ML20137M374

Insp Rept 50-482/97-05 on 970127-0214.Violations Noted.Major Areas Inspected:Operations,Maint & Engineering

ML20137M374
Person / Time
Site:	Wolf Creek
Issue date:	04/02/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20137M322	List: ML20137M316 ML20137M341 ML20137M374
References
50-482-97-05, 50-482-97-5, NUDOCS 9704080074
Download: ML20137M374 (54)

See also: IR 05000482/1997005

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ENCLOSURE 2

U.S. NUCLEAR REGULATORY COMMISSION f

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REGION IV  ;

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Docket No.: 50-482 -[

[ License No.: NPF-42

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Report No.: 50-482/97-05 -

Licensee: Wolf Creek Nuclear Operating Corporation.: j

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Wolf Creek Generating Station  ;

Facility:

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Location: 1550 Oxen Lane, NE

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Burlington, Kansas .

i ' Dates: January 27-31 and February 10-14,1997 j

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W. P. Ang, Team Leader-

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Inspectors: i

L. J. Smith, Reactor inspector

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D. N. Graves, Project Engineer

D. B. Pereira, Reactor inspector

D. B. Allen, inspector-in-Training

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G. Y. Cha, Contractor (Parameter)

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' Approved By: C. A. VanDenburgh, Chief, Engineering Branch j

Division of Reactor Safety j

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Attachment: Supplemental Information

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9704080074 970402

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O ADOCK 05000482-

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TABLE OF CONTENTS

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. EX EC UTIV E S U M M A R Y ~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv I

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R e p o rt D e t a il s ' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ' . . . 1 1

~ 1 O PE R AT I O N S . . . . . . . . . -. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1'

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01 Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 ' .

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01.1 Problem identification ................................ 1-

01.2 Problem Re solution . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2

O2 Operational Status of Facilities and Equipment . . . . . . , . . . . . . . . . . . . 3

4 ' O 2.1 . Operator. Work-arounds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 '

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02.2 Operability and Reportability Determinations . . . . . . . . . . . . . . . 5

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07 Quality Assurance in Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-

07.1 Problem Evaluation and Resolution . . . . . . . . . . . . . . . . . . . . . . 6

'07.2 Quality Assurance Audits ' . . . . . . . . . . . . . , . . . . . . . . . . . . . . . 9 '

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.- 07.3 Independent Safety Engineering Group . . . . . . . . . . . . . . . . . . 10

! 07.4 . Corrective Action Review Board . . . . . . . . . . . . . . . . . . . . . . . 11 ,

L 07.5 Plant Safety Review Committee . . . . . . . . . . . . . . . . . . . . . . . 12  !

07.6 Operating Experience Feedback Program . . . . . . . . . . . . . . . . . 13 l

07.7 Pla nt S t a f fing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 ,

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11. M A I N T E N A N C E . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

M2 Maintenance and Material Condition of Facilities and Equipment ..... 15  ;

M2.1 Review of Maintenance Backlog . . . . . . . . . . . . . . . . . . . . . . . 15

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M3 Maintenance Procedures and Documentation . . . . . . . . . . . . . . . . . . . 15 '

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M3.1 Review of Surveillance Test Packages . . . . . . . . . . . . . . . . . . . 15

M4 Mairmnance Knowledge and Performance .................... 16  :

M4.1 Maintenance Knowledge and Use of the Corrective Action  ;

4 Pr o g r a m . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

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M7 Quality Assurance in Maintenance Activities . . . . . . . . . . . . . . . . . . . 17 i

M7.1 Self As sessm ents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

$ M8 Miscellaneous Maintenance issues (40500) '. . . . . . . . . . . . . . . . . . . . .17 -

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M8.1 (Closed) EA 96-124, Violation I.C, Example 1 ............. 17  ;

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M8.2 (Closed) EA 96-124, Violation I.C, Example 2 ............. 18 i

M8.3 (Closed) EA 96124, Violation ll.D . . . . . . . . . . . . . . . . . . . . . . 18

M 8.4 (Closed) EA 96-124, Violation ll.E . . . . . . . . . . . . . . . . . . . . . . 19  !

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Ill. ENGINEERING . . . . . . . .................... ....... .......... 19

E2 ' Engineering Support .................................... 19

E 2.1 Engineering Support for Performance Improvement Requests .. 19

E2.2 Engineering Support of Operability Evaluations ............ 21

E3 Quality of Engineering Products . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

E3.1 Main Steam Isolation Valve and Feedwater Isolation Valve

Reliability improvement Task Force . . . . . . . . . . . . . . . . . . . . . 21

E3.2 Extent of Use of Temporary Modifications . . . . . . . . . . . . . . . . 22

E7 Quality Assurance in Engineering ........................... 23

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E7.1 Licensee Auxiliary Feedwater System Safety System

Functional Assessment .... ........................ 23

E7.2 Self-Assessment Team Qualifications, Objectivity, and

Independence .................................... 23

E7.3 Scope and Depth of Assessment ...................... 24

E7.4 Significant Licensee Assessment Team Conclusions . . . . . . . . . 26

E7.5 Independent NRC Inspection ......................... 28

E8 Miscellaneous Engineering issues . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

E8.1 (Closed) EA 96-124, Violation I.A . . . . . . . ... .......... 31

E8.2 (Closed) EA 96-124, Violation ll.A ..................... 33

E8.3 (Closed) Inspection Followup Item ..................... 34  ;

E8.4 (Closed) Unresolved item . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34

E8.5 (Closed) Licensee Event Report ....................... 35 i

V. M AN AG EM ENT M EETIN G . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

X1 Exit Meeting Summary . . . . . . . . . ......................... 36

ATTACHMENT: Supplemental Information

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EXECUTIVE SUMMARY

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Wolf Creek Generating Station

NRC Inspection Report 50-482/97-05

NRC Region IV inspectors and an engineering consultant performed a team inspection at

the Wolf Creek Generating Station during the weeks of January 27-31 and Februaiy 10-14, ,

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1997. The team (1) inspected the implementation of the licensee's corrective action

program, (2) reviewed licensee corrective actions for previously identified violations and

L open items associated with the January 1996 frazilice event, and (3) reviewed the

licensee's safety system functional assessmet.t of the auxiliary feedwater system. The

objective of the team inspection was to evaluate the licensee's effectiveness in identifying,

resolving, and preventing issues that degrade the quality of plant operations or safety.  ;

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Operations

j * Conditions adverse to quality were generally being appropriately identified in  !

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performance improvement request forms or other appropriate corrective action

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documents (Section 01.1).  ;

• The team noted that the licensee based their system for tracking operator work- -

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arounds on a very narrow definition. The licensee's definition was restricted to

activities, which could prevent effective operator action during a transient as

opposed to including any design deficiencies which required compensatory operator i

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actions. Although the team identified additional work-arounds (using the NRC

definition) that were not being tracked by the licensee's system, the licensee had

already initiated satisfactory corrective actions to correct each of these conditions

(Section O2.1). ,

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• The licensee had identified a program weakness regarding the adequacy of root I

cause evaluations and corrective actions for significant performance improvement  ;

requests. The licensee's corrective actions, which included the formation of a

Corrective Action Review Board, selection of performance improvement

coordinators, and the performance of root cause evaluation training, appeared to be

effective in addressing this weakness (Section 07.1).

• * The licensee had scheduled audits as required by the Technical Specifications and  !

the audit process had appropriately identified the need for improvements in the [

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corrective action process. (Section 07.2).

• The Independent Safety Engineering Group met the function, composition, and j

responsibilities requirements contained in the Technical Specification Administrative l

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Controls (Section 07.3).

• The team noted clear evidence that the Corrective Action Review Board was trying

to upgrade the quality of root cause evaluations and corrective action plans that

were being generated for significant performance improvement requests i

(Section 07.4).

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• The Plant Safety Review Committee conservatively dispositioned the items which

were presented for review and approval in accordance with the Technical

Specifications (Section 07.5).

• The team noted that the licensee had appropriately disseminated, reviewed, and

dispositioned operating experience information. However, the team noted that the

licensee had self-identified examples of weaknesses of the program associated with

the timeliness and effectiveness of some of the reviews (Section 07.6).

• The team concluded that the licensee's current staffing level and projected attrition

should not significantly impact the implementation of the corrective action program.

However, the team noted that a self-identified weakness associated with the

implementation of the program would require a significant shifting and management

of resources. (Section 07.7).

Maintenance

• The licensee had generally resolved hardware deficiencies in a timely fashion

(Section M2.1).

• Surveillance test deficiencies were being appropriately dispositioned (Section M3.1).

• The team noted that maintenance personnel had appropriately identified and

corrected conditions adverse to quality (Section M4.1).

• The licensee performed a good maintenance self assessment and was taking

appropriate corrective actions for the self-assessment findings (Section M7.1).

Enaineerina

• The team noted that the licensee had closed a performance improvement request

that had identified low flow through a component cooling water radiation monitor

without taking the necessary corrective actions. This failure was identified as a

violation of 10 CFR 50, Appendix B, Criterion XVI, " Corrective Action"

(Section E2.1).

• The licensee's feedwater isolation valve reliability task force had improved the

reliability of these valves (Section E3.1).

• The licensee's auxiliary feedwater safety system functional assessment team was

composed of well-qualified M;viduals who were sufficiently independent and

objective (Section E7.2).  !

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• -The scope and depth of the licensee's self-assessment of the auxiliary feedwater

system was sufficient to determine the functionality of the auxiliary feedwater

system (Section E7.3)  ;

• - The team generally agreed with the conclusions of the licensea's self-assessment

team. A noncited violation associated with the failure to implement Technical

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Specification Surveillance Requirement 4.3.3.5.2 was identified. This licensee-

identified and corrected violation is being treated as a noncited violation, consistent

with Section Vll.B.1 of the NRC Enforcement Policy (Section E7.5).  !

• . Although the licensee's auxiliary feedwater functional self-assessment identified

problems that resulted in operability issues which were reportable, no condition was

found that resulted in a plant shutdown or in situations where the auxiliary

feedwater system, or its safety-related components, would not have performed  :

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their intended function (Section E7.4). i

• The licensee's assessment team noted the following weaknesses (Section E7.4): l

• Review and incorporation of lessons-learned from industry expeijence .

needed improvement.  !

• Three surveillance tests failed to appropriately implement the Technical  :

Specification surveillance requirements. The examples required operability ,

evaluations and retest. Affected equipment were subsequently found to ]

have been capable of fulfilling required safety functions. (One of these 4

examples was reviewed by the NRC inspection team and is the source of the

noncited violation discussed in Section E7.5),

• The licensee had failed to perform post-modification tests for three

completed modifications. The licensee's review of current testing indicated

that the affected components were capable of perforrning their safety

function.

