ML20058E289

From kanterella
Jump to navigation Jump to search
Insp Rept 50-482/93-27 on 930912-1023.Violations Noted.Major Areas Inspected:Plant Status,Operational Safety Verification,Esf Walkdown,Maint Observations,Followup on Corrective Actions for Violations & Review of LERs
ML20058E289
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 11/17/1993
From: Yandell L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20058E276 List:
References
50-482-93-27, NUDOCS 9312060239
Download: ML20058E289 (23)


See also: IR 05000482/1993027

Text

.

.

.

.

APPENDIX B

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Inspection Report:

50-482/93-27

License:

NPF-42

Licensee:

Wolf Creek Nuclear Operating Corporation

P.O. Box 411

Burlington, Kansas

,

Facility Name:

Wolf Creek Generating Station

Inspection At:

Coffey County, Burlington, Kansas

Inspection Conducted: Seitember 12 through October 23, 1993

Inspectors:

G. A. Pick, Senior Resident Inspector

J. F. Ringwald, Resident Inspector

!c1Mb

O .11 M93

Approved:

E

A. Yandell, Chief, Project Section B

Date

i

Division of Reactor Projects

Inspection Summary

Areas Inspected:

Routine, unannounced inspection of plant status, operational

safety verification, engineered safety features walkdown. maintenance

observations, surveillance observations, followup, followup on corrective

actions for violations, onsite review of licensee event reports (LERs) and

in-office review of LERs.

Results:

-

The inspector identified a violation of Technical Specification 6.8.1.a

.

because personnel failed to properly implement a clearance order. The

inspector expressed concerns that clearance order problems continue to

he *dentified (Section 2.1).

ine inspector identified a violation of Technical Specification 6.8.1.a

l

.

because craft personnel began work in the field without obtaining the

shift supervisor's permission (Section 4.3).

,

The inspector determined that inadequate corrective actions had been

.

implemented to resolve the root cause identified in LER 482/93-003,

which resulted in a violation (Section 8.2).

I

9312060239 931139

4

{b

PDR

ADOCK 05000482

Q

PDR

- - .

.

.

--.

--

-

-

. - - - .

..

.-

-

!

i

'

.

.

.

.

>

-2-

j

!

'

The inspector identified a failure by the licensee to immobilize

>

equipment as specified by plant procedures which resulted in a violation

l

.l

(Section 2.3).

.l

The inspector identified two examples of a failure to properly support

and evaluate scaffolding which resulted in a violation (Section 2.6).

The licensee implemented strong controls for testing reactor vessel head

.;

!

vent valves (Section 2.2).

The licensee established strong controls over switchyard maintenance

activities. The inspector found that-the licensee did not effectively

l

incorporate switchyard work activities into the weekly and daily

i

schedules until questioned by NRC (Section 2.4).

!

The inspector found that the licensee had strong procedures-for

f

responding to process radiation monitor alarms (Section 2.5).

j

,

Yne licensee responded well to ventilation system testing issues

j

!

(Section 2.7).

!

The inspectors found the component cooling water system material

l

condition to be good. The licensee maintained a low percentage of the

l

plant area as contaminated (Section 3).

l

t

The inspector determined that a mechanic responded in an outstanding

manner to problems encountered while performing preventive maintenance.

l

The licensee implemented strong corrective actions in response to

inspector concerns (Section 4.1).

l

t

The system engineer responsible for instrument air provided excellent

i

response to air compressor trips and proactively recommended overhaul of

l

an air compressor (Section 4.2).

The inspector identified minor human factor weaknesses with the format

l

and coordination of test procedures (Sections 5.1 and 5.2).

i

1

A licensed operator exhibited very good communication practices that

l

ensured proper completion of a surveillance test and control of other

control room activities (Section 5.4).

Summary of Inspection Findings:

Violation 482/9327-01 was oper ed (Section 2.1).

Violation 482/9327-02 was opened (Section 2.3).

!

,

___

.

.

'

-3-

Violation 482/9327-03 was opened (Section 2.6).

l

Violation 482/9327-04 was opened (Section 4.3).

Violation 482/9327-05 was opened (Section 8.2)

Violation 482/9327-06 was opened and closed for tracking purposes

(Sections 6 and 7).

Unresolved Item 482/9228-02 was closed (Section 6).

Violations 482/9231-01, 482/9231-04, 482/9308-03, and 482/9314-02 were

closed (Section 7).

LERs 482/93-001, 482/93-003, 482/93-005, 482/93-007, and 482/93-011 were

closed (Sections 8 and 9).

Attacliment:

,

!

Attachment - Persons Contacted and Exit Meeting

,

l

l

__ _

~.

.

.

.

.

.

-4-

?

DETAILS

!

!

I PLANT STATUS (71707)

.

The plant operated at 100 percent power throughout the inspection period.

2 OPERATIONAL SAFETY VERIFICATION (71707)

i

The inspectors performed this inspection to ensure that the licensee operated

the facility safely and in conformance with license and regulatory

,

requirements and that the licensee's management control systems effectively

!

discharged the their responsibilities for safe operation.

The methods used to perform this inspection included direct observation of

activities and equipment, observation of control room operations, tours of the

.

facility, interviews and discussions with licensee personnel, independent

j

verification of safety system status and Technical Specifications limiting

i

conditions for operation, verification of corrective actions, and review of

l

facility records.

2.1 Boric Acid Filter Not Properly Bypassed

i

On September 21, 1993, after an unanticipated-automatic makeup to the volume

control tank occurred, a nonlicensed operator determined that the boric acid

filter in the chemical and volume control system was not bypassed'and isolated

1

as specified on Clearance Order 93-1825-BG. The licensee had initiated

Clearance Order 93-1825-BG in order to repair the boric acid filter drain

i

valve reach rod. The licensee intended to isolate the filter so that a large

amount of water would not drain as personnel cycled the drain valve. The

licensee determined that Valves BG V149, boric acid filter inlet isolation,

and BG V152, boric acid filter outlet isolation, were not fully closed.

The licensee immediately initiated Performance Improvement

Request (PIR) OP 93-1056 to identify the root cause and appropriate corrective

actions. The inspector interviewed the individual who performed the

investigation and reviewed PIR OP 93-1056. The inspector considered the

investigation to be detailed and thorough. The licensee attributed the root

cause to the failure to properly implement Procedure ADM 02-100, " Clearance

Order Procedure," Revision 27, Step 6.14, that specified requirements for

valves with reach rods. The procedure required, for valves with reach rods,

that the valve position be checked to ensure that the reach rod reflects the

l

desired valve position.

The f ailure to follow the requirements of Procedure ADM 02-100 is a violation

of Technical Specification 6.8.1.a (482/9327-01).

Even though the. licensee

performed an effective root cause evaluation, the violation will be cited

because of previous instances where personnel failed to properly implement, in

part, the clearance order process (refer to NRC Inspection

Reports 50-482/93-19 and 50-482/93-03).

l

-

_

-

-

- . -

.

-

.

__=

-

.

-

- _ . .

_

-

!

.

!

.

.

>

'

,

.

