IR 05000482/1990025

Insp Rept 50-482/90-25 on 900611-15.No Violations or Deviations Noted.One Unresolved Item Noted.Major Areas inspected:post-fire Safe Shutdown Capability Reverification & Assessment of Fire Protection Program Compliance W/App R

ML20055D991
Person / Time
Site:	Wolf Creek
Issue date:	07/02/1990
From:	Cwalina G, Clay Johnson, Murphy M, Singh A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20055D989	List: IR 05000482/1990025 ML20055D988
References
50-482-90-25, NUDOCS 9007100240
Download: ML20055D991 (11)

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APPENDIX- ,

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,; !{ . ', '!lfi i 11E ,i ', U.S'. NUCLEAR REGULATORY COMMISSION i REGION IV gp$ .e

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L,, .' +, , -NRCl Inspection Report: 50-482/90-25 -Operating License: NPF-42i-5 : '

W_ . Docket: 50-482-- -

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(4;',' "iLicensee:' P.O.: Box 411-Wolf KansasCreek Nuclear Opecctit.g Corporation'(W

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Burlington, 66839

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iFacility Name:' Wolf Creek Generating Station (WCGS)

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Inspection At: llCGS, Burlington, Kansas op i a '

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O^"  : Inspection Conducted:. June 11-15, 1990 l

. Inspectors:-

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b roib: cUw5 C. E. Johnson, Reactor Inspector, Plant . .

(,- M- 40 "

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l Systems Sectim, DMvision of Reactor Safet g> ,

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'+ ' A. Singh,\J4 tactor Tnspector, Test Programs

.Section, Division of Reactor' Safety Date f,

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,M spector, Test Programs D6te' .

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/E.11urphy( Reapto(,f Division o Reactor Safety-y- '. ,' (Qf m

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,{', _L i 2 .b l };b s i3 , Accompanying ' Mr. T.l A. Storey,: Fire Protection Enginee g .

_ Personnel: -Science Application International Corporation (SAIC)

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sApproved: l d 4996 N[ik'

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'.JG..Cwalin . Division of Reactor Acting Cnief, SafetyPlant Systems Section-Date ihiv w .1

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9007100240 900703 pW 7 ' PDR ADOCK 05000482 i,. O PDC

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o Inspection Summary *

V In Inspection Conduct'ed June 11-15. -1990 (Report 50-482/90-25).

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+ y Areas Inspected: Announced: inspection of postfire safe shutdown ~ capability j reverification and assessment of the fire pr 6 '*on a ogram's compliance with ;

~t he. requirements'of. Appendix R to 10 CFR Pi i, a

Results: :The inspection verified that the

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pM aas properly maintained the L

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-postfire s'afe; shutdown capability that was,c, ' . in the initial validation r inspection conducted during the~ period Jul; "gh August'3, 1984.~ Items requiring -licensee action, as a result unf. tt. . alt.al inspection,'were found t be completed and the initial concerns resolved. The licensee's Fire e

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- Protection / Prevention program and configuration management involvement, as it ,

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' relates-to maintaining _ Appendix R compliance, represents a strength;in the

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licensee's overall fire protection efforts. However. it_ appears that knowledge-

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of. the Postfire Safe Shutdown Methodology is not being maintained.at a leve1L ;

commensurate to-when the plant was originally licensed. This is considered i Ja weakness:in-the Postfire Safe' Shutdown progra "

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DETAILS- j

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1. ' PERSONS' CONTACTED 1

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' *Ei: Asbury Supervisor, Configuration Management

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i*R.. Benedict,LManager, Quality,Controli(QC) '

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/*J. Blackwell, Fire Protection 1 Specialist  ;

i* .*MC Brinkmeyer, Fire Protection Technician-

• H. Chernoff, Supervisor; Licensing-d F fML Dingler, Manager,: Nuclear Plant Engineering (NPE) - Systems; <

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-* C.cDunbar, Licensed Supervising' Instructor- ,i

• R.=F,lannigan,-Manager,NuclearSafety-Engineering (NSE)

• J. Gilmore, Supervisor, Operation Training  !

