ML20136E276
| ML20136E276 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 03/10/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20136E243 | List: |
| References | |
| 50-482-97-04, 50-482-97-4, NUDOCS 9703130163 | |
| Download: ML20136E276 (18) | |
See also: IR 05000482/1997004
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ENCLOSURE 2
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.:
50-482
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License No.:
Report No.:
50-482/97-04
Licensee:
Wolf Creek Nuclear Operating Corporation
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Facility:
Wolf Creek Generating Station
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Location:
1550 Oxen Lane, NE
Burlington, Kansas
Dates:
January 11 through February 22,1997
Inspectors:
J. F. Ringwald, Senior Resident inspector
J. L. Dixon-Herrity, Resident inspector
M. S. Freeman, Reactor Engineer
Approved By:
W. D. Johnson, Chief, Reactor Projects Branch 8
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ATTACHMENT: Supplemental information
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9703130163 970310
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ADOCK 05000482
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EXECUTIVE SUMMARY
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Wolf Creek Generating Station
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NRC Inspection Report 50-482/97-04
Ooerations
The inspector identified a violation of Technical Specification 6.8.1.a when a shift
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supervisor failed to log the entry into a Technical Specification action statement on
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July 28,1996, following a failure of a containment isolation valve. The shif t
supervisor failed to recognize that this valve failure resulted in entry into Technical
Specification Action Statement 3.6.3. The licensee's corrective action, following a
subsequent failure of the same vaive, identified the need for the licensee to submit
Licensee Event Report 50-482/96-10,but was not broad enough to identify this
' failure of the shift supervisor to acknowledge entry into the Technical Specification
action statement during the previous failure (Section 08.1).
A violation of Technical Specification 6.8.1.a occurred when a nuclear station
operator failed to follow the instructions in the procedure in use while
unsuccessfully attempting to trip the turbine-driven auxiliary feedwater pump. The
operator used an obsolete technique and was not aware of a modification to the
turbine that prevented the obsolete technique from succeeding in tripping the
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turbine (Section M1.3).
The licensee responded appropriately to the discovery of conflicting information
regarding safety injection accumulator temperature limits and the discovery that the
actual accumulator temperatures were below the low temperature limit for the
accumulators (Section 01.1).
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The inspector identified a driver card failure for a main feedwater regulating bypass
valve controller during a routine control board walkdown and the failure of operators'
to meet management expectations by not logging this failure in the supervising
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operator's log (Section 01.2).
The inspector reviewed the technique used by training personnel to implement
poison pills (intentional incorrect responses to orders) in simulator training
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scenarios. The licensee indicated an intent to perform a formal evaluation of the
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effectiveness of the complex scenario and poison pill training techniques
(Section 05.1).
Maintenance
An example of a violation of Technical Specification 6.8.1.a occurred during
turbine-driven auxiliary feedwater pump retesting activities when the licensee issued
an onithe spot change to a system operating procedure that could not be performed
as written (Section M1.3).
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.An example of a violation of Technical Specification 6.8.1.a occurred during
turbine-driven auxiliary feedwater pump retesting activities when the system
operating procedure provided inadequate precautions for low speed operation with
low bearing oil pressure (Section M1.3).
Enaineerina
An example of a violatica of Technical Specification 6.8.1.a occurred during
turbine-driven auxiliary feedwater pump retesting activities when a system engineer
f ailed to comply with the licensee's work control procedure by manually cycling the
turbine governor valve without the shift supervisor's permission and without an
approved work package (Section M1.3).
An example of a violation of Technical Specification 6.8.1.a occurred during
turbine-driven auxiliary feedwater pump retesting activities when a system engineer
directec operators to manipulate the speed of the turbine outside the guidance of
the procadure in use (Section M1.3).
The NRC Office of Nuclear Reactor Regulation project manager identified an
unresolved issue associated with cold overpressure mitigation with the installation
of the normal charging pump (Section E1.1).
The inspector identified an unresolved issue associated with the uso of vendor
technical manuals to select substitute parts in safety-related applications
(Section E1.2).
Plant Support
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The licensee identified a violation of 10 CFR 50.54(q) when they revised their
emergency action level forms, resulting in an inadvertent reduction in their
emergency planning effectiveness. Since the licensee's corrective actions were not
prompt, this violation did not meet the criteria for enforcement discretion
(Section P3.1).
