IR 05000482/1999003

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Insp Rept 50-482/99-03 on 990321-0501.Four NCVs Noted.Major Areas Inspected:Operations,Maintenance,Engineering & Plant Support
ML20207A358
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 05/21/1999
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20207A352 List:
References
50-482-99-03, 50-482-99-3, NUDOCS 9905260281
Download: ML20207A358 (20)
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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION

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REGION IV

l Docket No.: 50-482 i

License No.: NPF-42

Report No.: 50-482/99-03 i Licensee: Wolf Creek Nuclear Operating Corporation

Facility: Wolf Creek Generating Station l

Location: 1550 Oxen Lane, NE Burlington, Kansas Dates: March 21 through May 1,1999 l Inspectors: F. L. Brush, Senior Resident inspector l l

B. A. Smalldridge, Resident inspector l l

Approved By: D. N. Graves, Chief, Project Branch B

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ATTACHMENT: Supplemental information

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9905260281 990521 ADOCK 05000482

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EXECUTIVE SUMMARY

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Wolf Creek Generating Station NRC Inspection Report No. 50-482/99-03

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Operations

  • The power reduction and transitions associated with the shutdown of the reactor for Refueling Outage 10 were performed smoothly and error free (Section O1.2).
  • Operators drained the reactor coolant system to reduced inventory and midloop in a safe and deliberate manner, stopping on several occasions to ensure that all reactor coolant system levelindications were tracking as required. Operations department management effectively established an environm.ent in the control room which allowed the operators to focus on safe conduct of the evolution with few distractions (Section O1.3).

. A control room operator deborated the reactor coolant system for 31 minutes instead of the required 5 minutes. As a result, core thermal power exceeded the licensed power level of 3565 MwTh by 5 MwTh for a short period of time. The failure to monitor and 1 control reactor reactivity at all times is a violation of Technical Specification 6.8.1. This is a noncited violation and is in the licensee's corrective action program as Performance ]

Improvement Request 99-0946 (Section O4.1).

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. Poor communications, ineffective supervisory oversight, and inattention to detail by refueling personnel resulted in the li:ensee placing one fuel assembly on top of another in the fuel transfer cart. The refueling bridge crane protective devices prevented the full weight of the assembly from resting on the assembly in the transfer cart. The fuel assemblies were not damaged. The licensee halted fuel movement until corrective actions for the event were implemented (Section O4.2).

alterations with a direct access path open from the containment atmosphere to the )

auxiliary building atmosphere. A vent valve on the inside of containment and a test l connection valve on the outside of containment in the reactor coolant system Hot Leg 1 to the residual heat removal Pump A line were open. This is a noncited violation and is in the licensee's corrective action program as Performance improvement Request 99-1285 (Section 04.3).  !

Maintenance

. The movement of Reactor Coolant Pump B from the reactor coolant system to a shipping container was well planned and executed. The prejob briefing was thorough l

and interactive. Personnel did not receive any unplanned radiological exposure i (Section M4.1).

  • On March 12,1999, the licensee identified that prior to 1999 they had failed to complete testing of all containment isolation valves during Modes 5 or 6, as required by Technical

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Specification 4.6.3.2. However, all containment isolation valves had been successfully

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tested during this time. The majority of these valves were tested in modes other than that specified in the Technical Specification. This is a noncited violation and is in the licensee's corrective action program as Performance improvement Request 99-0860 (Licensee Event Report 50-482/99-02) (Section M8.1).

Enaineerina

. On November 9,1997, a snubber failure resulted in the licensee's discovery that prior to October 2,1995, several snubbers were inoperable. The licensee determined that these snubbers were not returned to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> as required by then applicable Technical Specification 3.7.8. This was a violation of the Technical Specification. However, the licensee determined that the systems and subsystems remained operable with the degraded snubbers installed. This is a noncited violation and is in the licensee's corrective action program as Performance improvement Request 99-0389 (Licensee Event Report 50-482/97-20) (Section E8.1).

Plant Suporgt

= A radiation worker entered a hot partic!e zone without wearing the protective clothing required by the radiation work permit. The licensee provided the inspectors with the results of their investigation, and the inspectors are continuing their review of this even This iter will be tracked as an unresolved item (Section R4.1).