• - The licensee found that the unreviewed safety question determinations,

operations information reports, and Technical Specification clarifications

were correct. However, the assessment team found that Technical

Specification clarifications needed significant enhancement.

• Weaknesses of the corrective action program similar to those identified by

Quality Evaluatian Audit Report K469 were identified. The weaknesses

included identification of incomplete corrective actions for closed

performance improvement requests. j

• The licensee's auxiliary feedwater assessment team noted the following strengths

(Section E7.4):

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• Calculations generally used appropriate input data and supported the

functional requirements stated in the updated safety analysis report. The

subject matter and the purpose of calculations were normally well defined. 1

The methodologies used were based on sound engineering principles and i

were consistent with normally acceptable industry standards.

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• In general, the design basis was found to closely match the updated safety

analysis report. Equivalency evaluations resulted in the correct translation of

regulatory requirements and design bases into design output that

appropriately defined the Wolf Creek Generating Station design.

• The recently initiated work product appraisal tool was judged to be an

effective tool for aligning the quality of engineering work products with

management expectations. The process was beginning to show

improvements in engineering output documents.

• The team noted that engineering department interface and communications with the

operations department associated with the essential service water warming line

performance characteristics was weak. As a result, an unexpected increase of the

-indicated lake temperature was observed by control room operators when the

essential service water warming lines were placed in service (Section E8.4).

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l. OPERATIONS

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01 Conduct of Operations j

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01.1 Problem identification j

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a. Insoection Scope (40500)

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The team reviewed the licensee's implementation of its problem identification

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were being appropriately identified. The team reviewed associated performance .:

improvement requests and discussed issues with licensee management and working  ;

level personnel. The team performed walkdowns of various accessible areas of the +

- plant, observed equipment condition, and observed work performance by plant t

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b. Qbservations and Findinas

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' .The team determined that Administrative Procedure AP 28A-001, " Performance 1

Improvement Request," Revision 6, specified the licensee's primary process for l

identifying, evaluating and resolving conditions adverse to quality. The procedure  !

required all personnel who identify problems, or potential problems, to document ,

them on a performance improvement request form and to promptly notify the duty

shift supervisor or Central Work Authority if a problem had the potential to affect j

plant operability. The procedure defined " problem" as equipment operation, j

program or procedure implementation, or work activities that do not occur as  ;

required. The procedure further defined the term " problem" to include " conditions

. adverse to quality" as used by 10 CFR 50 Appendix "B" Criterion XVI, " Corrective  !

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The team determined that Administrative Procedure AP 28A-OO1 established the

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central work authority and assigned it the responsibility for operability and

reportability reviews of performance improvement requests. The central work

authority was also assigned the responsibility for determining whether a  !

. performance improvement request was "significant" or "non-significant." The i

central work authority was assigned the responsibility for forwarding the l

performance improvement request to the responsible manager for evaluation and j

disposition of the performance improvement request. i

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The team discussed with performance improvement and assessment personnel the l

performance improvement request process and data. The licensee informed the

team that problem identification by means of the performance improvement request l

process had increased from 2289 performance improvement requests in 1994, and l

' 3074 performance improvement requests in 1995, to 3489 performance [

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irnprovement requests in 1996. Approximately 500 perforrnance improvement

requests had already been initiated in the first 2 months of 1997. Similarly, the

number of performance improvement requests categorized as "significant"

performance improvement requests had also increased from 74 in 1994, and 92 in

1995, to 176 in 1996.

Through the course of the inspection, the team noted that conditions adverse to

quality, observed by the team, were generally already identified by the licensee in

appropriate performance improvement request or other corrective action forms.

Several examples of conditions adverse to quality that the team reviewed are

discussed in the following sections of this inspection report.

c. Conclusions

The team concluded that conditions adverse to quality wers generally being

appropriately identified in performance improvement request forms or other

, appropriate corrective action documents.

01.2 Problem Resolution

a. Insoection Scooe (40500)

The 17, r viewed

e operating logs, interviewed licensed and nonlicensed operators,

observeo operations department plant status meetings, observed control room l

activities, accompanied equipment operators in the plant, and reviewed corrective j

action documents to determine if problems were being appropriately identified and l

handled using the corrective action program.

b. Observations and Findinas

The team found that operations personnel were correctly initiating performance

improvement requests and action requests as new issues were identified.

The team noted severalinstances where generic implications of equipment failure

had been considered. For example, during performance of a surveillance test on

December 13,1996, the essential service water pump room fan did not start as

designed. The licensee initiated significant Performance Improvement

Request 96-3281 to address this issue. The licensee concluded that the start

failure was caused by a change in procedure for adjusting circuit breaker plunger

travel. Loose auxiliary switch mounting screws also contributed to the problem.

Licensee personnel reviewed the circuit breaker data for other breakers, which had

been adjusted using the new procedure and identified three other breakers with

potential plunger travel setting problems. In addition, maintenance personnel

checked and tightened all similar safety-related circuit breaker auxiliary switch

mounting screws. Based on additional plunger travel measurements and testing,  ;

the licensee determined these breakers were operable as-found. Operations l

personnel documented the basis for their operability determination in the shift '

supervisor's log.

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c. Conclusions i

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The team concluded that operations personnel were appropriately initiating

performance improvement requests as new issues were identified. Operations  :

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personnel were generally ensuring that generic implications of equipment failure l

were addressed. {

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s 02 Operational Status of Facilities and Equipment  ;

2 O2.1 Operator Work-arounds  !

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a. Inspection Scoce (40500)

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The team reviewed licensee management's "Other Performance Indicators" list,

which tracked operator work-arounds. The team also interviewed 10 licensed and  !

nonlicensed operators to determine the status, use and disposition of operator work i

arounds. In addition, the team reviewed control room logs and performance i

improvement requests to identify conditions that appeared to result in operator  :

work-arounds. The team reviewed the conditions to determine if they were being i

appropriately dispositioned. l

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l b. Observations and Findinas l

The team verified that the licensee had identified only five operator work-arounds  !

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and that these were all tracked for resolution. The licensee had scheduled a

forecast date for closure and had determined the required plant status for the

closure of each operator work around.

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Routine Deoressurization of the Residual Heat Removal System I

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i During followup of an operating tog entry, the team found that operations personnel

were routinely depressurizing the residual heat removal system due to injection

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check valve back leakage. The team interviewed licensee personnel and found that

the licensee had developed a plan for the long-term repair of the leaking check

valves. The team also confirmed that the existing operating practices ensured that

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the lower pressure residual heat removal system piping was not bpng over

pressurized.

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! The team also confirmed that the check valve leakage rate was less than Technical

Specification leakage limits. Licensee personnel stated that they depressurized the

residual heat removal system when it reached approximately 80 psi. Further,

licensee personnel stated that it was only necessary to depressurize the system

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once or twice during a shift.

The team noted that this routine compensation for degraded equipment was not

listed as an operator work-around. Licensee personnel indicated that their definition

for an operator work around was more restrictive than the definition used by the

NRC. The licensee's definition was restricted to activities, which could prevent

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effective operator action during a transient as opposed to a broader definition

including any design deficiencies which required compensatory operator actions. ,

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Because of the apparent low rate of leakage, the team agreed that routine

depressurization was not an operator work-around by the licensee's definition.

The team determined that the licensee had developed appropriate compensatory

measures and long-term corrective action plans for this issue. However, the team

was concerned that the licensee's definition for an operator work-around may be

too narrow in scope, such that some potentially valid work-arounds may not be

identified. ,

Routine Entrv Into a Hiah Radiation Area to Adiost Component Coolina Water Flow

to a Residual Heat Removal Pumo Oil Cooler

Service loads are non-divisional heat loads that can be connected to either train of

component cooling water. When the service loads are swapped from one train to

the other, they affect the flow balance in the entire train. The flow decreases in

other parts of the component cooling water train when service loads are added.

When the service loads are removed, the flow in other parts of the component

cooling water train increase.

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The licensee had previously specified acceptable flow ranges for components which

are cooled by component cooling water. The licensee determined that the flow

range specified on the field label for the residual heat removal system oil cooler was

not wide enough to accommodate flow changes when the nonsafety service loads j

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were swapped from one train to the other. This technical issue could have been

resolved either by demonstrating that a wider range of flow would be acceptable, or

by modifying the flow balance, through throttle valve adjustment, so that regardless

of the application of service loads, the flow to the cooler would be acceptable.

In Performance improvement Request 96-2819, licensee personnel observed that it

was necessary for operators to routinely enter a high radiation area to adjust

component cooling water flow to a residual heat removal pump oil cooler. The

team learned that the component cooling water system had not been recently flow

balanced. The variation in component cooling water flow caused by system

realignment resulted in out-of-specification flow to the residual heat removal pump

oil cooler. Operator action was then necessary to correct the resulting

out-of specification condition.

In Performance improvement Request 96-1447, the licensee noted that they did not

have a general flow balance procedure for rebalancing the component cooling water

system when flow deviations were noted. As corrective action for this issue, the

licensee planned to perform a new flow balance. The flow balance procedure was

being developed with a completion due date of August 30,1997. Licensee

personnel stated this date was selected to support performance of the flow balance

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during the 1997 fall outage. Further, engineering personnel had an action request

to reevaluate the flow ranges specified on field labels for equipment cooled by the i

, component cooling water system. Licensee person.iel believed that the actions >

being taken for Performance Improvement Reques'. 96-1447 would resolve the .

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ALARA issue identified in Performance improvement Request 96-2819.

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The team noted that this issue was not designated an operator work around, I

consistent with the licensee's definition. Although, the team considered this issue i

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illustrative of the type of design condition that should be tracked for resolution as

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an operator work-around, the licensee had already developed appropriate plans to  !

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address this issue. j

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c. Conclusion 2 ~  !

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j Although the licensee used a very narrow definition for operator work arounds, the

team did not identify any operator work-arounds that were not being appropriately l

resolved.

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O2.2 Operability and Reportability Determinations l

a. Insoection Scooe (40500)  !

The team reviewed the shift supervisors log from December 13,1996 to

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January 27,1997, to evaluate operability determinations performed by the shift ,

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superintendent. The team also reviewed Administrative Procedure AP 26C-004,

" Technical Specification Operability," Revision 0, dated December 13,1996. The

team reviewed three degraded equipment conditions to determine whether

l operability determinations were performed and documented per the requirements of

l the new procedure. The team also reviewed two reportability evaluations.

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b. Observations and Findinas

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The team found that operations personnel correctly evaluated equipment

operability. Three examples of operability evaluations reviewed by the team are

discussed below.

Essential Service Water Pumn Room Fan Failure to Start - The team reviewed the

operating log operability evaluation record for the essential service water pump

room fan circuit breaker issue escribed in Section 01.2.b of this inspection report.