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Report Details
Summarv of Plant Status
The plant operated at essentially 100 percent power throughout the inspection period. On
January 18,1997, the shif t supervisor entered Technical Specification 3.0.3, made
preparations for a plant shutdown, then exited Technical Specification 3.0.3 as described
in Section 01.1 of this report. On February 7,1997, the board of directors of Western
Resources and Kansas City Power and Light, the two largest owners of the Wolf Creek
Nuclear Operating Corporation, voted to merge their two corporations into one. The
merger will require approvals of the shareholders and various regulatory agencies.
LOnerations
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Conduct of Operations
01.1 Safety iniection Accumulator Temoeratures
a.
Inspection Scoce (71707)
The inspector reviewed the circumstances surrounding the licensee's entry into
Technical Specification 3.0.3 on January 18,1997.
b.
Observations and Findinas
On January 17,1997, licensee personnel raised questions regarding the minimum
acceptable temperature for the safety injection accumulators. Engineering personnel
identified conflicting notes on different drawings and found that the Updated Safety
Analysis Report (USAR) stated that the operating temperature range for the
accumulators was60-120 F. The licensee made a containment entry to make local
temperature measurements of the safety injection accumulators. These
measurements showed that three of the four accumulators were below 60 F. The
shift supervisor declared the three safety injection accumulators inoperable, entered
Technical Specification 3.0.3 on January 18,1997, at 12:23 a.m., and made
preparations to shut down the plant as required by Technical Specification 3.0.3.
At approximately 1 a.m., engineering personnel informed the shift supervisor that
they had communicated with an individual who worked for the vendor of their
safety injection accumulators. This individual recalled work on the Wolf Creek
safety injection accumulators and on low temperature issues with safety injection
accumulators at other nuclear facilities. This vendor representative stated that there
was ample technical justification for the Wolf Creek safety injection accumulators to
be considered operable at temperatures at least as low as 50 F, and possibly at
even lower temperatures. Based on this telephone call, the shift supervisor declared
the safety injection accumulators operable and exited Technical Specification 3.0.3
at 1:10 a.m. The shift supervisor then asked engineering personnel for an
operability evaluation in accordance with Procedure AP 28-001, Evaluation of
Nonconforming Conditions of Installed Plant Equipment," Revision 4. Engineering
completed this evaluation and concluded that the safety injection accumulators
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would accomplish their safety function at temperatures as low as 50 F. The
licensee also initiated Performance Improvement Requests (PIRs) 97-0135 and
-0143, Configuration Change Package 07217, and USAR Change Request 97-024
to address this issue.
c.
Conclusions
The inspector concluded that the licensee responded appropriately to the identified
discrepancies in safety injection accumulator temperatures.
01.2 Loss of Power to Main Feed Reaulatina Bvoass Valve Controller D
a.
Insoection Scoce (71707)
During more than 30 control board walkdowns during the inspection period, the
inspector noted one instance in which normally illuminated control board indications
were not illuminated and had not been previously been identified by the operators,
b.
Observations and Findinos
On February 11,1997, the inspector noted that the normally illuminated indicators
for AE LK-580, " Main Feed Regulating Bypass Valve Controller D," were not
illuminated. The inspector questioned the control room operators, who replied that
they had not noticed this abnormalindication. When the operators replaced the
bulbs in the indicator, they still did not illuminate. The operators then initiated
Action Request 20371. Technicians determined that the controller was not getting
power, found that the driver card had failed, and replaced the card using Work
Package 119197.
The inspector noted that, while the failure of this controller was noted in an action
request, in the equipment out-of-service log, and on the turnover sheet, the failure
was not logged in either the shift supervisor's log nor in the supervising operator's
log. The inspector asked the operations manager whether operators were expected
to log this sort of failure in the logs. The operations manager said that a log entry
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for this type of equipment failure would be expected in at least the supervising
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operator's log. The operations manager said that this expectation would be
reinforced during the next shift operations group supervisor meeting.
c.
Conclusions
The inspector identified a driver card failure for a main feedwater regulating bypass
valve controller and found that operators f ailed to meet management expectations
by not logging this controller failure in the operating logs.
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05
Operator Training and Qualification
05.1
Complex Scenario and Poison Pilt Usaae in Ooerator Simulator Traininn
a.
Insoection Scope (71707)
The inspector reviewed the past year's history of complex scenarios and the poison
pill (intentionalinsertion of incorrect nuclear station operator responses) (Refer to
NHC Inspection Report 50-482/96-11,Section 3.4)in operator simulator training
with the training manager and other training division personnel.
b.