  • Just-in-time radiation worker training provided to all radiation workers before the start of Refueling Outage 10 was thorough and effective. This resulted in raising the awareness and knowledge of radiation workers in the area of radiation protection (Section RS.1).

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Report Details

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Summarv of Plant Status The plant began the report period on March 21,1999, at 100 percent power. On April 3,1999, the licensee shut down the plant to commence Refueling Outage 10. The plant was in the refueling outage for the remainder of the report perio l. Operations 01 Conduct of Operations O1.1 General Comments (71707)

i The inspectors conducted frequent reviews of ongoing plant operations. In general, the conduct of operations was professional and safety-conscious. However, a reactivity mismanagement event occurred and is documented in Section O4.1 of this report. Plant !

status, operating problems, and work plans were appropriately addressed during daily turnover and plan-of the-day meetings. Plant testing and maintenance requiring control room coordination were properly controlled. The inspectors observed several shift turnovers and noted no problem .2 Reactor Shutdown for Refuelino Outaae , Inspection Scope (71707)

i The inspectors observed operators transition the plant from 100 percent power to reactor shutdown in preparation for planned Refueling Outage 10. The inspectors reviewed the licensee's shutdown sequence and the following procedures:

= GEN 00-004, " Power Operation," Revision 36

= GEN 00-005," Minimum Load To Hot Standby," Revision 36

= GEN 00-006, " Hot Standby To Cold Shutdown," Revision 43 Observations and Findinas On April 1,1999, the licensee commenced a reactor shutdown from 100 percent power in preparation for planned Refueling Outage 10. Control room operators decreased power in accordance with Procedures GEN 00-004, -005, and -006. The licensee I entered Mode 5 on April The inspectors attended the prejob brief for the reactor shutdown and several preshift briefings during the reactor shutdown. The inspectors noted that the briefings were thorough, interactive, and emphasized personnel and reactor safety over schedule adherence. In each brief, shift supervision emphasized the use of human error reduction techniques such as Stop-Think-Act-Review, peer-checking, and three-way t

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l communication. Discussions between operators during the briefings revealed that the operators had trained extensively on the reactor shutdown procedures in the control room simulator before performing the actual evolutio The inspectors observed the operators' execution of the reactor shutdown and the majority of the requisite shutdown procedures in the control room. The inspectors noted that control room operators were well prepared, knowledgeable, and frequently discussed procedural steps. The operators coordinated well among themselves, nuclear station operators in the plant, and maintenance and engineering personnel. The supervising operators and the shift supervisors exhibited excellent command and control throughout the shutdown. The supervisors demonstrated excellent supervisory oversight and safety sensitivity by setting high standards and expectations for procedural compliance and prevention of error In particular, the inspectors observed that operators demonstrated good operating skills during the following evolutions:

  • Reactivity changes
  • Placing steam dumps in operation a Main feed pump overspeed trip testing a Transition from feedwater regulating valves to the bypass valves The inspectors found that all power reductions and associated transitions were performed smoothly and error free. The potential challenges to operators from reducing reactor power, decreasing turbine load, securing major secondary plant components, conducting surveillances, and to other plant manipulations not routinely accomplished were periormed professionally and efficiently, Conclusions The inspectors concluded that the power reduction and transitions associated with the shutdown of the reactor for Refueling Outage 10 were conducted smoothly and error fre .3 Reduced inventory Operations - Acoroach to Midlooo Inspection Scope (71707)

The inspectors reviewed the licensee's plan to operate at reduced inventory in the reactor coolant system during steam generator nozzle dam removal with fuel in the reactor. The inspectors also provided continuous coverage of the licensee's approach to midloop operation in the reactor coolant syste Observations and Findinas

} The inspectors reviewed the licensee's plan for operation with reduced reactor coolant inventory and their approach to midloop level in the reactor coolant system. The review included licensee Procedure GEN 00-008, " Reduced !aventory Operations," Revision l-3-

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The licensee informed the inspectors that they planned to reduce reactor coolant inventory to midloop in order to remove nozzle dams from Steam Generators B and C and vacuum fill the reactor before refilling the reactor coolant syste j l

Before the licensee commenced operation with reduced reactor coolant inventory, the l

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Inspectors reviewed and verified that the licensee had adequately prepared for this evolution. The inspectors verified:

Licensee procedures edequately covered midloop operations  !

