IR 05000482/1992032

Insp Rept 50-482/92-32 on 921122-930102.Violations Noted. Major Areas Inspected:Plant Status,Operational Safety Verification,Maint Observations,Surveillance Observations, Mgt Meeting & in-office Review of LERs

ML20128D618
Person / Time
Site:	Wolf Creek
Issue date:	01/26/1993
From:	Howell A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20128D501	List: IR 05000482/1992032 ML20128D498 ML20128D557
References
50-482-92-32, NUDOCS 9302100189
Download: ML20128D618 (18)

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APPENDIX B U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-482/92-32 Operating License No.: NPF-42 Docket: 50-482 Licensee: Wolf Creek Nuclear Operating Corporation P. O. Box 411 Burlington, Kansas 66839 Facility Name: Wolf Creek Generating Station Inspection At: Coffey County, Burlington, Kansas inspection Conducted: November 22, 1992, through January 2, 1993 Inspectors: G. A. Pick, Senior Resident inspector >

L. E. Myers, Resident inspector D. R. Calhoun, Resident Inspector, Region 111 R. ar , Reac or Inspector Approved: /. 3

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K. T . I el , Dale Divisi of Reactor Projects inspection Summa Areas inspected: Routine, unannounced inspection including plant status, operational safety verification, maintenance observations, surveillance observations, management meeting, followup of corrective actions for violations, followup of previously identified inspection findings, onsite review of licensee event reports (LERs), and inoffice review of LER Results:

• 1he licensee had not established contingency plans for operator response to an unisolable essential service water (ESW) leak due to freeze seal failure until questioned by the inspectors (Section 2.1).

. After personnel applied excessive force to a new fuel assembly because of failure to follow an approved procedure, the licensee implemented comprehensive corrective actions. A violation of procedural requirements occurred but was not cited (Sections 2.2 and 4.2).

9302100189 930201 PDR ADOCK 05000482 o PDR l

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• The licensee established, by thorough work planning and coordination, a freeze seal, which was needed in order to repair a leaking butterfly valve. Qualified personnel used a well-written, detailed procedure for controlling freeze seals. However, the inspectors rated that initial repairs to the valve did not correct the problem (Section 3.1).

• The licensee made offective use of thermograph The licensee identified potential circuit card failures prior to a failure occurring (Section 3.2).

• The licensee experienced difficulty in locating spare parts in their warehouse while in the process of repairing a failed emergency diesel generator (EDG) auxiliary lubricating oil pump (Section 3.3).

• During repair of a spent fuel pool cooling pump, licensee personnel followed proper radiological work practices. Work instructions were detailed; however, a procedure violation occurred when a mechanic improperly removed a ft' led bearing ($retion 3.4).

• Personnel demonstrated good communications and coordination during performance of surveillance activities. Licensee management periodically monitored fuel receipt inspections (Section 4).

• During the public Systematic Assessment of Licensee Performance (SALP)

meeting, the licensee provided their corrective actions to identified weaknesses. During a tour of the facility, NRC Regional management noted a number of control room and plant deficiencies that were greater than 1 year old (Section 5).

• The inspectors determined that the efforts of a quality assurance auditor, who identified that a spent fuel pool gate was moved over spent fuel assemblies, were commendable. The licensee investigated the incident to determine the facts and to initiate appropriate corrective actions. The inspectors identified a violation because the procedure for moving spent fuel pool gates did not contain precautions to prevent moving heavy loads over fuel assemblies (Section 7.3).

Summarv of insnection Findings:

• Violation 482/9232-01 was opened (Section 3.4).

• Violation 482/9232-02 was opened (Section 7.3).

• Violations 482/9026-01, 482/9135-01, and 482/91202-03 were closed (Section 6).

• Inspection followup Items 482/9136-05 and 482/9203-01 and Unresolved item 482/9231-03 were closed (Section 7),

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• LERs90-027, 91-012,91-023 and 91-023-01,91-025 and 91-025-01,92-003, and 92-010 were closed (Sections 8 and 9).

, Attachment:

• Attachment - Persons Contacted and Exit Meeting l

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-4-I DETAILS 1 PLANT STA1US (71707)

The plant operated at 100 percent power throughout the inspection perio On December 5, 1992, the licensee assigned Mr. Chet Fowler as Manage l Maintenance and Modification. Mr. Fowler in recent months participated as a j Performance Enhancement Program team member but, previously, he was the i Manager, Instrumentation and Control (l&C). The licensee assigned Mr. Ron Holloway, the 3r. tious Manager, Maintenance and Modification to be an Assistant to tie vice President, Plant 0)erations. Mr. Holloway will serve in .

this capacity until he attends the Novem>er 1993 hot license clas l On December 19, 1992 Mr. Jack Pippin, a Performance Enhanceinent Program team member, was reassigned as the Manager, Integrated Plant Scheduling. The licensee created the Integrated Plant Scheduling group to strengthen the daily scheduling of maintenance activities and reduce the backlog of outstanding work requests (WR).

