IR 05000482/1990031

Insp Rept 50-482/90-31 on 900801-0914.Violations Noted.Major Areas Inspected:Plant Status,Operational Safety Verification & Monthly Surveillance Observation

ML20062D006
Person / Time
Site:	Wolf Creek
Issue date:	09/14/1990
From:	William Jones NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20062D000	List: IR 05000482/1990031 ML20062C997 ML20062D002
References
50-482-90-31, NUDOCS 9011050228
Download: ML20062D006 (12)

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APPENDIX B I i V.S. NUCLEAR REGULATORY COMMISSION EE REGION IV

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NRC Inspection Report: 60-482/90-31 Operating License: NPF-42 2 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, Coffey Cour.ty, Burlington, Kansas Inspection Conducted: August 1 to September 14, 1990 l

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Inspectors: M. E. Skow, Senior Resident Inspector project Section D, Division of Reactor Projects

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L. L. Gundrum, Resident Inspector Project.Section D, Division of Retetor Pro.iects ,

l Approved: Ob3 tehk to W. B. Jones, Acti(3) Chief, Project Section D Dat'e '

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Division of Reactor Projects Inspection Summary Inspection Conducted August 1 to September 14,1990 (Report 50-482/90-31)

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Areas Inspected: Routine, unannounced inspection including plant status, operational safety verification, monthly surveillance observation, and monthly maintenance observatio Results: Three events related to inadequate work control practices were identified this inspection' period. These events involved a. test of the main

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generator voltage regulator, improper installation of scaffolding around

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safety-related equipment, and an unmonitored offsite release of t potentiall contaminated fluid. The licensee's safety assessment' program was not effective in identifying and correcting the-programmatic deficiencies related:to the main

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generator voltage regulator test'. '

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Two violations were identified regarding the test on the main generator voltage -

regulator >underexcited reactive ampere limit (URAL). The1first: violation involved the failure to conduct the test in accordance with~en approved.ttst procedure. There consequently was.no review of the potential affect on the ~

, plant safety busses prisr to performing the test. When theitest refulted in

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- unexpected alarms and low voltage on the emergency busses, the plant staff did not initiate a deficiency report as required by their procedures (the second violation) and timely corrective actions were not taken to ensure that the lack of controls which allowed the performance of the URAL test were correcte A maintenance truck struck + building inside the switchyard (paragraph 3.e).

The licensee had taken previous corrective action to control access to the switchyard, which included notifying the main control room prior to entering, ,

The licensee enhanced the_ access controls to consider the emergency diesel generators status prior to allowing trucks into the switchyard. The licensee's actions in response to this event, as well as a pinned spring support (paragraph 5.c), and to a small fire on a reactor makeup water transfer pump (paragraph 3.c) was goo i A surveillance test procedure was performed which had an excessive amount of revisions. The revisions resulted in a procedure that did not readily provide a clear and usable format (paragraph 4 a).

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i-3-DETAILS Persons Contacted Principal Licensee Personnel B. D. Withers, President and CEO

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J. A. Bailey, Vice President, Nuclear Operations

1. • F. T. Rhodes, Vice President, Engineering and Technical Services _

1. G. D. Bcyer, Plant Manager

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

1. • H. K. Chernoff Supervisor, Licensing , ,

1. • T. T. Deddens, Jr. , Outage Manager

• M. E. Dingler, Manager, Nuclear Plant Engineering (NiE) Systems ,

1. • R. 8. Flannigan, Manager, Nuclear Safety Engineering (NSO

1. C. W. Fowler, Manager, Instrumentation and Control (' 6C)

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1. N. Hoadley, Manager, Plant Design, NPE l