The team found that the shift superintendent had provided a detailed explanation of

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the basis for the operability determination in the shift log. However, an operability

. screening checklist was not completed as required by the December 13,1996,

j procedure revision. The circuit breaker problem occurred on December 13,1996;

4 therefore, the team concluded that this discrepancy was likely due to the normal  !

time lag before implementation of the new procedure revision,

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Control Power Transformer Ground Fault Protection - On January 13,1997,

maintenance personnel identified that a jumper was missing on a control power

transformer. As a result, the ground fault protection would not have worked.

Operations personnel did not initiate a screening checklist for this example because

the switchgear was already out-of-service and inoperable. During the followup

inspections to identify other missing jumpers, maintenance found a similar

deficiency. Operations personnel did initiate an operability screening checklist for

the identified deficiency. A performance improvement request was also iriitiated for

the issue.

Failure of Excess Letdown isolation Valve Stroke Time Test - On January 16,1997,

the excess letdown isolation valve failed its ASME Section XI open stroke time test.

The team determined that the valve had previously failed its open stroke time test

on January 22,1995, and October 22,1996, and that it was already being tracked

as an inoperable, but functional, valve in the licensee's equipment out-of-service

log. Since the valve was already being tracked as inoperable, operators did not J

initiate an operability screening checklist. The licensee stated that the close stroke

time test was within specification. ,

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The team generally agreed with the licensee's operability determinations. However, l

the team found that the licensee had not yet fully transitioned to the new procedure

revision requirements for documenting operability determinations. The team found I

it necessary to read the performance improvement request, the operability and

reportability determinations, and the equipment out-of-service log to determine the

full technical basis for the operability determinations.

The team reviewed two reportability determinations and found them to be correct.

c. Conclusions

Based on a few examples, the team concluded that reportability and operability

determiutions were being correctly performed. The team concluded that the basis i

for operability determinations was recorded in the shift superintendents log, the l

equipment out of service log and on operability screening checklists.

07 Quality Assurance in Operations

07.1 Problem Evaluation and Resolution

a. Inspection Scope (40500)

The team reviewed the licensee's implementation of its corrective action process to I

determine if issues that degrade the quality of plant operations or safety were being

appropriately evaluated and resolved. The team performed walkdowns of various

accessible areas of the plant, observed equipment condition, and observed work

6  ;

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l

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,

,

performance by plant personnel. The team reviewed audit and self-assessment  :

reports, performance improvement requests, and associated corrective action  ;

documents. The team discussed conditions adverse to quality that were observed  ;

by the team with licensee management and working level personnel, j

b. Observations and Findinas

The licensee performed a self assessment of the performance improvement I

request program in October and November,1995. The results of the self  ;

assessment were documented in Self-Assessment Report SEL 95-0049,

" Performance improvement Request Program," dated November 30,1995. The  !

self assessment found that root-cause evaluations for significant non-hardware

problems were weak, shallow in depth, and did not reflect that any root-cause ,

techniques were utilized. Performance improvement Request 95-2761 was initiated  !

<

to identify and resolve the self-assessment finding. As corrective action,

4

Administrative Procedure AP 28A-001, Revision 4, was issued to clarify the root- 7

cause evaluation requirements and to require root-cause analysis training of  !

personnel performing evaluations and independent review of significant  ;

,

performance improvement requests.

I

The licensee performed Quality Evaluations Audit K-461, " Corrective Action," and

issued the audit report on July 30,1996. The audit found that weak root-cause

-

investigations were still being performed for problems that had been identified in l

significant performance improvement requests. The licensee did not perform any  :

additional corrective action for this audit finding because insufficient time had j

passed since corrective action was performed for the above noted self assessment  ;

and performance improvement request. ,

'

e On Septernber 11,1996, the Nuclear Safety Review Committee Maintenance

1

Subcommittee reviewed five significant performance improvement requests and ,

noted problems with three of the performance improvement requests including poor  !

root-cause/ corrective actions for the performance improvement requests. The  !

inspector verified that the licensee had already corrected the problems noted with l

the five performance improvement requests. The subcommittee findings were  ;

, forwarded to the Nuclear Safety Review Committee by means of a memorandum to

i the Nuclear Safety Review Committee chairman dated September 23,1996. The  :

subcommittee discussed the problem during Nuclear Safety Review Committee

Meeting 96-02 on September 25,1996. The performance improvement and

assessment manager informed the comm' that a corrective action audit was  ;

scheduled for December 1996 and the audo sould address performance i

improvement request programmatic issues, ae Nuclear Safety Review Committee  ;

assigned action to the performance improvement and assessment manager to  ;'

discuss the results of the audit during Nuclear Safety Review Committee

Meeting 97-01 which had been tentatively scheduled for early 1997.

The licensee perforrned Quality Evaluations Audit K-469, " Corrective' Action," from i

September 19 to December 20,1996 and documented the results of the audit in a

report dated December 26,1996. The audit found that the corrective action >

7 >

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progran: had been effective in identifying conditions adverse to quality on -

{

performance improvement requests. However, the audit also found. several  :

'

weaknesses of the performance improvement request program implementation [

'

including four examples of weak root-cause analysis for signifkant performance

l ' improvement requests. Performance improvement Request 96-3063 was issued as

a result of the audit findings and included recommendations on how to improve f

root-cause analysis and identification of resultant corrective action. [

i

l The team determined that Performance improvement' Request 96-3063 was still . l

2

open. However, the team was informed by licensee senior managers, including the ,

performance improvement and assessment manager, of the following corrective +

l

' actions that already had been taken and are planned to resolve the performance  !

,

improvement request root-cause evaluation and corrective action weakness that

had been identified. l

I

• Revision 6 to Administrative Procedure AP 28A-001, " Performance

Improvement Request," was issued on January 3,1997. The revision

established the requirements for a Corrective Action Review Board, The j

board was chaired by the plant manager and included the vice president of  ;

i engineering, the director of site support, and the manager of performance

'

improvement and assessment. The board was assigned the responsibility for ,

review of all significant performance improvement requests following i

'

completion of the root-cause evaluation and the corrective action plan.  !

!  !

4

• The procedure revision also clarified the requirements for the performance l

' and independent review of significant performance improvement request i

root-cause evaluations and corrective action plans. I

!

• Another procedure revision was being planned to establish the requirements  :

for the use of performance improvement request coordinators. The ,

performance improvement request coordinators were intended to be I

dedicated and trained individuals who would be assigned responsibility for

, the performance of all root-cause evaluations and preparation of corrective

'

action plans for significant performance improvement requests assigned to

} their respective groups. At the time of the inspection, performance

< improvement request coordinators were being selected for each of the major

!' site work groups.

1

4

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• FPI international, Inc., an industry-recognized consultant on root cause

evaluations, was contracted to provide a 4-day root-cause training course

to performance improvement request coordinators. In addition, training

was being planned to discuss the specific procedure requirements of

.

Procedure AP 28A-001. Both training courses were planned to be

completed by March 31,1997,

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The team noted that the first Corrective Action Review Board meeting convened on

November 11,1996. The board reviewed and discussed its draft charter, purpose,

membership and responsibilities. The board also discussed improvements to the

company's corrective action program. On December 13,1996, the board met for

the first time to review root-cause evaluation and corrective action plans for six

significant performance improvement requests. The board returned all six with

comments. None were approved. From December 13,1996 to January 31,1997,

the board had met nine times, reviewed 32 significant performance improvement

requests (some were reviewed multiple times, and thus, counted several times), and

approved the root-cause evaluations and corrective action plans for only six

significant performance improvement requests.

The team identified one example of a performance improvement request that had ,

been dispositioned with inadequate corrective actions. The corrective action

violation and the performance improvement request are discussed in Section E2.1

of this inspection report. The performance improvement request had been

dispositioned prior to the formation of the Corrective Action Review Board.

c. Conclusions

The team noted that the licensee had identified that the root-cause evaluations and

corrective action plans for significant performance improvement requests were

weak. The licensee was taking corrective actions to improve the root-cause

evaluations and corrective action plans for significant performance improvement I

requests. The team concluded that the licensee corrective actions were

appropriate, and if fully and effectively implemented, should improve performance.

Continued critical review by the Corrective Action Review Board would provide

significant improvement to the process.

07.2 Quality Assurance Audits

a. Inspection Scope (40500)

The team reviewed the licensee's audit schedule and compared it with the

frequency requirements specified in the Technical Specifications. The team also j

evaluated the scope and depth of a corrective action audit performed by Utility i

Service Alliance, which was com;.leted January 22,1997. i

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b. O_bservations and Findinas

'

The team found that the licensee's audit schedule complied with the Wolf Creek

Technical Specifications Administrative Controls Section 6.5.2.8, " Audits." The  ;

'

team also found that the audit conducted by the Utility Service Alliance identified

problems, which were similar to those identified .in a similar audit recently

performed by the site Performance improvement and Assessment organization that

were discussed above.

9

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The United Service Alliance audit concluded that problems were being appropriately

identified. The audit identified weaknesses in the licensee's capability to document

operability determinations, to develop effective root-cause determinations and to

identify and correct the generic implications of problems. As a result of this audit

and others conducted in 1996, the licensee was in the process of upgrading their

corrective action program.

Additional audits reviewed by the team are discussed in Section 07.1 of the ,

inspection report above. -

.

c. Conclusions

The team concluded that audits were being scheduled as required by the Technical

Specifications. The team also concluded that the audit process was appropriately

identifying the need for improvements in the corrective action process.

07.3 Independent Safety Enaineerina Group

a. Inspection Scope (40500j

The team interviewed members of the Independent Safety Engineering Group to

determine whether they were accomplishing the functions described in the

Technical Specifications. The team reviewed completed plant surveillances and

maintenance work packages to confirm that required Independent Safety

Engineering Group verifications were being performed. l

l

b. Observations and Findinas 1

i

The team determined that the independent Safety Engineering Group examined

plant operating events, NRC issuances, industry advisories, and other sources of

operating experience information. Based upon those examinations, the Independent  :

Safety Engineering Group made detailed recommendations for improving plant l

>

safety to the Chairman Nuclear Safety Review Committee.

The team determined that the Independent Safety Engineering Group consisted of

six, dedicated, full-time engineers. Each member had greater than 10 years of i

professional level experience in engineering or related sciences. The team l

determined by a records review that the Independent Safety Engineering Group )

members monitored plant activities.

c. Conclusions

1

The team concluded that the Independent Safety Engineering Group met the '

function, composition, and responsibilities requirements contained in Technical

Specification Administrative Controls, Section 6.2.3.

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07.4 Corrective Action Review Board  !

.