2 OPERATIONAL SAFETY VERIFICATION (71707)

The objectives of this inspection were to ensure that the facility was being operated safely and in conformance with license and regulatory requirements and that the licensee's management control systems were effectively discharging the licensee's responsibilities for continued safe operatio The inspectors monitored licensee activities related to contingency plans for freeze seals and a new fuel assembly subjected to a strai 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 verification of safety-system status and Technical Specifications (TS)

limiting cor.ditions for operation, verification of corrective actions, and review of facility records, 2.1 Contingenc,y_ Plans for Freeze Seals On December 3,1992, prior to the installation of a freeze seal on the Train A ESW suction line, the inspectors noted that the licensee had documented contingency plans in WR 06042-92 for personnel working in the area in the event of catastrophic failure of the freeze seal. The licensee established the contingency plans because the suction line to Motor-Driven Auxiliary feedwater Pump A could not be isolated for the repair of Motor-Operated Valve AL HV031. ESW to Motor-Driven Auxiliary Feedwater Pump A. For approximately 10 minutes, the ESW system was open after removing the valve and before installing a blank flang If the freeze seal had failed at this time, the ESW line would drain down until the standby ESW pump started on low pressure, which could have introduced a large volume of water into the

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confined spac The inspectors questioned licensee personnel about I contingency plans for control room personnel because of the potential safety 1 hazard. As a result of the inspectors questions concerning control room i response, the licensee developed detailed contingency plans for operator l actions to be taken to minimize the volume of water introduced intt the valve

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ro In addition, the licensee changed Procedure MGM M00C-12. " freeze Seal '

Application," to require operations to prepare a written contingency plan as l part of any Wp or any temporary modification that requires the installation of a freeze sea '

2.2 .New Fuel Assembly Subjected to Excessive Force On December 16, 1992, as the licensee prepared to lift fuel Assembly J42 from the strongback of the container, the operator of the cask handling crane monorail auxiliary hoist placed the hoist switch in " normal" instead of " jog" as recuired by Procedure FHP 01-001, "New fuel Receipt," Revision 1 Procecure FHP 01-001, Step 7.1.17, required that the hoist operator place the monorail hoist switch to " jog" to take up the slack in the lifting cable after securing the fuel handling tool to the fuel assembly top nozzle and before unclamping the fuel assembly from the strongback. Since the hoist switch was in " normal," the licensee exceeded the procedurally required less than 200 pounds of force. The force applied to the fuel assembly top nozzle was approximately 1750 pounds. This amount of force could have damaged the fuel assembly grids or rodlets by interaction with the strongback clamps. . The licensee discontinued further inspection activities on the fuel assembl The licensee properly removed the fuel assembly from the container, visually inspected the fuel assembly, and stored the fuel assembly in the new fuel storage rack rather than in the spent fuel pool to facilitate later inspections. The visual inspection of the fuel assembly. revealed no apparent damage. After consultation with the fuel vendor, the licensee decided that the fuel vendor will conduct additional inspections to evaluate the acceptability of the fuel assembl The licensee initiated Performance Improvement Request (PIR) OP 92-0810. The immediate corrective action consisted of initiating Temporary Change Form MA 92-0139 that clarified procedure requirements. The temporary change form added several steps providing more detail for the removal of a fuel assembly from the container strongback. The inspector determined that:

(1) the procedure provided sufficient guidance prior to initiating the temporary change form, (2) the prejob briefing was adequate to arevent the occurrence, and (3) operator inattention to detail appeared to se the root cause. The failure to implement-Step 7.1.17 of FHP 01-001. constituted violation of TS.6.8.1.a for failure to follow an approved procedure. . However, the violation will not be cited because the criteria specified in paragraph VII.B.2 of the NRC Enforcement Policy were satisfied. The licensee identified the procedural noncompliance and determined the event was not reportable. The licensee'immediately took corrective-actions to prevent recurrence.- Before inspections of the fuel assemblies resumed, the licensee conducted a prejob brief for personnel associated with the activities on proper communication practices and adherence to the procedur The inspectors

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-6-observed several fuel inspections following the incident and determined that the effectiveness of the corrective actions prevented recurrence (refer to Section 4.2).