1. • R. W. Holloway, Manager, Maintenan:< and Modications >

1. • W. M. Lindsay, Manager, Quality Assurance (QE I

• R. L. Logsdon, Manager, Chemistry i

• T. S. Morrill, Manager, Radiation-Protection i

• D G. Naylor, Operations Support Supervisor

• D G. Moseby, Supervisor, Operation #*W. B. Norton, Manager, Technical Support

1. C. E. Parry, Director, Quality-

• J. M. Pippin, Manager, NPE

1. C. M. Sprout, Section Manager, NPE, WCGS '

1. • J. D. Weeks, Manager, Operations

1. • S. G. Wideman, Senior Licensing Specialist L #*M. G. Williams, Manager,-Plant Support .

l *J. A. Zell, Manager, Training l

l The inspectors also contacted other members af the' licensee's staff during

! the inspection period to discuss idertified issues. -

' * Denotes those personnel in attendance at the exit' meeting held on August 31, 199 # Denotes those personnel'in attendance at'the exit meeting held on 1 September- 14, 1990, f

Plant Status The plant operated in Mode 1 (at'or near 100 percent reactor thermal ;

power) during the inspection period. There were no reactor or turbine

!- trip . Operational Safety Verification -(71707) and Evaluation:of Licensee Self-Assessment Capability (40500)

The purpose of this inspection was- to ensure that the facility.-was being'- I operated safely and'in conformance with the license and regulatory i

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requirements. It-also-was to ensure that the-licensee's management i control systems were effectively-promoting 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 (LCOs), review of a corrective actions, and review of facility record l t

Areas reviewed during this inspection included, but were not limited to, control room activities, routine surveillances, engineered safety feature q

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operability, radiation protection. controls, fire protection, security,. #

plant cleanliness, instrumentation and: alarms, deficiency reports, and 3 corrective actions. Selected inspector observations are_ discussed below:' l On August 3, 1990, the licensee identified that a testable'checkvalve t in the auxiliary feedwater (AFW) system was prevented from fully opening by scaffolding which had been erected in.the area. The ;

checkvalve was located in the turbine ' driven AFW pump (TDAFWP)

suction line from the condensate storage tank. The extension arm on the testable checkvalve was restricted from movcment .to the full cpen i position by the scaffolding. This limited the checkvalve movement '

to approximately 24 percent of full ope i After learning of this occurrence, the1 inspectors began a walkdown of other areas where scaffolding-was present, The_ inspectors discovered an instance where scaffolding had the potential of blocking the movement of a local sample isolation ve1ve for the safety injection-pump miniflow header. A ccmplete walkdown of the remaining scaffolding was then per formed by the inspector and results engineering personnel. A third instance was identified where j scaffolding could potentially interfere'with a manually operated 3

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valve. The licensee-immediately removed the scaffolding from around l the TDAFWP suction line, and reoriented the' scaffolding around the j manual valves.

l l The licensee's program for control of scaffolding relied upon the

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scaffold crew to recognize and avoid potential: equipment-interferences. The licensee issued Licensee Event-Report (LER)90-018, " Technical Specification Violation-Improper Scaffold Installation Causes Inoperability of Turbine Driven Auxiliary Feedwater Pump," on September 4,1990. The LER stated that the TDAFWP had been 1eperabl e from; July 25 to August 3, 1990, as a

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result of the interfemance with the suction checkvalve. The Technical Specification (TS) Action Statement, TS 3.7.1.2,. allowed '

the TOAFWP to be inoperable up tc 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> without-requiring a p'ent shutdown provided all the action statement requirements are met. The NRC staff questioned the operability analysis provided in the LE In particular, the staff questioned whether adequate net positive suction head (NPSH) may have actually existed. The. licensee

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performed an analysis of the NPSH requirement for the TDAFWP and ;

whether the checkvalve opening to 24 percent would would meet the !