. a. Insoection Scope (40500)  ;

i

The team reviewed Corrective Action Review Board activities to determine the

board's contribution toward assuring that conditions adverse to quality are '

corrected. The team reviewed board meeting minutes, attended a board meeting,-

'

and discussed board activities with licensee management and working level  !

personnel.

4 b. Observations and Findinas ,

j As noted in Section 07.1 of the inspection report above, the Corrective Action  :

'

Review Board was formed and met for the first time on November 11,1996. The  ;

i board had met as a group approximately 11 times and started its performance  !

improvement request review activities on its third meeting on December 13,1996. [

.

On January 29,1997, the team attended a Corrective Action Review Board ,

meeting. The meeting was held to review the root-cause analysis and corrective  !

action plans for significant performance improvement requests.

, l

'

The membership of the Corrective Action Review Board included the plant manager,

,

vice president plant operations, vice president engineering, and manager

[ performance improvement and assessment. The board took a critical and

questioning approach to each performance improvement request that it reviewed.

The board questioned the training and qualifications of the preparer and

independent reviewer of each root-cause analysis, and whether the administrative

procedure had been followed. The board also questioned whether the root-cause

was correctly identified, the corrective actions were appropriate and addressed the

stated root-cause, proposed corrective actions would be effective, and the generic

implications of the identified condition. Programmatic controls used to ensure that

the corrective actions were performed were also discussed by the board.

The team found that the board members were well versed in the methods of root- )

cause analysis and corrective action planning. They set high standards for the

performance improvement requests they reviewed and rejected those performance

improvement requests that did not meet their expectations. Several of the

performance improvement requests had been befcre the Corrective Action Review i

Board previously and been rejected. Only 6 of the 32 performance improvement j

requests submitted to the Corrective Action Review Board had been accepted since

.

the initiation of reviews by the board in December 1996.

l I

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c. Conclusions

- The team concluded that the Corrective Action Re' view Board was clearly trying to I;

!~ upgrade the quality of root-cause evaluations and corrective action plans that were l

being generated for significant performance improvement requests. However, the ,

f

team also concluded that the long-term effectiveness of the Corrective Action

- Review Board could only be judged based on recognizable improvement in the

I

4

licensee's corrective action program.

,

4 07.5 Plant Safety Review Committee

,

s

a. Insoection Scope (40500)

1

4 .,

On January 29,1997, the team attended Plant Safety Review Committer  :

I Meeting 752 to determine how the committee performed it's Technical  !

Specifications 6.5.1 required functions. l

.

i

b. Observations and Findinas  ;

The committee evaluated several procedure changes and updated safety analysis l

report change requests to confirm that they did not involve an unreviewed safety .  !

question determination. The team noted that the committee asked challenging  !

questions and, as a result, several items were withdrawn from consideration. The l

team determined that the on site review committee was clearly committed to

upgrading the standard for updated safety analysis report compliance. l

l

In Updated Safety Analysis Report Change Request 97-007, the licensee identified

that Figure 6.2.4-1 incorrectly indicated that the main steam isolation valves f ail

close. The licensee determined that for some failure mechanisms the valves could

f ail as-is. During the meeting, the licensee stated that other sections of the

updated safety analysis report correctly described the design of the main steam

isolation valves and that they planned to make this correction in accordance with

10 CFR 50.71(e).

The team was concerned that the main steam isolation valve failure modes may not

have been adequately considered in the 10 CFR 50 Part 100 dose calculations. The

team reviewed Updated Safety Analysis Report Chapters 6.2.4 and 10.3 and

confirmed that they were consistent with the requested change. The licensee

noted that the main steam isolation valve actuator design includes redundant

electrical and pneumatic circuits. As a result, the worst-case single f ailure could

only cause one main steam isolation valve to fail as-is. Licensee personnel stated

this case was bounded by existing dose analysis. However, loss of all power and

air (beyond single failure design considerations) results in all of the main steam

isolation valves failing as is. The team agreed that all valves f ailing as-is was a

beyond design basis failure mode and did not have to be considered in the dose

analysis.

12

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.

c, Conclusions

The team concluded that the Plant Safety Review Committee conservatively

dispositioned the items which were presented for review and approval in

accordance with the Technical Specifications.

07.6 Operatina Exoerience Feedback Proaram

a. Insoection Scope (40500)

The team reviewed the licensee's operational experience feedback program to

determine its effectiveness in assessing, documenting, and informing appropriate

plant personnel of significant plant events in an effort to prevent their occurrence at

the plant. The team reviewed 28 NRC information notices, four NRC bulletins, four

significant operating experience reports, and six operating plant experiences.

b. Observation and Findinas

The team found that the operating experience feedback program procedures

provided appropriate controls for forwarding information regarding events to the

appropriate licensee review personnel. The team determined that corrective actions

resulting from the review of information for operational events were planned, and

corrective actions were implemented and tracked to completion via the performance

improvement request process. The team verified that the timeliness of initial

screening and review of industry information was, on the average, less than five

days. The team found that the review of operating experience documents were

tracked to completion via the performance improv: ment request process.

A licensee self assessment of the operating experience feedback program

performed in September 1996, and documented in Self-Assessment

Report SEL 96-027, noted that the due date assignment process allowed the initial  !

review of operating experience feedback issues to be delayed for an indeterminate l

length of time. The licensee initiated Performance improvement Request 96 2409 )

on September 27,1996, to address this weakness. The team noted the licensee

now plans to normally complete the initia! review of these items within 30 days.

The team also noted that none of the operating experience feedback issues had

initial review due dates greater than 30 days.

The licensee documented another self assessment in Self-Assessment

Report 96-011, " Auxiliary Feedwater Systern Functional Assessment," performed

from July to December 1996, which identified two industry experience reviews that

,

had missed the opportunity to identify that auxiliary shutdown panel 86X relay

surveillances had not been performed. Industry Technical Information Program  ;

Reviews 3231 and 3312 detailed surveillance testing of the auxiliary shutdown

panel and its associated equipment, but did not specifically mention testing the 86X

relays. Section E7.5 of this inspection report provides additional information related

to this problem.

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c. Conclusions

'

,

The team. concluded that the operating experience information was generally being -i

i disseminated appropriately. The team concluded that reviews and corrective

j actions for operating experience was being controlled. However, the team also

noted that the licensee had identified examples of weaknesses of the program  !

associated with the timeliness and effectiveness of some of the reviews.

07.'7 Plant Staffina l

l i

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a. Inspection Scope (40500)

.

,

The team reviewed licensee plant staffing records. The team discussed plant

staffing with licensee senior managers, middle managers and working level

personnel. The team reviewed the impact of plant staffing on the adequacy of the.

'

l licensee's implementation of the corrective action program.

i

, b. Observation and Findinas

The team determined that the Wolf Creek Generating Station Strategic Business

s. Plan projected the plant staffing level through the year 2001. The plan showed  ;

4 1010 employees at Wolf Creek in 1996 and projected a 3.8 percent per year

, reduction through 1999 and a projected a staff of 900 employees in 1999 and .

beyond. The plan projection was based on projected attrition rates.

i The team was informed by the newly appointed President and Chief Executive

Officer that the Strategic Business Plan was, as stated, a plan. The Chief Executive  !

i Officer also informed the team that the plan was subject to continuous review and

i- that he would be reviewing it further with the onset of his new appointment.

Finally, the Chief Executive Officer noted that he had no restrictions in making

-

adjustments to the plan to suit the needs of Wolf Creek.

I

c. Conclusions ,

l The team concluded that the Wolf Creek Generating Station staffing level, and

'

projected attrition should not significantly impact the implementation of the

, corrective action program. The team noted that self-identified weaknesses >

associated with the implementation of the program would require licensee shifting i

I

and management of resources.

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fl. MAINTENANCE

M2 Maintenance and Material Condition of Facilities and Equipment

M2.1 Review of Maintenance Backfoo

a. Inspection Scope (40500)

The team reviewed a list of open, non-refueling, power block safety-related work

packages. The team also reviewed the licensee's procedure for establishing work 6

priorities.

b. Observations and Findinas

The team found there were approximately 150 open non-refueling power block

safety-related work packages. The team determined that this backlog was low

based on experience at other facilities. The team noted that there were no open

Priority 1 or 2 items. The team also noted that the Plant Safety Review Committee

routinely reviewed maintenance items over 6-months old to ensure management ,

attention was focused on resolving these issues.

c. Conclusions

The team concluded that licensee personnel were resolving hardware deficiencies in

a timely fashion. j

M3 Maintenance Procedures and Documentation

i

M 3.1 Review of Surveillance Test Packaaes l

)

a. Insoection Scone (40500) 1

l

During the review of operating logs described above, the team identified several ,

potential test deficiencies. The team reviewed copies of the following completed l

data packages to determine if the test deficiencies were correctly dispositioned.

STS AL-102, "MDAFW Pump B inservice Pump Test"

STS AL-201B," Auxiliary Feedwater System Train B inservice Valve Test"

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STS AL-210, " Auxiliary Feedwater System inservice Check Valve Test"

STS IC-244, " Analog Channel Operational Test Nuclear Instrumentation System l

Power Range N44 Protection Set IV"

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2 b. Observations and Findina- ->

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1 The team found that the data packages were properly filled out with generally i

adequate documentation of the details of the test performance. The licensee was '

able to justify apparent discrepancies identified by the team. The team reviewed

the recorded data against the acceptance criteria and found the test results to be  :

,- correctly identified as satisfactory or unsatisfactory. For each test deficiency, ,

'

appropriate troubleshooting and retesting were performed and properly - ,

documented.  !

i '

Surveillance test packages were properly completed, deficiencies were properly

identified and documented, and appropriate troubleshooting and corrective actions'  !

] 3

were taken, in accordance with the licensee's procedural requirements. j

I

c. Conclusion

The team concluded that surveillance test deficiencies were being appropriately  !

dispositioned. i

M4 Maintenance Knowledge and Performance l

'

M4.1 Maintenance Knowledae and Use of the Corrective Action Proaram l

a. Inspection Scope (40500)

i The team reviewed the action request and work package log for the period from

i

December 13,1996, to January 26,1997, and correlated some of the information

! with the operating log entries. The team determined if conditions adverse to quality

] were being appropriately identified and corrected. l

t

b. Observations and Findinas j

i

The team found that maintenance was generally appropriately identifying and  !

correcting conditions adverse to quality. Specifically, the team noted that ,

maintenance personnel took appropriate generic corrective action when a pressure l

1

switch capillary tube failed on the Class-lE electrical equipment air conditioner. The

!