2.3 Conclusions The licensee implemented effective work area contingency plans during conduct of planned maintenance. However, until questioned by the inspector, the licensee had not established contingency plans for the control room operators to respond to an unisolable ESW system leak. A br' 'ge crene operator failed to follow an approved procedure, which resulted in To potential overstressing of the grid straps and rodlets on a new fuel assembly. The licensee properly responded to the event, determining that the fuel assembly should receive a j more detailed inspection prior to being use MAINTENANCE OBSERVATIONS (62703)

The purpose of inspections in this area was to ascertain that maintenance activities on safety-related systems and components were conducted in accordance with approved procedures and TS. Methods used in this inspection included direct observations nf maintenance activities, interviews with personnel, and review of record .1 Pepairs on Auxiliar_v Feedwater (AfW) Suction Valves

On NoveTiber 27, 1992, the licensee determined that Motor-Operated Valve Al HV031 was experiencing seat leakage such that lake water was leaking into the pump suction. Normally, the AFW pump suction is aligned to _the

- condensate storage tank. Motor-operated Valve Al HV031 performs two safety-related functions: (1) the valve opens under accident conditions when the supply from the condu sate storage tank is not available and; (2) the

, valve provides a pressure boundary for the AFW system. The ESW suction valve opens when the condensate storage tank falls to 21.9 pounds por square inch gage (psig). Chemistry personnel had determined from daily steam generator i samples that the-sodium concentration was increasing. The licensee also determined that the condensate storage tank sodium levels had increased, necause the ESW suction valve leaked, lake water at approximately 112 psig iiowed into the pump suction header, which is nominally pressurized to 80 psig (the water head of the condensate storage tank). The lake water passed thro ; a Ug pump, through the test return line of the AFW pumo, and into the conde A 4 ~ rage tank. The lake water degraded the high-quality water maintaiwJ in the condensate storage tan From discussions with licensee personnel, the inspector determined that no steam generator chemistry limits were exceeded. The steam generator limits for sodium, sulfates, and chlorides are 20 parts per billion (ppb). The

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limits for the condensate storage tank are 10 ppb. On three occasions, December 3, 22, and 28, 1992, the chemistry limits for the condensate storage tank were exceeded following ESW pump tests. The contaminant of the highest concentation was sulfates, which reached 388 ppb,178 ppb, and 23.8 ppb,

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-7-respectively. For each chemical intrusion, the licensee flushed the auxiliary feedwater pumps and placed the condensate storage tank on recirculation through a spare demineralizer in accordance with their procedure Valve AL HV031 is a Fisher Controls Company, 6-inch butterfly valve, Type 9221, with a stainless steel disc that rotates closed into a rubber T-seal. The licensee installed this type of valve in both motor-driven AFW pump suction lines. In addition, the turbine-driven AFW pump has an 8-inch butterfly valve of the same type on the suction lines from each ESW trai When the licensee operates the ESW pumps during surveillance tests, the pressure increases to approximately 150 psig. This results in degradation of the T-seal and increases t'- 'eak rato. Because of this degradation, the licensee has plans to rep' 4 ls type of butterfly valv After adjutting the limits on the motor actuator for Valve AL HV031, the leak rate did not decrease; consequently, mechanical maintenarce prepared to install a freeze seal and repair the valve. Since the ESW suction valve to the AFW pump is unisolable, the licensee must install a freeze seal to isolate the valve whenever the valve must be removed for repair. On December 2,1992, mechanics installed the freeze seal in accordance with WR 05937-92 and dssoCiated Temporary Modification Order 92-052-EF. The licensee removed the valve and identified erosion and corrosion on the valve body section that holds the T-seal in place. An engineering evaluation for WR 06016-92 concluded that the valve could be used as-is until the next refueling outag The licensee determined that the corrosion effects did nc. a'fect the safety-related functions and that a new T-snal would stop the leakag The licensee consulted the vendor who agreed that the replacement of the T-seal would stop the leakage. Mechanics reassembled the valve using a replacement T-seal, adjusted the valve limits, and conducted postmaintenance testing. However, the valvc started to leak after the licensee completed the ESW pump operability surveillance. Because the leak rate continued to increase, the licensee performed additional valve repairs on December 5,1992, which were similar to those described above. The licensee weld repaired the eroded and corroded area and machined the surface to the original design specifications. The venoor provided the dimensions and a vendor representative witnessed the repair. The licensee installed and postmaintenance tested the valve successfully on December 5, 199 The inspe: tors observed and monitored most aspects of these activities. Good work plrAning and continual oversight were noted. Qualified personnel properly installed the freeze seal equipment. .The inspectors noted that the freeze seal installation in a confined space was closely monitored by safety personnel who had -installed temocrary ventilation alarming oxygen. analyzer The detailed work instructions provided a contingency plan for the catastrophic failure of the freeze seal. Personnel conducting the freeze seal process were cognizant of the contingency plan. The inspectors considered the licensee controls for installing the freeze seal to be good.