Observations and Findinas
On February 12,1997, the inspector discussed the use of complex scenarios and
the poison pill concept with training personnel to identify what lessons training
personnel had learned from the use uf these training techniques. During the
discussions, the training personnel expressed a belief that the complex scenario was
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an effective tool to provide more realistic scenarios for operators and to enable
them to learn techniques for more effectively working under conditions c' increased
stress.
During discussions regarding the implementation of the poison pill, t. ining
personnel explained that they had experienced some difficulty with nuclear station
operator discomfort during the implementation of the poison pill. Nuclear station
operators considered their communications to be inaccurate, and even dishonest,
when training personnel directed them to report that they had completed that action
ordered by control room operators after they were told by simulator instructors that
they would actually be simulating the performance of a different action in
implementing the poison pill in an attempt to address this nuclear station op9rator
discomfort, simulator instructors altered their method of implementing the poison
pill. For example, upon receipt of an order from a control room operator to isclate a
particular atmospheric relief valve, the instructor would then direct the nuclear
station operator to simulate isolating a different atmospheric relief valve and report
the closure by the valve number of the valve actually closed. This unusual report
from the nuclear station operator would confuse control room operators, cause
them to check the drawing, and thus prompt them that a poison pill had been
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implemented, without having to discover it from system parameter indications.
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The inspector asked the training personnelif they had reviewed the effectiveness of
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the complex scenario and use of the poison pill. The training personnel replied that
they had informally discussed these techniques along with other issues during the
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end of training cycle meetings, but that they had not performed a formal review of
the effectiveness of these training techn' ques with an attempt to gather lessons
learned for future training technique improvements. The training manager also
acknowledged that they had no plans to perform such an evaluation. The training
manager subsequently indicated that a formal evaluation would be appropriate and
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stated that they would perform a formal evaluation of these training techniques by
April 30,1997. NRC review of this evaluation is an Inspection Followup ltem
(482/9704-08).
c.
Conclusions
The inspector reviewed the use of two new training techniques during discussions ~
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with training personnel and noted that they had experienced some implementation
difficulties associated with the use of the poison pill. The inspector also noted that
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the training department had not performed, and had not planned to perform, a
review of the effectiveness of these new training techniques. The training manager
subsequently indicated that they planned to perform a formal evaluation of these-
training techniques by April 30,1997.
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Miscellaneous Operations issues (92901)
08.1 (Closed) Unresolved item 50-482/9618-01: Operability of Valve EF HV0034,
essential service water to containment coolers, inside containment isolation valve.
This item involved the failure of Valve EF HV0034 to close on demand on several
occasions, including October 9 and July 28,1996, and the failure of operators to
consider the applicability of Technical Specification 3.6.3 following the f ailure on
July 28,1996. The licensee responded to the October 9,1996, failure by initiating
Licensee Event Report 96-10. Following the f ailure on October 9,1996, the shift
supervisor entered the action statement associated with Technical Specification 3.6.3. The inspector noted that a similar entry did not occur following
the failure on July 28,1996. After evaluating this issue, the operations
superintendent acknowledged that the shift supervisor should have enterad thu
action statement for Technical Specification 3.6.3 on July 28,1996, and hitiated
PIR 97-0464. The inspector noted that the licensee complied with the Tect:nical
Specification 3.6.3 requirement following the July 28 and October 9,1996,
f ailures, but failed to recognize or log the limiting conc 4 tion for operation ents y on
July 28. Administrative Procedure AP 21-001," Operations Watchstanding
Practices," Revision 4, Step 6.2.3.d, required the shift supervisor icg to coinain log
entries for entry into Tec1nical Specification action statements due to major
equipment being out of service for maintenance or due to equipment failure.
Operators also log entry into Tec'inical Specification limiting conditions for operation
into the equipment out-of-service log. The equipment out-of-service log for July 28,
1996, contained no entry for the failure of Valve EF HV0034, and therefore no
entry into Technical Specification 3.6.3. The corrective action following these two
failures was not sufficiently broad for the licensee to identify this issue. The failure
to log entry into the action statement for Technical Specification 3.6.3 on July 28,
1996,is a violation of Technical Specification 6.8.1.a (482/9704-01).
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11. Maintenance
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Conduct of Maintenance
M 1.1 General Comments on Maintenance Activities
a,
Insoection Scoce (62707)
The inspectors observed all or portions of the following work activities.