.l licensee determined that the failure was caused by system vibration which was

!

exacerbated by loose pressure switch mounting screws. Licensee personnel  ;

!

performed the necessary repairs, inspected and tightened mounting screws on other  !

i similar air conditioning units, and upgraded the associated preventive maintenance  !

instructions to provide a caution to the electricians, alerting them to use adequate f

torque when tightening the mounting screws. No other pressure switch capillary [

, tube failures were identified. l

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c. Conclusions

,

The team concluded that maintenance personnel were generally appropriately f

identifying and correcting conditions adverse to quality. f

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M7 Quality Assurance in Maintenance Activities

M 7.1 Self Assessments

a. Inspection Scope (40500)

The team reviewed Self-Assessment Report SEL 96-046, " Effectiveness of

Improved System Engineering / Maintenance involvement," completed November 18,

1996.

b. Observations and Findinas

The licensee identified that the expectations concerning the responsibility of system

engineering and maintenance engineering were not well defined. The assessment

also concluded that the maintenance manager and the system engineering manager

shared that same overall vision, but that their expectations had not been

communicated. The team reviewed the system engineering manager's plan for

clarifying the system engineer's responsibilities and found it to be a reasonable

approach to addressing the issue,

c. Conclusions

The team concluded that the licensee performed a good maintenance self

assessment. The team also concluded that the licensee was taking appropriate

corrective actions for the self-assessments findings. .

!

M8 Miscellaneous Maintenance issues (40500)

M8.1 (Closed) EA 96-124. Violation I.C. Examole 1 (03013); Inadequate turbine-driven

auxiliary feedwater pump packing instructions, j

i

Work instructions for the turbine-dnven auxiliary feedwater pump packing did not 1

include adequate instructions for ti;;btening of the packing gland follower nuts, j

proper installation of the packing gland follows, nr the directions for what 1

constituted a proper post-maintenance pump run to obtain proper packing leakoff.

For corrective actions (licensee letter WM 96-0081, dated July 31,1996), the

licensee revised the pump packing procedures to provide the guidance that had i

been previously lacking. The revised packing information and event discussion

were incorporated into maintenance training material, and a training session was j

conducted with the maintenance planners to critique the event and review the

revised packing and maintenance run in work instructions. A new preventive  ;

maintenance task was implemented to inspect the sleeve nuts on the auxiliary )

feedwater pumps and tighten them if necessary. The surveillance frequency and '

17

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run time duration was increased to provide more operating data on packing

performance following repacking utilizing the revised procedure. Additionally, for

unscheduled corrective maintenance on the auxiliary feedwater or emergency diese!

'

generator systems, a knowledgeable individual was to be assigned to provide

independent oversight of the maintenance activity.

2

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The inspector reviewed the revised pump packing procedure, the preventive  :

maintenance. task to inspect the sleeve nuts, the revised training material, the I

documentation supporting the additional training, and completed documentation l

regarding sleeve nut inspections and pump packing performance. The inspector

concluded that the licensee had appropriately implemented the required corrective

'

actions.

!

M8.2 (Closed) EA 96-124 Violation I.C, Example 2 (03023): Failure to identify and

correct deficient conditions on the turbine-driven auxiliary feedwater pump.

!

Improper adjustment of the turbine-driven auxiliary feedwater pump packing had ,

4

been previously identified, but actions were not taken to determine and correct the

cause of the deficient condition.

The licensee performed a number of corrective actions to address this violation

(licensee letter WM 96-0081, dated July 31,1996). The maintenance manager re-

emphasized expectations regarding the importance of using self-critical evaluations >

,

and soliciting the involvement of system engineers in resolving maintenance

corrective actions. System engineering was placed under the chief operating  ;

e

officer, and a single system engineering supervisor was assigned responsibility for

all auxiliary feedwater issues. A self assessment was conducted in November

1996 to determine the effectiveness of the system engineering group's involvement

in plant activities. Additional training regarding pump packing was provided to .

planners and mechanics, and was made available to system engineers.  !

Additionally, a post-maintenance test specifically for the turbine-driven auxiliary ,

feedwater pump was developed and implemented.

i The inspector reviewed the documentation supporting completion of the licensee's

,

actions stated above. The results of the self assessment indicated that while some

improvement in system engineering involvement had been noted, areas for

improvement were identified in inter-departmental expectations and

communications. The inspector concluded that the licensee had satisfactorily

addressed the required corrective actions.

,

Mts.3 LClosed) EA 96-124, Violation ll.D (07014): Failure to take appropriate corrective

action on the turbine-driven auxiliary feedwater pump.

This violation involved the identification of a deficient condition regarding

insufficient thread engagement on the inboard packing gland follower nuts, and j

subsequent closure of the work request without further action,  ;

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The licensee's corrective actions for this violation were identical to the actions  !

taken for the violation discussed in Section M8.2 of the inspection report above and

were adequately c-ompleted and implemented.

M8.4 (Closed) EA 96-124. Violation ll.E (08014): Failure to follow turbine-driven

auxiliary feedwater pump work instructions.

During maintenance on the auxiliary feedwater pump packing, the packing g!and

follower nuts were left " finger tight" as opposed to "srug" as required by Work )

Order WP 108952. J

i

4 in response to this violation (licensee letter WM 96-0081, dated July 31,1996), j

the licensee conducted additional. maintenance department training regarding the j

.

necessity to follow procedures and to seek guidance if the work instructions are not '

in agreement with their job knowledge. The mechanics were trained on the

I

rewntten instructions for repacking of the turbine-driven auxiliary feedwater pump.

Training and counseling was provided to maintenance supervisurs regarding 1

. management expectations for supervising work in the field, work package quality, )

and procedure adherence. A new maintenance planning superintendent was

_

l

assigned from the operations department to provide more of an operational focus in

the planning process. Maintenance department self assessments were conducted

in September 1996 (SEL 96-010) and in December (SEL 96-049) and identified i

areas for continued improvement. While improvement was noted in pre-job  !

briefings and preventive maintenance work packages, management expectations I

were not consistently met for corrective maintenance work packages.

'

The inspectors reviewed the self assessments and determined that they were

comprehensive and provided meaningful feedback. Eleven performance ,

improvement requests were written to address the areas for improvement, and

were found to be subsequently closed. Effective implementation of the corrective

'

actions associated with those performance improvement requests should further

. enhance the quality of work packages. Additionally, the inspector reviewed the

revised training material regarding pump packing and found it to be satisfactory to

'

address the previously identified issues.

111. ENGINEERING

,

E2 Engineering Support

'

E2.1 Enaineerino Sucoort for Performance Improvement Reauests

a. Insoection Scoce (40500)

In addition to other performance improvement requests discussed in the report, the

team reviewed the following performance improvement requests to assess the

adequacy of the dispos.itions, including the root-cause analysis and corrective action

19

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4 b6'""W .' #

W kl *'*M 1 m'W * w- -~

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plans: Performance improvement Requests 96-2413, 96-1129, and 96-1963. The

team also reviewed Calculations M-EG 13, "CCW radiation monitor flow orifice,"

and M-EG-11-W, " Component Cooling Water Heat Exchanger and Bypass Pressure

Drop Evaluation."

b. Observations and Findinas

low Flow to the Component Coolina Water Heat Exchanaer Radiation Monitor

Performance improvement Request 96-1129 documented that licensee personnel

observed that the component cooling water system radiation monitor rotometer

unexpectedly indicated zero flow. The licensee found that during some plant

conditions, the heat exchanger bypass temperature control valve fully opens and

bypasses most of the component cooling water flow around the heat excnanger.

A:: a result, the flow through the radiation monitor drops below the lower end of

the rotometer indicating range. The licensee dispositioned the performance

improvement request without taking any corrective actions, stating that "...the

Updated Safety Analysis Report requirements of sample flows of 1-5 gpm are met

as determined by document review and equipment walkdown for normal system

lineups."

The team reviewed two calculations, which the licensee personnel had used to  ;

make their determination (i.e., Calculation M-EC-13, " Component Cooling Water i

Radiation Monitor Flow Orifice," and Calculation M-EG-11-W, " Component Cooling

Water Heat Exchanger and Bypass Pressure Drop Evaluation.") The team

determined that the calculations did not provide an adequate basis for concluding

that the updated safety analysis report requirements for sample flow were met.

The radiation monitor is located in a non-seismic pipe in series with two restricting

orifices and in parallel with the component cooling water heat exchanger and the

bypass temperature control valve. A Brooks rotometer is in series with the

radiation monitor. The rotometer ranged from 1.5 to 10 gpm, so flow less than

1.5 gpm indicated zero. The radiation monitor vendor, General Atomic, specified

the radiation monitor would function for flows of 0.5 to 5 gpm. Updated Safety

Analysis Report, Section 11.5.2.2.2, specified the sample flow through the

radiation monitor was 1 to 5 gpm.

Calculation M-EG-13 predicted that at 0.5 gpm each restriction orifice in the line to

the radiation monitor would have a differential pressure drop of 0.5 psid. Since i

'

there are two restricting orifices in the line, the team noted that a pressure drop of

at least 1.0 psid would be necessary to drive 0.5 gpm flow through the monitnr.

Calculation M-EG-11-W predicted that the component cooling water heat exchanger

and the bypass temperature control valve have a differential pressure drop of

approximately 1.0 psid (i.e.,0.8 to 1.2) when the temperature control valve was

full open. Therefore, the team determined that the licensee had not demonstrated

that a minimum of 1.0 gpm flow would pass through the component cooling water

radiation monitor for all expected conditions.

20

. _ - _ - - _ _ _ _ _ - ._.

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.

'Another contributing factor not considered in the licensee's calculation was the

detrimental effect of corrosion on the flow through'the restricting orifices. There

were two documented occasions when either dirty components had to be replaced

or the line flushed to restore flow through the radiation monitors.

10 CFR 50, Appendix B, Criterion XVI, " Corrective Action," requires that conditions

adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective

material and equipment, and nonconformances be promptly identified and

corrected. The failure to correct this design deficiency after it was identified in

Performance improvement Request 96-1129 is a violation (50-482/9705-01).

c. Conclusions

The engineering staff incorrectly closed a performance improvement request related

to low flow through a component cooling water radiation monitor without taking

the necessary corrective actions. This a violation of 10 CFR 50, Appendix B,

Criterion XVI, " Corrective Action."

E2.2 Enaineerina Sucoort of Ooerability Evaluations

a. Insoection Scope (40500)

The team reviewed ten engineering evaluations which were performed to

support operability determinations. The team also reviewed Administrative

Procedure AP 28-001, " Evaluation of Nonconforming Conditions of installed

Plant Equipment." Revision 4, which governed engineering evaluations.

b. Observations and Findinas

The team found that the ten engineering evaluations reviewed by the inspectors

accurately supported the corresponding operability determinations.

E3 Quality of Engineering Products

l

E3.1 Main Steam isolation Valve and Feedwater Isolation Valve Reliability Imorovemenf

Task Force

a. Insoection Scope (40500)

!