~ *W.cGoshorn,' Wolf Creek Coordinator '

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R. Hackmani Supervising; Instructor: .+

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J. Hall,LQC Supervisor >

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'*M. Hancock, Engineer II. _

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'*H. ;Hoadley, = Manager,i Plant- Design-NPE <

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• R.CHolloway; Manager,LMaintenance and Modification 1*W.i Lindsay, Manager,- Quality Assurance (QA) q

' *A. ;McGraw, Engineer I: . .;

• MLMegehee, Supervisor, Compliance ~

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• T.;Morrill, Manager, Radiation Protection l

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• Dh Moseby, Supervisor, Operations *

• W1'Norton,~ Manager, Technical-Support

• D.' Parks, Supervitor,, Corporate Training

• C, Parry ,t Directo a, Qualit '

. . J. Pippin.nManager, NPEc

• *E. Peterson,'QA-Auditor' .

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4 JG. Rathbun,fManager, NPE-Wichitat -

t L*C'. Sprout,'.Section Manager, NPE J

G *JLWeeks, "anager,

Operations '

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. , :S;! White. Fire Protection, Summer Intern J

%F s*S. Wide in, Senior Engineering Specialist

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• R.;Wrighti Supervisor, QA Audits

• J. Zelli Manager, Trainingi .

1' . CERHAK FLETCHER ASSOCIATES I o .

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. *H.! Fletcher,TConsultant o i J . ~. .

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Q; .~* Denotes those individuals attending the' exit neetin i 't

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Thefinspectorsla'1so interviewed -other licasee employees durthy the inspectio .!-

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'P 2. -FOLLOWUP'ON PREVIOUSLY IDENTIFIED ITEMS (92701) ,

(Closed)InspectorFollowupItem(482/8918-01): Review of.the completed (

refurbishment of Target Rock-valves - This item involved-Target Rock solencid .

operated valves utilizing silicone insulated pigtail leads on their-solenoisi  :

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and reed. switch assemblies. The silicone wire insulation used in the environmental qualification (EQ) of-the subject valves could have cracked.,

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Refurbishment kits to' correct the identified problems were to be installed on '.-,,;

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_the fourteen valves affected during the next outage.-

The inspector _ reviewed the completed maintenance work requests and determine . this _ item accep table;for closur . POSTFIRE SAFE SHUTDOWN CAPABILITY (64150)

a The purpose of this inspection was to determine whether the licensee has4

(1)-developed and implemented a configuration management program with respect to j

.postfire. safe, shutdown capability, and (2) maintained the postfire safe '

' shutdown capability that was-verified during the initial validation inspection

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- conducted (from July 30 through~ August 3, 1984.

/ 3.1 Configuration Management Program The-inspectors conducted a detailad review of Plant Modification 3 Requests-(PMRs) in-order to verify that the configeration management progr'am ;i related 1to Appendix R compliance and postfire safe shutdown capability was adequate.. Procedures were reviewed to determine (1).if provisions were

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included to ensure.that all>PMRs are reviewed for_ Appendix R compliance and safe shutdown concerns'; (2) that adequate guidance is provided to ensure that i the: impact of PMRs on Appendix R compliance and the postfire safe shutdown .

M capability is considered; and (3) that provisions to ensure that all PMRs, which

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impact Appendix R compliance and postfire safe shutdown capability, are reviewed

,to determine their effect on the analysis, procedures, and programs-which support and implement this capabilit Selected PMRs, for which the: safe shutdown analysis could have been impacted, were reviewed to verify proper implementation of the configuration management procedures. Review of' the PMRs selected' indicated that the procedures to determine'.and identify any impact on 'the safe shutdown analysis and related; .

procedures andl programs were being implemented satisfactorily, -.l

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322, Configuration Control Procedures and Implementation Configuration control procedures were reviewed to determine if PMRs were being reviewed adequately by qualified individual The. procedures reviewed included:

KPN-C-301 Initiation of Plant Modification Requests .

KPN-C-307 Plant Modification Request Revisions and Closeouts  !

KPN-0-316 Fire Protection Review h .,

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The procedures demonstrated that a datailed. review of plant modifications was i required to determine if the fire pritection program was impacted. However,

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-the, inspectors noted that no proceduras identified the qualifications of the individuals performing the review. 'In addition, several procedures referred to *

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a " qualified fire protection engineer";-however, no= individual is currentl '

designated. in this position nor are qua'lifications specified. The licensee a committed to modify the appropriate procedures'to include the ovalifications of -i'

the personnel _ performing the review and'which individuals or position would.-

serve as the= qualified fire protection engineer. The. proposed modifications to the procedures were acceptable to the inspector .3 Postfire Safe Shutdown Procedures 3.3.1:-Procedure Review i