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114141
Task 9
Annual preventive maintenance'
testing of emergency lighting
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116956
Task 2
Oil leak repair on the turbine-driven
auxiliary feedwater governor
117557
Task 1
Turbine-driven auxiliary feedwater
turbine trip / throttle and governor '
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valve lubrication
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117861
Task 1
Preventive maintenance testing of
the turbine-driven auxiliary
feedwater turbine governor valve
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117911
Task 1
Gasket replacement on the turbine-
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driven auxiliary feedwater turbine
crossover pipe
117922
Task 21
Oil sampling of the turbine-driven
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auxiliary feedwater pump governor
118121
Task 1
New drain line installation on the
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turbine-driven auxiliary feedwater
turbine
118121
Task 6
Insulation installation on the
turbine-driven auxiliary feedwater
pump drains
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119257
Task 1
Chemical etch testing on a normal
charging pump piping hanger
baseplate
119260
Task 1
Chemical etch testing on a normal
charging pump piping hanger
baseplate
SYS AL-124
Revision 1
Postmaintenance run of the
turbine-driven auxiliary feedwater
pump
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b.
Observations and Findinas
Except as noted in Section M1.3, the inspectors found no concerns with the
maintenance observed.
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Conclusions
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Except as noted in Section M1.3, the inspectors concluded that the maintenance
activities were being performed as required.
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M1.2 General Comments on Surveillance Activities
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hsoection Scoce (61726)
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The inspectors observed all or portions of the following surveillance activities.
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STS AL-103, Revision 25
Turbine-driven auxiliary feedwater pump
inservice pump test
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STS GK-OO18, Revision 19
Control room emergency vent system Train B
operability test
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STS GN-OO1, Revision 8
Containment cooling fans operation test
STS KJ 005A, Revision 27
Manual / auto start, synchronization, and loading
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of Emergency Diesel Generator NE01
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b.
Observations and Findinas
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Except as noted in Section M3.1, the inspectors found no concerns with the
surveillances observed.
c.
Conclusions
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Except as noted in Section M3.1, the inspectors concluded that the surveillance
activities were being performed as required.
M1.3 Turbine-Driven Auxiliarv Feedwater Pumo Retest
a.
Insoection Scope (62707)
The inspector evaluated several problems which occurred during the
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postmaintenance retest of the turbine-driven auxiliary feedwater pump.
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b.
Observations and Findinas
Ga January 24,1997, during the performence of Procedure SYS AL-124, " Venting
the Turbine-Driven Auxiliary Feedwater Pump Oil System," Revision 1, the auxiliary
feedwater turbine tripped on overspeed Shortly afterwards, the system engineer
manually cycled the governor valve to determine if it was sticking. This activity
was performed without a work package or an approved procedure and without the
permission of the shif t supervisor. When the system engineer cycled the valve, the
limit switches on the valve changed positions, causing the position indicating lights
in the control room to change. This unexpected change in control board indication
caused the control board operators to be concerned. The shift supervisor identified
the cause of the changing indication and directed the system engineer to stop the
valve manipulation. Procedure AP 16C-002," Work Controls," Revision 4, required
troubleshooting activities to be initiated using a work package task and implemented
with the permission of the shift supervisor. The failure of the system engineer to
comply with the requirements of Procedure AP 16C-002 is an example of a violation
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of Technical Specification 6.8.1.a (482/9704-02).
After additional troubleshooting activities, the system engineer and shift supervisor
believed that the problem had been identified and corrected, because poor
communication suggested that an instrumentation and controls technician had
found loose connections in the governor valve control wiring. After verifying
electrical continuity through a particular connection point, the technician had been
able to remove a terminal from a connection point using pliers and had properly
relanded the terminal. This activity had been erroneously communicated to the shift
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supervisor as a loose connection that logically could have caused the overspeed.
After the work crews and system engineer shift change, the shift supervisor
subsequently permitted personnel to perform Procedure SYS AL-124 again. During
the performance of this procedure, the system engineer directed turbine operation
not specified by the procedure. Step 6.1.4 required the operator to locally open the
trip-throttle valve manually and slowly increase the turbine speed to between 3850
and 3900 rpm. Contrary to this procedural requirement, the system engineer
directed the control room operator to manually control the governor to adjust the
turbine speed below this range without a procedure change. The purpose of this
direction by the system engineer was to attempt to cycle oil through the governor
valve hydraulic actuator to ensure complete venting of the governor oil system.
This informal operation of the turbine outside the requirements of the procedure in
effect is a second example of a violation of Technical Specification 6.8.1.a
(482/9704-02).