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-8-From discussions wf th licenses personnel, the inspectors determined that a hardware failure analysis' on the valve seat failures is being performed. The failure ana'ysis should be completed within 4 months, following the completion of Refueling Outage VI. The licensee will inspect the interior of the remaining ESW valves and collect additional data to aid in the analysis. The licensee will decide on final corrective actions following completion of the failure analysi .2 heg ntive Maintenance on Train B Control Room Air Conditioning Unit SGK04B On December 7, 1992, the inspectors observed maintenance activities on the control room. air conditioning unit. The electricians obtained approval from the shift supervisor prior to beginning work activities. The electricians conducted a number of preventive maintenance items as directed by a supplemental instruction sheet attached to WR 52423-92. Activities performed included: (1) check and adjust all fan drive belts, (2) . inspect contactors for degradation, (3) megger fan motor and compressor, and (4) check wire connections for tightness. The inspectors determined that the electricians identified no nonconforming conditions and that they were-knowledgeable of the work scope. Test equipment used was within the calibration due dates, and the inspectors cbserved proper involvement by quality control personne As part of this WR, rest.lts engineers performed a thermographic signature of control cabinet electrical connections for Air Conditioning Unit'SGK04B prior to de-energizing the unit. The licensee identified two electrical connections

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inside the breaker that had excessive temperature readings (hot spots).

Procedure EMG 08-001, " Infrared Thermography, " Revision 0, specifies that a

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WR should be written whenever a component exhibits temperature readings that are 20 F greater than similar component temperatures. The Phase A and B temperatures were 38 F and 25of above the Phase C temperature. As a result, I- the licensee generated WR 06034-92_to troubleshoot and repair the hot spot The electricians did not identify any loose connections during the inspection that would have caused or contributed to the hot spot Upon connector

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disassembly, the electricians and the inspectors noted that the material condition of the connectors appeared good and the connectors were not discolored or damaged. A quality control inspector. verified proper lifting and relanding of the leads. After Air Conditioning Unit SGK04B was restored to service, the licensee performed another thermographic signature of the control cabinet to-ensure that the hot spots were eliminated. All temperatures were within the-acceptance criteri .3 EDG Lubricatinq Oil pump On December 10, 1992, a nonlicensed operator determined that the EDG A auxiliary lubricating oil (keep warm) pump was not rotating. The shift supervisor determined from review of TS Interpretation 9-86 that the EDG remained operable as long as the lubricating oil temperature did not fall below 115 F. Subsequently, the licensee started EDG A periodically to maintain the oil temperature above the setpoint until repairs could be

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implemente The licensee determined that they had no spare parts for the failed pump and did not have an operable spare pump. A spare pump, lacated in the warehouse, had been removed -in 1991 because of mechanical seal leakage but was not yet repaired. The system engineer determined that the pump was not I repaired because spare parts were not available; consequently, the system engineer initiated a use-as-is disposition so that the spire pump could be installed until parts were procure The licensee declared EDG A inoperable at 9:33 p.m. on December 10, 1992, so that the pump could be replaced. The replacement pump required a mechanical seal. An engineer located a mechanical seal that was procured under Purchase Order 520868 initiated in 1987, but the spare part was not assigned to the auxiliary lube oil pum). From discussions with licensee personnel, the inspector determined t at the spare mechanical seal was assigned to no particular component. Generally, spare parts are assigned to a com)onent, i such as the EDG, and not to subcomponents, such as the auxiliary lu)e oil pump. The mechanical seal was located by searching for a mechanical sea In the future, the licensee's Spare Parts Configuration Management program will l have provisions to facilitate the location of spare parts for subcomponent For components that are repaired frequently or spare parts that are used often, the licensee will assign an identifier, develop procurement specifications, and identify applications to assure -that the parts remain in stock and are easily identifie <

The licensee initiated another WR for rebuilding the auxiliary lube oil pum Mechanics rebuilt and installed the pump on December 12, 1992. After completing an operability test for EDG A on December 13, 1992, in accordance with Procedure STS KJ-005A, Revision 17, " Manual / Auto Start, Synchronization, ;

and Loading of Emergency Diesel Generator NE01," the licensee returned EDG A !

to service. On December 14 and 15, 1992, the inspectors observed repair activities of the auxiliary lube oil pump that had failed on December 10, 1992. The licensee determined that the locking ring had failed because of fretting created by normal pump vibration. The work was conducted in accordance with work instructions documented under WR 70896-9 The work instructions were well written. The mechanic followed the work instructions and referred to the vendor manual. drawing .4 Disassembly of Spent Fuel Pool Coolina Pump A (PEC01A)

On December 8,1992, the inspectors observed the disassembly of Spent Fuel Pool Cooling Pump The mechanical seal failed and was leaking slightly contaminated cooling water at a rate of- approximately 10 gallons per minut WR 05923-92 directed craft personnel to: (1) disassemble the pump, . (2) .

replace the defective parts of the mechanical seal, and (3) replace the i bearings, if necessary. The work instructions were detailed and comprehensive. The mechanics disassembled the pump within the contaminated area created by the leak and complied with the instructions of the radiation work permi The contaminated area was properly posted, and health physics ;

technicians periodically monitored the repair activities. The mechanics found 5 that the thrust bearing and inner bearing were damaged, resulting in the

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failure of the mechanical seal. When the thrust bearing failed, the shaft and ,

impeller moved and damaged the pump casin The inspectors observed a mechanic hammering the inner bearing from the pump shaft contrary to the work instructions. Step 2.16 of the work instructions directed the craft to remove the inboard bearing by using a bearing puller or equivalent. The mechanic failed to inform his supervisor of the destruction

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of the bearings or the decision to remove the bearing from the pump shaft by other means than that specified in the work instructions. The-failure to follow the work instructions of.a WR 05923-92 is a violation (482/9232-01).