-5-

,

i

2.2 Reactor Vessel Head Vent System

l

On September 23, 1993, the inspector received information that the Wolf Creek

t

'

reactor vessel head vent valves might be subject to spurious opening. Another

facility had a downstream reactor vessel head vent valve open inadvertently

when personnel stroked the upstream reactor vessel head vent valve with

!

reactor coolant system pressure at 150 psi.

i

i

i

Previously, the inspector reviewed this area in NRC Inspection

l

Report 50-482/93-01, Section 7.4.

Letter WM 92-0115 dated July 14, 1992,

i

specified that in Modes 5 and 6, a pressure transient severe enough to open

l

l

the downstream reactor vessel head vent valves while performing valve

l

,

operability testing could not occur. The inspector found that

.

!

Procedure STS BB-205, "RCS Inservice Valve Test," Revision 8, Step 2.2.1.1,

l

specified that, if pressure is above 50 psi, but no more than 60 psi, close an

j

l

upstream valve then open the valve % turn to establish flow. This action

1

,

would reduce the flow rate prior to opening the reactor vessel head vent

!

valves. The inspector verified that the open-stroke time for each reactor

vessel head vent valve was 0.5 seconds; hence, at 50 to 60 psi the pressure

l

transient should not exceed 120 psi /sec. Design information from Westinghouse

-

indicated that the valves would open if a pressure transient greater than

!

250 psi /sec occurred.

(

l

The inspector concluded that the licensee's procedural controls should prevent

l

spurious opening of the reactor vessel head vent valves.

In addition, if the

reactor vessel head vent valves spuriously open, as the pressures equalize,

the system flow would reseat the reactor vessel head vent valves.

}

2.3 Temporar_y Ecuipment Control Issues

At the beginning of the inspection period, the inspector questioned licensee

personnel about the appropriateness of the exempt equipment list contained in

.

Procedure ADM 01-201, " Control of Temporary Equipment," Revision 5.

The

!

licensee controls temporary equipment in the plant to protect permanent plant

!

equipment and to assure personnel safety. The inspector reviewed the safety

evaluations supporting procedure changes that added eyewash stations to the

exempt equipment list and speci9ed plant locations for liquid nitrogen

dewars. The inspector found the safety evaluations to be thorough.

i

t

The inspector researched previous revisions of Procedure ADM 01-201 and

determined that licensee personnel had not conducted the same level of review

and evaluation for existing items on the exempt equipment list. The licensee

l

decided to reevaluate the temporary equipment control program and issued

PIR TS 93-1003. The licensee scheduled the review to be completed by

November 12, 1993.

!

.

On September 26, 1993, during a plant tour, the inspector observed numerous

l

carts around the auxiliary building tool room that were not immobilized. One

!

cart contained cast iron parts that exceeded the 50-pound limit specified in

,

!

L

- - _

,

-_

._

_

= , . _ . .

. - .

- - .

-

.

. -

. _ _ .

_.

'

.

.

!-

i

-6-

l

Procedure ADM 01-201.

Procedure ADM 01-201, Step 4.3.3, specified that

i

equipment having rollers or wheels capable of moving during a seismic

condition shall be immobilized to restrict / limit movement. The failure of

!

licensee personnel to immobilize the carts is a failure to follow procedures

l

as required by Technical Specification 6.8.1.a (482/9327-02). The failure to

immobilize the equipment could have resulted in harm to personnel or damage. to

equipment, such as the residual heat removal room sump pump. The licensee

-

issued PIR MA 93-1075 to ensure an investigation would be performed to

identify the root cause and implement corrective actions.

In addition, on two

'

subsequent occasions, the inspector found other carts surrounding the tool

room that had not been properly immobilized.

l

l

.

On October 8, 1993, licensee personnel met with the inspector and described

!

the results of their investigations stemming from PIR MA 93-1075 and

.

PIR TS 93-1003. The investigation for PIR MA 93-1075 found that craft

l

personnel were unfamiliar with Procedure ADM 01-201 requirements and that

,

craft personnel had the misconception that the area surrounding the tool room

was an approved storage area.

Presently, the licensee has no approved storage

areas in the auxiliary building.

l

The corrective actions in response to PIR TS 93-1003 resulted in licensee

!

personnel revising their methodology for control of temporary equipment. The

'

licensee intended to limit control of temporary equipment in the facility to

i

Seismic Category I structures, and the licensee initiated a revision to

.

Procedure ADM 01-201 that described the new methodology. Preliminarily, the

~

'

licensee defined equipment as stable, unstable, and mobile and specified

requirements within the Seismic Category I structures for controlling each

!

type of equipment. The licensee will continue to require that mobile

j

l

equipment be immobilized. The licensee will designate approved storage areas

i

l

after they complete the appropriate evaluations. The licensee constructed a

!

concrete pad adjacent to their radioactive waste building. After the licensee

l

encloses the concrete pad, the licensee will begin storing materials and

l

components in the building during the first quarter of 1994.

,

l

2.4 Control of Switchyard Activities

l

The inspector reviewed the licensee's controls for personnel performing work

'

in the switchyard.

The inspector evaluated licensee controls for:

(1) Access to the switchyard,

I

'

(2) Control of switchyard work activities,

(3) Training of nonplant personnel on the applicable plant procedures, and

(4) Conduct of quality assurance audit /surveillances.

The inspector found that Procedure KGP-1400, " Substation / Switchyard

Protection," Revision 2, provided guidance for coordination with Kansas Gas

and Electric for conduct of maintenance within the Wolf Creek

substation / switchyard fence and Panel MA 105, main transformer site relay

panel, located in the turbine building.

-

..

..

-

,

l

l -

-7-

Procedure KGP-1400 specifies responsibility for various onsite groups,

provides steps to be followed for planning and coordinating work activities,

and references WCGS Standing Order 23, " Control of Switchyard Maintenance,"

Revision 2, which provided additional information to the shift supervisor for

control of switchyard maintenance. The licensee utilized Form KGF-40,

" Substation Work Authorization," to control work activities in the switchyard.

Personnel identify the component (s) to be repaired, the number of vehicles and

personnel entering the switchyard, the planned work start and finish dates,

.

'

and any required compensatory measures.

Designated personnel in

!

instrumentation and control (I&C) and electrical maintenance provided

coordination of the switchyard activities.

System operations for Kansas Gas and Electric revised a company-wide

department instruction in December 1991 to specify requirements for Kansas Gas

and Electric personnel working in the Wolf Creek switchyard. The instruction

letter, "WCGS Substation / Switchyard Directive," reflected the same

,

t

requirements as Procedure KGP-1400 and enclosed a copy of Form KGF-40.

Personnel had not received refresher training after the initial program

development in 1991.

From discussions with licensee personnel, the inspector found that personnel

entering the switchyard contact security personnel and the control room. The

security personnel request permission from the control room to allow personnel

entry into the switchyard. The personnel inform the control room of the

i

substation work authorization number and inform the control room when work

commences. The inspector found that the control room did not always have a

substation work authorization on hand when the switchyard workers arrived.

