IR 05000482/1998008

Insp Rept 50-482/98-08 on 980302-06.No Violations Noted. Major Areas Inspected:Operations,Maintenance,Engineering & Plant Support

ML20217F975
Person / Time
Site:	Wolf Creek
Issue date:	03/30/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20217F971	List: IR 05000482/1998008 ML20217F968
References
50-482-98-08, 50-482-98-8, NUDOCS 9804020038
Download: ML20217F975 (23)

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ENCLOSURE

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U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-482 License No.: NPF-42 Report No.: 50-482/98-08 Licensee: Wolf Creek Nuclear Operating Corporation Facility: Wolf Creek Generating Station Location: 1550 Oxen Lane, N Burlington, Kansas Dates: March 2-6,1998 inspector (s): D. G. Passehl, Senior Resident inspector, Callaway Plant L. E. Ellershaw, Reactor inspector D. N. Graves, Senior Project Engineer B. A. Smalldridge, Resident inspector, Wolf Creek Generating Station Approved By: W. D. Johnson, Chief, Project Branch B Attachment: SupplementalInformation

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9904020038 900330 PDR ADOCK 05000482 G PDR

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EXECUTIVE SUMMARY Wolf Creek Generating Station NRC Inspection Report 50-482/98-08 Ooerations

• The program foridentifying and resolving problems was good. A review of a sample of the licensee's followup of problems revealed that line organization personnel were property implementing the program (Section 01.1).

• A review of a sample of self assessments performed by the line organization found the assessments to be comprehensive and sufficierstly critical (Section 07.1).

• A review of a sample of quality assurance organization audits and surveillances found the audits and surveillances to be comprehensive and sufficiently critical. A review of the followup of some findings revealed that licensee personnel were property evaluating the findings. The licensee was on schedule for performing all audits as required by the Technical Specifications (Section 07.2).

. Implementation of the industry operating experience feedback program was satisfactor A previously identified weakness regarding timeliness of information review was satisfactorily addressed (Section 07.3).

- The licensee made satisfactory progress in implementing recommendations from the two completed common cause analyses and an industry peer review (Section 07.4).

Maintenance

• Maintenance personnel appropriately evaluated and dispositioned the sample of problems reviewed by the inspectors (Section M1.1).

- The sample of maintenance department self-assessments reviewed was good. The licensee's followup to the findings was appropriate (Section M7.1).

. The sample of quality assurance audits reviewed was good. The licensee's followup to the findings was appropriate. The licensee was on schedule for performing all audits as required by Technical Specifications (Section M7.2).

Enaineerino

- The Updated Final Safety Analysis Fidelity Review Project Plan did not provide guidance, discussion, or training in order to ensure proper implementation of the corrective action program. In addition, there was failure to initiate performance improvement requests for some discrepancies that were identified as significant. This item required further review to determine whether conditions existed that may violate or be in conflict with the operating license (Section E1.1),

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• _ Other aspects of the licensee's program for identifying and resolving problems in engineering were good. In general, engineering department personnel were proper 1y implementing the program (Section E1.2).

• The sample of engineering department self assessments reviewed was good. The licensee's followup to the findings was appropriate (Section E7.1).

~ Plant sanoort

. The sample of quality assurance audits in the radiological protection and chemistry area reviewed was good. The licensee's followup to audit findings was appropriate

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Report Details 1. OPERATIONE 01 Conduct of Operations 01.1 Problem Identification and Resolution Insoection Scoce (40500)

The inspectors evaluated whether operations department personnel were appropriately identifying problems and implementing timely corrective actions. The evaluation included review of operability evaluations, reportability determinations, and performance improvement request Qbservations and Findinas The inspectors observed that the licensee was appropriately identifying and classifying problems. In 1997, the licensee initiated 4,213 pe.rformance improvement requests. Of these,144 were classified as "significant"in accordance with Administrative Procedure AP 28-001, " Performance improvement Request," Revision 9. From January 1 through March 6,1998, the licensee initiated 633 performance improvement requests. Of these,22 were classified as "significant."

The inspectors reviewed the applicable procedures. Procedure AP 28-001 specified actions to take upon discovery of a problem or potential problem. Appropriate guidance was included in the procedure, and examples included in the procedure demonstrated an appropriate threshold for identification and use of the proces Administrative Procedure AP 26C-004, " Technical Specification Operability," Revision 1, provided instructions for determining operability of components, systems, and structures required to comply with Technical Specifications. The procedure provided sufficient guidance with regard to making operability determinations, including actions to take if additional technical assistance was neede The inspectors reviewed a sample of performance improvement requests. The requests were reviewed for:

. initial identification and characterization of the problem, including operability and reportability;

. elevation of problems to proper level of management for resolution;

. root cause analysis;

