IR 05000482/1990021
| ML20043E790 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 06/05/1990 |
| From: | Gagliardo J, Hunter D, Vickrey R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20043E788 | List: |
| References | |
| 50-482-90-21, NUDOCS 9006130386 | |
| Download: ML20043E790 (9) | |
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APPENDIX
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC' Inspection Report:
50-482/90-21 Operating License: NPF-42 Docket: 50-482 Licensee: Wolf Creek Nuclear Operating Corporation (WCNOC).
P.O. Box 411 Burlington, Kansas 66839 Facility Name: Wolf Creek Generating Station (WCGS)
Inspection At: WCGS, Burlington, Kansas
. Inspection Conducted: May 7-11, 1990 Inspet. tors:
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. B. Vickrey,leacv.or Inspectoy)0perational Date p Programs Section, Division of Keactor afety l
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Hunter, Senlor Reactor Inspecipr Dat6
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Operational Programs Section, Division of Reactor Safe Approved:
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gT1ardo, %hief OperAtfonal Programs Date l
Sect on, Division of Reac(pf Safety
, Inspection Summary
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Inspection Conducted May 7-11,1990(Report 50-482/90-21)
i Areas Inspected: Routine, unannounced inspection of actions you have taken
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with regard to previous identified inspection findings and the followup of
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previous inspection findings and weaknesses identified during the emergency j
operating procedures (EOP) team inspection conducted in early 1988.
Results: Withintheareasinspected,oneviolationwasidentified(failureto follow procedures, paragraph 3.1). One inspector followup item was identified (conducting appropriate audits of corrective actions for identified deficiencies, paragraph 3.8).
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The licensee had, in general, handled the correction of the previously identified weaknesses associated with the E0P team inspection in an acceptable manner. The noted exceptions included an inconsistency in the processing of temporary and permanent procedure changes which were previously identified by the NRC, the lack of backup documentation as part of the E0P review package regarding the " stripping" of certain DC loads to conserve the station batteries during the loss of vital AC power, the lack of definitive requirements for E0P field walkdowns and documentation, and the requirement to verify the reactor coolant system boron concentration at the hot standby conditions in the control room evacuation procedure.
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During a walkdown of the auxiliary feedwater (AFW) pump rooms and area, it was noted that a cable connector associated with the turbine-driven AFW pump turbine was broken, exposing the electrical wiring and internals of the mechanisms to the room environment (dust and dirt, humidity, etc.) and allowing ~
the flexible conduit to contact the turbine metal, which is hot during operations. The deficiency had been previously identified by the licensee; however, this condition had not been dispositioned effectively by the licensee.
The licensee had not provided oversight and audits of the corrective actions associated with the findings of the NRC E0P team inspection performed in March and April 198,-
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DETAILS'
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PERSONS CONTACTED WCNOC
- S. G. Wideman, Senior Engineering Specialist
- R. S. Benedict, Manager, QC
'*R. K. Steinbrock, Engineering
'*R. D. Flannigan, Manager, NSE
- J. E. Gilmore, Supervisor, Operator Training
- D. L. Fehr, Manager, Operations Training
- R. C..Hagan, Manager. Nuclear Services
- C Sprout, Manager, HP-WC
- J. L.' White, Manager; Human Resources
- R. W. Holloway, Manager, Maintenance and Modification
- J. Weeks, Manager, Operations
- L. E. Borders, Operator Training Instructor
- D. L. Erbe, Supervisor, Section Operations
'J. A. Zell Manager Training
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- M. G. Williams, Manager; Plant Support
- H. K. Chernoff, Supervisor, Licensing
- F. T. Rhodes, Vice President E&TS
- J. A. Bailey, Vice President, Nuclear Operations
- G. D. Boyer, Plant Manager
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- J. W. Johnson, Chief of Security
- B. D. Withers, President and CEO
- C. E. Parry, Director, Quality a
- W. M. Lindsay, Manager, QA i
D. Moseby, Operating Supervisor J. F. Deddens, Outage Manager M. E. Dingler, Manager, NPE System The inspectors contacted other licensee personnel during the inspection.
- Denotes attendance at exit interview conducted on May 11, 1990.
2.