  • Licensee assessment of risk was completed l
  • Operators were trained for operation with reduced inventory
  • Sufficient power sources were available, including emergency power
  • Two independent, continuous reactor coolant level indications were available
  • Two independent core temperature indications were available
  • Adequate vent paths and flow paths were available
  • The ability to achieve containment closure if core cooling were lost l The inspectors leamed that during midloop operations, in the event that core cooling was lost, the time to onset of boiling in the core was 52 minutes, followed by the onset of core uncovery at 6.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. The licensee planned to maintain both of the residual heat removal system pumps, a safety injection pump, and a centrifugal charging pump l available to provide cooling water to the core at all times during operation at reduced reactor coolant inventor ,

On April 28, the licensee drained the reactor coolant system to midloop approximately 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> after shutting down the reactor. The inspectors provided continuous I coverage of the licensee's reduction of the reactor coolant system inventory and

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approach to midloop reactor coolant leve l The inspectors found that operators conducted the evolution in a safe and deliberate !

I manner, verifying and cross-checking reactor coolant system levels and temperatures on a regular basis. On several occasions, the operators stopped draining to ensure that j all levels were tracking as required. The inspectors noted that a reactor operator was I

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assigned to monitor and control the level in the reactor coolant system during the evolutio i The inspectors noted that shift supervisors took steps to minimize activities in the control room that were unrelated to the draining evolution. On several occasions, the inspectors observed that the shift supervisor suspended other activities in the plant that could have possibly diverted operators' attention from the evolution, and an off-watch operator was assigned to answer all phone calls to the control room. The inspe : tors i concluded that the environment established in the control room allowed the operators to focus on the draining evolution with few distractions.

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The inspectors also verified that operators were aware of critical limits and parameters l

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associated with the systems and components used during the evolution, such as residual heat removal pump vortex limits. In addition, the inspectors observed that operators used good three-way communication and peer-checking during the evolution and that adequate communications were established with watchstanders that were stationed outside of the control room in support of the evolutio However, the inspectors observed that one watchstander, assigned to monitor a backup level indication standpipe in the containment building, was relieved by another watchstander without first obtaining permission from the supervising operator. Tha oncoming watchstander in the containment building did not appear to be familiar with the " reference point" from which to report changes in level to the control room. The senior operations manager on shift quickly took action to prevent recurrence.

l Management oversight of the evolution was effective and control room supervisors limited the activity in the control room to allow the operators to focus on safe conduct of the procedur Conclusions The inspectors concluded that operators drained the reactor coolant system to reduced inventory and midloop in a safe and deliberate manner, stopping on several occasions

, to ensure that all reactor coolant system level indications were tracking as required.

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Operations department management effectively established an environment in the control room which allowed the operators to focus on safe conduct of the evolution with few distraction Operator Kn-aledge and Performance 0 Reactivity Mismanaaement Event Insoection Scoce (71707)

The inspectors reviewed the licensee's response to a reactivity mismanagement even Observations and Findinas A control room operator deborated the rr mor coolant system longer than required for appropriate reactivity control. The licensee used the boron thermal regeneration system to remove boron from the reactor coolant system to compensate for fuel burnup. This method was used at the end of an operating cycle rather than adding water to dilute the reactor coolant system. To accomplish this, a reactor operator diverted flow through an ion exchangor in the boron thermal regeneration system. Based on the reactor coolant system boron concentration, the required duration of the flow through the ion exchanger was 5 minute However, a control room operator diverted water through the ion exchanger for 31 minutes. As a result, the reactor coolant system average temperature reached !