An engineering disposition for WR 05923-92 was initiated to evaluate the damage caused by the impeller impinging on the casing and to evaluate any damage caused by the loose parts of the destroyed inboard bearing. The pump is designed to the requirements of the American Society of Mechanical EngineersSection III, Class 3. The licensee determined that the wear groove

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on the pump casing caused by the rotating impeller did not exceed the minimum wall requirements and that t te casing could be used as-is. The mechanics reinstalled the pump shaft since only minor scratching and marring occurred in

, the area of the bearing seats and oil seals. The pump was successfully

repaired by replacing the impeller, bearings, and seals on January 2,199 The inspectors reviewed the work history of the spent fuel cooling pumps and discussed the work history with results engineering. Electrical maintenance

replaces the motor bearings and mechanical maintenance replaces the pump bearings at separate times without coordination. Results engineering noted that, following the replacement of either the pump nr the motor bearings, the bearings on the other _ component would soon degrade. After results engineering expressed concerns about the methods used to replace the pump and motor bearings, all the groups met to discuss the bearing replacement method. As a

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result of discussions, the maintenance planning group coordinated the electrical maintenance, mechanical maintenance, and results engineering efforts for the pump and motor bearing repairs on January 2,1993. For future

bearing and seal repairs, mechanical and electrical maintenance will replace

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both sets of bearings at the same time.

Because of previous failures of the spent fuel-pool cooling pump, licensee management directed results engineering personnel to perform a self-assessment of the pump repair activities. The engineers reviewed the work activities to 4 determine a root cause of the thrust bearing failure. Preliminarily, the licensee determined several con.tributing causes but no definite root caus Potential causes included inadequate bearing clearances, alignment practices, and work practices.

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3.5 Conclusions The licensee implemented good work plans for the repair of a butterfly valve

that 6xperienced seat leakage. Initial repairs were._not successful; however,

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added planning and coordination resulted in a high-quality repair. The mechanics implementing the freeze seal were knowledgeable and aware of all

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-11-contingency plan Management involvement was eviden During performance of the various maintenance activities, the test instruments were within calibratio The licensee demonstrated effective implementation of their thermography program while performing preventive maintenance on a control room air conditioning uni The licensee properly evaluated repair methods for an EDG lubricating' oil pump. The licensee determined that a spare lubricating oil pump could be used as-is until locating spare parts in the warehouse. Presently, the licensee identifies spare parts by components, such as the EDG, and not by a subcomponent, sach as the auxiliary lube oil pump. In the future, the licensee's Spare Parts Configuration Management program will allow the licensee to identify spare parts by subcomponent During repair of a pump in a contaminated area, mechanics followed good radiological practices. The work instructions for the repair of the pump were detailed and comprehensive; however, when difficulties occurred, a mechanic violated his work instructions. The mechanic did not consult with his supervisor nor did he have the work instructions revised, which resulted in a violatio SURVEILLANCE OBSERVATIONS (61726)

The purpose of inspections in this area was to ascertain whether surveillance of safety-related systems and components was being conducted in accordance with TS and approved procedure .1 Chlorine Detector Testina On December 9, 1992, the. inspectors observed I&C technicians perform the analog channel operational test for the control room chlorine detectors for both Trains A and B. The testing activities were conducted in accordance with Procedure STS IC-280A, Revision 12, " Analog Channel 0P Test - CTRL RM DET Train A," and procedure STS 10-280B, Revision 10, " Analog Channel OP Test -

CTRL RM DET Train B." The I&C technicians obtained approval from the shift supervisor prior to testing each train. The chlorine sensors were required to trip in 7 seconds or less to meet the acceptance criteria; however, the Train A and B detectors tripped in 12.43 and 14.50 seconds, respectivel Also, the techniciant determined that the as-found high-side span value was out of toleranc In response to the inadequate trip times, the licensee initiated WRs 06148-92 and 06152-92 to replace both of the chlorine sensors. The technicians replaced the chlorine sensors and reperformed the procedures achieving-acceptable trip response times. Minor adjustments of the high-side span potentiometer returned the span values within limits. Good communications and coordination occurred among the I&C technicians, operations personnel, and the I&C planne .