• implementation of corrective actions;

. evaluation of repetitive conditions; and

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-2-ec evaluation of corrective action scope, including applicable related systems, equipment, procedures, and personnel action The inspectors identified no concem The inspectors reviewed a sample of the "significant" performance improvement requests for effectiveness followup review. Procedure AP 28A-001 required that, for each performance improvement request classified as significant, a followup be performed in order to determine the effectiveness of the corrective actions., The inspectors observed that the effectiveness followup reviews were either performed or scheduled and had no concem Conclusions

- The program for identifying and resolving problems was good. A review of the licensee's followup of some of the problems revealed that line organization personnel were properly implementing the progra Quality Assurance in Operations 07.1 Review of Operations Department Self-Assessments insoection Scone (40500)

The inspectors reviewed four self-assessments performed by operations department personne Observations and Findinas

' The inspectors reviewed Administrative Procedure AP 28D-001, "Self Assessment Process," Revision 2. The procedure provided sufficient guidance for the conduct of self assessment activitie The inspectors observed that the self-assessments were satisfactorily conducted in accordance with the procedures in general, the assessments were thorough and critical. Performance improvement requests were initiated as required in accordance with Procedures AP 28D 001 and AP 28A-001, Conclusions --

A review of a sample of self-assessments performed by the line organization found the assessments to be comprehensive and sufficiently critica .

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-3-07.2 Quality Assurance Auditt Insoection Scoce (40500)

The inspectors reviewed three surveillances and one audit performed by the quality assurance organization of operations department activities. The inspectors evaluated whether the licensee had performed all audits as required by Technical Specification The inspectors evaluated followup reviews performed by the quality assurance organizatio The inspectors observed that some quality assurance audits were reviewed during NRC inspections conducted over the past several months. The inspectors focused this inspection on those audits not reviewed during the previous inspection Observations and Findinas The inspectors reviewed a list of completed quality assurance audits. The inspectors also reviewed the licensee's schedule for performing the audits. The inspectors observed that the licensee was in compliance with Technical Specification Requirement 6.5.2.8, " Audits." The inspectors identified no concem The inspectors reviewed Administrative Procedure AP 20A-004, " Audit Procedure,"

Revision 3. The procedure provided sufficient guidance to perform the required audits and to document audit findings appropriatel The inspectors reviewed Self-Assessment K-480, " Indoctrination and Training (Operations)." This was an audit conducted in accordance with Procedure AP 20A-00 The scope of the audit was comprehensive and had mainly positive findings. One weakness was identified regarding operator knowledge of reactor theory and thermodynamics. The licensee initiated action ta increase the emphasis on training in these areas. The scope of the audit appeared comprehensive and satisfied the requirements of Technical Specification 6.5. .

The inspectors also reviewed three surveillances conducted by the quality assurance organization of operations department activities. The surveillances involved:

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. emergency diesel generators surveillances;

. plant winterization activities; and

. qualifications of members of the Nuclear Safety Review Committe The quality assurance surveillances were comprehensive and sufficiently critica Performance improvement requests were initiated as needed. The inspectors reviewed I two performance improvement requests the licensee had initiated to resolve potential {

deficiencies with these surveillances. The inspectors had no concern l l

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-4- Conclusions A review of a sample of quality assurance organization audits and surveillances found the audits and surveillances to be comprehensive and sufficiently critical. A review of the followup of some findings revealed that licensee personnel were properly evaluating the findings. The licensee was on schedule for performing all audits as required by the Technical Specification .3 Ooeratino Experience Feedback Proaram Insoection Scoce (40500)

The inspectors reviewed the licensee's operational experience feedback progra Observation and Findinos The inspectors reviewed Administrative Procedure AP 20E-001, " Industry Technical information Program," Revision 3. This procedure established the guidelines for the review and analysis of industry technicalinformation. The procedure provided sufficient guidance to ensure that industry information was reviewed, evalualed, and translated into actions as necessar The licensee initiated performance improvement requests for each document received by the Industry TechnicalInformation Program Coordinator. The coordinator performed an initial screening and assigned the performance improvement request to the appropriate manager for evaluatio NRC Inspection Report 50-482/97-05 documented a weakness with the timeliness of some evaluations performed by the licensee. This weakness appears to have been resolved. A management expectation existed that the initial evaluation of performance improvernent requests initiated in response to industry events be completed within 30 days. The inspectors questioned seven personnelin the licensing, performance assessment, and corrective actions departments on the time allowed to complete the initial evaluation of performance improvement requests initiated in response to industry events. All knew of the 30-day expectation. Although several of the individuals thought the limit was proceduralized, the expectation appeared to be well know The inspectors reviewed Performance improvement Request 97-2856 which had been initiated to address actions to be taken in response to Institute of Nuclear Plant Operations' Significant Operating Experience Report 96-01. The operating experience report had not been fonvarded to the Industry Technical Information Program Coordinator and thus had not been screened for applicability. Although no changes to Procedure AP 20E-001 were deemed to be necessary, the licensee discussed the issue j internally and personnel were made aware of the necessity to distribute correspondence, documents, and other industry information to the appropriate groups for review. The inspectors considered these actions to be appropriat _ _ -- a