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586.8"F, which was 0.3'F above the normal operating value. Reactor thermal power reached a maximum value of 3570 MwTh, which was 5 MwTh above the licensed limi The licensee immediately added boron to the reactor coolant system and restored the reactor coolant system temperature and reactor power to the required values. The licensee documented the event and corrective actions in Performance Improvement Request 99-0946. The licensee attributed the event to personnel error. The reactor operator was distracted and failed to keep track of the time of deboratio The licensee's corrective actions included:

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Briefing all control room crews on the event and methods to prevent recurrence; )

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Reviewing and revising appropriate procedures and training the operating crews

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Conducting just-in-time training on reactivity control prior to the startup from the

refueling outage; and

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Plant management attendance at simulator training sessions and reinforce reactivity management expectation Licensee Administrative Procedure AP 21-001," Operations Watchstanding Practices," I Revision 12, Section 6.1.1, required that licensed operators monitor and control the reactivity condition of the reactor at all times. Regulatory Guide 1.33, Appendix A, Section 1.b, required that the licensee implement procedures which define the authorities and responsibilities for safe operation and shutdown. Technical Specification 6.8.1.a required, in part, that written procedures be established, implemented, and maintained covering the applicable procedures recommended in i Appendix A of Regulatory Guide 1.33, Revision 2, February 197 ;

The failure to monitor and control the reactor reactivity at all times was a violation. This Severity Level IV violation is being treated as a noncited violation consistent with Appendix C of the NRC Enforcement Policy (50-482/9903-01). This violation is in the licensee's corrective action program as Performance improvement Request 99-0946.

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l A control room operator deborated the reactor coolant system for 31 minutes instead of

! the required 5 minutes. As a result, core thermal power exceeded the licensed power level of 3565 MwTh by 5 MwTh for a short period of time. The failure to monitor and control reactor reactivity at all times is a violation of Technical Specification 6.8.1. This is a noncited violation and is in the licensee's corrective action program as Performance improvement Request 99-094 l-6-

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04.2 Fuel Assembly Placed on Too of Another Assemb!v in the Fuel Transfer Cart Insoection Scope (71707)

The inspectors reviewed the licensee's response when a fuel assembly was placed on ,

top of another assembly in the fuel transfer cart when in the vertical positio !

1 Observations and Findinos The licensee was in the process of defueling the reactor. After placing a fuel assembly in the fuel transfer cart for transport from the containment building to the spent fuel building, the crew on the refueling bridge crane was relieved by another crew. The fuel assembly was not transferred from the reactor building to the spent fuel pool. The new '

crew picked up the next assembly from the reactor vessel and moved the bridge crane to the transfer cart location. When the assembly was lowered, it started to rest on the fuel assembly that was still in the transfer cart. A bridge crane protective device prevented the full weight of the fuel assembly from being lowered onto the assembly in the cart. A fuel assembly weighs approximately 2200 pounds. The protective device

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actuated at 150 pound The crew raised the fuel assembly and notified the appropriate licensee personnel. The licensee determined that the fuel assemblics were not damaged. The refueling crew '

l then placed the assemblies in the spent fuel pool. The licensee halted all fuel movement and conducted an investigatio The licensee determined that the factors which contributed to the event were poor communications, lack of supervisory oversight, and inattention to detail. The refueling bridge crane operator was responsible for sending the fuel from the reactor building to the spent fuel building. The offgoing operator did not inform the oncoming crew that this had not been dor,e. Also, the refueling senior reactor operator did not fully review the status or locatiori of fuel handling equipment cr fuel assemblie The licensee's c orrective actions included;

. Revising Fuel Handling Procedure FHP 02-011," Fuel Shuffle and Position Verification," Revision 19, to clarify communication requirements;

  • Briefing the fuel handling senior reactor operators on command and control j standards; l

. Briefing the fuel handling personnel on the correct method for conducting turnovers; and q

. Providing remedial training on refueling operation There were no additional problems associated with fuel movement during the core i offloa l l

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, Conclusions The inspectors concluded that poor communications, ineffective supervisory oversight, and inattention to detail by refueling personnel resulted in the licensee placing one fuel assembly on top of another in the fuel transfer cart. The refueling bridge crane protective devices prevented the full weight of the assembly from resting on the assembly in the transfer cart. The fuel assemblies were not damaged. The licensee halted fuel movements until corrective actions for the event were implemente .3 Containment Penetration Bvoass Durina Core Alterations Insoection Scope (71707)

The inspectors reviewed the occurrence of and the license's response to a bypass of a containment building penetration isolation during core alteration b Observations and Findinas On April 12,1999, the operations manager informed the inspectors that a direct air i