LICENSEE ACTION ON PREVIOUSLY IDENTIFIED VIOLATIONS (92702)
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(Closed) Violation (482/8908-02):
Failure to Train Operators in Plant Modifications This violation resulted from a plant modification of emergency diesel generator controls, in that information on the facility change was not provided to all licensed operators prior to returning the modified equipment to service.
l-The inspectors reviewed the licensee's response and corrective actions. These actions included changes to requalification training lesson plans and changes
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to Administrative Procedure ADM 01-042, " Plant Modification Request
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-4-Implementation." Procedure ADM 01-042 had been revised to clarify the circum-
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stances when immediate training was required prior to system restoration; the revision included requirements for documentation and delineation of methods to ensure that licensed operators were cognizant of system changes prior to assuming licensed duties. The inspector also reviewed licensed operator requalification Lesson Plans LP096, Revision 001, " Emergency Diesel Generators,"
and LP095, Revision 0, " Plant / Industry Events," which had incorporated the above modification to the diesel generator output breakers. The licensee's corrective action appeared to be acceptable. The inspector had no further questions. This item is considered closed.
3.
FOLLOWUP (92701)
In the E0P NRC Team Inspection Report 50-482/88-13, two violations and a number of observations and concerns were identified in the report. During this inspection, the inspectors reviewed the licensee's actions related to those items. The procedures reviewed are listed in the attachment to the report.
3.1 Control of Temporary / Permanent Procedure Changes
A violation identified during the E0P team inspection (482/8813-01) was
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associated with the failure to have an adequate procedure and with the procedure change process as specified in ADM 07-100, Step 7.2.2.4.
The corrective actions taken by the licensee for the violation included a change to the l
procedure step to require that "A temporary change used in the performance of system operation,... operations response to plant evaluations,... shall l
l be referenced at the applicable step prior to procedure usage." The changt was l
made in 1988 (MA 88-245) to clarify the requirement that procedures used on an immediate basis, such as alarm response procedures and emergency operating i
procedures (including off-normal procedures), have the temporary change referenced at the applicable procedure step upon issuance of the temporary
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I change.
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TheinspectorreviewedseveralE0Psandoff-normal (OFN)procedurestodetermine that the procedure change process was continuing to be implemented satisfactorily.
The review of 0FN 00-019 " Loss of Instrument Air," Revision 5, in the main control room revealed that a procedure change (MA 90-071, dated May 2, 1990)
hed been listed in the front of the this procedure; however, the change had not been entered or referenced at the applicable procedure step. The deficiency was brought to the attention of the licensee, and the condition was corrected imediately by the operations group. The operations group performed a review of the E0Ps, 0FNs, and alarm response procedures in the control room and the auxiliary shutdown panel to ensure that other procedure changes were entered properly. A second example was identified in the procedurcs in the control room and was corrected immediately. The inspector reviewed 0FN 00-019 at the
. simulator and noted that the change had been entered at the procedure steps as technical support center, and simulator) procedure changes (control room, required. The inspector's review of the revealed that the changes entered at each location were not being entered consistently. Examples of the
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inconsistencies included the failure to enter all of the change, the deletion
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of a page in error, the failure to reference the specific change numbers, and the entry of the change number at the bottom of the page rather than at the specific step. These examples, even though not considered safety significant, indicated the need to upgrade the controls associated with the procedure change process. These inconsistencies noted were provided to the licensee. The failure to enter or reference the procedure change (MA 90-071, dated May 2, 1990) in Procedure OFN 00-019 " Loss of Instrument Air," Revision 5, in the control room at the applicable step as specified in ADM 07-100, Step 7.2.2.4, is an apparent violation (482/9021-02), but a Notice of Violation is not being issued because the criteria of Section V.A. of the NRC's Enforcement Policy have been met.
3.2 EMG C-0, " Loss Of all AC Power," Revision 2 (Changes MA 90-032, MA 89-111, and MA 89-060)
During the review of the procedure and supporting documentation by the inspector, a number of concerns were noted and identified to the licensee.
3.2.1 Procedure Step 14 required that nonessential DC bus loads be shed per Attachment A, which provided a list of selected distribution breakers associated with the station batteries (e.g., " Breaker NK 4112"); however, the specific DC loads were not identified in the procedure, attachment, or backup data package (e.g., " Breaker NK 4119, various letdown and excess letdown valves, BIT inlet bypass valves fail closed and position indication lost"). The lack of the backup data in the EMG data package was discussed with a licensee representative.