During the review of operating logs, the team noted that it was necessary to

dispatch an operator to raise the setting for the air acct mulator for a main steam

l

21

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isolation valve.' The team reviewed design basis information related to this pressure-

'

i

I setting and the accumulator sizing. The team also reviewed the output document

1 for the feedwater isolation valve and main steam isolation valve task force. The

i. team interviewed personnel responsible for planning maintenance and testing  :

I

~ activities related to these valves.  !

4

b. Observations and Findinas

-

l When questioned by the team, the licensee was not initially abic to present a clearly .

. supported design basis for the air accumulator sizing for the main steam isolation .

valves and the feedwater isolation valves. Following the on-site NRC inspection.  !

the licensee contacted the valve vendor and was able to demonstrate that the

current operating practices were appropriate.

3

.. i

Based on review of the task force report, interviews with licensee personnel, and a

I

review of the reliability and availability data provided, the team determined that the

feedwater isolation valve, main steam isolation valve reliability task force had

, improved the reliability of these valves.

c. Conclusions

The design basis for the sizing for the main steam isolation valve air accumulators

. was acceptable. Further, the licensee had significantly improved the reliability of

'the feedwater isolation valves.

l E3.2 Extent of Use of Temocrary Modifications

i

.

a. Insoection Scope (40500)

i The team reviewed the licensee's list of open temporary modifications. The team

also performed walkdowns of the emergency diesel generator systems, the

accesible portions of the auxiliary feedwater system, the essential service water

system, and a general walkdown of other areas of the plant.

1

b. Observations and Findinas

The team did not identify any temporary notifications that were not on the

licensee's list of open temporary modifications. The team found that all open j

-

temporary modifications were less than 1 year old. The team reviewed the ]

. description of the modifications and did not identify any which were inappropriate.  ;

2

- c. Conclusions

The team concluded that the licensee was resolving temporary modifications in a

"

timely manner,

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- E7 Quality Assurance in Engineering

E7.1 Licensee Auxiliary Feedwater System Safety System Functional Assessment

.

-

The licensee performed a functional assessment of the auxiliary feedwater system

as a result of a commitment to the NRC contained in letter WM 96-0081 of

July 31,1996. The letter provided the licensee's responso and corrective actions

for engineering related violations identified in NRC Enforcement Action EA 96-124,

I

dated July 1,1996. The enforcement action resulted from multiple equipment

problems experienced during the January 1996 Wolf Creek Generating Station frazil

icing event. in its letter, the licensee committed to perform an auxiliary feedwater

_

system functional assessment (in addition to functional assessments of three other '

systems) to test the effectiveness of the licensee's corrective action plan, and to

assure that no additional potentially safety / operational significant design concerns

exist.

In addition, letter WO 96-0118, dated August 22,1996, included a commitment for

the functional assessment to include a review of a sample of completed design  !

,

modifications to ensure that necessary post-modification testing was completed.

E7,2 Self-Assessment Team Qualifications. Objectivity, and independence l

a. Insoection Scone (37550)

'

The purpose of this portion of the inspection was to determine the qualifications,

j objectivity, and independence of the licensee':: auxiliary feedwater system

functional assessment team. The NRC team reviewed the licensee' functional

assessment report and associated records, interviewed team members, and

discussed the functional assessment with the licensee's team and other licensee

personnel,

b. Observations and Findinas

?

The NRC team found that the licensee's team consisted of a team leader, four full-

time members from civil, electrical, mechanical design engineering, and a safety  ;

analysis engineer. On a part time basis, more than 13 members of the licensee's

'

technical and administrative staff provided additional support. The NRC team

determined that the licensee's team consisted of experienced engineers with

significant engineering experience at the Wolf Creek Generating Station. Eleven

members of the licensee's team had Bachelor of Science degrees or higher, four

were licensed professional engineers, and five held senior reactor operator licenses.

The self-assessment team functionally reported directly to the vice president of

engineering. The vice president of ongineering approved the various revisions of

the functional assessment plan, and also approved the final report.

As discussed further in succeeding sections of this inspect:on report, the licensee's

team performed a critical functional assessment and identified numerous conditions

that required further evaluation and corrective actions.

23

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c. Conclusion

The NRC team concluded that the licensee's team was composed of well-qualified

individuals who were sufficiently independent and objective. The team was capable

of performing good assessments.

E7.3 Scope and Death of Assessment

a. Insoection Scoce' (37550)

The NRC team reviewed the scope and depth of the licensee's assessment to

determine if it had sufficiently verified the functionality of the auxiliary feedwater

system.

b. Observations and Findinas

The NRC team determined that the licensee's assessment consisted of a review of

the auxiliary feedwater system from water sources (condensate storage tank and

crossover valves from the essential service water system) to the steam generators'

main feedwater header. The functional assessment also included a limited review

of ancillary support systems, such as the steam supply to the turbine driven

auxiliary feedwater pump and the condensate storage tank.

The licensee performed the functional assessment during the period of July 8 to

December 31,1996. Over 5-person years were expended on this effort. The

functional assessment resulted in the initiation of 187 corrective action documents.

In some cases, the corrective actions were reportable, but no condition was found

that resulted in a plant shutdown or in situations where safety-related systems and

components would not have performed their intended function.

The licensee reviewed 237 design modification packages, and found that, in

general, the design inputs and assumptions were adequate when compared with

the design and licensing basis. In most cases, design change information was

found to be adequately incorporated into design documents.

The licensee reviewed 398 calculations to assess whether the major design inputs

and assumptions were reasonable, that the calculations were technically adequate,

and, therefore, supported the functional requirements as stated in the updated

safety analysis report. The detailed review process involved identification and

review of major design inputs and assumptions to assess reasonableness, and that

they were justifiable and verifiable. Design inputs used in the calculations were

also reviewed to determine their source and in some cases checked to gain a high

degree of confidence for their correctness.

24

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' The licensee's team reviewed 80 " Industry Technical Information Program" review

packages that had been previously performed. Three industry technical information

program reviews were identified in which actions were not completed at the time of

closure and/or were not totally responsive to the identified issue. Two industry

technical information program reviews related to testing of controls at the auxiliary '

shutdown panel that did not associate the issues documented with a Technical

Specification noncompliance.

The licensee reviewed over 1400 auxiliary feedwater system statements associated

with the licensing basis. The major source was the updated safety analysis report,

but statements from the Technical Specifications, the safety evaluation report for

the original operating license, and docketed correspondence were also used. The

updated safety analysis report statements were compared with the final safety

analysis repcrt statements. The updated safety analysis report statements were

subsequently correicted to surveillance testing. This process validated the existing

system design against the enrrent updated safety analysis report and ensured that

the system could perform its design functions.

f

The licensee's team found good agreement betwee.n the updated safety analysis

report and the design basis. Corrections were generally editorial and typographical.

Two updated safety analysis report updates were scheduled to incorporate the

necessary corrections.

The licensee reviewed 262 functional requirements, and concluded that the testing

and surveillance programs effectively verified the safety functions required of the

auxiliary feedwater system.

i

Thirty-nine Technical Specification surveillance procedures were used to vai!date

many of the auxiliary feedwater functions, including Technical Specification j

requirements. Three of the surveillance procedures were found inadequate to

comply with their associated Technical Specification requirement. These l

deficiencies are discussed in Section E7.4 of this inspection report. However, in all l

<

three cases, subsequent testing confirmed that the systems or components would

have been able to perform their design function.

The licensee's team evaluated unreviewed safety question determinations / licensing l

screening reviews and determined that the conclusions were correct. l

The licensee's team reviewed and identified numerous minor typographical

discrepancies related to vendor manuals, design drawings, and data bases

associated with the change packages.

The licensee team randomly selected 52 implemented design change packages to

determine whether post-modification testing was specified or should have been

specified, whether the testing was adequate to return the plant equipment to

operational status, and whether the test was completed.

l

25

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.

The licensee's team reviewed 200 performance improvement requests associated

with the auxiliary feedwater system. The licensee's team found that approximately

10 percent were closed with some action outstanding or without . fully responding to

the performance improvement request issued. The problem was similar in nature to

the root-cause evaluation and corrective action weaknesses discussed in previous

sections of this inspection report.

The licensee's engineering department had a process for prioritizing and scheduling

work activities based on safety significance, plant availability, commitments and

regulatory requirements. This process was used to assign priorities for the

significant corrective action issues identified by the self assessment.

c. Conclusion

The NRC team concluded that the scope and depth of the licensee's assessment

was sufficient to determine the functionality of the auxiliary feedwater system.

'E7.4 Sionificant Licensee Assessment Team Conclusions

a. Insoection Scooe (375501

The NRC team reviewed the licensee's Self Assessment Report SEL 96-011,

" Auxiliary Feedwater System Functional Assessment." The NRC team discussed

the results of the assessment with the licensee managers, the team leader, and

team members. The NRC team summarized the licensee's conclusions.

b. Observations and Findinas

i The licensee team concluded that, although problems were identified in the

assessment that resulted in operability issues, which were reportable, no condition

'

was found that resulted in a plant shutdown or in situations where the auxiliary

? feedwater system, or its safety-related components, would not have performed

their intended function. Specifically, the assessment team noted the following

strengths:

• Good Calculations

Calculations generally used appropriate input data and supported the

functional requirements stated in the updated safety analysis report. l'he

subject matter and the purpose of calculations were normally wel! defined.

The methodologies used were based on sound engineering principles and

- were consistent with normally acceptable industry stadards.

Calculations were properly checked, approved, and revisions were

controlled. Calculations appropriately referenced computer programs that

were used and the programs had been verified and validated. Finally,

referenced calculations and documents were odequately identified and

crossed referenced in the body of the calculations.

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• Uodated Safety Analysis Report Anreement with Desian Basis

)

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in general, the design basis was found to closely match the updated safety l

analysis report. Equivalency evaluations resulted in the correct translation of

regulatory requirements and design bases into design output that  ;

appropriately defined the Wolf Creek Generating Station design.

• Work Product Aooraisal Tool l

l

Although recently implemented, the appraisals were judged to be an

effective tool for aligning the quality of engineering work products with

management expectations. The process was beginning to show

improvements in engineering output documents.

The licensee's self-assessment team noted the following weaknesses:

• Industry Technical information Proaram Reviews

Review and incorporation of lessons learned from industry experience

needed improvement. Three industry technical information review packages

were found that had been closed with recommended actions not completed

and/or not responsive to the issue.

• Effectiveness of Post-Modification Testina and Surveillance Proaram j

!

Although the assessment team determined that the program was generally

adequate, three surveillance test examples were noted that failed to

appropriately implement Technical Specification surveillance requirements.