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pathway was discovered between the containment building and the auxiliary building, while core alterations were in progress. At 5:55 pm, on April 11, Valve EJ V-154, the reactor coolant system Hot Leg 1 to the residual heat removal Pump A suction vent, and Valves EJ V-047 and -48, the reactor coolant system Hot Leg 1 to the residual heat removal Pump A suction test connection and vents, were placed in the open position per )

Clearance Order 98-1050-EJ to support p:anned maintenance. Opening these valves

' inadvertently provided a direct communication between the containment atmosphere and the auxiliary building atmosphere through Penetration 79. At 6:56 a.m. on April 12, the licensee commenced the removal of fuel from the reactor core as part of scheduled work planned for Refueling Outage 10. Several hours later an off-watch senior reactor operator discovered the direg access pathway through containment Penetration 79 for the residual heat removal c'ystem while reviewing clearance orders for planned wor The licensee immediately suspended core alterations per the requirements of Technical Specification 3.9.4 and took action to shut Valve EJ V-154 to eliminate the containment penetration isolation bypass condition. The licensee also performed a complete review of all clearance orders that could have affected containment penetrations to ensure that no other direct access paths existed from the containment atmosphere to the outside atmosphere. No other direct access paths were identified. This was identified in licensee Performance improvement Request 99-128 The licensee failed to ensure that each penetration which provided direct access from '

I the containment atmosphere to the outside atmosphere was closed before commencing core alterations. This resulted in a violation of Technical Specification 3.9.4.c when core alterations were conducted with a direct access path open between the containment

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l atraosphere and the auxiliary building. This Severity Level IV violation is being treated j as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy (50-482/9903-02). This violation is in the licensee's corrective action program as ,

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Performance Improvement Request 99-128 !

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s Conclusions The inspectors concluded that a violation of Technical Specification 3.9.4.c occurred when the licensee conducted core alterations with a direct access path open from the containment atmosphere to the auxiliary building atmosphere. A vent valve on the inside of containment and a test connection valve on the outside of containment in the reactor coolant system Hot Leg 1 to the residual heat removal Pump A line were ope This is a noncited violation and is in the licensee's corrective action program as Performance improvement Request 99-128 . Maintenance M1 Conduct of Maintenance M1.1 General Comments - Maintenance Inspection Scoce (62707)

The inspectors observed or reviewed portions of the following work activities:

Work Order 98-010-28, O.A. 4 Trevitest procedure on Steam Generator B safety valve

  • Work Order 98-127282-003, BB HV-13 limit switch adjustme * Work Order 98-128246-001, rnain steam isolation valve hydraulic oil replacement
  • Work Order 98-128426-002, NB0013 breaker testing
  • Work Order 98-201155-000, Standby Diesel B inspection for gear train backlash per MPM-M0180-01
  • Work Order 98-205446-000, Component Cooling Water Pump B motor inspection and bearing oil change
and connection assembly on Cylinder 8 l
  • Procedure SYS AF-121," Heater Drain Pump Operation," Revision 3 I

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  • Procedure SYS BG-203, " Shifting and Borating CVCS Mixed Bed Demineralizer,"

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Procedure SYS EF-200, " Operation of Essential Service Water System,"

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- Procedure MPM M0180-00, " Standby i)iesel Generator Inspection," Revisian 2

  • Procedure FHP 02-011, " Fuel Shuffle and Position Verification," Revision 20 Observations and Findinas With the exception of the rnaintenance descriticd in Sections M2.1 and M4.1, the inspectors identified no substantive concems. All work obst ved was performed with the work packagem present and in active use. The inspectors Pequently observed supervisors and system engineers monitoring job progress, and quality control personnel were present, when require M1.2 General Comments - Surveillance Insoection Scoce (61726)

The inspectors observed or reviewed all or portions of the following test activities:

  • Test Procedure GEN-00-004, * Power Operations," Revision 36;
  • Test Procedure GEN-00-005," Minimum Load To Hot Stand'ay," Revisioi 36-
  • Test Procedure GEN-00-006, " Hot Standby To Cald Shutdown," Revision 42;

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  • Test Procedure GEN-00-008, " Reduced inven'.ory Opera'. ions, Revision 8; i
  • Test Procedure GEN-00-009," Refueling," Pevision 1;
  • Test Procedure STN AC-007," Turbine Ova; speed Trip Test," Revision 12;

= Test Procedure STS KJ-Oiits, viede: Generator NE02 24-Hour Run,"

Revision 5;

= Test Procedure STS EJ-206," Residual Heat Removal System inservice Valve,"

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  • Test Procedure STS SF-001, Conirol Rod Parking," Revision 3 l Observations and Findinas l

l The surveillance testing was conducted satisfactorily in accordance with the licensee's )

approved programs and Technical Specifications.