The supervisor of operations informed the shift supervisors that if personnel

arrive without a prepared substation work authorization they should not be

admitted until receipt of a substation work authori::ation in the control room.

Further, the inspector found that the supervisor of operations recommended

that the 1&C and electrical maintenance coordinators maintain a list of

routine switchyard maintenance activities. The licensee obtained these

updated lists from Kansas Gas and Electric prior to the end of the inspection

period.

The inspector identified weaknesses in the planning and scheduling of

switchyard work activities.

Even though the licensee had requirements to

)

schedule routine work 30 days in advance, the licensee did not place the work

activities on their weekly schedules. Also, on many occasions personnel

identified emergent switchyard work activities 2 days prior to commencing

work; however, the licensee did not include the emergent work on the daily

work schedule addendum. The licensee informed the inspector that switchyard

work activities would be added to both work schedules.

The quality assurance department performed two surveillances since June 1991,

which reviewed portions of the program for controlling switchyard activities.

In Surveillance 5-1888, " Control of Vital AC Power Sources During Maintenance

Activities or Refueling Outages," quality assurance determined that

Procedure KGP-1400 and WCGS Standing Order 23 established adequate

l

'

.

.

-

-.-

-

.=

-

--

_.-

-

.

--

-.

'

,

j

.

!.

,

,

l

i

't

-8-

i

!

<

L

i

l

programmatic controls to control switchyard work activit.ies. Also, shift

f

supervisors demonstrated a good working knowledge of the procedures. The

!

(

l

surveillance noted that the licensee had implemented actions in response to an

l

NRC Information Notice; however, implementation of corrective actions was

l

l

slow.

In Surveillance S-1991, " Control of Cranes and Heavy Loads," quality

l

assurance determined that the program provided appropriate information for

l

l

!

controlling switchyard maintenance activities.

2.5 Radiation Monitor Alarm Response Procedures

I

On September 28, 1993, the inspector reviewed the licensee's procedures that

!

describe actions to be taken in response to process radiation monitor alarms.

The inspector reviewed the procedures listed below:

l

.

Number

Revision

Title

,

ALR 00-061A

7

Process Rad Hi Hi

ALR 00-061B

8

Process Radiation Hi

!

ALR 00-0610

5

Process Rad Mon Failure

i

0FN 88-006

0

High Reactor Coolant Activity

l

OFN 00-010

6

Accidental Radioactive Release

j

j

The inspector verified that all process radiation monitors cause Alarm

l

Windows 61A, -61B, or -61C to annunciate if the alarm setpoint, the alert

t

'

setpoint, or a monitor failure occurs. The inspector determined that all

process radiation monitors had specific response actions described in the

offnormal procedures with the exceptien of Radiation Monitor GH RE022,

t

radwaste building exhaust particulate detector. Radiation Monitor GH RE022

{

!

'

l

will alarm on high particulate activity with the setpoint a factor of 10 lower

l

than a nearby gaseous radiation monitor. The offnormal procedures contain

,

!

guidance for responding to specific radiation monitor alarms.

In addition,

for any radiation monitor not listed, the offnormal procedures had guidance

for responding to Annunciator Windows 61A and 618. These entry conditions

together captured all process radiation monitor alarms. The licensee revised

l

the affected procedure to include Radiation Monitor GH RE022.

l

2.6 Improper Scaffolding Construction

On October 5, 1993, the inspector observed I&C technicians ascend scaffolding

erected over Component Cooling Water Heat Exchanger A.

While the technicians

climbed onto the scaffolding, the inspector observed the scaffold move and

,

then noticed that a vertical member of the scaffold touched Valve EG-V205,

Component Cooling Water Heat Exchanger A temperature bypass upstream

.

isolation. The inspector noted that personnel had tied the scaffold to a

'

component cooling water pump room cooler ventilation duct support and to a

component cooling water pipe support. The. inspector determined that

Procedure ADM 01-113 " Scaffold Construction," Revision 5, Step 5.2.d, stated

that a scaffold shall not be in contact with or secured to any safety-related

or special scope structure / equipment unless allowed by an evaluation. The

evaluation documented in Scaffold Request 93-S0836 did not authorize the

-

.

-

.

.

.

-9-

scaffold to be in contact with safety-related equipment or secured to

,

safety-related supports. This failure to construct the scaffold in accordance

i

with the procedure is a violation of Technical Specification 6.8.1.a

(482/9327-03).

The licensee agreed that personnel constructed the scaffold contrary to

Procedure ADM 01-113 and initiated PIR MA 93-1111. The licensee removed the

scaffold, inspected Valve EG-V205 and found no damage, walked down scaffolding

'

in areas containing safety-related equipment, and walked down the auxiliary

building looking for unapproved scaffolds. The licensee identified one other

scaffold tied to safety-related equipment and identified no undocumented

scaffolding.

The licensee found no damage or other effects to safety-related

equipment.

The licensee determined that craft personnel attached the scaffold

l

to safety-related equipment because of a misunderstanding between results

'

engineering and the scaffold constructors.

The scaffold constructors

understood the phrase " permanent structures" on the scaffold request to

,

include any permanent plant equipment.

The evaluator intended to include

,

'

permanent steel structures only. The licensee planned to revise the procedure

to require that engineers go into the field to show the scaffold constructors

,

where to tie-off scaffolding. The licensee also intends to add a minimum

l

clearance requirement when constructing scaffolding next to safety-related

components. The inspector concluded that these immediate and planned

corrective actions appeared appropriate.

On October 22, 1993, the inspector identified a scaffold next to Spent Fuel

Pool Heat Exchanger B tied to a support for special scope equipment. The

l

inspector noted that Scaffold Request 93-50850 did not have an evaluation that

allowed the scaffold to be secured in this manner as required by

Procedure ADM 01-113. This is a second example of failure to construct the

scaffold in accordance with the procedure and is a violation of Technical Specification 6.8.1.a (482/9327-03).

The licensee agreed that personnel constructed the scaffold contrary to

l

Procedure ADM 01-113 and initiated PIR MA 93-1197.

In response to this second

occurrence, the licensee stated 100 percent of scaffolding to be erected would

be reviewed in the field by engineers. The field reviews will continue until

!

the licensee completes upgrades to the scaffold program. The licensee plans

to visit another utility that has a scaffold program recognized to be

effective. After this visit, the entire scaffolding program will be revised.

The inspector concluded that these corrective actions were appropriate.

The inspector also reviewed the PIR history for scaffolding concerns for the

past 2 years and noted that the licensee identified no conditions that

required PIRs for safety-related equipment.

Several PIRs identified

weaknesses in the scaffolding prigram, and three PIRs identified scaffold

construction deficiencies. The inspector concluded that the scaffold program

had weaknesses, but the licensee acknowledged and was addressing these

weaknesses.

-_

!

.

.

4

-10-

2.7 Control Room Filtration and Pressurization System Testing

The inspector monitored the licensee's responses to problems encountered

during control room ventilation tests and reviewed the results for both the

,

Trains A and B.

The licensee performed the tests in accordance with

Procedure STS PE-009, " Control Room Filtration and Pressurization Systems Flow

Rate and Combined Pressure Drop Test," Revision 3.