t-12-4.2 New Fuel Assembly Inspection On December 23, 1992, the inspectors observed licensee personnel performing fuel assembly inspections in accordance with Procedure FHP 01-001. The licensee procured the fuel in preparation for Refuel VI that is scheduled to begin March 5, 1993. The procedure incorporated the following activities for the fuel assemblies: (1) removal from the shipping containers, (2) initial receipt inspection, and (3) transfer to the spent fuel pool racks or to the new fuel storage racks, During these fuel receipt activities, reactor engineering demonstrated good coordination with operations and health physics personnel. All instruments were properly calibrated and within calibration due date The procedure contained detailed and comprehensive notes, precautions, and prerequisites. Quality control personnel performed independent inspection of the fuel. The inspection of the new fuel was deliberate and cautious. The inspectors noted that licensee management observed the in-progress activities at various time .3 Conclusions Personnel received approval from the shif t supervisor prior to beginning work activitie Technicians utilized calibrated test equipment. Good communications and coordination was evident during performance of work activitie Procedures were well written and detaile MANAGEMENT MEETING (30702)

On December 15, 1992, licensee management presented the action plans for the Performance Enhancement Program to the NRC Region IV Regional Administrator and members of his staff. Following the meeting, the Regional Administrator and other members of Region IV management toured the facility and commented on the good level of housekeeping and material condition of the plant. However, Region IV management noted that a number of " aged" (i.e., greater than 1 year old) WR deficiency tags were located in the control room and throughout_the plant. These comments were communicated to licensee senior managemen On December 16, 1992, a public meeting between NRC and the Wolf Creek Nuclear Operating Corporation was conducted at the Eisenhower Nuclear Trainirig Center to discuss the SALP report for the period October 6, 1991, through October 10, 1992. NRC presented a performance summary of each of the seven functional areas rated in the report. The performance summary included the SALP rating that was based on an assessment of the inspection findings identified during_

the assessment period. The licensee responded by addressing the actions taken

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-13-6 FOLLOWUP 0N CORRECTIVE ACTION FOR VIOLATIONS (92702) (Closed) Violation 482/9026-01: Inadeauate Corrective Action This violation documented two examples of inadequate corrective actio The first example specified that the corrective actions for LER 87-014 failed to prevent recurrence of similar events as discussed in LERs89-016 and 90-004 that were related to monitoring past due surveillances. The licensee failed to formalize the review of the past due surveillance report that documented TS required surveillance tests that were not performed by the required due dat The second example documented that corrective actions in response to LER 90-010 were not fully effective. An AFW pump was rendered inoperable without the knowledge of control room personnel because the room cooler access door was removed during troubleshooting. The corrective actions in response to LER 90-010 required informing maintenance and operations personnel that room cooler doors must remain intact to ensure operability of the room coole Also, maintenance personnel were made aware of the necessity-to inform the shift supervisor of all troubleshooting activitie However, on June 19, 1930, a similar occurrence occurred because not all control room operators were made aware that I&C personnel were troubleshooting the control rod position indication syste Tht inspectors determined that corrective actions related to resolving the first example were effective. The inspectors verified that the past due report was issued daily and that the surveillance scheduling group remains cognizant of past due surveillances. Although, there have been missed surveillances recently created by a breakdown in communications and an incorrect change to the surveillance database, the licensee has not missed-TS surveillances because the past due report was not reviewe The inspectors verified that the licensee conducted training to assure that personnel were aware of their responsibilities to inform the .itrol room of troubleshooting activities. Also, control room personnel were informed of their responsibility to understand the full scope of the troubleshooting. The licensee changed their corrective action program to require that all actions in response to LERs, NRC violations, and other significant conditions adverse to quality are formally reviewed to evaluate the effectiveness of the corrective actions. Also, effectiveness followup reviews were required for PIRs. The inspectors verified that the Plant Safety Review Committee reviewed significant PIRs. The use of effectiveness followups was described in NRC Inspection Report 50-482/92-2 C.2 (Closed) Violation (482/9135-01): Failure to Comply With TS 3.1. TS 3.1.2.1 requires that, with the plant in Modes 4, 5, or 6, a boron injection flowpath from either the boric acid storage system or the refueling water storage tank via a centrifugal charging pump to the reactor coolant system be operable. With none of the flowpaths operable, it requires the suspension of all operaticns involving core alterations or positive reactivity change _ _ _ - _ _ _ _ _ - _ _ .