When the operations, maintenance, integrated plant scheduling, system engineering,
and plant managers arrived on site and learned of the inadvertent overspeed trip,
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the plant manager stopped the work on the turbine-driven auxiliary feedwater pump
and directed a thorough evaluation of the circumstances to ensure that all facts
were known and evaluated before proceeding. Subsequent to this evaluation, the
licensee prepared On-The-Spot Change 97-0023 to Procedure SYS AL-124. This
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change provided for a controlled variation of the turbine speed to ensure complete
venting of the oil system. Step 6.1.4 of Procedure SYS AL-124 was changed by
On-The-Spot Change 97-0023 to require the operator to locally increase the turbine
speed to approximately 2500 rpm. When the operator attempted to perform this
step, the governor valve was initially shut. As the operator opened the trip-throttle
valve, at the point in the valve travel where a yoke mounted limit switch closed, the
switch initiated the ramp generator circuitry, which opened the governor valve. The
turbine speed increased to approximately 3300 rpm and was steam limited by the
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trip-throttle valve position. The operator then began to close the trip-throttle valve
in an attempt to achieve the 2500 rpm required by the procedure. When the same
limit switch opened, the governor valve closed, resulting in the turbine slowing to
approximately 1100 rpm. The operator repeated this several times with similar
results. With the turbine-driven auxiliary feedwater pump in the nominal
configuration, Procedure SYS AL-124 modified by On-The-Spot Change 97-0023
could not be performed. The issuance of this procedure change that could not be
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performed is an example of a violation of Technical Specification 6.8.1.a in that it
resulted in an inadequate procedure (482/9704-03).
After the operator made several attempts to achieve 2500 rpm, the test performers
left the turbine running at approximately 1100 rpm. At that speed, the bearing oil
pressure was approximately 6.5 psig. During the pre-evolution briefing, the system
engineer discussed the precaution listed in Step 4.3, which required operators to
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closely monitor bearing oil pressure when the pump operated at low speed to
ensure proper lubrication. The shift supervisor defined low oil pressure as any
pressure less than 10 psig. However, the system engineer did not recommend or
direct operators to trip the pump with the pressure below the defined low oil
pressure for approximately 5 minutes. During this time, the shift supervisor walked
from the control room to the pump room, and several people in the room asked the
system engineer if the pump should be tripped because of the low oil pressure.
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Upon arrival at the pump room, the shift supervisor discussed the test with the
system engineer. The system engineer told the shift supervisor that the pump
should be tripped. The shift supervisor then ordered the operator to trip the pump.
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The subsequent revision to the pr cedure provided much more specific guidance in
the precaution listed in Step 4.3 o. Procedure SYS AL-124 and required operators to
trip the pump if pressure dropped below 5 psig, increased above 20 psig, or caused
Annunciator 00-128D to alarm. The failure of Procedure SYS AL-124 to provide
specific low oil pressure tripping criteria represents a failure to establish a required
procedure and is a second exampie of a violation of Technical Specification 6.8.1.a
(482/9704-03).
The licensee performed a basic engineering disposition associated with Work
Package Task 118781-2,which concluded that the operation of the pump with oil
pressure below 10 psig for a total of approximately 9.6 minutes did not cause
damage to the turbine or the pump. The disposition also stated that operation at
pressures just above the 5 psig alarm setpoint on a transient basis was acceptable.
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When the shift supervisor directed the operator to trip the turbine-driven auxiliary
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feedwater pump, the operator pulled on the trip linkage, causing the turbine speed
to increase. After trying this several times, another operator tripped the turbine by
pushing down on the manual trip lever Procedure SYS AL-124, Step 6.1.5,
directed operators to trip the turbine-driven auxiliary feedwater pump using the
manual trip lever. The operations manager later stated that the technique of using
the trip linkage was an obsolete technique that had been acceptable prior to
modifications to the linkage. The failure of the first operator to trip the pump using
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the method prescribed by the procedure is a violation of Technical
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Specification 6.8.1.a (482/9704-04).
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The licensee prepared On-The-Spot Change 97-0024to Procedurc SYS AL-124,
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which corrected the problems noted during the performance of the test using On-
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The-Spot Change 97-0023. This test and the subsequent testing required to
demonstrate pump operability v'as completed satisfactorily. The licensee initiated
PIR 97-0363 to address thes- r.nd other concerns identified during this work. The
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licensee also formed a soe.n to address the concerns raised by this PIR.
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Conclusions
Three violations occurred during the performance of retest activities following
maintenance and modification of the turbine-driven auxiliary feedwater pump.
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M3
Maintenance Procedures and Documentation
M3.1 Surveillance Procedure Nomenclature Differences
a.
