Division of Reactor Safety
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A. Singh, Renqtor7 nspector, Test Programs Date
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Section, b Vision of Reactor Safety
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D.- L. Kil b'y,-MacturjInspector,' Test Programs te Section, Division of Reactor Safety
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. Approved:
N W.T. Seidle, (31ef, TETE Programs Section Date
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7e Division of Reactor Safety
Inspection Summary Inspection Conducted April-9-13,1990,_(Report 50-482/90-09)
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' Areas Inspected: Announced inspection for system entry retest (SERT) in the.
areas ot moTiTTcations,. temporary modifications, and maintenance activities.
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9005110108 900507 PDR ADOCK 0500048:2 O
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-Results: The licensee had a strong program for determining the need for retest and for identifying the appropriate type of retests. The licensee also had a good program for development and performance of adequate procedures for retests of structures, components, and systems following plant modifications and maintenance activities. One minor observation was made; the licensee did not have any formal training program for the modification work request program. The licensee stated an intention to evaluate the need for such a training program,
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DETAILS
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PERSONS CONTACTED WCH0C:
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- J.'A. Bailey, Vice President, Nuclear Operations
- R. S'.- Benedict.. Manager, Quality Control (QC)
- B.: Bergstrom,: Supervist q Maintenance and Modification Services Group
- G. D. Boyer, Plant Manager
- H. K. Chernoff Supervisor, Licensing
- A. B. Clason, tianager, Engineering Supervisor
- R. D. Flannigan, Manager,. Nuclear Services
- C, W. Fowler, Manager,' Instrumentation and Control
- J. F. Hall, QC Supervisor-
- R. W. Holloway, flanager, Modification
- D. Hopper, Licensing Specialist
- W. M. Lindsay, Manager, Quality Assurance (QA)
- R. K. Lewis, Supervisor, Results Engineering
- M. H. Megehee, Supervisor, Compliance Engineering
- D. G. Moseby, Supervisor, Operations
- C. E. Parry, Director, QA
'*J. M.JPippin, Manager, Nuclear Plant Engineering
- F. T. Rhodes, Vice President, Engineering and-Technical Services
~ *H. L. Stubby, Supervisor, Technical Training
- S. Wideman, Senior Licensing Specialist
- J. A. 'Zell, Manager, Training
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J. Gilmore, Supervisor, Operator Training D. Naylor Operations Support Supervisor L. Nowles, Maintenance Engineering Specialist B. Blecha, Maintenance Engineering Specialist
.NRC
- C.' t. ' Johnson, Reactor Inspector, Region IV v.ie inspectors also interviewed other licensee employees during the inspection.
' Denotes those attending. tt'e exit meeting conducted on April 13, 1990.
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INSPECTION OBJECTIVES AND METHOD
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The overall objective of this inspection was to determine.the licensee's performance in.the area of system entry retest identification, documentation, and performance.
-To accomplish this objective, the inspection team determined that retest
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requirements were evaluated during modification and maintenance planning and that the retest procedures met regulatory requirements, connitments, and'
. industry guides or standards.
It was also determined that retest requirements
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-were considered for all system boundary violations. The inspection team aiso verified that the retests proved operability and assured that the design basis was satisfied for structures, systems, and components that were modified or subjected to maintenance during this refueling outage.
The inspectors. reviewed the licensee's administrative procedures for design changes, temporary modifications, and maintenance. The procedures, which defined responsibilities and the retest requirements for the plant modifications, are listed in Attachment C.
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Work items scheduled for the refueling outage in progress during this inspection were assessed. The inspectors selected 14 design changes and 14 maintenance-related work authorization packages for detailed review. The performance of one modification retest was observed.
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INSPECTION FINDINGS SUMMARY The licensee was found to have a strong program for identifying, planning, S
, developing, and performing retest procedures. Retest requirements were addressed, in detail, in the areas of modifications and maintenance work.
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Responsibilities were wel! defined, and personnel experience was found to be very good at all levels of involvement. However, one observation was work request-(HWR) or temporary modification (TM)g program for maintenance identified involving the lack of a formal trainin programs. The present engineering experience level offsets the immediate r.eed for such formal training programs, but with career advancement and attrition this experience level could become diluted.
There were no violations or deviations. identified during this inspection.-
4.
MODIFICATION TESTING (72701,37828)
The purpose of this part of the inspection was to determine the process by which a design change-is developed, reviewed, installed, and tested prior to final.close out of the modification packages. The inspector reviewed 14 plant modificationrequest(PMR)packagesandtheassociatedretestpackages. These
'PMRs are. listed in Attachment A.