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-14-On November 19 and again on November 20, 1991, with the plant in Mode 5 and no centrifugal charging pump operable, licensed operators injected borated water at 2473 and 2040 ppm boron, respectively, into the reactor coolant syste Since the reactor coolant system was at a boron concentration of approximately 2500 ppm, these actions resulted in an addition of positive reactivit The inspectors verified that the licensee revised Procedure SYS BB-110

" Reactor Coolant System Fill and Vent," to specify that the boron concentration of the fill water must be greater than or equal to 2400 ppm and greater than or equal to the existing reactor coolant system boron concentration. The licensee incorporated specific instructions regarding automatic operation of the reactor makeup control system into the licensed operator requalification training program. The licensee changed Procedure SYS BG-200, " Reactor Makeup control System Operating," to include a caution reminding control room operators that the reactor makeup control system is in the automatic mode of operatio .3 (Closed) Violation 482/91202-03: Missed TS Surveillance Test This violation was issued because of a missed TS surveillance requirement that was documented by LER 90-027 (refer to Section 8). The inspectors verified that the licensee's corrective actions documented in their violation response had been implemente The surveillance program upgrades included changes to the software programs such as: (1) a 2-year, look-ahead scheduling program, (2) the scheduling program automatically assigns a 25 percent alert time (the number of days before the due date), and (3)- when 3rocedures are performed less than 6 days before the scheduled date, the scleduled and late dates do not change 7 FOLLOWUP (92701) (Closed) Inspection Followup Item (482/9136-05): Fuse Control The licensee evaluated the adequacy of their methods for fuse control in order to develop a fuse control program by June-30, 1992. During the inspection, the inspectors reviewed Wolf Creek Nuclear Operating Corporation interoffice correspondence, Letter 8591-0061, dated August 24, 1992, and Wolf Creek Procedure ADM 01-247, " Fuse Verification and Control." Revision 0. The inspectors concluded that the licensee has developed and implemented a formal fuse control program as prescribed by Procedure ADM 01-24 .2 (Closed) Inspection Followup Item (482/9203-01): Boric Acid Monitoring Program The boric acid corrosion monitoring program did not include valves and components located outside containment that were within the reactor coolant pressure boundary. To address this concern, the licensee initiated PIR 92-0112 in order to conduct an engineering evaluatio . -

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-15-During the inspection, the inspectors reviewed the results of the engineering _

evaluation dated May 29, 1992, and noted that the final disposition of this engineering evaluation resulted in additional valves and components being added to the boric acid monitoring program. The inspectors verified tha Procedure ADM 08-215, " Boric Acid Monitoring Program," Revision 3, included the additional valves and component .3 (Closed) Unresolved Item 482/9231-03: Gate Seal Inspection and Renlacement in the Spent Feel _ ['oo_1 On November 5, 1992, the licensee began inspection activities on the gate seals for the cask loading pool and the fuel transfer canal gates. In order to inspect the gate seals, licensee personnel lifted the gates from the storage locations and positioned the gates in the pool so that the seals could be visually inspected by divers. The licensee transported the cask loading pool canal gate from the storage location into the cask loading pool where it was inflated and visually inspected. The seal had numerous leaks that were observed from above the pool. Since the fuel transfer canal gate seals were the same age as the cask loading pool gate seals, the licensee decided to .

place the fuel transfer canal gate in a position where it could be inflated and inspected from above the pool before divers entered the pool. The licensee lifted the fuel transfer gate off the storage rack and rotated the gate in order to visually observe the seal from above the pool. The seal failed when inflated, and the fuel transfer canal gate was relocated to the storage rac Af ter relocating the fuel transfer canal gate, a quality assurance auditor, who was conducting a surveillance of the spent fuel pool gate seal inspections, raised a concern that the gate may have been over spent fuel elements. The licensee stopped the work activities to resolve this concer Quality assurance initiated Quality Program Violation (QPV) 11/92-071 for a violation of TS 3.9.7. TS 3.9.7 states that loads in excess of 2250 pounds shall be prohibited from travel over fuel assemblies in the spent fuel poo The licensee issued Reportability Evaluation Request 92-077= to evaluate reportability and began investigating the circumstances surrounding the movement of the gat The licensee concluded, on November 30, 1992, after interviewing all personnel actively involved or witnessing the event, and reviewing maps of fuel

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locations, that the 5200 pound gate had not travelled over fuel assemblies during movement of the gate. On December 2, 1992, quality assurance issued QPV 11/92-071 based on the observations of the auditor. On December 2, 1992, the licensee initiated PIR 92-0783 and developed a task force from all groups involved with the activities to identify appropriate corrective action Groups that vere represented included: operations, system engineering, reactor engineering, results engineering, mechanical maintenance, and health physic The inspection and work activities of the gate seals were initiated by WR 51566-92 and performed in accordance with Procedure MPM KE-002, " Spent Fuel