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-5- l NPSH requirement, The licensee found that adequate NPSH existed for .

condensate storage tank (CST) levels down to 2 feet above the bottom i of the tank. The plant control systems were set to automatically shift the TDAFWP1 suction from the CST to the essential service water i system when the CST level reaches about 6.5 feet above the bottom of the tank. The licensee stated that they would revise the LER to ,

include the additional informatio '

In this instance, the safety significance of the scaffolding interferences were minor but demonstrated the potential for rendering-safety-related equipment inoperable. During discussions with the

' licensee about their corrective action, the inspectors expressed concern that the scaffold crew and their supervisor did not appear to: 4 recognize the safety significance and operating characteristics of the various systems and components in the plant.where they install  !

scaffold. The licensee stated that they would provide additional:  :

training for personnel that perform-scaffold inspection duties. The i inspectors will review the licensee's corrective actions and the  !

revised LER during a subsequent inspectio ! On August 16, 1990, at about 10:21 a.m. CDT, a small fire was discovered in the "A" reactor makeup water transfer pump, Operators had previously found.that the breaker for the pump motor had trippe Workers noticed smoke in the auxiliary building =and a fire alarm was "

received in the control room. The fire-brigade was dispatched-to the pum One fire brigada member, who was working near the= area, .

noticed oil leaking down the pump shaft and a small flame beginning to form at the base of the vertical pump motor. He'promptly extinguished the fire with dry chemical. The licensee found that the- -

pump had a seized bearing and a bad phase in the motor windings. The  ;

l motor bearings had been replaced during the preceding night. .There- i

was no adverse radiological consequence because of the fire.. The >

} fire was contained to a small area and no' noticeable' smoke' damage

! occurred. The licensee planned to replace the reactor makeup water j transfer pump 1 assemblies with different type pumpCdue to continuing  ;

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problems with the bearings. The licensee's response to the fire was j goo < On August 24, 1990, the inspector reviewed a Defect / Deficiency Report '

(DDR) which had been initiated by a-QA engineer.: The.00R ident'fied a finding from a QA surveillance. The surveillance, Licensee Quailty:

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Assurance Surveillance TE: -53359 S-1845c" Vendor Work Plans,"

identified a finding, QPV 7/90-060, concerning attest performed on the main generator voltage regulator. .The test was performed on.Ma .

16, 1990, and involved verifying / adjusting the< main generator exciter -

regulator URA The test required that the. main generator voltage regulator.

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controller be adjusted :to' verify that the URAL was properly set. The 1 controller setting was lowered which resulted ina significantly, l

, lower voltage en electrical buses throughout the plant. The~ lower ,

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-6-l voltage caused one of four undervoltage sensors to trip on each of (

the two safety-related electrical busses. An automatic load shed of the safety-related busses would have occurred if two out'of four undervoltage sensors had tripped '.or the as aciated bu Automatic emergency diesel generator: start signals would have been '

received on the loss.of power to its associated bus. Alarms were received in the control room which indicated that a main generator '

trip was: imminent. In addition, low voltage was sensed by most of'

the nonsafety-related electrical busses. At the time this adjustment t test was performed, the "A" diesel generator was out of service fo i maintenance and would not have started on a loss of power to its-l electrical-bu Surveillance finding, QPV 7/90-60, identified that-the licensee had .

violated their approved procedures by not performing the test . .

in accordance with a reviewed and approved procedure as required by TS 6.8.1. There was no apparent review to determine that the test ,

did not pres'ent an unreviewed safety question or its potential..to !

affect safety related equipment. The test was performed using an -

unapproved postmaintenance test instruction that;was given in Work l Request (WR) 01379-8 The inspector _noted that the WR did~not ,

identify limitations on the generator output voltage adjustment, the q possibility of creating an actual undervoltage condition,~or that a main generator trip-could occu The licensee has initiated corrective action to place all work on'

equipment in service-under procedural control. These corrective actions were initiated' following the inspectors inquiries into,the event. The inspector did note that the corrective e ion for the QA )

finding was scheduled by the licensee to be completed by December 31r '

1990. The NRC staff concurs with the~QA engineer's finding that the'-

i the test was not conducted in accordance with a properly reviewed and l approved procedure which would have included a review to determine

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l the affect of the test on' safety related' equipment and the potential ,

! for an unviewed safety' questio This is a violation of TS 6.8.1 .