The most extensive modification, PMR-2149,
= involved replacement of orifice bores, valves, fittings, pipes, and relocating a monitoring panel from the communication' corridor to the control building basement. This panel houses the flow indicators, which monitor the service / essential service water flow to the ultimate heat sink (VHS) while remaining Outside the radiological control area (RCA). The inspector found that appropriate tests had been specified and performed to assure the
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operability of the system. Appropriate tests had also been identified and performed for the other pMRs reviewed by the inspector. These PMRs are listed in Attachment A.
In each instance, operability of the component and/or system would have been verified upon completion of the required testing. The boundaries established for the testing were appropriate. Test exceptions were identified and
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-5-dispositioned. The tests reviewed contained appropriate system restoration instructions as well as turnover to operations procedures for the modified system. The tests reviewed included mechanical, electrical, and-instrumentation and control-testing. The inspector noted that provisions had been inade to revise instructions, procedures, and drawings prior to operation of the modified systems or components. Timely retraining had also been specified when required.
The inspector also observed the post-modification hydrostatic test for the Reactor Coolant pump seal throttle valve replacement. The operators who performed the test followed the established procedures. The inspector did not identify any descrepancies during the test. The test results met the acceptance
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There were no violations or deviations identified in this area of inspection.
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TEMPORARY M001FICAT10tl TESTiti (??701, 378281
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The inspector reviewed the licensee's temporary modification program, which was-described and administrative 1y controlled by Procedure ADM 01-228, " Temporary Modifications."
A temporary modification may be initiated by any plant personnel by completing
- the " requestor" section of a temporary modification order (TMO)..The TM0 is then subjected to a series of reviews that establish the safety classification, a
applicability of a 10 CFR 50.59 evaluation, need for independent verification,
'and an operations impact evaluation. Actual implementation can be commenced only if a maintenance work request (MWR) or a special procedure is initiated.
Retest requirements for installation and restoration are evaluated and established under the MWR program or by specific steps in the special procedure.
The.TN0 log was reviewed and the subjects of the outstanding Th0s were determined to be of a minor nature and for the majority, not safety-related.
At the time of the inspection, there were 87 TM0s open. Of these, 13 had been; generated to support the refueling outage in progress. The licensee was actively pursuing a program to reduce the number of aged TMOs, and 32 were scheduled to be cleared by the implementation of permanent plant modification requests.
The licensee does not have any formal training program for the MWR or Tli0
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program. Reliance is placed in on-the-job training and required reading programs. The licensee acknowledged that they have realized significant benefits from a formal training program in root cause analysis.
The inspector concluded that with the recent extensive revisions to both the MWR and TM0 procedures and programs, a similar, formal training program could be used to establish uniformity and eliminate inconsistencies in the modification testing area. The licensee stated an intention to evaluate the need for such a training program.
There were no violations or deviations identified in this area of the-inspection.
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POST-NAINTENANCE TESTING (72701)
'This portion of-the inspection deelt with the licensee's control and x
performance of post-maintenance testing.
-The inspector concluded that,the licensee had an effective program in place and it appeared to be functioning well. However, the inspector noted three minor-problem areas:
(1) not all work requests had the retests specified prior to releasing the work request to the field, (2) there appeared to be a lack of
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consistency in filling out the work requests (this appeared to be the result of the recent major revision to the work request procedure), and (3) a lack of -
direction as to when to enter N/A in work request form blocks instead of leaving them blank.
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The inspector reviewed 4 administrative procedures and 14 work requests (see Attachment). An additional review was conducted of Interoffice Correspondence MA 90-0052, " post Maintenance Testing."
The work request administrative procedure, ADM 01-057, was revised and issued in March 1990.- The revision was major in scope and included a new work request form. The new form and procedure appeared to be the cause of the inconsistencies
.noted during the work request review. The new form'contains blocks for
' testing. (i.e., operability testing) post-maintenance testing) and " service"
" pre-service [ sic)" testing (i.e.,
The old form only had one space for
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retest description and was somewhat confusing. The inspector-found the revised procedure to be an improvement over the older procedure, but some clarification should be added. The procedure should specify that "N/A" be placed in blocks' to signify that the item was reviewed and does not apply. The blocks, at present, may or may not be marked N/A depending on which individual filled out the form.
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The-blocks for'preservice and service testing are usually not filled out prior to releasing the work request to the field. At a minimum, basic preliminary tests should be specified. Additional tests can be added-if the work scope is changed during the' job performance.
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At present there is no specific procedural guidance for evaluating or specifying post-maintenance testing ; however, Interoffice Correspondence MA'90-0052 does contain such guidance, and formal direction-is being promulgated.
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The work request samples examined contained completed and in progress work requests.