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-16-Pool Seal Preventive Maintenance Activity," Revision 0, that required seal inspection and replacement in the pool by divers. Procedure MPM KE-002 required the installation of a temporary safety cable on the gate while moving the gates in the spent fuel pool and required operations personnel to move the gate according to the requirements of Procedure FHP 03-007, " Spent Fuel Pool Bridge Crane Operating Instructions and Daily Checks." Procedure FHP 03-007 did not have a precaution concerning movement of heavy loads over fuel. The inspectors noted that Procedure FHP 03-007 did not designate a path for safely moving heavy loads in the spent fuel pool. The failure to provide precautions and guidance in Procedure FHP 03-007 to prevent moving heavy loads over fuel assemblies is a violation of TS 6.8.1.a (482/9232-02). As a result of the QPV and the licensee investigation, Procedures MPM KE-002 and FHP 03-007 were

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changed to include precautions to prevent heavy loads from traveling over fuel assemblies. In addition, the licensee moved the fuel assemblies from the gate transfer pat ONSITE REVIEW OF LICENSEE EVENTS REPORTS (92700)

(Closed) LER 482/90-027: TS Surveillance Requirement not Satisfied Because of a Change to the TS Procedure Database While reviewing why Procedure STS ML-001, " Monthly Surveillance Log," was not performed in Modes 5 and 6, the licensee determined that the procedure should have been performed. TS 4.3.2.1 requires, in part, that both the control room isolation automatic actuation logic relays and the balance of plant engineered safety teatures actuation system logic relays be tested monthly. The licensee determined that, prior to Refuel IV, I&C personnel stopped performing Procedure STS IC-212, " Actuation Logic Test 80P ESFAS," Revision 4, and Procedure STS IC-229A, " Actuation Logic Test Load Shedder and Emergency Load Sequence Group 1 (Red)," Revision 1, in Modes 5 and 6 that accomplished the surveillance requirements; however, the licensee failed to add the surveillance requirements to Procedure STS ML-001, as intende On May 9,1990, the licensee satisfactorily performed Procedure STS ML-00 The inspectors reviewed the licensee's corrective actions related to this event. The licensee implemented a full-time surveillance coordinator who reviews all TS surveillance procedure revisions. The inspectors determined that there have been no other missed TS surveillances created because of changes to procedures. This error was a failure to update the surveillance database related to these specific procedures, which was different from other examples of database updating error IN0FFICE REVIEW OF LICENSEE EVENT REPORTS (90712)

The inspector reviewed the following LERs, determining that the corrective actions discussed in the report were appropriate and were complete .1 (Closed) LER 91-012: 4-hour Loquinq of the Comparisons of Control Rod Demand Position to Digital Position Indication was Temporarily Stopped D_u_e to Misinformation Durina Plant Computer Modifications

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- 9.2 (Closed) LER 91-023 and 91-023-01: Nonlicensed Personnel Inadvertently-Bumped 480 Vac Supply Breaker Resultina in Engineered Safety Features Equipment Actuations 9.3 (Closed) LER 91-025 and 91-025-01: No Operable Centrifugal Charaina Pumps Durina Boron Injection 9.4 (Closed) LER 92-003: Inattention to Detail Results in Failure to Maintain Proper Control Room Ventilation System Line Up 9.5 (Closed) LER 92-010: Inadeauate Procedural Guidance Causes a Technical Specification Violation

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ATTACHMENT

, 1 PERSONS CONTACTED P. D. Adams, Supervisor, Reactor Engineering R. S. Benedict, Manager, Quality Control A. B. Clason, Supervisor, Maintenance Engineering M. K. Cnvey, Supervisor, Results Engineering

T. F. Deddens, Manager, Outage M. E. Dingler, Manager, Nuclear Plant Engineering Systems, Support D. L. Fehr, Manager, Operations Training C, W. Fowler, Manager, Maintenance and Modifications R. B. Flannigan, Manager, Nuclear Safety Engineering D. E. Gerrelts, Manager, Instrumentation and Control W. J. Goshorn, Wolf Creek Coordinator, KEPC0

! N. W. Hoadley, Manager, Equipment Engineering R. W. Holloway, Assistant to Vice President, Operations D. Jacobs, Supervisor, Mechanical Maintenance

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J. D. Lutz, Regulatory Compliance Engineer

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O. L. Maynard, Vice President, Plant Operations K. J. Moles, Manager, Regulatory Services

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T. S. Morrill, Manager, Rac ation and Protection D. G. Moseby, Supervisor, Operations W. B. Norton,_ Manager, Technical Support F, T. Rhodes, Vice President, Engineering C. E. Rich, Jr., Supervisor, Electrical Maintenance B. B. Smith, Manager, Modifications C. M. Sprout, Manager, System Engineering J. D. Weeks, Manager, Operations M. G. Williams, Manager, Plant Support The above licensee personnel attended the exit meeting. In addition to the personnel listed above, the inspectors contacted other personnel during this

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inspection period, 2 EXIT MEETING An exit meeting was conducted on January 8, 199 During this meeting, the inspector reviewed the scope and findings of the report. The licensee did not identify as proprietary any information provided to, or reviewed by, the inspecto ,, _ , _ ~ _.