(482/9031-01). The enforcement criteria specified-in.Section V.A of ,

the Enforcement Policy was reviewed for consideration as 'a noncited violation The staff-found that the licensee;had-not-promptly identified the event, nor had the scope of the event _been evaluated.

E Therefore, this will remain a cited violatio The inspector reviewed the licensee's corrective action program to-determine what prog *ammatic controls should have resulted in the event being identified for'further evaluation. The' licensee's approved Procedura KGP-1210, Revision 3, " Programmatic Deficiency Reporting," required that a programmatic deficiency report be-initiated for a significant condition adverse to quality that 1 i

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includes a.ceviation from expected' plant performance. "During the;

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performance of the test, the undervoltage condition.that; occurred was -t unexpected by the licensee and the vendor representative on site '

i observing the tes The operators failed.to initiate'a deficiency

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report when the test deviated from the expected plant performanc l This failure to initiate a programmatic deficiency report is an F

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apparent violation (482/9031-02).. The licensee also has other means.

! of bringing to management attention an event of this type that may 1

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have been appropriate, but none was use The inspector reviewed the licensee's corrective' actions for this event. It was noted that the licensee's management'did-not discuss ,

the event with the control room crews until after the management meeting with the NRC staff. This was approximately 3. weeks after the inspector began inquiring about the event. The discussions that were held with the operators involved the need to be fully cognizant of all ongoing work, the potential impact and consequences of the work, and to stop or prevent activities which involve potentially unacceptable safety risks. The licensee's failure to promptly ;

implement corrective action to ensure-that the operating crews properly controlled testiry activities is a further example of the ,

above cited violation (482/9031-02). j On September 11', 1990,' a management meeting was held _with-the licensee in the NRC Region IV; office. At the meeting, the_ event, '

root cause, and corrective actions were' discusse The licensee -

representatives at'the meeting'were not adequately informed about the meaning and significance of certain control-room alarms as listed by j the control room alarm printer.- As a result, the perception of~the NRC staff present .at the meeting was that the voltage sensed on the safety busses and throughout the plant were not as low as?was the

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actual case. The staff's perception following the meeting was that -

the voltage decreased to 90 percent'of normal voltage. However, voltage actually decreased to approximately:70 percent of normal voltage. After additional questions by the inspector following'the meeting, the licensee clarified the :information provided to-the staff

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during a teleconference on' September 14, 199 The licensee's self-assessment of the URAL event was weak. The event was identified by a licensee QA auditor during an audit of " Vendor Work-Plans." The sensitivity demonstrated by^the auditor in identifying the 10 CFR 50.59 was excellent. However, the.11censee's self-assessment in dealing with this significant event,'once identified, was weak. Licensee efforts appeared to be directed toward the original QA audit finding rather than expanding-self-assessment e narts to include the areas identified in the-apparent violati I On August 9, 1990, a plant' safety-review committee (PSRC) meeting was attended by.the inspector. A quorum of committee members was-present. The information covered at the meeting had been distributed <

July 30, 1990, to allow ample time'for review by the-committee members. prior to the meeting. 'All items brought before the committee ,

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were approved. The inspector found that the PSRC.provided an f

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i adequate review of the material presented during.this meting.

However, the NRC staff noted the PSRC review of LER 90-018, for the restricted checkvalve, should have ensured that an appropriate-operability determination had been made and that the LER text clearly.'

supported their assessmen On August 27, 1990, the-shift supervisor discovered .that workers were I pumping water from the turbine building oily waste sump to storm drains bypassing radiation monitors. .This was promptly' stopped by the shift superviso The operation of the temporary pumping method was to allow repairs to the.line normally used to pump down the oily waste sump, which is radiologically monitored. This was an example of lack of communication and control of planned maintenance activity with the control room. The amount released was estimated by the-licensee to be less than 100 gallons with activity levels well below NRC limits. This determination was based on a: sample;of the sump by '

chemistry technicians immediately following .the' event. The licensee planned to submit an LER on this event. The staff is reviewing the recent' problems concerning work control in the' aggregate. . .The evaluation of the licensee's corrective actions to this specific event will be. reviewed and the findings discussed in a future inspection repor ',

, On September 11, 1990,4 while the plant was at 100 percent power, a'

Kansas Gas and Electric boom truck struck a building inside the owner '

contr 11ed area 345 KV switchyard. Workers were backing the; truck -

out from around a building in the switchyard following maintenance on

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a nearby breaker. The truck dented the. steel. building near the. roof'

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in a corner of the building. Damage to;the corner was apparent from inside the. building. The batteries used'for backup control = power to the switch gear were located near the' damaged corner of the; building.