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M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Reyiew of Material Condition Durina Plant Tours 1 Inscection Scope (62707)

The inspectors performed routine plant tours to evaluate plant material conditio Obsq:vations and Findinas i l

In general, where equipment deficiencies existed, the deficiencies were previously identified by the licensee for corrective action. The licensee completed major maintenance activities during the inspection period associated with Refueling Outage 10. The inspectors entered the containment building during Mode 4 following the reactor shutdown to inspect the condition of the containment liner coatings and the general condition of the components and equipment. The inspectors identified no

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problems. The inspectors noted a marked improvement in housekeeping and temporary l equipment management inside containment over the previous refueling outag Conclusions l l

The material condition of those plant systems and components evaluated during this l inspection period was good with few equipment deficiencies. Housekeeping and temporary equipment management inside containment improved over the previous refueling outag M4 Maintenance Staff Knowledge and Performance M4.1 Reactor Coolant Pumo Move Inspection Scope (62707) l l

The inspectors attended the prejob briefing and reviewed the reactor coolant pump !

move from the reactor coolant system to a shipping containe Observations and Findinas The licensee replaced reactor coolant Pump B during the refueling outage. All personnelinvolved in the move were present for the prejob brief. The inspectors noted that the prejob briefing was thorough, interactive, and emphasized personnel safety. In l

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each brief, the use of human error reduction techniques was emphasized. The licensee used a videotape of previous reactor coolant pump moves to describe the evolutio Risk significant portions of the move were discussed using the videotape as well as contingency actions in the event of a proble Health physics personnel emphasized the importance of as low as reasonably achievab!e (ALARA). The reactor coolant pump move went smoothly. Personnel involved in the evolution did not receive any unplanned exposure. Overall, the reactor coolant Pump B move was well planned and executed, Conclusions The inspectors concluded that the movement of reactor coolant Pump B from the reactor coolant system to a shipping container was well planned and executed. The prejob briefing was thorough. Personnel did not receive any unplanned radiological exposur M8 Miscellaneous Radiation Protection issues (92904)

M8.1 (Closed) Licensee Event ReDort (LER) 50-482/99-002-00: testing of Phase A containment isolation valves was not conducted in accordance with Technical Specification 4.6.3.2. On March 12,1999, the licensee reported that containment isolation valve testing was performed for some Phase A containment isolation valves during modes not permitted by the Technical Specificatio Technical Specification 4.6.3.2.a required that each containment isolation valve that receives a Phase A isolation signal be tested during Modes 5 or 6 at least once per 18 months. The licensee discovered that Procedure STS KJ-001 A/B," Integrated Diesel Generator Safeguards Actuation Test," Revision 21, only verified the satisfactory movement of a small number of the valves associated with a Phase A containment isolation signal. This procedure was identified in the licensee's master surveillance test cross-reference as the only procedure that satisfied the testing requirements specified in Technical Specification 4.6.3. The licensee found that all containment isolation valves that were required to actuate on a Phase A isolation signal had been tested successfully. The majority of the valves were tested in modes other than those specified in the Technical Specification, using other licensee procedures. Since operability testing of all of these valves had been successfully completed during the required 18-month cycle, the safety significance of this failure to meet the surveillance requirements of the Technical Specification is lo The licensee identified the failure to meet the mode requirements for these tests in Performance Improvement Request 99-0860. Additionally, the licensee determined that the surveillance requirements of Technical Specifications 4.6.3.2.b and 4.6.3.2.c, regarding Phase B and containment purge and exhaust iso;ation valves, were satisfied by Procedure STS KJ-001 A/ In the LER, the licensee committed to revising all of the actuation logic test and slave relay test procedures used to test the containment isolation valves to identify that they

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l are used to meet the surveillance requirements of the Technical Specification. In l addition, the licensee committed to include the subject of this LER in an overall evaluation of missed surveillance tests using common cause methodology. The licensee committed to completing these commitments by October 15 and )