3.2.2 Procedure Step 5.b (Response Not Obtained Temporary / Permanent Procedure Change MA 89-060) required the performance of Attachment F " Doors Blocked Open in Auxiliary Feedwater Corridor," to enhance the turbine-driven auxiliary feedwater pump room cooling. Document review and interviews revealed that the
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opening and blocking open of the fire doors for cooling purposes appeared to be i
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nonconservative. The overall impact of opening all the doors (exposing the two
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L motor-driven auxiliary feedwater pumps to a potential elevated temperature and l.
high humidity environment) was not specifically addressed. The procedure did L
not addre.is the closure of the doors to the motor-driven auxiliary feedwater I
pumps if necessary to protect the equipment from degradation and to ensure l
availability of the motor-driven pumps when AC power was recovered. This matter was discussed with the licensee representative, l
afirehosefromValveKC-Y278(ponseNotObtained)requiredtheconnectionof 3.2.3 Procedure Step 15.2, (Res L
turbine building isolation, 2004 feet l
elevation) to Valve AP-V006 [ condensate reject to condensate storage tank (CST)
' isolation], starting the diesel-driven fire pump, and filling the CST, as E
necessary, to maintain the desired level.
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-6-During the field walldown of the procedure steps, the inspector noted that the locally maintained emergency locker (AFW area) contained flanges and fittings to facilitate connections; however, the appropriate tools were not specifically provided in the locker.
Interviews revealed that the appropriate tools would i
be obtained by the shift operations and maintenance personnel during the response to the event. The lack of dedicated and available tools necessary to
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respond to the emergency situation in an expeditious and uncomplicated manner was noted as a coment and discussed with the licensee representatives.
- 3.3 EMG F-0. Critical Safety Function Status Trees (CSFST). Revision 2
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The inspector reviewed and discussed the nionitoring of the CSFST during
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emergency situations. The shif t manning included the shif t supervisor /shif t t
technical advisor, a senior licensed operator, and two licensed operators. The
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minimum shift compliment provided a licensed person (excluding the shift
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supervisor) to specifically monitor the CSFST. The licensee noted that, with exception of night shifts and weekends, additional licensed personnel were
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3.4 0FN 00-017. " Control Room Evacuation." Revision 9 The purpose of the procedure was to provide instructions for the evacuation of the control room, manning the auxiliary shutdown panel, and shutting down and maintaining the plant in hot standby conditions.
The review of the procedure, including Attachments A through D, by the inspector
determined that the procedure did not specifically address the initiation and verification of boration to the reactor coolant system to establish the hot shutdown value, although this was addressed in Procedure OFN 00-103, " Control Room Not Habitable." Whether or not the initiation of boration should be covered in both procedures for consistency was discussed with a licensee representative.
3.5 Administrative Controls Regarding Emergency and Off-Normal Procedures The inspector reviewed the general and specific procedures established to control the generation of the emergency and off-normal procedures. The review was to ascertain that the requirements were addressed including procedure writing, verification / validation, training, and changes.
3.5.1 Emergency Operating Procedure Walkdowns Procedure Step 4.4.2 of ADM 01-052, " Emergency Procedure Generation Package Wolf Creek Generation Station," and Procedure Step 2.6.1 of ADM 02-022
" Writer's Guide for Emergency Operating Procedures," addressed validation of the emergency response guidelines and the E0Ps to ensure that the procedures were accurate and useable. The procedures specified the performance of at least a deck-top review, control room walkthrough, or a simulator performance or walkthrough utilizing a " team training" concept. j
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The review of the administrative procedural controls, including the validation checklist, specified in ADM 02-022, " Writer's Guide for Emergency Operating Procedures," did not provide definitive requirements or criteria with regards to the use of plant walkdowns as an essential part of the validation process.
Discussions revealed that the E0Ps and changes to the E0Ps were given a plant walkdown when deemed appropriate by the personnel assigned to the validation activity. A licensee representative stated that the plant walkdowns were performed, as appropriate, in addition to the desk-top reviews and simulator or control room walkthroughs; although the guidance in the administrative procedures and documentation was limited. The inspector and a licensee
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representative walked down selected steps associated with Procedure EMG C-0,
" Loss of All AC Power," and no specific inadequacies were noted during the control room and field walkdown.
i The guidance providing definitive requirements and criteria associated with the walkdown portion of the validation process and specifying the necessary documentation regarding this quality activity could have been strengthened, and
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this matter was discussed with a licensee representative.