The licensee tested

Train A on October 7, 1993, and tested Train B on October 14, 1993.

During the Train A test performance on October 7, 1993, personnel obtained

flow data that exceeded the test acceptance criteria and Technical

l

Specifications limits.

The licensee stopped the test and initiated a work

request.

The licensee found that the flows upstream and downstream of the

specified measurement point indicated that the flows met the acceptance

.

criteria. The licensee attributed the false high-flow readings to increased

i

l

turbulence since personnel took measurement near a throttled damper.

The

licensee changed the monitoring point to prevent flow fluctuations during

future tests.

l

During the Train B test performance on October 14, 1993, all required data to

ensure operability met specifications. However, the licensee determined that

'

l

the pressure drop across the prefilter exceeded the limits of 3.6 psid.

Consequently, the licensee exited from the test, cleaned the prefilter, and

'

,

reinitiated the test. The licensee discovered that they had no instructions

i

that required checking the prefilter differential pressure prior to performing

'

the test. The licensee informed the inspector that a preventive maintenance

activity for inspecting the prefilter would be developed prior to the next

test performance.

Craft personnel initiated their cleanup act'vities on the prefilter prior to

control room personnel entering the limiting conditions for operation.

Quality assurance personnel initiated PIR OP 93-1141, as part of an equipment

control audit, because a limiting conditions for operation may not have been

properly entered. The licensee initiated Reportability Evaluation

i

l

Request 93-044 to determine reportability and to cetermine whether the

'

limiting conditions for operation should have been entered. The licensee

determined that the deficiency was not reportable because the other train

remained operable and Technical Specifications had a 7-day allowed outage time

before any required actions. Also, the licensee determined that, for work

activities of this nature, only control room log er,tries would be made.

2.8 Conclusions

The licensee performed a comprehensive, detailed evaluation into a clearance

order deficiency. The failure to properly implement the requirements of the

clearance order resulted in a violation because of recurring problems in this

area. The inspector found the licensee controls for testing of reactor vessel

head vent system valves to be excellent. The inspector identified a violation

of administrative procedure requirements because personnel failed to

immobilize equipment with rollers on several occasions. The inspector

l

1

.-

~ --

- -

_ . -

-

,

.

,

.

-11-

questioned the appropriateness of items placed on the exempt list in

'

l

Procedure ADM 01-201.

The inspector determined that the licensee established

l

strong controls over access to the switchyard by maintenance personnel. The

l

licensee incorporated switchyard maintenance in the weekly and daily schedule

i

i

after the inspector determined that the licensee did not use the scheduling

process for switchyard work activities. The inspector identified improper

scaffold construction on two occasions.

In response to the first occurrence,

the licensee implemented appropriate corrective actions but not in time to

l

prevent a second occurrence. After the inspector identified the second

i

occurrence, the licensee stated that 100 percent of scaffolding, when erected,

would receive field review by engineers until improved program guidance is

i

developed. The licensee responded well to problems identified during

,

ventilation system testing.

3 ENGINEERED SAFETY FEATURES WALKDOWN (71710)

The inspectors reviewed the operational readiness and material condition of

.

the component cooling water system. The inspectors verified system components

to be operable as required by Technical Specifications. The inspectors

,

verified that Procedure CKL EG-120, " Component Cooling Water System Valve,

l

Switch and Bretker Lineup," Revision 15, contained all valves listed on the

l

system piping and instrumentation diagrams. Also, the inspectors walked down

the accessible portions of the component cooling water system in the

'

auxiliary, radioactive waste, and fuel buildings. During the system walkdown,

the inspectors found housekeeping generally good and identified to the

!

licensee the areas that had poor housekeeping. The inspectors noticed that

the licensee maintained a low amount of contaminated areas (approximately

,

2.7 percent). The inspectors reviewed the maintenance history of the

i

component cooling water system for the past 2 years and identified no

problems.

!

4 MAINTENANCE OBSERVATIONS (62703)

!

The inspectors reviewed this area to ascertain that the licensee conducted

,

maintenance activities on safety-related systems and components in accordance

i

with approved procedures and Technical Specifications. Methods used in this

,'

inspection included direct observations of maintenance activities, interviews

with personnel, and review of records.

4.1 Auxiliary Feedwater Pump B Couplina Maintenance

On October 6, 1993, the inspector observed mechanics perform preventive

maintenance on the Auxiliary feedwater Pump B motor-to-pump coupling as

specified in Work Request 50994-93.

The work request specified changing the

grease and measuring the coupling gap. The inspector reviewed the work

instructions and found them to be very specific and easy to understand.

The

mechanics performed the measurements in accordance with the work instructions

and found that the coupling gap was too large. Consequently, the mechanics

--

-

.

-

,-

..

-

.

,

'

!

l

.

!

,

,.

.

l

iI

l

-12-

l

consulted with maintenance engineering and referred to the vendor manual for

!

'

the pump. The second set of measurements still indicated the coupling gap was

too large.

l

I

i

The mechanic again consulted with maintenance engineering and referred to the

vendor manual for the motor. The vendor manual for the motor specified

I

'

aligning the motor coupling at magnetic center and described how to identify

the magnetic center. After consulting the vendor manual for the motor, the

i

mechanics concluded that the second set of measurements had incorrectly been

l

taken at the mechanical center of the motor shaft.

The licensee revised the

.

work instructions to specify placing the motor shaft at magnetic center. The

mechanic documented the above evolutions on Work Request 50994-93. The

i

coupling gap measurement met specifications with the motor placed at magnetic

!

center. The inspector concluded that the mechanics demonstrated a strong

i

awareness of problems and took appropriate corrective actions.

Maintenance personnel initiated PIR MA 93-1110 after the inspector expressed

i

concern about the adequacy of the work instructions. Although the work

!

instructions had specific, detailed steps, the instructions did not have

sufficient guidance about placing the motor at the magnetic center when taking

i

the measurement.

Concurrently, the system engineer had contacted maintenance

j

engineering about the work instructions. Maintenance engineering issued

l

PIR MA 93-1112 that documented the conflict between the pump and motor vendor

i

manuals and recommended reviewing other pump and motor vendor manuals for

j

similar conflicts.

j

The inspector expressed concerns regarding previous performances of the

i

coupling preventive maintenance activities. The licensee demonstrated that

j

following the coupling gap measurements taken for the turbine-driven auxiliary

l

feedwater pump in 1986, they made the coupling gap measurement optional.

{

However, in 1992 the licensee revised the preventive maintenance instructions

!

!

to require inspection of the coupling, change out of the-coupling grease, and

l

verificaticn of the coupling gap as part of their reliability centered

l

maintenance program. The inspector found that this measurement of the

,

coupling gap was the first measurement for either motor-driven auxiliary

!