Insoection Scooe (61726)
The inspector observed operators perform Surveillance Procedure STS GK-001B,
" Control Room Emergency Vent System Train B Operability Test," Revision 19.
b.
Observations and Findinas
On January 3,1997, the inspector observed the performance of
Procedure ST S GK-001B. The operators understood the purpose of the test and the
requirements of the procedure. The inspector noted several differences between
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the indication nomenclature on the ventilation panel and in the procedure. For
example, the procedure required operators to verify the positions of
Dampers GK HZ-83A and -83C, but the indicators on the ventilation panel were
labeled GK ZL-83A and -83C. In addition, the procedure required operators to verify
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the position of Damper GK HZ-30A. The position for this damper was indicated by
the lower set of indicating lights on the hand switchplate for GK HIS-30. Near
these lower indicating lights, the word DAMPER had been engraved on the
switchplate. Above the engraved word DAMPER, the letter A had been
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handwritten, presumably as an aid to operators performing the procedure. This
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marking was similar to the hand switchplate for GK HIS-83 that had the label
DAMPER B engraved near the lower set of indication lights. The inspector noted
these discrepancies and asked the operators if these discrepancies caused any
confusion during the performance of this surveillance. While the operators said that
these discrepancies did not cause confusion, they also expressed their preference
for unambiguous labeling which matched the nomenclature in the procedure. The
operators stated that they would discuss these discrepancies with the operations
procedure writers. Operations personnel promptly revised Procedure STS GK-001B
and the similar procedure for Train A to correct these nomenclature discrepancies.
The inspector also noted that the handwritten marking on the ventilation panel had
been removed.
c.
Conclusions
The inspector noted minor nomenclature differences between the ventilation panel
and indication references in associated surveillance procedures. Operations
personnel promptly revised these surveillance procedures to correct the
discrepancies.
111. Enaineerina
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E1
Conduct of Engineering
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E1.1
Cold Overoressure Mitiaation Related to the Normal Charaina Pumo installation
a.
Inspection Scoce (375511
The inspector reviewed the impact of the normal charging pump installation on cold
overprossure mitigation.
b.
Observations and Findinas
During a site visit, the NRC Office of Nuclear Reactor Regulation project manager
asked engineering personnel on February 11,1996, whether the design modification
which installed the normal charging pump also factored the higher flow capacity
into the cold overpressure mitigation analysis. During the evaluation needed to
answer this question, the licensee discovered that they had considered cold
overpressure mitigation in the analysis. However, the licensee discovered that
engineering may not have clearly communicated the cold overpressure mitigation
requirements, because General Procedure GEN 00-006," Hot Standby to Cold
Shutdown," Revision 36, Step 6.34.6, required operators to place the normal
charging pump in pull to lock prior to cooling the reactor coolant system
temperature below 325 F. According to operations personnel, this temperature had
been chosen because they used the assumption that the normal charging pump cold
overpressure mitigation requirements would be similar to the cold overpressure
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mitigation requirements for the centrifugal charging pumps and safety injection
pumps described in Technical Specification Bases 4.4.9. After evaluating this
assumption more thoroughly, the licensee determined that this assumption was not.
correct, and the normal charging pump should be placed in pull to lock prior to
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cooling the reactor coolant system temperature below 368 F. The licensee initiated
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PIR 97-0439 to address this issue. On February 16,1997, operations personnel
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issued On-The-Spot Change 97-0089 to General Procedure GEN 00-006, which
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reducing the lowest reactor coolant system cold leg temperature below 368 F.
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This issue will be tracked as an unresolved item pending a better understanding of
the root cause (482/9704-05).
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c.
Conclusions
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The NRC identified an unresolved item associated with the implementation of
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which installed the normal charging pump.
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E1.2 Use of Vendor Technical Manuals for Selectina Substitute Parts
a.
Insoection Scoce (37551)
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The inspector evaluated the process the licensee used for selecting a substitute
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freon filter in the SGK05A, Train A, Class 1E switchgear room air conditioning unit.
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b.
Observations and Findinas
On January 27,1997, procurement engineering personnel authorized workers to
use a Sportan Catch-All RC-4864-HH filter core in the freon system of the SGK05A
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air conditioning unit. When workers procured Sportan Catch All RCW-48 cores, the
only cores approved for use in the SGK05A air conditioning unit, they found that all
onsite spares were damaged. The licensee initiated PIR 97 0322 to address the
discovery of these damaged filter cores.