The inspectors rev ewed Procedure OFN 00-017. " Control Room Evacuation." Thi procedure is base- an a' shutdown methodology provided to the NRC-by-

' Standardized Huclear Unit Power Plant System (SHUPPS) letter dated August 23,

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- 1984, which was subsequent 1y' reflected in Supplemental Safety Evaluation

- Report (SSER)5. The letter to the NRC defined-requirements for certain

" phases" of the shutdown to be accomplished in specific periods of time with the first phase to be accomplished in 5 minutes. Uhile this was not

- specifically reflected in the procedure, the' licensee indicated that-tb"e time r

! requirements were consider d when the procedure was written. The insp. : ors

asked to see the basis for these time requirements, which wtre reflecto in the 1984: letter and-SSER 5. The licensee was unable to produce the basis for these i time _ requirements at the time of the: inspection. The licensee committed to -

provide the. basis 1 for the' time' requirements to the HRC.. This will remain as ,

an unresolved item pending. receipt of the time basis documenation. In-  !

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addition to this specific concern regarding the basis for time requirements,.

the inspectors developed a more general concern that this issue may indicate i that'the licensee 'is not adequately maintaining the bases for their-postfire safe shutdown methodolog Unresolved Item (482/9025-01): Provide Basis for 5-niinute time requirement'

outlined in SHUPPS letter dated August 23, 1984, and SSER The -inspectors reviewed Procedure 0FN 00-14, " Hot. Standby to Cold Shutdown From j Outside the Control Room." This procedure indicated that cold shutdown could-be achieved from outside the control room without the need to re-enter the control room for repairs. 'This conflicted with information provided in the ;

licensee's Updated Safety Analysis Report (USAR). The USAR's wording indicated

'that the operators would have to re-enter the control room for repairs prior to ' ,

going to cold shutdown. The inspectors requested the licensee to clarify the !

discrepancy. Upon review,- the licensee determined that the USAR had not been properly u'pdated following modifications identified to the NRC in the '

August 23,-1984, letter. The licensee committed to change the USAR to indicate that re-entry into the Control Room to make repairs was not required to achieve cold shutdown. The inspectors reviewed a marked-up change to the USAR and found it satisfactor m

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i 'S 3.3.2- Operator Requalification Program for Abnormal Operating Procedures- -

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(Fire Protection Relatedl C' lThe inspectors reviewed the documentation for both licensed and non-licensed T reactor operator requalification training pertaining to postfire safe shutdown ;

procedures. The training program requires specific traicing on these 4 m procedures?as part of the overall' training on emergency precedures. The review i also indicated that the operators have received current traiaing on remote f shutdown procedures. The lesson plans were reviewed and found' adequate. On

the basis of this-review, the inspectors found the operator recualification-j ( , program, with respect to postfire safe shutdown, to be satisfac'.ory.- >

In addition to a review of training procedures and records, the inspectors also witnessed a drill which simulated plant shutdown from outside the Control Roo '

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.The drill demonstrated that the operators were knowledgeable of the procedures

.and of the plant. The procedures reviewed ne listed in the Attachmen ,

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3.4: Associated Circuits Review u The licensee identified that all' circuits meeting the definition of an

. associated circuit were treated as Class 1E and included in their area by area

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safe shutdown analysis. The. licensee stated that there had been no changes in-

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the~ analysis since the initial validation, which was documented in NRC Inspection Report 50-482/84-19 and SSER 5. The inspectors concluded that the ,

.g licensee's analysis of-associated circuits continues to remain satisfactory and

{ meets the< requirements of Appendix R, SectionLIII.L.

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1 3.5 -Emergency Lighting -- I The. inspectors reviewed the adequacy of the installed emergency. lightino

required-by Section;III.sl of Appendix R.- The lighting was reviewed to ensure that'it wasJadequate'to provide the necessary illumination of access and egress paths;for shutdown personnel and that there would be adequate light to perform L any manual; actions necessary to achieve safe shutdow In addition, lights

- were inspected in the field to ensure that. they have been adequately maintained. Surveillance procedures were reviewed to ensure that they have been properly implemented. The inspectors found the emergency lighting installations-and maintenance program to be satisfactor '

[, 3.6 . Fire Hazards Analysis . .

t Changesito the Fire Hazards Analysis (FHA) since the initial validation were

. reviewed to ensure that the capability still existed to achieve and maintain-shutdown following a fire, and that the bases for any deviations previously

's granted by the -NRC had not been adversely impacted. The inspectors did not identify'any unacceptable changes to the FH The' inspectors also performed a plant walkdown intended to determine if the FHA still adequately reflected plant design and fire protection features. During the walkdown, the inspectors observed fire barriers, fire barrier penetrations,

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automatic suppression systems', manual. hose. stations, separation of safe

, shutdown components, and cable wrappin ~

.No discrepancies between' the FHA and actual. conditions were identified. No !