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3.5.2 Off-NormalProcedures(OFN)
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The inspector reviewed the administrative controls associated with the generation of the 0FNs. Document review and interviews revealed that the OFNs were controlled within the general requirements of Procedures ADM 07-100 and ADM 07-101; however, the OFNS were written utilizing the two-column format (Action / Expected Response and Response Not Obtained) similar to the E0Ps. The administrative controls did not specifically address this practice. The inspector's review of selected 0FNs did not reveal deviations from the established practice; however, to ensure consistency with the 0FNs format, scope, and content specific guidance should be considered. This coment was discussed with a licensee representative for further consideration.
3.6 Emergency Lighting Installation The inspector reviewed the emergency lighting deficiency identified during the 1988 E0P inspection. The licensee performed a survey of the plant areas where local operator actions were required and identified four areas which needed additional emergency lighting. Document review and interviews revealed that the licensee had initiated a Plant Modification Request PMR 02744 (Revision 1,
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dated January 1,1990) to correct the situation. The PMR was planned to be implemented in mid-1990. During the interim period (1988 to present), the licensee provided additional lights for the operations staff in emergency kits (NRCInspectionReport 50-482/89-23).
The inspector had no further questions regarding this matter.
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The inspector reviewed ADM 02-022, Revision 6, " Writer's Guide for Emergency Operating Procedures." The improvement recommendation index and six improvement recommendations were reviewed from the November 4, 1988, through April 3, 1990, time frame. During this review, the inspector noted that only 9 individuals had originated the 48 index entries during this time period. The largest portion of these entries were from training department personnel. The inspector was concerned that there was what appeared to be a lack of entries by individual licensed operators. During interviews with training department i
personnel, the inspector was informed that most of their improvement recomenda-tions were a result of simulator observations and examination question analysis.
During interviews with licensed operators, the inspector was informed that, for
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the most part, they were taking their improvement recomendation information to
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the operations supervisor who was the subject matter expert. The licensed operators were satisfied that the operators' recomendations and concerns were being properly addressed and that the operators were being provided satisfactory answers and appropriate feedback. The inspector's review and assessment of the
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quality of the E0Ps appeared to support that the handling and processing of
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l identified deficiencies appeared to be in accordance with the writer's guide l
and had resulted in satisfactory ret,olutions of identified deficiency.
3.8 Corrective Action Audits The inspectors reviewed the licensee's audits to determine if an audit of the specific corrective actions resulting from the E0P inspection findings had
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been conducted. No such audit was identified. The requirement for an audit of this type is only that they be conducted on a sampling basis (Technical
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Specification 6.5.8.2); however, discussions with licensee representatives did l
not convince the inspectors that the licensee was doing adequate audits of corrective actions for identified deficiencies. Since this issue was outside
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and it is carried as an inspector followup item (50-482/9021-02).
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EXIT INTERVIEW (30703)
The inspectors met with the licensee representatives (denoted in paragraph 1)
on May 11, 1990. The inspectors sumarized the inspection purpose, scope, and findings. The licensee acknowledged the coments and did not identify any specific proprietary information to the inspectors.
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s ATTACHMENT Documents Reviewed Administrative Procedures ADM 01-001, " Introduction to Wolf Creek Generating Station Procedures,"
Revision 16 ADM 01-052, " Emergency Procedure Generating Package Wolf Creek Generating Station," Revision 3
ADM 02-021. "Use of Procedures in Operations," Revision 11 ADM 02-022, " Writer's Guide for Emergency Operating Procedures," Revision 6 ADM 07-100, " Preparation, Review, Approval, and Distribution of WCGS Procedures," Revision 44 ADM 07-101, "WCGS Procedure Content and Format," Revision 28 Emergency Procedures EMG C-0, " Loss of All AC Power," Revision 2 (Temporary / Permanent Changes MA 90-032, MA 89-111, and MA 89-060)
ENG CS-02, " Loss of All AC Power Recovery with Safety Injection Required,"
Revision 2 EMG F-0, " Critical Safety function Status Trees," Revision 2 EMG C-21. " Uncontrolled Depressurization of Steam Generators," Revision 2 EMG FR-HS, " Response to Steam Generator Low Level," Revision 2 EMG C-11. " Loss of Emergency Coolant Recirculation," Revision 2
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Off-Normal Procedures 0FN 00-013. " Control Room Not Habitable," Revision 18
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OFN 00-015, " Loss of Shutdown Cooling," Revision 8 0FN 00-017, " Control Room Evacuation," Revision 9 0FN 00-019, " Loss of Instrument Air," Revision 5, (Temporary / Permanent ChangeMA90-071)
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