'

feedwater pump. Corrective actions specified on PIR MA 93-1110

~

1

included eliminating the coupling gap measurement during preventive

maintenance, reviewing standard supplemental work instructions to determine

,

t

whether instructional weaknesses exis6, and verifying that the rotating

equipment alignment procedure provides appropriate guidance. The inspector

considered the corrective actions to be effective. The inspector determined

that deleting the requirement to measure the coupling gap during preventive

maintenance would be prudent and noted that the relative positions of either

the driver or the pump on the pedestal are not altered when the' preventive

maintenance (i.e., grease changeout) is performed.

4.2 Air Compressor B Postmodification Testing

During this period, the licensee replaced the Train B piston-type instrument

air compressor with a screw-type air compressor.

The licensee installed the

_

'

'

.

.

-

-13-

1

screw-type air compressor in accordance with Plant Modification Request 02980,

" Replace Instrument Air Compressor." In addition, the licensee installed

stainless steel internals into Valve EF V076, Air Compressor B essential

service water (ESW) return check valve, and installed a 1%-inch drain line

for testing Valve EF V076 because of problems experienced with the Train A

check valve (refer to NRC Inspection Report 50-482/93-24, Section 2.7).

The

licensee performed a preoperational readiness test of Air Compressor B in

accordance with Procedure TP TS-152, "New B Air Compressor Prep For

Preoperational Test," Revision 0.

The licensee performed the preoperational

test in accordance with Procedure TP TS-156, "New B Air Compressor

Preoperational Test," Revision 0.

During the preoperational test, no major problems occurred.

The licensee had

a vendor representative present during the testing.

Because high intercooler

temperatures occurred while the air compressor operated unloaded, the vendor

representative decreased the back pressure for the intercooler.

No

inadvertent shutdowns occurred during the acceptance testing.

Subsequently,

the air compressor tripped while running unloaded after operators completed

Procedure STS EF-210B, "ESW System Inservice Check Valve Test," Revision 4.

After operations accepted Air Compressor B, the system engineer issued a work

request to overhaul Air Compressor C since past experience demonstrated

numerous minor maintenance problems following long periods of operation.

Initially, the licensee did not identify the root cause for the high

intercooler temperature trip. Consequently, the licensee initiated a

procedure change to require operators to vent the system and verify that water

flowed from the vent valve. Also, the licensee initiated PIR NP Y3-ll47 to

ensure personnel investigated the inadvertent air compressor trip.

One week later, Air Compressor B tripped on high intercooler tempertture while

running loaded.

Review by the system engineer and I&C personnel identified an

intermittent resistance temperature detector (RTD).

Further evaluation

concluded the RTD caused the previous air compressor trip. At the end of the

inspection period, the licensee continued to review the failure mechanism of

the RID.

The licensee suspected the RTD required a different design

application.

Presently, the RTD is submerged in the air flow, but the

licensee has reviewed the possibility of using thermowells.

4.3 Work Performed Without Shift Supervisor Permission

On October 12, 1993, the inspector observed a machinist perform work required

by Work Request 02815-93. The licensee had experienced unacceptably high "as

,

found" relief valve setpoints in Lonergan Engineering relief valves. Lonergan

I

Engineering Bulletin 91-001 identified that certain valves will lift above the

i

set pressure if the lifting lever is in contact with the valve stem. The

,

i

engineering bulletin described the necessary measurements and adjustments to

'

prevent this from occurring.

After observing the mechanics perform work on emergency diesel generator

starting air tank relief valves, the inspector observed the machinist present

i

7

l '

'

.

.

.

-14-

l

!

the work request to the shift supervisor asking for permission to begin work.

The shift supervisor performed a detailed review of the work request. After

!

the shift supervisor asked the mechanics several questions, the maintenance

l

engineer explained that personnel began work prior to obtaining permission

l

from the shift supervisor. The inspector had not known that the personnel did

'

not have permission to start until the maintenance engineer informed the shift

supervisor. The shift supervisor further questioned the machinist regarding

the specifics of the work performed to ensure that the work had no impact on

the operability of the diesel generators. The shift supervisor also prompted

'

the machinist and maintenance engineer to write PIR MA 93-1135.

Procedure ADM 01-057, " Work Request," Revision 27, Step 7.24, requires that

l

personnel obtain permission from the shift supervisor prior to beginning work

!

activities. Also, Procedure ADM 01-057, Figure 6, " Work Request Flow Chart,"

l

requires a worker to obtain the shift supervisor's permission prior to

starting work. The performance of this work without the shift supervisor's

permission is a violation of Technical Specification 6.8.1.a (482/9327-04).

4.4

Safety-Related Pump Oil Change

On October 13, 1993, the inspector observed the oil sample collection and oil

change for the outboard motor bearing of Safety Injection Pump B in accordance

l

with Work Request 51895-93. The inspector observed the mechanics use

appropriate mechanical and radiological work practices. The inspector

questioned the mechanic's use of the same funnel used in draining the old oil

to supply the new oil to the bearing, particularly after the mechanic noted

and wiped some foreign material from the funnel after flushing the funnel with

new oil. The mechanic replied that this was acceptable since he flushed the

i

funnel prior to adding the new oil. The inspector found the mechanic's

conclusions to be appropriate and considered the sump operable.

l

4.5 Planning and Scheduling of Maintenance Activities

The inspector attended the licensee's planning and scheduling meetings in

preparation for the Safety Injection Pump B train outage.

From discussions

with licensee personnel, the inspector found that the licensee implemented all

i

packages ready for maintenance.

From review of the open outstanding work

requests, the irspector determined that a significant number related to repair

and/or refurbishment of motor-operated valves (MOVs) not installed in the

l

plant.

Because the MOVs were not installed in the field, the inspector

concluded that the work requests did not affect plant safety and did not

contribute to the maintenance backlog.

4.6 Conclusior;s

l

l

A mechanic responded in an outstanding manner to problems encountered during

)

pump-to-motor coupling gap measurements. After the inspector expressed

j

'

concern over adequacy of the work instructions and prior work performances,

the licensee parformed a detailed review that demonstrated this was the first

performarice of these work instructions.

The licensee implemented strong

corrective actions to reduce the potential for future confusion. The system

i

I

I

--

._

l

.s

.

!

I-

(

.

-15-

!

engineer responsible for the instrument air system provided an excellent

response to an air compressor trip and proactively recommended overhaul of

another air compressor.

The inspector identified a violation of procedure

requirements when maintenance personnel performed work without the shift

supervisor's permission. The inspector noted that the shift supervisor

demonstrated a questioning attitude in reviewing the work request.

5 SURVEILLANCE OBSERVATIONS (61726)

The inspectors reviewed this area to ascertain whether the licensee conducts

surveillance of safety-significant systems and components in accordance with

Technical Specifications and approved procedures.

5.1 ESW Inservice Pump and Valve Test

On October 6, 1993, the inspector observed a licensed operator perform the

quarterly inservice pump test for ESW Pump B.

The operator performed the test

in accordance with Procedure STS EF-1008, "ESW System Inservice Pump B Test

l

and ESW B/ Service Water Cross Connect Valve Test," Revision 12. The inspector-

noted that test personnel performed a prejob brief that identified the test

sequence, responsibilities, and objectives. The inspector determined from

discussions with the operator that he was knowledgeable about the general test

sequence.