-deviations from the requirements set forth:in' Appendix'R were observed other than.those previously stated in the SE (

, 4.c FIRE PROTECTION /PREVEllTION PROGRAM (64704)

iThe purpose?of this inspection was to evaluate the overall adequacy of the

, licensee's fire protection / prevention-program and to determine that the 11censee was implementingLthe: program in conformance with regulatory

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requirements and industry guides and standard !

4.1 Program Review and-Implementation ,

1The inspectors reviewed.the USAR and administrative procedures, which

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constitute the approved fire. protection program. These procedures are listed insthe enclosed Attachment.. ' is review verified that the licensee had J

technically acceptable procein s to implement the fire protection progra t Procedural guidance was prov1 M to control combustible material and reduce fire hazards. The procedures a;;o provided for maintenance and surveillances on fire suppression, detection, and support equipment. Personnel training, qualifications, and responsibilities were satisfactorily addressed. Maintenance ,

evaluations that significantly increase fire risk were properly controlle The inspectors toured accessible areas of the plant site to observe general area- conditions, workLactivities in progress, and visual condition of fire protection; systems and equipment. Combustible-materials, flammable and  !

combustible liquid and gas usage were restricted or properly controlled in i areas containing. safety-related equipment and component Items checked included _ positions of selected-valves, fire' barrier conditions, hose statiens,

, hose houses, fire lockers, and fire extinguishers for type, location, and-conditio There were no welding, cutting, or use of open flame ignition sources found in ;

.the areas toured. > General housekeeping: conditions were found to be very goo '

Fire brigade equipment, including emergency breathing apparatus, was found to

beLproperly stored and maintaine Operability and. surveillance test requirements for WCGS have been removed from

.the. Technical Specifications and are contained in'the fire protection manua Fire protection systems and equipment installed for protection of safety-related

= areas were found-to be functional and tested in accordance with the requirements i t specified.in the Fire Protection Manual. During the review of selected completed

surveillance tests, some discrepancies were noted in data recording and step

. sign-off. These discrepancies were discussed with a licensee representative and will _be corrected. The discrepancies did not affect the acceptability of the surveillance tests. 'Also noted during the review was a lack of acceptance criteria or comparative pump performance curves in the annual fire pump F

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' surveillance test. .The information was.available from the fire protection specialist. The licensee:is assessing the need for including the pump curves in the test procedure .e During the review of Procedure FP-205, " Monthly Surveillance Test, a Spray / Sprinkler Valve Position Yerification," the inspectors noted that the April test had identified two' valves that were mislabeled and two valves that h should be deleted since they were check valves and could-not be position verified. Further review of previous tests revealed that these valves were

. verified and signed off'as correct. These verifications werc~ accomplished by a -

number:of different operations personncl. The licensee reviewed this test as *

far back as initial' licensing and determined that the error has existed for ;

approximately 5 years,. All four valves invo he the two diesel generator room preaction suppression' deluge valves and the associated systems. The mislabeled valves were air supply valves and are normally open. These valves, even though mislabeled, were verified open and the system function was not affected. The two check valves are te11 tail drains on the deluge valves.and are normally

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open. Actuation of the deluge system pressurizes these valves and closes the Interviews with some of the operators revealed that they had rationalized that

=if there was no flow from the valves, they were. closed and.so noted on the' j~

valve lineup sheets. iSince this error did not involve actual repositioning'of the valves there was no affect on-the function. However, the continued action of qualified operators..to verify by-signature a vahe condition that could not

.be physically-verified is .a matter of concern and will be carried as an inspector

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followup item for further review.into the overall valve lineup check and ;

verificationprogram.-(482/9025-02)