The examples required operability evaluations and retest. Affected

equipment were subsequently found to have been capable of fulfilling

required safety functions,

in addition, three examples of lack of performance of necessary

post-modification tests for completed modifications were noted. Review of

current testing indicated that the affected components were capable of

performing their safety function.

• Unreviewed Safetv Question Determinations, Operations Information

Reoorts and Technical Specification Clarifications

Unreviewed safety question determinations, operations information reports,

and Technical Specification clarifications were found to be correct.

However, the assessment team found that Technical Specification

clarifications needed significant enhancement. The assessment team found

the justification for an example clarification to be weak and lacked sufficient

detail to adequately reconstruct the basis for the clarification.

27

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.

• Effectiveness of Previousiv Comoleted Corrective Actions

Weaknesses of the corrective action program, similar to those identified by

Quality Evaluation Audit Report K469, were identified. The wr &6sses

included identification of incomplete corrective actions for closed

performance improvement requests.

E7.5 Independent NRC inspection

a. Insoection Scone (37550)

The NRC team reviewed the licensee's assessment report, the associated

performance improvement requests, and the action requests to develop an

understanding of the basis for the assessment team's conclusions.

Tne NRC team reviewed selected design ci ange peckages and calculations. In

addition, selected system / components that were excluded from the self-assessment

scope, that affect the performance of the auxiliary feedwater system, were

reviewed. Finally, the NRC team walked down accessible portions of the auxiliary

feedwater system to confirm the as-built configuration,

i

b. Observations and Findinag

The NRC team generally agreed with the conclusions of the licensee's assessment i

team. The inspection activities, which resulted in a divergent or amplifying view,

are described below.

I

l

Adeouacy of Calcdation Inout Data

The NRC team reviewed five safety-related calculations and generally agreed with

the licensee's assessment of the quality and substance of calculations. However,

the NRC team noted a weakness regarding calculation input data. The team found j

that different sources were used for turbine-drivun auxiliary fendwater pump

characteristics used as input data in several calculations. The calculations obtained

the input data from two sources, a pump curve and a pump characteristics table.

However, the NRC team determined that, despite the use of different input data,

the calculations provided acceptable results and the design margins were not

reduced.

The team discussed the differences in calculation input data with the licensee. The

licensee acknowledged the team's concern and issued Performance improvement

Request 97-0465 to formally evaluate the noted conditions. The licensee

acknowledged the need to establish an accurate and urrent information data base

as part of their performance ~ improvement request corrective actions.

28

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P

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System / Components Excluded from the AFW System Functional Assessment

The NRC team noted that the following system / components, that provide critical

input or ;.iterface to the AFW system, were excluded from the assessment:

• Emergency Service Water System

• Station Service Battery / Safety related DC Systern

• Steam Generator Level and Lo-Lo Level Set Points

.

The NRC team discussed the completeness of the auxiliary feedwater system

assessment with the licensee. The licensee informed the team that the emergency  :

service water system functional assessment, currently scheduled for completion by

June 30,1997, would evaluate the safety function it serves for the auxiliary

feedwater system, including the ficw requirement for the auxiliary feedwater

system. The licensee informed the NRC team that analysis of the batteries was

performed in 1992 es part of an electrical distributic.1 system functional

assessment. In addition, the licensee indicated thr c a similar analysis of the

batteries was also performed in 1995 when AT&T round cell batteries were

installed. The licensee informed the NRC team thr,t the steam generator level and

lo-lo level auxiliary feedwater pump initiation sigr.als would be reviewed as part of

the assessment of the solid state protection system logic. That assessment will be  !

performed s committed to by the licensee in their response to NRC Generic

Letter 96-01, " Testing of Safety-related Logic Circuits," which they provided in

Letter WO 96-0068, dated April 18,1996.

The NRC team reviewed electrical system distribution design drawings. The

NRC team found that 125 volt vattery banks NK11, NK12, NK13, and NK14, and  ;

battery chargers NK21, NK22, NK23 and NK24, provided 6dequate dc power to {

solenoid-operated valves that allow operation of auxiliary feedwater system air j

operated valves. The NRC team confirmed that adequate dc power was supp!ied

for the performance of the auxiliary feedwater system safety function.

i

The NRC team reviewed the licensee's auxiliary feedwater pump initiation setpoints

l

based on steam generator level. The NRC team reviewed Calculation SA-92-109,

"Stearn Generator Level Setpoint Analysis ITIP 02006," Revision O. The NRC team

determined that the auxiliary feedwater pump initiation setpoints were appropriate.

The NRC team reviewed the steam generator level trip setooint surveil lance test

Procedure STS IC-203, " Analog Channel Operational Test 7300 Process

Instrumentation Protection Set 111 (Blue)," Revision 17, to determine if auxiliary ,

feedwater pump initiation signals based on steam generator level setpoints were i

being tested appropriately. The NnJ team reviewed the results of the surveillance

tests that were performed on October 11,1996, and January 16,1997. The NEC i

team determined that the test procedure and periodic licensee performance of the

procedure provided adequate assurance that the auxiliary feedwater pump initiation

signals based on steam generator level setpoints, would start the pumps as

designed.

29

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Effectiveness of Testino and Surveillance Proarams

The NRC team noted that the licensee's auxiliary feedwater system functional

assessment determir.ed that the testing ard surveillance programs effectively

verified the system's safety functions and was generally adequate. However, the

NRC team also noted that the licensee's assessment identified Technical

Specification discrepancies in the performance of surveillance tests. The NRC

inspection team reviewed one of the licensee-identified discrepancies in the

surveillance program and the licensee's associated corrective actions.

Technical Specification Surveillance Recuirement 4.3.3.5.2

On October 29,1996, the licen;ee's assessment team determined that Technical

Specification Surveillance Requirement 4.3.3.5.2 was not being fulfilled through

the performance of Surveillance Test Procedure STS RP-04, " Auxiliary Shutdown

Panel Control Switch Test," Revision 9. Technical Specification Surveillance

Requirement 4.3.3.5.2 required that auxiliary shutdown panel controls be

demonstrated operable at least once per 18 months by operating each actuated

component from the auxiliary shutdown panel. The licensee's surveillance

procedure did not positively assure that contacts of 86X relays actuated by the

auxiliary shutdown panel isolation switches actually changed state as required.

The licensee's team determined that startup testing partially verified the functions

of the relay but periodic surveillance testing of the relays had not been performed

since startup.

The licensee's self-asse sment team initiated Performance improvement

Request 96-2788 to document the problem. 'The licensee declared the 86X relays

inoperable and entcied the Technical Specification 3.3.3.5 action statement that

the inoperable controls be restored to operable within 7 days or be in at least hot

standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in hot shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

The licensee submitted to the NRC Licensee Event Report 96-017 to inform the

NRC of the condition and the licensee's corrective actions.

The licensee issued an on the spot change to Surveillance Procedure STS RP-004 to

perform a one-time baseline test to verify that all functions of the 86X relays were

in accordance with the design, and to fulfill the surveillance requirement that the l

contacts of the actuated 86X relays changed state. The licensee successfully

completed the test, determined that the relays were operable, and exited the

Technical Specification action statement, on November 4,1996. l

The NRC team reviewed the on the spot change version of Procedure STS RP-004,

Revision 10, and determined that the test was performed satofactorily. The

NRC team reviewed Surveillance Procedure STS RP-004, Revision 10, to ensure

that all functions of the 86X relays were tested. The NRC team determined

that revised Procedure STS RP-004 would test the 86X relays when the contacts

changed state.

30

b

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The NRC team determined that the licensee-identified violation of Technical

Specification Surveillance Requirement 4.3.3.5.2 couid not have been reasonably

prevented by licensee corrective actions for a previous violation or a previous

licensee finding that occurred within the past 2 years of this NRC inspection. The

NRC team further determined that the violation had been corrected and did not

appear to be willful in nature. This licensee identified and corrected violation is

being treated as a noncited violation, consistent with Section Vll.B.1 of the NRC

Enforcement Policy (50-482/9705-02).

c. Conclusion

The NRC team concluded that the licensee's assessment team identified examples

of weaknesses in the implementation of lessons-learned from industry experience,

in the implementation of testing and surveillance requirements, and in the

implementation of the licensee's corrective action program. A noncited violation

associated with a Technical Specification surveillance requirement was identified.

E8 Miscellaneous Engineering issues (40500)

E8.1 (Closed) EA 96-124, Violation I. A (01013): Failure to identify and correct

inadequate Essential Service Water (ESW) warming line flow.

The inability of the Essential Service Water warming line to prevent the

accumulation of frazilice became apparent on January 30,1996, when one train of

ESW became inoperable and the other train was degraded due to frazilice

accumulation at the ESW intake structure. The warming line flow inadequacy was

not previously identified and corrected although several opportunities for j

'

identification had been available and missed.

The licensee determined that the root-cause of this violation was licensee

management's failure to: (1) provide consistent and demonstrated expectations,

and (2) establish and implement effective personnel accountability tools and/or

procnsses. This failure resulted in multiple examples of inadequate engineering

rigor, !nadequate documentation of engineering work and judgment, and the lack of

a sufficient questioning attitude.

I

in Letter WM 96-0081, dated July 31,1996, the licensee committed to perform

several actions to correct these deficiencies. First was the development of an

enhanced personnel' evaluation process such that supervisors evaluate engineers

work against a specified set of performance elements. Additionally, the licensee

committed to improve their process for evaluating, targeting, prioritizing, j

scheduling, and tracking tasks assigned to the engineering staff. Both of these

items were to have been tested during the second half of 1996 and revised as

reviews warranted. The licensee reviewed all outstanding safety-related action l

requests greater than six-months old to identify whether any long term safety or 1

,

31

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operationally significant concerns were present, and committed to continue to

reevaluate all safety-related action requests greater than six-months old and to

report on those evaluations to the Plant Safety Review Committee. The licensee

also committed to perform extensive functional assessments of four safety-related

systems.

The _ inspector reviewed the implementation of the engineering work product

evaluation form and interviewed the Vice President Engineering, the Manager of

System Engineering, and the Supervisor for Electrical /l&C Design Engineering. The

document utilized for evaluating engineering work products was comprehensive and

encornpassed a number of attributes that were necessary for a high quality product.

Expectations for use of the evaluations regarding frequency of evaluations and

feedback to the individual engineers evaluated were determined by the Vice

President Engineering and understood by the other individuals interviewed by the

inspector. The inspector reviewed several completed evaluation forms and

concluded that constructive feedback had been conveyed back to the evaluated

engineer. The system engineering organization, although reporting to the plant

rnanager was included in the work product evaluation program and reported those

results through the Vice President Engineering.