In addition, some of the work requests were on the old form, and some m
were on the revised form. The new form is superior in specificity and clarity to the older form. The transition from the old form to the new one has caused some minor problems. The desirability of formal training in this area was previously discussed in paragraph 5 of this report.
- The inspector concluded that the templeted work requests and the in progress work requests-which contained retest requirements satisfactorily addressed the post-maintenance test and operability of the systems and/or components upon which maintenance had been performed.
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The inspector concluded that post-maintenance testing was satisfactory and that the proposed formal direction for post-maintenance testing will add to its effectiveness.
No violations or deviations were identified.
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EXIT INTERVIEW
An exit meeting was held on April 13, 1990, with the personnel identified in paragraph 1 of this report..At the. exit interview, 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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ATTACHMENT A
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Plant Modification-
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Dat'e g
Request'TIHE) No.
Title h
PMR-948 Replacement of Reactor 12/14/88 Revision 6 Coolant Pump Seal Throttle Valves-
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Solid State Protection System 8/23/89 PMR-1482
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Modification to Prevent Revision 3 Inadvertent Containment Spray
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PMR-1544 Technical Specification 5/2/89 Revision 4 Connitment Controlling Access to Areas Greater
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than IR/HR
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PMR-1754 Steam Generator.'D'
11/1/89 Revision 1 Instrumentation Removal PMR-1830 Diesel Generator Jacket Water 4/5/88 Revision 1:
Expansion Tank Level Drawing Changes
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PMR-2149 Minimum Flow to Standby 3/15/90
. Revision 4 ServiceWater(EA) Components
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' PMR-2268.
Containment Cooling Fan 8/30/88
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Vibration Switches PMR-2287 Pressurizer Operated-5/19/89
' Revision 2 Relief Valve Block Valve Control PMR-2492
. Automatic Pod Control 11/3/89 Revision 1 PMR-2493 Reactor Cavity 1/18/90
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Revision 1 Permanent Seal Ring PMR-2842 Air Lock Shop 3/14/90 Pavision 1 Shaft Seal Modification-PMR-2937 Mid-Loop Independent 3/12/90 Revision 1 Level Indication PMR-2987 NAMCG Limit 7/21/89 Revision 0 Switches Replacement
. WORKREg,UESTSREVIEWED WR-60039-90 Snubber Fuictional Test WR-00821-90 RHR Train A & B Cooldown Valves WR-04778-89 Remove / Reinstall DG Exhaust RTD WR-02994-89 Vessel Vent Position Indication
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WhiO1414-90;
- EDG Cylinder Exhaust Thermocouples
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WR-00787-90.
Inst.all/Renove Temporary Shielding
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- Lo Pressure Feed Heater Level Controller WR-01528-901 Containment Cooler Leak Test WR-01693-90.
Containment Cooler Tube Bundle Repair WR-91744-89 Limitorque Actuator
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' WR-60477-89 PM-Battery. Charger WR-05682-86 Limitorque Operator o
WR-60179-89 12-inch Gate Valve ~ Motor Operator WR-60147-89 12-inch Gate Valve Motor Operator
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ATTACHMENT B-0A Audits and
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Subject Date TE:50140-K196 Work Control 2/29/88 TE:50140-K234 Test Control 12/29/88-TE:50140-K246 Work Control 4/17/89
'1E:50140-K268 Test Control 12/19/89-TE:53359 S-1700 Maintenance and Modifications 12/13/88 of the Main Feedwater Control and Bypass Valves
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TE:53359 S-1710 Chlorine Monitor Replacement 1/4/89 TE:53359 S-1714 Gansa Metric Cabic and Detector 1/18/89 Replacement TE:53359 S-1739 Maintenance Program for Motor 6/7/89 Operated Valves TE:53359 S-1774 Reactor Trip Breaker Maintenance 1/3/90 Program TE:53359 S-1786 Pressurizer Safety Valve Rebuild 3/12/90
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ATTACliMENT C Procedure No.
Title Date ADM'01-042 Plant Modification 11/27/89 Revision 16 Request Implementation ADM-01-057'
Work Request _
4/4/90 Revision 17-KGP-1131 Plant Modification 4/4/90 Revision 7 Process ADM 01-228 Temporary Modifications 11/6/89 Revision 0 ADM 01-050'
WCGS Operational Phase 11/29/88
. Revision 3.
Verification Program ADM 02-104 Instrument Out of Service-2/22/88 Revision 6 Control
'ADM 02-110 Control of Information.
12/20/89 kevision 13-Tagging ADM 08-808, 18C Group Maintenance -
6/14/88 Revision 5 and Troubleshooting Activities ADM 08-206 Corrective Maintenance ADM 08-203 Maintenance and Modification Organization ADM 08-201 Control of Maintenance and Modification
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