The batteries were not damaged. No damage occurred to.any outside

switchyard equipment.

Kansas : Gas and Electric, one of'the Wolf' Creek l Generating Station owners, maintains the switchyard;.however,.the R

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licensee, Wolf Creek Nuclear-Operating Corporation, controls and also-has routine access to the switchyard 'And performs some switchyard H

, operations when directed by the owner. At the time of the event, one diesel generator was out of service for maintenance.. The licensee has' reminded the control room operators to be sensitive to the maintenance activities- taking place. in the switchyard.-- The licensee's corrective actions included requiring personnel to notif the control room prior to taking a truck into the switchyard, and -

that access to the switchyard will be restricted when a diesel generator is out of servic ,

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Events identified during this inspection period demo ~nstrated continuing problems with with the control of work. activities-'and' assessment of.the' r H' events. The unavailability of an emergency diesel' generator indicates that a heightened. sensitivity to events which could disrupt offsite power.

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. . Monthly Surveillance Observation (61726)

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The purpose of this inspection was to ascertain whether surveillance of

! safety-significant systems and components was being conducted in

accordance with 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 procedure, o The surveillance procedure was in conformance with TS requirements, o The operating system and test instrumentation was within its current b calibration cycle, o Required administrative approvals and clearances were obtained prior to initiating the test, o LCOs were met and the system was properly returned to service, and o The test data were accurate and complete and the test results met TS requirement The surveillances witnessed and/or reviewed by the inspectors'are listed below:

o STS EF-925, Revision 2, " Containment Coolers Flow Verification;"

o STS KJ-005B, Revision 12, " Manual / Auto Start, Synchronization, and i Loading of Emergency Diesel Generator NE02;" and o STS NB-005, Revision 6, " Breaker Alignment Verification."

Selected inspector observations are discussed below: 4 On Monday August 6,1990, the procedures for STS EF-925, " Containment Coolers Flow Verification," were reviewed. -Revision 2 was opproved

' October. 16, 1989. Procedure Change MI 90-539, dated June 8, 1990, replaced Revision 2 in its entiret ~

Procedure Change MI 90-550, . '

dated June 10, 1990, corrected a. typographical error on MI.90-53 Procedure Change MI 90-575, dated July 5,1990, was a complete rewrite of the procedure because of Plant Modification *

Request No. 3345 that developed a .new method of measuring flo '

Procedure Change MI 90-577, dated July 6,1990, was issued to correc the valve lineup.in MI 90-575. Procedure Change MI'90-646, dated j August 6,1990, was issued to. clarify the range of test gages to be- ,

used. The-test was completed on August 6 and.the' flow was determined to be within the requirements of TS 4.6.2.3(a). All of -the procedure changes were marked as temporary and' permanen ;.

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The five attached changes and revisions to the procedure made it difficult to ensure that the proper steps were being performed. -The date of the last total rewrite of the procedure was July 6,1990, and ,

the procedure was performed on August 6, 199 L

.i The operations staff had to expend additional time to evaluate what !

steps were to be performed based on an approved procedure with five l changes attached, It was the observation of the inspector that the l procedural rewrites increased the potential for missing steps withi ,

the procedure or for performing the incorrect step, On August 20, 1990, operators took the "B" emergency diesel generator out of service for maintenance. They failed to-perform:STS NB-005 within the TS 4.8.1.1;1 and -4;8.3.1-required 1-hour time limi They recognized their error and performed the surveillance 5 minute late. . The licensee planned to submit an LER on this event. The  ;

inspectors will review the LER and report any fi.ndings in a subsequent report.'