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Wolf Creek Instraction Manual M-622.1-00061-W28," Instruction Manual for
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Package Air Cond tioning Units," Revision 16W, the vendor technical manual for the
SGK04 and SGK05 cir conditioning units, specified RCW-48 cores in the
recommended spare parts list, and included pages from Sporlan Catch-All
Bulletin 40-10. These bulletin pages listed 31 different filter shells and 6 different
filter cores that would fit in these shells. The bulletin described the RCW-48 core
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Core." The bulletin also listed two different felt eiements that would fit in these
shells.
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The procurement engineer and the procurement engineering supervisor explained
that they did not need to perform a formal equivalency evaluation in order to
substitute the RC-4864-HH core for the RCW-48 core, because they were both
listed, along with the RC-4864 core, in the vendor technical manual as acceptable
and interchangeable substitutes. The only section of the vendor technical manual
and the design specification document that specified which core should be used in
these filter shells was the vendor technical manual recommended spare parts list,
which specified only the RCW-48 core. The procurement and design engineering
personnel stated that their architect-engineer reviewed all their safety-related vendor
technical manuals and incorporated them into the plant design basis. As such,
engineering personnel used the vendor technical manuals as design information with
the same confidence as they used with a design calculation or drawing.
Engineering personnel suggested that this vendor technical manual review was
specific enough to evaluate these three filter cores and, if any of them had been
unsuitable, they would not have been listed in the vendor technical manual.
On December 11,1984, the architect-engineer revised Requisition SU-1940 to
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procure RC-4864-HH cores under the design specification for SGK04 and SGK05.
However, the licensee was not aware of any evaluation that suggested that this
was appropriate for this application.
On April 30,1996, procurement engineering personnel completed Commercial
Grade Dedication Package 060-P0003," Core, Filter-Drier, Catch-All Part Number
RC-4864-HH (Sportan), Revision O. This package evaluated the use of the
RC-4864-HH core for use in the SGK04 and SGK05 air conditioning units. This
package considered the core material and noted a telephone call to the vendor, but
did not acknowledge nor disposition a significant difference between the two filters
in that the RCW-48 filter was listed as a high capacity core, and the capacity of the
RC-4864-HH filter was not addressed at all. While procurement engineering
completed Material Equipment Change Notice P95-1428, the RC-4864-HH cores
were not released for use because the commercial grade dedication required one of
these filters to be shipped offsite for analysis. On January 27,1997, procurement
engineering personnel revised the commercial grade dedication package to permit
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the dedication activities to be performed onsite. Once the RC-4864-HH filters were
dedicated for use in this safety-related application, one was used in the SGK05A air
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conditioning unit.
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The inspector questioned the basis for considering the RC-4864-HH filter cores
equivalent to the RCW-48 cores and, therefore, questioned the suitability of using
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the RC-4864-HH cores in the SGK05A air conditioning unit on January 27,1997.
In addition, the inspector questioned the assumptions used by licensee personnel in
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assuming that all information in the vendor technical manual was design basis
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information and acceptable for use in design and procurement evaluations without
further documented evaluation. Procurement engineering personnel suggested that
additionalinformation could be obtained from the architect-engineer regarding the
vendor technical manual review that led to their classification as design basis
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docume~nts and that this information may answer the inspector's questions. The
licensee initiated PIR 97-0310 to track this issue. This issue will be an unresolved
item pending a review of this additional inSrmation (482/9704-06).
c.
Conclusions
The inspector identified an unresolved item regarding the licensee's use of vendor
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technical manualinformation in selecting substitute pa'rts in safety-related
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applications.
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E2.2 Review of USAR Commitments
A recent discovery of a licensee operating their facility in a manner contrary to the
USAR description highlighted the need for a special focused review that compares
plant practices, procedures, and/or parameters to the USAR descriptions. While
performing the inspections discussed in this report,.the inspectors reviewed the
applicable portions of the USAR that related to the areas inspected. The inspectors
verified that the USAR wording was consistent with the observed plant practices,
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procedures, and/or parameters.
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IV. Plant Support
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P3
Emergency Planning Procedures and Documentation
P3.1
Ir: correct Emeraency Action Level Forms
a.
Inspection Scope (71750)
The inspector reviewed the licensee's response to discovering incorrect emergency
action level figures,
b.
Observations and Findings
On January 15,1997, during a training class, licensee personnel noted that the
emergency action level form for safety system failure or malfunction,
Block 8-SSFM3, provided an arrow to the Alert classification given a "no" response,
and this path should have resulted in the declaration of a site area emergency. The
licensee initiated PIR 97-0116 and proceeded to implement a change to the form.