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-5- Conclusions implementation of the industry operating experience feedback program was satisfactor A previously identified weakness regarding timeliness of information review was satisfactorily addresse .4. Review of Common Cause Analyses Insoection Scope (40500)

The inspectors reviewed the licensee's progress in implementing recommendations from two common cause analyses and an industry peer revie Observations and Findinas The licensee performed a common cause analysis during July and August 1997. The licensee performed the analysis to investigate ways to improve human performanc The final common cause analysis report was issued on September 10,1997, and included a number of recommendation During an NRC inspection in October 1997, documented in NRC Inspection Report 50-482/97-19, the inspectors identified that the licensee had not initiated a comprehensive action plan to evaluate or implement the recommendations. The licensee initiated Performance improvement Request 97-3757 to ensure that all of the recommendations were properly evaluated and implemented if require The inspectors reviewed the status of Performance Improvement Request 97-375 Although the performance improvement request was not closed, most of the recommendations had been implemented. Others were still under consideration. The licensee's progress was acceptable. While implementation of all of the corrective actions was not complete, completion dates were appropriately scheduled, and the proposed corrective actions were satisfactor The licensee conducted a second common cause analysis in October 1997. The licensee initiated many performance improvement requests based on this analysis. The inspectors reviewed a sample of the performance improvement requests. The inspectors determined that the proposed corrective actions appeared appropriate and completion dates were appropriately schedule The inspectors observed that several of the recommended areas for improvement from the second common cause analysis 'were similar to those of the original analysis. One example was a need to improve work procedures. In these instances, the licensee closed the new performance improvement requests by incorporating them into the performance improvement requests from the earlier analysis. The inspectors determined that the closed performance improvement requests were dispositioned appropriately.

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-6-The inspectors observed that the duplicate findings from the two common cause analyses were due, in part, to lack of a procedure describing the common cause analysis evaluation process, unclear trend coding criteria, and the frequent use of" unknown" as a trend code. The licensee initiated performance improvement requests to address these area A peer review of the licansee was conducted in May 1997 by an industry grou Performance improvement Request 97-2402 was initiated to address identified areas for improvement. Corrective actions had been completed regarding reconfiguring the organization that provided oversight of the corrective action process and human performance monitorin Other completed corrective actions were already in progress at the time of the evaluation and included things such as error reduction training for licensee staff, implementation of Performance Improvement Request Coordinators, and implementation of the Corrective Action Review Board. Other corrective actions related to specific findings were scheduled for completion with due dates assigned. The proposed corrective actions and due dates were appropriat A common cause analysis evaluation for the fourth quarter of 1997 was in progress at the time of this inspection. The inspectors did not review the preliminary finding Conclusions The licensee made satisfactory progress in implementing recommendations from the two completed common cause analyses and an industry peer revie .5 PJant safety Committee Insoection Scoce (40500)

The inspectors attended one plant safety review committee meetin Observations and Findinas The inspectors attended the plant safety committee meeting on March 4,1998. The meeting considered procedure changes, unreviewed safety question determinations, a design change package, a plant modification request, and a reportability evaluation reques Discussion and interaction among the plant safety committee members and presenters of issues was satisfactory. The plant safety committee recently adopted two methods to facilitate gaining the necessary information for decision making:

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+ Presenters to the plant safety review committee were verbally given the expectation that information pertinent to decisions should be provided in the presentation; and

. Plant safety committee review members directed lines of questioning to the presenter that were focused on assuring that information necessary for decision making was clearly understoo The inspectors observed that the licensee satisfactorily employed the new method The committee did not approve some of the items presented for various reasons, including lack of clarity of supporting documents and lack of preparation by the presenters. The licensee re-emphasized to the presenters the need for clarity of supporting documents and adequate preparation. The inspectors had no concems with the committee's disposition of the items presente Conclusions Licensee performance during an observed Plant Safety Review Committee was satisfactor II. MAINTENANCE M1 Conduct of Maintenance M1.1 Problem Identification and Resolution Insoection Scope (40500)

The inspectors reviewed a sample of performance improvement requests, nonconformance reports, and action requests, and evaluated whether maintenance department personnel were appropriately identifying problems and implementing timely corrective action Observations and Findinas The inspectors reviewed the performance improvement requests, nonconformance reports, and action requests for:

+ Initialidentification and characterization of problems;

. Elevation of problems to proper level of management for resolution;

- Root cause analysis;

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. !mplementation of corrective 3ctions;

. Evaluation of repetitive conditions; and

. Evaluation of corrective action scope, including applicable related systems, equipment, procedures, and personnel action The inspectors observed that, in general, maintenance department personnel were appropriately identifying, evaluating, and implementing timely corrective actions for identified problem The inspectois reviewed a sample of the "significant" performance improvement requests to determine if effectiveness followup reviews were appropriately performed or scheduled. The inspectors had no concem Conclusions Maintenance personnel appropriately evaluated and dispositioned the sample of problems reviewed by the inspector M7 Quality Assurance in Maintenance Activities M7.1 Review of Maintenance Deoartment Self-Assessments Insoection Scope (40EA01 The inspectors reviewed self-assessment activities performed by the maintenance departmen Observations and Findinas The licensee conducted many self-assessments in the maintenance area. The inspectors observed that, in general, the self-assessments were thorough and had many good recommendations. The inspectors observed that the licensee initiated performance improvement requests as appropriate for weaknesses and recommendations. The inspectors selected a sample of performance improvement requests written for the weaknesses and recommendations. The inspectors identified no concern One self-assessment reviewed was Self-Assessment SEL 97-014. " Post Maintenance Testing." This self-assessment was conducted by an outside contractor and the report was not written in the normal format and style. One consequence was that the recommendations were not clearly identified and summarized. However, the licensee performod a thorough review of the report and extracted the implicit and explicit recommendations. The licensee initiated performance improvement requests as appropriate, i

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The licensee developed a training plan to incorporate some of the recommendations in the postmaintenance testing self-assessment. The inspectors observed that the training plan was comprehensive in addressing the recommendation Conclusions The sample of maintenance department self-assessments reviewed was good. The licensee's followup to the findings was appropriat M7.2 Quality Assurance Audits Insoection Scoce (40500.)

The inspectors evaluated whether the licensee had performed all audits as required by Technical Specifications. The inspectors also evatusted followup reviews performed by the quality assurance organizatio The inspectors observed that some quality assurance audits were reviewed during NRC inspections conducted over the past several months. The inspectors focused this inspection on those audits not reviewed during the previous inspection Observations and Findinas The inspectors reviewed a list of completed quality assurance audits for the maintenance area. The inspectors also reviewed the licensee's schedule for performing audits. The inspectors observed that the licensee was in compliance with Technical Specification Requirement 6.5.2.8, " Audits." The inspectors identified no concem The inspectors reviewed a sample of audits in the maintenance area, in general, the audits were thorough and had good findings. The inspectors observed that the licensee initiated performance improvement requests as appropriate. The inspectors selected a sample of performance improvement requests written as a result of the audit Corrective actions identified on the performance improvement requests were either completed or on schedule to be completed. The inspectors identified no concem Conclusions The sample of quality assurance audits in the maintenance area reviewed was goo The licensee's followup to audit findings was appropriate. The licensee was on schedule for performing all audits as required by Technical Specifications.

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- 10-fil. ENGINEEFDLQ E1 Conduct of Engineering E1.1 Problem identification and Resolution - Uodated Safety Analysis Reoort (USAR) Insoection Scope (40500)

The inspectors focused their inspection on an engineering department review of the USAR. The licensee, in Letter ET 97-0047, dated May 1,1997, to the NRC, committed to the USAR review with the following objectives:

. Provide reasonable assurance that any previously unknown, USAR-related safety or regulatory significant concems which could affect ongoing operations are identified; and

. Provide reasonable assurance that the USAR is complete and accurat The USAR fidelity review was part of an overall design basis / licensing basis project and consists of a line-by-line review of the USAR and comparison to the applicable design and licensing-related document The effort was being controlled by Self Assessment Plan SEL 97-044, " Wolf Creek Generating Station Updated Safety Analysis Report Fidelity Review," dated October 17, 199 The effort was initiated as a project plan on July 24,1997, and subsequently changed to a self-assessment plan, with an expected completion date of October 199 Obse vations and Findinos  ;

Self Assessment Plan SEL 97-044 assigned responsibility for developing and

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maintaining a corrective action screening mechanism for USAR discrepancies to the -

USAR Fidelity Review Project Lead. The plan required tnat all corrective actions

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associated with the USAR fidelity review be conducted in accordance with Procedure AP 28A-00 The plan stated that the overall corrective action methodology consisted of:

. an initial screening of identified discrepancies;

. a detailed review of identified discrepancies; and

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-11-The plan required the conduct of an initial screening to ensure that prompt corrective action was initiated on USAR discrepancies which may have an impact on safety or operability (considered safety significant) or that required immediate corrective action for any other significant reaso When a discrepancy was identified between a description in the USAR and an existing Wolf Creek Generating Station (WCGS) condition (i.e., procedure, physical arrangement, design, documentation, or analysis), the following question was to be answered: "Given a discrepancy between a description in the USAR and an existing WCGS condition, is the existing condition acceptable?"