The inspector verified that test personnel utilized calibrated test

equipment and-observed clear, concise communications among personnel. All

test data met specifications.

The inspector found that recently revised Procedure STS EF-100B caused

unnecessary stroking of MOV EF HV024, ESW B/ service water cross connect valve,

and MOV EF HV026, ESW B/ service water cross connect valve. The unnecessary

stroking had no safety impact. The licensee performed the test to verify

compliance with Technical Specification 4.0.5.

The inspector considered the

failure of the procedure to provide sufficient guidance to prevent unnecessary

stroking of safety-related MOVs to be a minor human factor deficiency.

In

addition, quality assurance personnel initiated PIR OP 93-1115 because

operators deviated from their approved procedure by using the plant computer

data instead of the control panel gauge to determine whether system pressure

exceeded 113 psig. The licensee included the NRC identified procedure

weakness in PIR OP 93-1115. The procedure required that if the system

pressure exceeds 113 psig, the service water pumps should be secured.

The inspector questioned the basis for the maximum service water system

pressure limit of 113 psig. The licensee demonstrated that 113 psig reflects

an administrative limit prior to the low-flow condition for the service water

pumps. Further, the licensee demonstrated that the service water pumps should

not be operated with system pressure above 120 psig, the shut off head for the

service water pumps, aad stated that the service water system pressure always

exceeded 113 psig after starting the ESW pump and prior to closing

MOVs EF HV024 and -026.

The system pressure exceeds 113 psig with the service

water cross-connect valves open since the ESW pump discharge pressure is

150 psig. The inspector considered the licensee's failure to modify

_ _

'

s

,

,

,

-16-

t

Procedure STS EF-100B to accurately reflect actual system operating conditions

to be a weakness. The procedure problems were minor and had minimal safety

significance. Operators did not secure the service water pumps because, by

the time the pumps were secured, the crossconnect valves would be closed. The

!

licensee initiated action to correct the procedure.

5.2 Slave Relay Testina

l

On October 6,1993, the inspector observed a licensed operator and I&C

i

technicians perform Procedure STS IC-616A, " Slave Relay Test K616 Train A

Safety Injection," Revision 5.

The procedure verified that actuations

required for Slave Relay K616 occurred upon receipt of a safety injection

signal.

The inspector determined that the licensee poorly coordinated the initial

conditions and restoration sections of Procedure STS IC-616A with

l

Procedure STS EF-100B.

Procedure STS IC-616A, Step 3.1, specified ensuring

i

that ESW Pump B operated in accordance with Procedure STS EF-200, " Operation

l

of the ESW System," Revision 14; however, the operator entered

Procedure STS IC-616A from Procedure STS EF-100B, Step 6.1.36.

Procedure

STS IC-616A, Step 6.11, specified that personnel restore ESW B in accordance

with SYS EF-202, " Transferring ESW Supply to Service Water System," Revision

12, and required a signoff and verification signoff that the personnel

l

l

restored the system; however, the personnel returned to Procedure STS EF-1008,

1

Step 6.1.37.

Subsequently, 'icensee personnel informed the inspector that

l

they changed the procedure steps to refer to STS EF-100B because the slave

relay test is normally performed in conjunction with the pump inservice test.

!

5.3 Valve Stroke Timing Surveillance

l

On October 12, 1993, the inspector observed operators verify the valve stroke

l

time for Valve EF HV044, ESW B to air compressor, in accordance with

Procedure STS EF-201, " Component Cooling Water System Inservice Valve Test,"

Revision 9.

The inspector noted that this test satisfied Technical

!

Specification Surveillance Requirement 4.0.5.

The operators used effective

communication techniques. The inspector had one minor observation that the

!

licensee immediately addressed.

,

5.4 Rod Testing

,

On October 13, 1993, the inspector observed operators verify proper rod

operation in accordance with Procedure STS SF-001, " Control and Shutdown Rod

Operability Verification," Revision 10. The inspector noted that this test

satisfied Technical Specification Surveillance Requirement 4.1.3.1.2.

The

inspector found that operators used formal communications that clearly

apprised all control room personnel of the test activities. This

communication resulted in effective coordination of the test and permitted the

supervising operator to monitor and control plant activities. The inspector

concluded that the operators effectively performed the surveillance test.

1

e

.

.

.

.

.

-17-

P

5.5 Conclusions

During an inservice test of ESW Pump B, the inspector noted that the newly

upgraded test procedure had minor human factor deficiencies. Ihr inspector

determined that a quality assurance auditor identified another longstanding

procedure weakness during an equipment control audit. The inspector

identified the poor coordination among licensee test procedures.

The

inspector observed very good communication, control and coordination of

control room activities during control rod testing.

6 FOLLOWUP (92701)

(Closed) Unresolved Item 482/9228-02:

Licensee Reviews of Operator Logs

The inspector initiated this unresolved item because of log discrepancies

.

identified by both NRC and the licensee in various building watchstander logs.

On October 15, 1993, the NRC issued a letter transmitting a Notice of

Violation of 10 CFR 50.9, " Completeness and Accuracy of Information," to Wolf

Creek Nuclear Operating Corporation. NRC was concerned with the conduct of

some licensee personnel who improperly maintained watchstander logs. However,

because of the corrective actions taken, the violation required no response

and had no severity level assigned. The failure to accurately document

information on watchstander logs is identified as a violation of 10 CFR 50.9

(482/9327-06).

7 FOLLOWUP DN CORRECTIVE ACTIONS FOR VIOLATIONS (92702)

7.1

(Closed) Violation 482/9231-01:

Incdeauate Alarm Response Procedure

This violation was cited because the licensee failed to modify an alarm

response procedure. When the normal drain path from the refueling water--

storage tank became blocked, the licensee established an alternate drain path.

The licensee created an information tag that explained the alternate path and

posted the information tag on the control panel. However, the licensee failed

to modify the alarm response procedure.

Af ter the inspector identified this deficiency, the licensee issued a

temporary procedure change to the affected procedure. The licensee determined

this deficiency to be weaknesses between coordinating the information placed

i

on information tags and implementing required procedure changes.

Subsequently, the licensee changed Procedure ADM 02-110, " Control of

l

Information Tags," to provide guidance for implementing procedure changes in

place of or in conjunction with developing information tags.

The inspector verified that the licensee revised Procedure ADM 02-110 to

provide guidance for initiating procedure changes instead of or in conjunction

,

!

with information tags. The licensee added a statement to the procedure

l

precautions and limitations and in the body of the procedure that specified

information tags and operator aids should not be used in place of procedures.

l

.

~__

._ __

_

_

._ - .__

\\ *

.

.

.

.

,

-18-

7.2 (Closed) Violation 482/9231-04:

Failure to Properly Implenent an

l

Approved Procedure

,

This violation occurred when an . operator failed.to perform-

.

'!

Procedure SYS BG-201, " Shifting Between Positive Displacement-and Centrifugal

Charging Pumps," Step 4.2.6, which required operators to close

Valve BG HV8106, positive displacement pump recirculation valve. The failure

to close Valve BG HV8109 resulted in a loss of charging and letdown flows for

i

-

20 seconds.