Inspector Followua Item (482/9025-02): Further investigation into the overal1

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valve lineup. check and verification progra The inspectors;also reviewed fire brigade training and drill records. Th records were in order and confirmed that training and drills were being conducted at the specified intervals. The inspectors also observed a'backshift unannounced' fire brigade dril1. The response was satisfactory and' the

evaluation and attack planning were considered very good. ~.The inspectors had no comments on the conduct of

the drill. 'During the. training review the inspectors interviewed the training department manager and selected instructors. This interview focused on the concern regarding staffing and turnover that was raised in NRC Inspection Peport 50-482/90-01. The training department continues to operate below approved' staffing levels. This has not :

directly affected fire brigade training but does have a potential effect in operator licensing training since the loss of experienced personnel is I primarily in this. are l 4.2 Quality Assurance Audits The-larc four QA audits in the area .of fire protection were reviewed by the inspectors. These audits were conducted on an annual schedule. Two of these l l

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g*f audits: involved the services of qualified outside consultants. The-audits were-c icomprehensive. System / equipment' alterations,' tests, surveillances, and r maintenance;_ fire. brigade drills, and training; records,-and'overall problem ,

. procedures were addressed. Discrepancies identified were forma 11y' presented.to 't m '

the'affected' organization. Responses were. tracked to closeout and actions <

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taken were reviewed for adequac ,

' EXIT MEETING ,

An. exit. meeting was held. June 15,L1990,.with the personnel indicated in

a paragraph 1 of-this report.' At this meeting, the scope of the inspection and-Lthe findings' were summarized. . The' ' licensee did;n'ot, identify as proprietary: any

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of-the information providedEto,'or> reviewed by,:the inspector ~. .  ?

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ATTAtllMENT r

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> r Administrative Procedures, i 1 '

j Procedbre.No; Title Date

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> -j JADM 13-100,;  : Fire Protection Manual- August'9, 1988- .

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, -Revision 2.: , t 7 '

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lADM 13-102', Control of Combustible Materials- . March 28, 1990 ,

' ; Revision 8: :ADM 13'-103, Fire' Protection: Impairment i

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Revision 6- Control .. July! 25 ; - 1989

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i ADM :13-104, - Development andLUse of Fire .. . .. a fn, -Revision 3- >

, Preplans

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1 -ADMi13-200,e Fire . Protect' ion .; Training' Program May.16,-1990, -

Revision 4 i 4 ADM 13-300, Fire Preplans Preparation Guide November 23, 1988 J[

> 16 Revision ~3; 4

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.ADM 13-901,, iFire Incident' Reporting Procedure .MarchT25,1988'

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. Revisions 1- *H ADM13-902L ' Fire Drills ^ .

'May 31, 1990:

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R ADM-13-903 , . Fireiand Life Safety Inspectiois) -November 8, 1989' m ..,

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Revision 13 ,

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1. , ' Adit 02-006 slluclear? Station'0perator:

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Qualifications and Responsibihties August 3, 1989 f

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ADM 02-210; Operations Watch-Station  :

LRevision:8: '

. Qualifications May 5, 1988; l

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mu l Adit.06-211, .. Nuclear-Station Operator -

,y :RevisionE4.- Requalification Training - -

December 12,,198 , in ,

M , llADM-06-230- , Instructor. Training,Qualificatiok,

1. Revision 9 Continuing Training and Certification- February 14, 1990

,N -0FN 00-013, " Control Room flot Habitable m

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=RevisionL10 July 15,-198 I

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Revision 6: From Outside the Control Room March 14, 19892

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0FN'00-016;  % Fire Response; ,

February 28, 1990

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cRevision 5 ,

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Room Evacuation Revision 9- ' June 18. 1989:

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J -CKL WQ-008, 7 Auxiliary Building Operator .

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_ : Revision 2 Watch qualification Card November 28, 1989-

'CKL'WQ-007, iTurbineLBuilding.0perator .

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," < Revision 1 Watch Qualification Card May 24.-1989=

y FireLProtection Revjew

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, e" ' ' 1 3 'Revisio'n KPN-C-307,[. 1 Revisions and Close Outs July 24, 1989 o . ,

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, KPN-C-30'l, Initiation of Plant Modification 4, _ Revision 9- Requ'ests - July 24,'1989

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201566) LInstallation of Fire Dampers in' February 20, 1986

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nie ,ca1 :E-698HE-H Modify' Diesel Generator Control March 15, 1988 Circuit

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0'1855" Addition.of Firewrapping to Conduits July 13, 1985 n:

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102928 Correct' Wiring-Discrepancies July 5, 1989

, w-4 10328s' Rewire Halon Release Contacts- March 29, 1990 x ,

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