Prompt and comprehensive review of this question was imperative because the condition might violate or be in conflict with the premise under which the NRC granted the WCGS operating licens Procedure AP 28A-001 defined a problem as equipment operations, program or procedure implementation, or work activities that do not occur as required. The procedure defined the performance improvement request threshold as the point where an issue becomes important enough to fall into the performance improvement request program. A performance improvement request was required for all such problems. All personnel, including contractors, were required to promptly identify problems or potential problems on a performance improvement reques Performance improvement requests were classified according to Significance Level I through Significance Level IV, with Level I being the most significant. Performance improvement requests classified as Significance Level I, ll, or til could not be closed until all designated actions have been complete The due dates of performance improvement requests were intended to serve as a management tool in allocating resources and ensuring issues are resolved in an appropriate time frame. Procedure AP 28A-001 allowed extensions of the due dates with the approval of the responsible manage The responsible manager was defined as the person who assigned the necessary resources to ensure root cause analysis, corrective actions, and other activities were performed in a timely fashion. The responsible manager was allowed to change performance improvement request significance levels if available information warranted such a change, and the change was documented in the performance improvement request. Procedure AP 28A-001 also stated that the responsible manager should forward a copy of the performance improvement request to the originato The Central Work Authority was a dedicated group that performed the initial review of performance improvement requests for operability and reportability. The group also determined the initial significance level of performance improvement request <

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-12-Procedure AP 28A-001 stated that the Central Work Authority should contact the performance improvement request originator to assure that the performance improvement request reviewer understands the issue prior to closure. Also, the procedure stated that the assigned evaluator should contact the performance improvement request originator to validate the problem description and obtain clarification or additional information prior to performing the evaluatio The inspectors noted that Plan SEL 97-044 did not provide, other than by reference to Procedure AP 28A-001, any guidance or discussion pertaining to initiation of performance improvement requests in order to assure proper corrective action program implementation. The inspectors also noted that neither Procedure AP 28A-001 nor Plan SE 97-044 provided definition or guidance with respect to timeliness or due dates.

During review of Plan SEL 97-044, and discussions with licensee personnel, the inspectors leamed that a USAR Review Database had been established to document discrepancies identified during the review process. The plan methodology flow chart provided for discrepancy input to the USAR Review Databas The USAR Fidelity Review Project Lead informed the inspectors that, in order to assure discrepancies are acted upon in a timely manner, each Tuesday and Thursday an appointed group met to conduct an initial screening of discrepancies identified since the previous meeting. This would limit the maximum elapsed time between discrepancy identification and initial screening to four day The inspectors reviewed a sample of the Database input forms and noted that provisions had been made to address all pertinent information, including classification of the discrepancy. The method for identifying the input forms was based on the number of the USAR chapter, section, paragraph, table, etc., that the discrepancy was being written agains The inspectors, on March 5,1998, reviewed printouts from a sample of input forms, all of which designated the discrepancies as significant. Of the 12 input forms:

. one was 5 months old; e one was 4 months old;

. one was 3 months old;

• three were 1 month old;

. two were 2 weeks old; and

+ four were 1 week ol According to the plan, each of the 12 significant discrepancies would have undergone at least the required initial screening to ensure immediate corrective actions were initiate The inspectors observed that none of the input forms referenced a performance improvement request number. When asked, licensee personnel informed the inspectors that performance improvement requests had not been generated. By failing to initiate

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-13-performance improvement requesta and effect prompt and comprehensive reviews of the identified discrepancies, the question deemed imperative by the plan regarding conditions that might violate or be ir, conflict with the premise under which the NRC granted the WCGS operating licenst; remained unanswere I

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The inspectors intend to perform furtlier reviews to determine whether conditions existed l that may violate or be in conflict with dhe premise under which the NRC granted the WCGS operating license. Pending thrs review, this is considered an unresolved item (50-482/9808-01).

In response to this issue, the licensee initiated Performance Improvement Request 98-0622. The performance improvement request stated: "NRC SA/QV (Safety Assessment / Quality Verification) audit identified a potentialissue that the USAR iridelity Project (SEL# 97 ~044) may be outside the corrective action process. This is not deemed a reportabilty or operability concern."