'

The licensee specified that they would employ " positive discipline" as

corrective actions to address the personnel error.

" Positive discipline"

i'

involved the responsible individual describing the event, the corrective

actions, the root cause, and the consequences to management and his peers.

The inspector monitored one of the presentation sessions. The individual who

l

erred described his actions, described the event, and addressed the importance

,

of self checking and following procedures.

In addition, the inspector found

f

!

the engineering evaluation of the effects of the loss of letdown to be

thorough.

7.3

(Closed) Violation 4R2/9308-03:

Failure to Perform a Timely

"

Surveillance

,

!

During Refuel VI with water level less than 23 feet above the reactor vessel

-!

flange, the . licensee determined that the inservice test for Residual Heat

l

Removal Pump B was not performed prior to the late date. The licensee

1

declared the pump inoperable and determined that they violated Technical

l

Specification 3.9.8.2.

The licensee found that miscommunications among

personnel in the operations department resulted in the missed surveillance.

The inspector reviewed the corrective actions that the licensee implemented to

address the breakdown in coordination and communications. The licensee added

!

a late surveillance notification form, which is provided to the control room

I

l

2 days prior to the late date as specified in Procedure ADM 01-300,

Step 5.6.2.2.

Also, the licensee changed Procedure ADM 01-300 that required a

,

'

2

PIR to be initiated whenever a late surveillance notification form is issued

because the licensee considered issuance of the late notification form to

!

indicate weaknesses in surveillance scheduling.

,

The integrated planning and scheduling group developed a rolling schedule that

includes surveillance tests.

Personnel use the rolling schedule to develop

the weekly work activities schedule.

For semi-annual, annual, and 18-month

'

surveillance tests, the surveillance group provides the integrated planning

,

and scheduling group with information 3 weeks in advance. The inspector

verified that the licensee utilized the weekly activities schedule to schedule

i

surveillance tests that have a frequency of greater than 1 month through the

integrated planning and scheduling group planning process.

,

--

l

.

.

!

'

o

-19-

i

7.4

(Closed) Violation 482/9314-02: Failure to Correctiv Transfer Desian

,

!

Data into the Appropriate Documents and Computer Data Bases

This violation was cited for two examples of failing to properly control

l

i

design information.

The first example occurred because personnel failed to

update the computer database to reflect revised axial flux difference limits

listed in the Core Operating Limits Report. The failure to update the limits

rendered the axial flux difference monitor inoperable since the outdated

l

limits were nonconservative. With the monitor inoperable, operators failed to

l

log the axial flux difference hourly, as required by Technical Specifications.

'

Upon identification, the licensee immediately declared the axial flux

difference monitor inoperable and logged the axial flux difference hourly.

The licensee identified the root cause as an inadequate review of the Core

Operating Limits Report since personnel failed to recognize that the axial

l

flux difference monitor constants required modification. The licensee issued

a computer software modification to correct the immediate problem with the

axial flux difference monitor and developed a procedure checklist to be used

when reactor engineers implement nonroutine design changes. The inspector

l

verified that Procedure RXE 03-003, " Determination of Implementation

!

Requirements for Nonroutine Design Changes," Revision 0, referenced the PIR

>

l

that documented the investigation and listed items to be considered for

implementation of a design change.

Procedure RXE 03-003 specified that

l

nonroutine design changes include Technical Specifications revisions, Core

Operating Limits Report revisions, fuel design changes, Updated Safety

Analysis Report revisions, and other modifications as selected by the reactor

engineering supervisor.

The second example occurred because the licensee failed to develop shutdown

margin tables based on the correct 100 percent rated thermal power value. The

l

licensee used the uprated thermal power value of 3565 megawatts instead of the

current operating thermal power value of 3411 megawatts to develop the tables.

Reactor engineering personnel believed that Manual WCRX-12, " Control Room

Operating Curves and Tables Reference Manual Cycle 7," reflected

3411 megawatts rated thermal power for the first 200 effective full power days

l

then reflected the rerated power of 3565 megawatts rated thermal power. The

licensee attributed the deficiency to weak communications. The licensee had

not used the affected tables in Manual WCRX-12 prior to discovering the error.

The licensee immediately added a correction factor to plant procedures that

I

referenced appropriate WCRX-12 tables until the tables were updated. The

licensee addressed the communication problems by having the personnel involved

identify the root cause and develop procedure enhancements to address the

deficiency.

The licensee revised Procedure KP-C237, " Reload Design and Safety

Evaluation," to require formal transmittal of proposed core design changes to

reactor engineering prior to approval, as compared to previous transmittals or

telephone discussions. The licensee revised Procedure KP-1537, " Development

'

and Control of Technical Guidelines / Topical Reports," to require assumptions

and conditions associated with data to be explicitly documented. The

i

i

-

.

. . -

.

_

.

._

-

.

.-

- >

.

!

.

t

,

l*

l

<

q

!

-20-

!

inspector verified that the licensee implemented the procedure changes and

-

!

updated WCRX-12 to reflect the correct rated thermal power levels.

!

f

7.5 (Closed) Violation 482/9327-06:

Falsification of Plant Records

As described in Section 6, this violation required no response because of the

corrective actions that the licensee implemented. The inspector formally

opened and closed the violation in this report for tracking purposes.

{

7.6 Conclusions

i

The licensee implemented strong corrective actions in response to NRC-

i

findings. Personnel errors were addressed by implementing " positive

'

discipline." The licensee implemented good corrective actions in' response to

a missed surveillance. The licensee implemented generic actions to address

!

!

future design information transfer between onsite and offsite reactor

l

engineering groups.

j

8 ONSITE REVIEW OF LERs (92700)

i

I

8.1

(Closed) LER 482/93-001:

Inadeauate Technical Specifications Developed

i

by Westinghouse Results in a Failure to Include All Time Delays in

l

Technical Specifications Response Time Testina

l

The licensee determined, while reviewing concerns related to.a Westinghouse

technical bulletin, that they had potentially operated the facility in a

condition outside the design basis. The reactor coolant pump undervoltage

i

!

trip circuit did not include time delays created by reverse electromotive

force as a factor in the actual circuit-response time. The licensee performed

a safety evaluation and concluded that the plant had not operated outside of

!

the design basis. The licensee attributed the root cause.to inadequate

i-

Technical Specifications developed by Westinghouse because they failed to

l

include the reactor coolant pump reverse electromotive force effects created

!

by the pump coast down. Also, the licensee determined that they should have

included the coni.rol rod gripper finger release times as part of the

respunse-time tests.

The licensee reviewed historical rod-drop time tests to identify the

appropriate gripper finger release time.

The licensee verified that the added

time caused by reverse electromotive force only affected the reactor coolant

pump undervoltage trip. However, all reactor protection system response times

!

were affected by the added control rod gripper finger release time. The

licensee stated that they would alter the response-time test procedures to

i

account for the control rod gripper finger release time and that they would

!

change Procedure STS RE-007, " Rod Drop Time Measurement," to require

determining the control rod gripper finger release time. Additional actions

included providing the information to the Westinghouse Owners Group so that

i

other plants would be made aware of the problems.