August 16,1999, respectivel l

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The failure to complete the testing of containment isolation valves associated with a Phase A isolation signal during Modes 5 or 6 as required was a violation of Technical Specification 4.6.3.2.a. This Severity Level IV violation is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as Performance improvement Request 99-0860 (50-482/9903-03)

l Ill. Enalneerina E8 Miscellaneous Engineering Issues (92903)

E8.1 (Closed) LER 50-482/97-020-00.-01: failure to meet snubber Technical Specification limiting conditions for operation requirements. On December 9,1997, the licensee reported the occurrence of a historical violation of Technical Specification 3.7.8. This LER documented snubber failures in various systems which were identified during Refueling Outage 9. The identified snubbers were determined inoperable during the time frame when former Technical Specification 3.7.8 was applicable. The licensee's evaluation revealed that these snubbers were not replaced or restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> as required by the Technical Specification. Technical Specification 3.7.8 was removed from the Technical Specifications by Amendment 89 in 199 The licensee identified several snubber failure mechanisms. These included vibration, hydraulic transients, incorrect assembly, and corrosion. The inspectors found that the corrective actions developed by the licensee to prevent and detect similar snubber failures in the future were satisfactory. In Performance Improvement Repor197-4040, the licensee determined that the failed or degraded snubbers had no actual or potential impact on plant safety. The failed snubbers affected only a single support in any given i subsystem. The licensee's evaluation found that none of the failed snubbers rendered a system or subsystem inoperable. The licensee's findings were supported by the inspector's review of the following:

  • Performance Improvement Request 97-2124
  • Performance improvement Request 97-4040;
  • Performance Improvement Request 99-0134
  • Performance improvement Request 99-0389 The failure to replace or restore failed snubbers to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of identification was a violation of then applicable Technical Specification 3.7.8. As a resul /eral safety-related snubbers were found to be failed or degraded in 199 .

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However, the licensee determined that the systems and subsystems remained operable with the degraded snubbers installed. This Severity Level IV violation is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Polic This vio!ation is in the licensee's corrective action program as Performance Improvement Request 99-0389 (50-482/9903-04).

IV. Plant SUDDort R1 Radiological Protection and Chemistry Controls R General Comments (71750)

The inspectors observed health physics personnel, including supervisors, routinely touring the radiologically controlled areas. Licensee personnel working in radiologically controlled areas exhibited good radiation worker practice Contaminated areas and high radiation areas were properly posted. Area surveys posted outside rooms in the auxiliary building were current. The inspectors checked a sample of doors required to be locked for the purpose of radiation protection and found no problem R Violation of Radiation Wock Permit Insoection Scope (71750)

The inspectors reviewed the circumstances surrounding a maintenance worker entering a potential hot particle area without the required protective clothing. The inspectors also reviewed the following documents:

. Radiation Work Permit 99-3202, Revision 00;

  • Procedure AP 258-100, " Radiation Worker Guidelines," Revision B; and

. Procedure RPP 02-105," Radiation Work Permit," Revision 1 Observations and Findinas On April 16, the inspectors observed the work associated with nozzle dam installation on the platforms for Steam Generators B and C from video displays at the health physics remote coverage location at acces.s control. While the nozzle dam installation was in progress for Steam Generator C, the covering health physics technician and the  ;

inspectors noted that a maintenance worker had entered the steam generator platform  !

access area on the 2000 foot level of the containment building. The inspectors observed that the worker did not appear to be wearing the required protective clothin The inspectors observed thm the health physics technician at the remote coverage location, who was in communication with the maintenance technicians on the platform l