During discussions with USAR fidelity review team members and supervisory personnel, the inspectors teamed that contractors serving as team members, with the exception of the initial general employee training, had not received specific training regarding the performance improvement request / corrective action process. While there were no specific requirements for such training identified, the inspectors considered this to be important since the primary mission of the team members was to review and identify d'.screpancies and initiate the steps necessary to effect corrective actio The inspectors were also informed that the process for creating performance improvement requests within the scope of the USAR fidelity review group had evolve When discrepancies we,is identified during the early stages, the information was brought to the review group lead. That individual created the performance improvement request rather than the discrepancy identifier. The current process had the person who identified the discrepancy write the performance improvement reques The inspectors conducted a review of 11 performance improvement requests initiated as a result of the USAR fidelity review process. Observations were made for the following performance improvement requests:

. Performance improvement Request 97-3138 was initiated on October 10,1997, and was classified by the initiator as Significance Level 11. The issue dealt with leakage from residual heat removal and containment spray system encapsulation tank Immediate actions were taken, including making an operability determination and conducting a meeting with the initiator, other members of the USAR fidelity assessment team, licensing, nuclear analysis, and design engineering. At the same time, a reportability evaluation request (RER 97-093) was initiate L ,

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performance improvement request completion / closure was established as March 31,199 . Performance improvement Request 97-3239 was initiated on October 31,1997, and dealt with a control room design change which may have resulted in an increased inleakage not accounted for in the control room habitability calculations. The licensee's initial determination showed that they remained below General Design Criterion 19 control room habitability limit Since no apparent operability issues were involved, licensee personnel proposed to redo the applicable calculation, but delay the final evaluation until additional information is available from the USAR fidelity review which might affect the outcome. Therefore, a due date of June 30,1998, was establishe . Performance improvement Request 97-3701 was initiated on November 11, 1997, and dealt with a question as to whether adequate controls existed to ensure that cumulative effects of conditions are considered when evaluating potential discrepancies. The initial screening determined that no operability or reportability issues existed. A due date of Decernber 12,1997, was establishe As allowed by Procedure AP 28A-001, the responsible manager approved a due date extension request to December 30,199 The reason for the extension was that time was unavailable due to required support for the NRC architect engineerinspection and/or Refueling Outage I The inspectors did not consider this to be a reasonable basis for an extension of that magnitude in that it appeared to be an issue that could be readily resolve i

. Performance improvement Request 97-3714 was initiated on November 12, 1997, and dealt with the effects of stuck open residual heat removal system relief valves. A due date of December 12,1997, was established. An evaluation was performed and the performance improvement request received final approval for closure on December 17,1997. The inspectors considered the evaluation to be proper and correct, even though the evaluation documentary allowed for some ambiguity and was not as concise as was expecte . Performance Improvement Request 97-3723 was initiated on November 12, 1997, and dealt with potential dose consequences to the individual responsible for closing the personnel air lock and for personnel inside containment during a design basis fuel handling accident. The performance improvement request was assigned as Significance Level IV. The licensee's initial evaluation determined

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H-15-that the results of the post-LOCA dose ca!culations contained in the USAR meet the requirements of 10 CFR Part 100 for the exclusion zone and the low population zon The licensee also determined that there was no obvious need to calculate additional specific exposures for operators performing actions during this postulated event to meet the regulatory requirements. However, the licenseo determined that, prior to closure of the performance improvement request, additional review would be performed on the analysis requirements related 1) the calculation of radiological doses following a fuel handling accident. Therefr,re, extended due date was appro/ed to March 31,1998. The inspectors cor4ide:ed this to be a proper and prudent evaluation and decisio . Performance improvement Request G7-3932 was initiated on November 28, 1997, and dealt with a lack of correlation between system leakage procedures and pump surveillance test procedures such that the periodic system testing addressed in the USAR might not be conducted as intende The performance imnrovement request was subsequently closed on December 22,1F sith a note that this subject is duplicated in Performance improvement Reyma 97-3138, which dealt with system leakage of radioactive water outside containment. This closure statement, by itself, was not totally correc In fact, the subject matter of Performance improvement Reques. 97-3932 (system leakage test procedure adequacy) had no relationship to Performance improvement Request 97-3138. However, during the inspectors' review of Performance improvement Request 97-3138, it was identified that the actions required to correct the condition identified in Performance Improvement Request 97-3932 were, in fact addressed in performance improvement Request 97-313 These actions were part of the " Plans for Adcb?nal Actions" section which necessitated keeping Performance improvement Request 97-3138 open until March 31,1998. Specifically, the corrective actions associated with Performance improvement Request 97-3932 dealt with revisions to the identified system leakage procedures to require performance of leak measurements with the applicable pumps running and quantification of allleak The inspectors did not identify any improper or incorrect actions associated with Performance Improvement Requests 97-3239,97-3563,97-3738,97-3759, and 97-411 .