The inspector noted that this was not changed as of 8:30 a.m. on January 21,
1997, and asked why the change had not yet been made. Emergency planning
personnel stated that the change had been prepared, but that it required approvals
from the county and state agencier, and from the plant safety review committee.
The emergency planning manager stated that county and state agency approvals
occurred on January 17,1997, but the plant safety review committee approval
would not be sought until their next scheduled meeting on January 22,1997. The
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emergency planning manager also stated that they believed other emergency action
level classification " trees" would have resulted in the correct classification of this
event scenario. When the inspector reviewed this alternative classification
methodology, the inspector and emergency planning manager agreed that there
were no other " trees" that would have resulted in the same classification with the
possible exception of the administrative form.
The inspector reviewed the control room emergency actic.: lovel forms at 4:49 p.m.
on January 21,1997, noted that the forms still containee the error, and asked the
shift supervisor if any attempt had been made to infcan shift sicoervisors of this
error. The shift supervisor was surprised to learn of this error, scated that they had
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not been informed, and immediately made a log ertry and contacted the emergency
planning manager. The emergency plan change was approved by the plant safety
review committee on January 22,1997,
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This error in the emergency action levels occurred on February 23,1996, when
emergency planning personnel prepared changes to the emergency action levels
following the frazil icing event described in NRC Inspection Report 50-482/96-03.
This change was made without NRC approval, based on the licensee's conclusion
that the change met the requirements of 10 CFR 50.54(q). This regulation stated
that the licensee may make changes to the emergency plans without prior
Commission approval only if the changes do not decrease the effectiveness of plans
and meet the standards of 10 CFR 50.47(b). Since the emergency action level
change actually decreased the effectiveness of the plans, this change is a violation
of 10 CFR 50.54(q). While this violation was licensee identified, corrective actions
were not prompt. Therefore, this violation did not meet the criteria for not being
cited (482/9704-07).
Following the discovery of this error in the emergency action levels, the licensee
discovered another error in the emergency action level for radioactive effluent
release during a simulator scenario on January 23,1997. Once this error was
discovered, the licensee initiated a change, notified the control room immediately,
and completed the revision to the emergency action levels that same day,
c.
Conclusions
The licensee identified a violation of 10 CFR 50.54(q) when they inadvertently
changed their emergency action levels, resulting in a decrease in the effectiveness
of their emergency plan without NRC approval. Since the licensee's corrective
actions were not prompt, this licensee-identified violation does not meet NRC
Enforcement Policy criterion for not being cited.
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V. Manaae' ment Meetinas
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Ex:: Meeting Summary
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'The inspectors presented the inspection results to members of licensee management at the
. conclusion of the inspection on February 21,1997. The licensee acknowledged the
findings presented. -The licensee stated an intent to perform an evaluation of the
effectiveness of complex scenarios and poison pill training techniques used in simulator
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training.
The inspectors asked the licensee whether any materials examined during the inspection
should be considered proprietary. No proprietary information was identified.
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ATTACHMENT
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
Licensee
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D. L. Fehr, Manager, Training
O. L. Maynard, President and Chief Executive Officer
B. T. McKinney, Plant Manager
J. W. Johnson, Manager, Plant Security
B. S. Loveless, Manager, Radiation Protection
R. Muench, Vice President Engineering
W. B. Norton, Manager, Performance Improvement and Assessment
R. L. Sims, Manager, System Engineering
C. C. Warren, Chief Operating Officer
J D. Weeks, Manager, Emergency Planning
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INSPECTION PROCEDURES USED
Onsite Engineering
Surveillance Observations
Maintenance Observations
Plant Operations
Plant Support Activities
Followup - Plant Operations
ITEMS OPENED, CLOSED, AND DISCUSSED
Ooened
9704-01
Operability of Valve EF HV0034 (Section 08.1)
9704-02
Turbine-driven auxiliary feedwater pump retest
(Section M1.3)
9704-03
Turbine-driven auxiliary feedwater pump test
(Section M1.3)
9704-04
On-the-spot change for pump testing (Section M1.3)
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9704-05
Cold overpressure protection related to the normal charging
pump installation (Section E1.1)
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9704-06
Use of vendor technical manuals for selecting substitute
parts (Section E1.2)
9704-07
Emergency Procedures and documentation (Section P3.1)
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9704-08
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Evaluation of effectiveness of innovative treining techniques
(Section 05.1)
Closed
50-482/9618-01
Operability of Valve EF HV0034 (Section 08.1)