I

l

i

. . .

,

_

__

_

_ . _ _ .

_

__ _

_

I k

g

4

i

i

-

,.

-21-

!

The inspector verified that the licensee changed the affected procedures. The

i

licensee presented the information to the Westinghouse Owners Group Licensing

!

Subcommittee in April 1993. The inspector verified that Wolf Creek placed the

l

information onto the nuclear network as suggested by the subcommittee.

!

8.2

(Clostd) LER 482/93-003:

Personnel Error by Licensed Operators Resulted

!

,

l

in a Di ect Flow Path Between the Containment-Atmosphere and the

'

Auxiliar> Building Durina Fuel Movement

While draining ESW B in accordance with Procedure SYS EF-420, "ESW A(B) Train

l

Drain," Revisicn 0, in Mode 6, the licensee created a direct path between the

.

auxiliary and c)ntainment buildings. The licansee discovered the flow path

-

!

while restoring from a local leak rate test on ESW valves. The licensee

!

developed Procedure SYS EF-420 to be performed in modes that did not require

l

containment closure. When the licensee altered Procedure SYS EF-420,

i

personnel only considered the requirement to have one train of ESW operable.

'

Personnel failed to consider the requirements of maintaining containment

'

closure during fuel movement even though Procedure SYS EF-420 had a precaution

i

about containment closure. This event was documented in NRC Inspection

l

'

Report 50-482/93-03, Section 2.8, as a violation of Technical Specification 3.9.4 and was not cited because the licensee satisfied the

'

criteria specified in paragraph VII.B.2 of the NRC Enforcement Policy. As a

'

corrective action to prevent recurrence, the licensee committed to review all

,

operating procedures for systems penetrating containment for similar

l

deficiencies.

.

The licensee immediately established containment closure. The licensee

.

i

!

attributed the root cause to personnel error.

Licensee personnel addressed

j

how using their self-checking program could have prevented this violation of

-

containment integrity. As committed, the licensee reviewed other systems with

!

l

existing procedures for draining the part of the system that penetrates

containment and identified a total of three procedures that were affected.

,

l

The inspector verified that the licensee revised Procedure SYS EF-420. The

!

inspector found that the licensee also corrected Procedure SYS EM-420, " Safety

l

Injection System Drain," Revision 1, to provide explicit guidance immediately

before the applicable steps cor.cerning containment closure requirements

whenever systems inside containment were drained.

The third procedure identified, Procedure SYS EG-401, " Component Cooling Water

System Drain Procedure," Revision 0, was not modified in like manner.

The

inspector considered the failure to provide explicit guidance in

Procedure SYS EG-401, as specified in LER 482/93-003, to be a violation of

10 CFR Part 50, Appendix B, Criterion XVI (482/9327-05). The licensee changed

Procedure SYS EG-401 to provide explicit guidance prior to the appropriate

steps that addressed requirements for containment closure after the inspector

identified the deficiency.

l

. .

.

-

.

-22-

8.3

(Closed) LER 482/93-005:

Failure to Perform "As Found" Local Leak

Rate Test

On March 22, 1993, an electrician removed the actuator for Valve BG HV8105,

centrifugal charging pumps to regenerative heat exchanger containment

isolation, before personnel performed the "as found" Type C local leak rate

test, as specified in the supplemental work instructions. The licensee

determined that the electricians had inadvertently skipped the required step.

Immediately, the electrical maintenance supervisor discussed this event with

electrical maintenance personnel. The licensee identified this occurrence as

cognitive personnel error and initiated " positive discipline" for the

individual.

The inspector reviewed the memorandum that documented the individuals

" positive discipline" discussion. The electrician described the various

changes to the work activities he was to perform, described some schedule

pressures (outage), and admitted that he missed the step. The electrician

described the importance (missed Technical Specification requirement), the

consequences (personnel injury / equipment damage), and preventive actions (self

checking) related to this deficiency.

8.4 Conclusions

The inspector found that the licensee completed their commitment to review

other draindown procedures that have the potential to violate containment

integrity. However, after review of the affected procedures, the inspector

identified a violation because the licensee failed to effectively implement

corrective actions. One of the affected procedures was not modified to

provide explicit guidance that would eliminate the potential for a similar

situation to exist. The inspector found that the licensee implemented strong

corrective actions in response to the other events.

9 IN-OFFICE REVIEW 0F LERs

(90712)

The inspector reviewed the following LERs and determined that personnel

completed the corrective actions discussed in the report.

9.1

(Closed) LER 482/93-007:

Late Surveillance Test Performance Caused By

Lack of Oversight of the Surveillance Program Results in a Technical

Specification Violation

9.2 (Closed) LER 482/93-011:

Nuclear Plant Information System Axial Flux

Dif ference Limits Were Not Updated With Technical Specifications

Revision

____ - ___

.,

,

..

o

-

ATTACHMENT

1 PERSONS CONTACTED

N. S. Carns, President and Chief Executive Officer

K. B. Clair, Supervisor, Maintenance Planning

A. B. Clason, Supervisor, Maintenance Engineering

H. E. Dingler, Manager, Hot License Training

D. L. Fehr, Manager, Operations Training

i

C. W. Fowler, Manager, Maintenance and Modifications

R. B. Flannigan, Manager, Nuclear Safety Engineering

D. E. Gerrelts, Manager, Instrumentation and Control

R. C. Hagan, Vice President Nuclear Assurance

K. M. Harvey, Manager, Document Services

S. F. Hatch, Specialist, Quality Assurance

W. M. Lindsay, Manager, Quality Assurance

R. L. Logsdon, Manager, Chemistry

A. S. Mah, Senior Engineer, Nuclear Safety Engineering

0. L. Maynard, Vice President Plant Operations

B. T. McKinney, Manager, Operations

T. S. Morrill, Manager, Radiation Protection

W. B. Norton, Manager, Nuclear Engineering

J. D. Pappan, Specialist III, Quality Assurance,

C. E. Parry, Director Performance Enhancement

J. M. Pippin, Manager, Integrated Plant Scheduling

C. E. Rich, Jr., Supervisor, Electrical Maintenance

T. L. Riley, Supervisor, Regulatory Compliance

R. L. Sims, Supervisor, Results Engineering

B. B. Smith, Manager, Modifications

C. M. Sprout, Manager, System Engineering

J. D. Stamm, Manager, Support Engineering

S. G. Wideman, Supervisor, licensing

M. G. Williams, Manager, Plant Support

D. P. Wiltse, Shift Supervisor

The above licensee personnel attended the exit meeting.

In addition to the

personnel listed above, the inspectors contacted other personnel during this

inspection period.

2 EXIT MEETING

An exit meeting was conducted on October 27, 1993. During this meeting, the

inspectors reviewed the scope and findings of the report. The licensee did

not identify as proprietary any information provided to, or reviewed by, the

inspectors.

The licensee stated, as an interim measure, that engineers would review

l

100 percent of erected scaffolding for compliance with program requirements

l

until more specific program guidance is developed. The licenNe took no

exception to any of the findings.

l

l