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-16- Conclusions The Updated Final Safety Analysis Fidelity Review Project Plan did not provide guidance, discussion, or training in order to ensure proper implementation of the corrective action program, in addition, there was failure to initiate performance improvement requests for some discrepancies that were identified as significant. This item required further review to determine whether conditions existed that may violate or be in conflict with the operating licens E1.2 Problem Identification and Resolution - Other Insoection Scoce (40500)

The inspectors evaluated whether engineering department personnel were appropriately identifying problems and implementing timely corrective action The inspectors reviewed performance improvement requests generated by the engineering departrnent with corrective actions assigned to the operations departmen The inspectors also reviewed performanc,e improvement requests generated and dispositioned by the engineering departroen Observations and Findinas The inspectors verified that assigned corrective action items were accomplished. The verification process included consideration of the following:

e initialidentification and characterization of the problem;

. elevation of problems to proper level of management for resolution;

. root cause analysis;

. implementation of corrective actions, including evaluation of repetitive conditions; and

. expansion of scope of corrective actions to include applicable related systems, equipment, procedures, and personnel action The majority of performance improvement requests initiated and dispositioned by engineering department personnel were adequate. The inspectors noted some examples of weakness in performance improvement requests that referred to the corrective action section of other performance improvement requests, in these instances, the corrective actions of the second performance improvement request did not

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clearly address the intended corrective actions of the first performance improvement request. The most notable case was identified with Performance improvement Request 97-148 ,

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-17-Performance improvement Request 97-1484 was written to addrass problems with repeated failures of essential service water to containment air coolers' containment isolation Valve EFHV34. As part of the corrective action, Performance Improvement Request 97-2029 was issued, in part, to evaluate " reconditioning" valve seats and notifying operations department personnel with information regarding problems with valve Although Performance improvement Request 97-2029 provided an adequate evaluation of " reconditioning" valve seats, the evaluation of the need to notify operations department personnel on problem valves was not addresse fonclusions Other aspects of the licensee's program for identifying and resolving problems in engineering were good. In general, engineering department personnel were properly implementing the progra E7 Quality Assurance in Engineering Activities E7.1 Review of Enaineerino Deoartment Self-Assessments Insoection Scoce (40500)

The inspectors reviewed self-assessment activities performed by the maintenance departmen Observations and Findinas The licensee conducted several self-assessments in the engineering area. The inspectors observed that, in general, the self-assessments were thorough and had many good recommendations. The inspectors observed that the licensee initiated performance improvement requests as appropriate for weaknesses and recommendations. The inspectors selected a sample of performance improvement requests written for the weaknesses and recommendations. The inspectors identified no concems with followup of identified items.

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The inspectors also verified that the licensee was on schedule for performing all audits required by the Technical Specification Conclusions The sample of engineering department self-assessments reviewed was good. The licensee's followup to the findings was appropriat _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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-18 IV. Plant Support R7 Quality Assurance in Radiological Protection and Chemistry Activities R7.1 Quality Assurance Austs Insoection Scoce (40500)

The inspectors evaluated whether the licensee has performed all audits as required by .

Technical Specifications. The inspectors also evaluated followup reviews performed by the quality assurance organizatio The inspectors observed that some quality assurance audits were reviewed during NRC inspections conducted over the past several months. The inspectors focused this inspection on those audits not reviewed during the previous inspection Observations and Findinos The inspectors reviewed a list of completed quality assurance audits for the radiological protection and chemistry area. The inspectors also reviewed the licensee's schedule for performing the audits. The inspectors observed that the licensee was in compliance with Technical Specification Requirement 6.5.2.8, " Audits." The inspectors identified no concem The inspectors reviewed a sample of audits in the radiological protection and chemistry area. In general, the audits were thorough and had good findings. The inspectors observed that the licensee initiated performance improvement requests as appropriat The inspectors selected a sample of performance improvement requests written as a result of the audits. Corrective actions identified on the performance improvement requests were either completed or on schedule to be completed. The inspectors identified no concem The inspectors also verified that the licensee was on schedule for performing all audits required by the Technical Specification Conclusions The sample of quality assurance audits in the radiological protection and chemistry area reviewed was good. The licensee's followup to audit findings was appropriat ,-

.. . g-19-V. MANAGEMENT MEETING X1 Exit Meeting Summary The exit meeting was conducted on March 6,1998. The licensee did not express a position on any of the findings in the repor The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary, No proprietary information was identifie ..