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installing the nozzle dams, attempted to have someone direct the worker out of the platform access area. These attempts were unsuccessful; the worker eventually exited the area without promptin The inspectors reviewed Radiation Work Permit 99-3202 and determined that the worker was required to have continuous health physics technician coverage and be clothed in a full set of protective clothing. In addition, the radiation work permit required wearing paper coveralls, extra rubber gloves, extra plastic booties, an extra hood, and a face shield. The worker was wearing a single set of full protective clothing, an extra pair of cloth coveralls, and extra rubber gloves and rubber shoe covers. The inspectors determined that by failing to comply with protective clothing requirements of the radiation work permit, the maintenance worker violated the radiation work permit. This was identified in licensee Performance improvement Request 99-135 On April 17, the licensee informed the inspectors that they were investigating the circumstances associated with the incident. The licensee provided the inspectors with the results of their investigation, and the inspectors are continuing their review of this event. This item will be tracked as an unresolved item (50-482/9903-05). Conclusions A radiation worker entered a hot particle zone without wearing the protective clothing required by the radiation work permit. The licensee provided the inspectors with the results of their investigation, and the inspectors are con'inuing their review of this even This item will be tracked as an unresolved ite R5 Staff Training and Qualification R Just-in-Time Trainina Inspection Scoce The inspectors observed just-in-time training provided by the health physics department to all radiation workers before the start of Refueling Outage 1 Observations ard Findinos The manager of radiation protection directed that just-in-time radiation worker training i be provided to all radiation workers immediately before the refueling outage. This type of training was provided to radiation workers before the previous refueling outage and was successfulin raising the awareness and knowledge of the workers in the radiation protection are The training included a filmed lecture on the radiation protection program which was developed by the station's radiation protection training department. This was followed by a practical training session which required all participants to enter the radiologically controlled area. After receiving a detailed briefing on the use of radiation work pnrmits,

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the workers demonstrated their ability to properly don and remove protective clothing.

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The inspectors found that the lecture was adequate and effective in communicating program requirements. The inspectors noted that the practical training inside the radiologically controlled area was excellent. The instructors engaged each worker and provided a detailed briefing on radiation work permits, survey maps, the use of protective clothing, and practical methods of maintaining dose ALAR c. Conclusions The inspectors concluded that the just-in-time radiation worker training provided to workers before the start of Refueling Outage 10 was complete and effective. This resulted in raising the awareness and knowledge of radiation workers in the area of radiation protectio V. Manaaement Meetinas X1 Exit Meeting Summary l

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The exit meeting was conducted on April 30,1999. The licensee did not express a position on any of the findings in the report.

l The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

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ATTACHMENT

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SUPPLEMENTAL INFORMATION '

PARTIAL LIST OF PERSONS CONTACTED Licensee M. J. Angus, Manager, Licensing and Corrective Action G. D. Boyer, Chief Administrative Officer J. W. Johnson, Manager, Resource Protection O. L. Maynard, President and Chief Executive Officer B T, McKinney, Plant Manager R. Muench, Vice President Engineering S. H. Koenig, Manager, Performance improvement and Assessment C. C. Warren, Chief Operating Officer .

INSPECTION PROCEDURES USED IP 37551 Onsite Engineering I IP 61726 Surveillance Observations IP 62707 Maintenance Observations l lP 71707 Plant Operations IP 71750 Plant Support Activities IP 92902 Followup - Maintenance IP 92903 Followup - Engineering IP 92904 Followup - Plant Support ITEMS OPENED AND CLOSED Ooened 50-482/9903-01 NCV Reactivity mismanagement event (Section 04.1)

50-482/9903-02 NCV Containment penetration bypass during core alternations (Section 04.3)

50-482/9903-03 NCV Testing of Phase A containment isolation valves was not conducted in accordance with Technical Specification 4.6. (Section M8.1)

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50-482/9903-04 NCV Failure to meet snubber Technical Specification limiting conditions for operation requirements (Section E8.1)

50-482/9903-05 URI A maintenance worker entered a potential hot particle area ,

without the required protective clothing (Section R8.1)

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Closed 50-482/97-020-00, LER Failure to meet snubber Technical Specification limiting 01 conditions for operation requirements (Section E8.1)

, 50-482/99-002-00 LER Testing of Phase A containment isolation valves was not conducted in accordance with Technical Specification 4.6. (Section E8.2)

50-482/9903-01 NCV Reactivity mismanagement event (Section 04.1)

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50-482/9903-02 NCV Containment penetration bypass during core alternations (Section 04.3)

50-482/9903-03 NCV Testing of Phase A containment isolation valves was not conducted in accordance with Technical Specification 4.6.3.2

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(Section M8.1)

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! 50-482/9903-04 NCV Failure to meet snubber Technical Specification limiting conditions for operation requirements (Section E8.1) -

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