l The revisions made to the surveillance precedure were not indicative of the licensee's established program. In this case, the procedure should not have been performed until the surveillance test prw edure was prepared '

in a format that would have reduced-.the potentialt for missing steps or performing the wrong steps. The one failure to perform a surveillance test on time was the. result of an individual's inattention-to detail and did not appear to a programmatic problem. Actual performance of.the '

procedures appeared adeqJate. The licensee staff appeared knowledgeable of the tasks that they performe . Monthly Maintenane.e 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 Mems verified in this inspection included:

o Activities did not violate limiting conditions.for operations-ane

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redundant components were operable, j

o Required administrative approvals and clearances were obtaineci before initiating work, o Radiological +ontrols were properly impiemented,

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o Fire prevent on controls were. implemented,

'o Required alignments and surveillances to verify postmaintenance operability were performed,

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o Replacement parts and materials used were properly certified, o Craftsmen were qualified to_ accomplish the designated task and additional t(:hnical expertise was made available when needed, o QC hold points and/or checklists were used and QC personnel observed designated work activities, and

o Procedures used were adeouate, approved, and up to dat l Portions of selected maintenance activities regarding a WR were observe The WR and related documents reviewed by the inspectors is listed below:

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WR 50250-90 Limitorque operator. maintenance Selected inspector observations are discussed below: j On August 8, 1990, the inspector observed the. performance of maintenance on the AFW system Limitorque motor operator fo Valve ALHV0031. The 'rintenance activity was performed in accordance +

with approved Procedure MGE E00P-02, Revision 7,'and Procedure Change MI 90-195. The electrical maintenance and QC personnel were-knowledgeable of the procedure and performed the work in accordance with +.he procedur <

The inspection of the motor-driven-AFW' Pump "A" was performed under WR 50250-90. There were no problems noted in the performance of_ this ,

WR, The'WR did have a box checked that a . radiation work permit (RWP)

was required. The worker had annotatediin the blo'ck for RWP No, thtt step as N/A. No RWP was actually required for the work-activity and'

did not af fect the performance of' the 'WR. 'Two. other. WRs 'being performed in the AFW pump rooms were: reviewed and did not require an RW 'f Maintenance personnel found a spring hanger on the "B" residual heat removal (RHR) pump suction pipe pinned. The support contained two spring assemblies,'one on either side of the pipe. 'One of the two 1 spring assemblies was pinned. The' pinned assembly restricted .

i movement of the pipe due to thermal expansion. _ Operators immediately l declared'the pump out of service-and entered the-72-hour LCO in

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accordance with TS 3.5.2. When the: hanger was' subsequently unpinned, no movement in the.hancer was noted.- Enqineering personnel _ analyzed-the thermal' stress on the pipe that would.have occurred-with the'

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system in operation. The stresses were1found to.be Within' code '

allowable limits. The" licensee _ removed the. hanger for-testint and verified that it was operable. 'The.11censeeIhad.not determined when the pin was installed. The program tn-control' pinning of spring .

hangers had been previously st engthn ed. Theilicenseeibelieves'the' a ,

hanger may have been pinned 'during_ construction"or early in plant '

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operation. At the end.of the inspection period,-the licensee was reviewing when the pin may have been installed and whether other ;

hangers may be affected. -The current pinnirq program was also under l review to ascertain whether any weaknesses. . :ist in the the program. .-

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The maintenance workers appeared qualified and trained for the. tasks that i they performed. Licensee's immediate corrective action to finding a ,

spring support pinned =was good, and planned followup corrective action '

appeared acceptabl ; Exit Meeting (30703) .i i

The inspectors met with licensee personnel (denoted in paragraph 1) on i August 31 and September 14, 1990. The inspectors ~ summarized the scope and- !

findings of the inspection. The licensee did not identify as proprietary 1 any of the information provided to, or reviewed by, the inspector '

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