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ATTACHMENT l

SUPPLEMENTAL INFORMATION l

PARTIAL LIST OF PERSONS CONTACTED Licensee I

M. Blow, Superintendent, Chemistry G. Boyer, Chief Administrative Officer K Davison, Acting Manager Operations R. Flannigan, Manager, Nuclear Engineering D. Gerrelts, Superintendent, Systems K. Hall, Superintendent, Corrective Action i K. Harvey, Manager, Document Services L. Jones, Superintendent, Maintenance Support S. Koenig, Supervisor, Quality Evaluations G. Lawson, Superintendent, Maintenance and Planning G. McClellano, Quality Specialist B. McKinney, Plant Manager  ;

K. Moles, Manager, Information Services  ;

i W. Norton, Manager, Performance improvement and Assessment R. Osterrieder, Supervisor, Safety Analysis G. Pendergrass, Supervisor Engineer, Support Engineering C. Rich Jr. Superintendent, Maintenance Electrical B. Smith, Supervisor, Mechanical K. Spahr, Supervisor, Human Performance L. Stevens, Superintendent, Nuclear Safety Engineering S. Wideman, Senior Engineer, Spt.cialist J. Yunk, Senior Engineer, Specialist J. Zell, Manager, Engineering Performance NPS J. Ringwald, Senior Resident inspector INSPECTION PROCEDURES USED IP 40500 Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems LIST OF ITEMS OPENED S0-482/9808-01 URI Review whether conditions existed that may violate or conflict with the operating license (Section E1.1).

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l-2-DOCUMENTS REVIEWED Procedures l AP 12-003, " Foreign Material Exclusion," Revision 2 AP 16C-001, " Action Request," Revision 3 AP 16C-003, ' Work Package Task Planning," Revision 5 AP 16E-002, " Post Maintenance Testing," Revision 0 AP 20A-004, " Audit Procedure," Ravision 3 l

AP 20E-001, " Industry Technical Information Program," Revision 3 AP 26A-001, " Reportable Events - Evaluation Documentation," Revision 3 AP 26C-004, " Technical Specification Operability," Revision 1 AP 28A-001, " Performance Improvement Request," Revisions 7, 8, and 9 AP 28D-001, "Self Assessment Process," Revisions 2 and 3 ,

AP 28-001, " Evaluation of Nonconforming Conditions of Installed Plant Equipment," Revision 6 AP 28 006, "Nonconformance Control," Revision 5 Performance improvement Requests 96-1967 97-2952 97-3714 97-1115 97-2974 97-3715 97-1220 97-3138 97-3723 97-1249 97-3177 97-3738 97-1310 97-3205 97-3757 97-1484 97-3207 97-3759 97-1591 97-3239 97-3860 97-1995 97-3353 97-3932 97-2029 97-3447 97-4046 97-2132 97-3356 97-4071 97-2146 97-3530 97-4117 97-2313 97-3563 97-4144 97-2402 97-3581 98-0269 i 97 2856 97-3701 98-0622 j Self-Assessment Reports SEL 97-011," Auxiliary Feedwater System Walkdown" SEL 97-012, " Mechanical Maintenance Training Program" SEL 97-014, " Post Maintenance Testing" SEL 97-021, " Foreign Material Exclusion" SEL 97-023," Instrumentation and Controls and Electrical Training Program" SEL 97-027, " Pre-Conditioning of Components Prior to Performance of Surveillance Technical Specifications (STS)"

SEL 97-032, " Quality Control Qualification and Certification Process" l

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SEL 97-036, ." Engineering Suppod and Qualification Program" SEL 97-037, " Containment Leakage Rate Testing Program" SEL 97-044, ' Wolf Creek Generating Station Updated Safety Analysis Report Fidelity Review"

SEL 97-046, " Warehouse Receipt Proces*"

SEL 97-047, " Utility Review of Licensee Event Reports" SEL 96-055, ." Essential Service Water System Functional Assessment" Quality Assurance Audits Self-Assessment K-480, " Indoctrination and Training (Operations)"

Self-Assessment K-481, " Radiological Emergency Preparedness Program"

. Self-Assessment K-473, " Process Control Program" Self-Assessment K-482, " Security and Visitor Control" Self-Assessment K-483, " Access Authorization and Fitness for Duty"

Self-Assessment K-472, " Indoctrination and Training of the Unit Staff (Except Operations)"

Self-Assessment K-487, " Plant Maintenance" Self-Assessment K-471, " Technical Specifications and Surveillance Testing" Action Requests 5794 23579 24306 24307 Reportability Evaluation Reports97-030 97-084 97-042 97-089 97-057 97-093 97-058 97-104 97-063 97-114 1 97-067'97-117  !

l 97-074 98-001 Other Common Cause Analysis Report Dated September 10,1997 Common Cause Analysis Report Dated October 30,1997 Plant Safety Review Committee Agenda Package 808 1 Training Lesson Plan GT 12 332 03, " Post Maintenance Testing Development" Letter ET 97-0047, dated May 1,1997

= USAR Fidelity Review Punch List L _ . - _ _ _ - - - . _ _ _ . - - _ _ _ _ - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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