The inspector reviewed the program developed and utilized for tracking and

scheduling engineering issues and work products. Included in the program were

priority, resource estimates (both human and financial), projected time estimates,

and milestones. Guidance for the program was documented in a white paper issued

in June 1996, and included all engineering organizations on site. The inspector

determined that the program was detailed and was capable of providing accurate

information regarding tracking and scheduling of engineering tasks as long as the

information provided to the system w.ss timely and properly updated.

The inspector also verified that the first review of the outstanding safety-related

action requests was conducted on May 7,1996. A requirement for system

engineering personnel to review outstanding safety-related action requests, and for

the PSRC to review this list of outstanding action requests (greater than 6-months

old), was incorporated into Administrative Procedure AP 22C-OO2, " Work

Scheduling During Power Operations," Revision 3.

The first of the four functional assessments was performed on the auxiliary

feedwater system and was completed in December 1996. This assessment was

revieweu by the inspectors and the results are discussed in Section E.7 of this

report. The schedule for completion of the remaining three assessments was

determined to be satisfactory for closure of this item.

The inspector concluded that the licensee had properly implemented the corrective

actions for the referenced violation.

32

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4

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E8.2 - (Closed) EA 96-124. Violation ll. A (04013): . Design errors in Essential Service  ;

Water (ESW) warming line calculations.

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Incorrect assumptions during construction regarding ESW warming fine temperature.

and flow rates failed to ensure that the ESW design bases was properly translated

into the ESW system design. These design deficiencies became apparent during

the frazilice event of January 30,1996.

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As immediate corrective actions during and following the event, the licensee t

- performed actions to remove and prevent ice buildup during that period of cold

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weather. Additionally, the licensee generated a " Contingency Plan for Ice  ;

Prevention Measures at the ESW Intake," which contained steps and measures to j

be taken to prevent future ice accumulation and subsequent challenging of the ESW

system capability. The inspector verified that these actions had been completed.

Longer-term corrective actions included: (1) ESW system design modifications to

ensure adequate warming line flow and temperature, (2) the installation of vent

lines on the ESW warming lines, (3) the installation of additional temperature

monitoring instrumentation at the ESW intake structure and incorporation of this

information into the plant design bases, and (4) the incorporatic.1 of the use of an. i

air bubbler and frazilice detection device into a stand alone pr.2edure. I

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The inspector verified that the design modification to ensure adequate ESW flow

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, and temperature in the warming flow lines had been completed. The inspector

. verified that post-modification testing had been completed and adequately

demonstrated the capability of the system to meet the modification objectives. The

l warming line vent lines were verified to be installed and, at the time of the

inspection, the warming line was in service and the vent was functioning properly.

The inspector also verified that the additional temperature indications were installed

,

and functioning. Additional indications were added for the lake side temperature of

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the ESW intake structure, the temperature inside the intake structure upstream of

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the trash racks, and the temperature of the suction and discharge of the ESW

pumps. Readouts for the instruments were recorded on the plant computer and

was monitored in the control room.

Calculations associated with this design modification had been previously reviewed ,

and documented in NRC Inspection Report 50-482/96-21. Procedure SYS EF-205,

"ESW/ Circ Water Cold Weather Operations," was generated to provide additional

guidance as to when to initiate the use of the warming line and enhance monitoring

for frazilice conditions. This procedure incorporated the use of the added

temperature indications, the use of an air bubbler in the intake structure, and the

, use of a chain suspended into the C.SW intake structure as a physical indicator of

the ontat of frazilice formation. ,

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Safety system functional assessments planned by the licensee for other systems

should deterrnine if similar errors in design assumptions exist elsewhere and I

whe't er additional corrective actions are warranted. The inspector concluded thnt

the ht.ensee had adequately completed their corrective actions associated with thi.

violation.

E8.3 (Closed) inspection Fo:lowuo item 50-482/96003-12: Engineering work product

weaknesses and plans for self assessments. l

The inspectors reviewed the causes and corrective actions for the engineering work l

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product weaknesses (discussed in Section E8.1 of this inspection report) as well as

the results of the first safety system functional self-assessment (Section E.7 of this

inspection report) and the proposed schedule for completion of the remaining s

assessment s The inspectors concluded that the issues had been adequately

addressed by the licensee.

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E8.4 (Closed) Unresolved item 482/9624-04: Cooling lake temperature monitor.

The licensee had installed this monitor as part of commitments made in response to

Enforcement Action EA 96-124 following the formation of frazilice in the essential

service water structure in January 1996. The inspector had questional the control

of design inputs when the essential service water warming knes vvw:;%d in

service and operators were not aware of the effect warming flow had on the

recently installed lake temperature monitor. A review of the design process

resulted in three remaining concerns: (1) the acceptability of using a nonsafety-

related temperature instrument to perform the safety-related function of indicating

when to initiate the warming line flow; (2) what was meant by the licensee's

commitment to include lake water temperature in the design basis; and (3) how the

licensee identified, approved, documented, and controlled design inputs.

In response to the inspector's questions, engineering personnel indicated they hsd

known of the effect warming flow would have on lake temperature indication and

had even discussed installing the monitor in the lake farther away from the essential

service water structure. However, engineering personnel had not communicated >

this information to operations personnel and, therefore, operators observed an

unexpected increase in indicated lake temperature when the warming lines were

first placed in service. The outstanding NRC concerns were addressed as follows:

• Administrative Procedure AP 05-007, " Determination of Safety

Classification," Revision 2, Step 6.2.4.2 provided instructions to determine a

component's function within a system and to evaluate that function against

Attachment C of the procedure. Attachment C, Step C.15 provided

guidance regarding process instrumentation connected to safety-related

systems and gave an exception for when this instrumentation could be

considered nonsafety-related. If the process instrurnentation was not

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required to accomplish a safety-related function it could be considered- j

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nonsafety-related. The licensee determined that the lake temperature

i monitor provided an enhancement to the lake monitoring capabilities and, -j

thus, met this exception. Therefore, the instrument was not designated as  !

safety-related. ,

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• The licensee indicated that their intent to include lake temperature, ESW  !

pump suction temperature, and warming line temperature indications into the  :

design basis meant to include it in the documents that describe the physical ,

design of the plant which included drawings, specifications, and procedures.

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The inspector verified that this had been completed. l

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• Administrative Procedure AP 05-005, " Design, implementation and

l Configuration Control of Modifications,". Revision 2, provided instructions for i

}

implementation of modifications to controlled and noncontrolled structures,

l systems, and components. Section 6.2.b described the handling of design

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inputs, including design basis and regulatory requirements, and provided  ;

instructions for coordinating changes with other affected groups, including  !

operations. However, Section 6.2.4.3, provided that non-safety-related i

design change packages did not require design inputs and independent j

verification. Procedure AP 05A-001, " Design inputs," Revision 0, provided  !

"

instructions for how design inputs were identified, documented, reviewed,

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approved, and controlled. This procedure did not apply to nonsafety-related

structures, systems, componerits, and subcomponents. The licensee

determined that, even though the design change package that installed the

lake temperature monitor was safety-related, the actual temperature

instruments themselves were nonsafety-related, and therefore, the design

. input requirements of Procedure AP 05-005 were not applicable.

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T'.1e inspector determined the licensee followed the appropriate procedures when  !

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classifying the lake temperature monitor as nonsafety-related and, therefore, was

correct in not applying design input requirements. However, the unexpected *

temperature increase observed by operators which resulted when the essential

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service water warming lines were placed in service indicated a weakness in the

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, communication of expected system performance characteristics to the Operations

Department by Engineering parsonnel.

E8.5 (Closed) Licensee Event Report 96-017-00: Failure to comply with Technical

Specification Surveillance Requirement 4.3.3.5.2.

On October 29,1996, the licensee determined that Technical Specification

Surveillance Requirement 4.3.3.5.2 was not being adequately accomplished

through the applicable surveillance precedure. The surveillance procedure did not

positively assure that contacts of 86X relays actuated by the auxiliary shutdown

panel isolation switches actually changed state as required.

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The NRC team review of this licensee event report, and licensee corrective actions,

are discussed in Section E7.5 of this inspection report.

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V. MANAGEMENT MEETING

3

X1 Exit Meeting Summary

The team presented the inspection results to members of licensee management at

the conclusion of the inspection on February 14,1997. The licensee acknowledged

the findings presented.

The team asked the licensee whether any materials examined during the inspection

were proprietary. No proprietary information was identified.

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ATTACHMENT

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SUPPLEMENTAL INFORMATION

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PARTIAL LIST OF PERSONS CONTACTED .

Licensee

M. Blow, Superintendent, Chemistry ,

T. Damashek, Supervisor, Licensing  ;

D. Dullum, Supervisor, Plant Trending and Evaluation l

R. Flannigan, Manager,- Nuclear Safety and Licensing  !

C. Fowler, Manager, Integrated Plant Scheduling 1

M. Gayoso, Comptroller

N. Hoadley, Manager, Support Engineering  ;

R. Holloway, Project Engineer, Design Engineering j

T. Hood, Supervisor Engineer, Electrical, instrumentation and Control 1

R. Hubbard, Superintendent, Operations j

J. Johnson, Superintendent, Security .

L. Jones, Superintendent, Maintenance Support

S. Koenig, Supervisor, Quality Evaluations l

G. Lawson, Superintendent,; Maintenance and Planning ,

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~ P.' Lof tus, Manager, Industry and Regulatory Reengineenng  ;

J.' Lyle,' System Engineer . j

G. McClelland, Quality Specialist i

B. McKinney, Plant Manager j

R. Miller, Superintendent, Mechanical Maintenance

D. Moore, Manager, Maintenance  !

R. Muench, Vice President, Engineering

~ W. Norton, Manager, Performance improvement and Assessment

C. Redding, Engineering Specialist, Licensing

K. Scherich, Supervisor, NSSS System

R. Sims, Manager, Systems Engineering

L. Stevens, Supervisor, Nuclear Safety Engineering

C. Warren, Vice President, Chief Operating Officer

C. Younie, Manager, Operations

J. Yunk, Engineering Specialist, Licensing

J. Zell, Project Engineer

NRC

! F. Ringwald, Senior Resident inspector

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LIST OF INSPECTION PROCEDURES USED

IP 40500: Effectiveness of Licensee Controls in identifying, Resolving, and Preventing

Problems.

IP 37500: Enginuering

LIST OF ITEMS OPENED _ CLOSED, AND DISCUSSED

Opened

50-482/9705-01 VIO Failure to correct component cooling water radiation

monitor low flow

50-482/9705-02 NCV Failure to test auxiliary shutdown panel relays

in accordance with Technical Specification

Surveillance 4.3.3.5.2

Closed

EA 96-124, Failure to identify and correct inadequate essential service

Violation I.A water warming line flow

(01013):

EA 96124, inadequate turbine-driven auxiliary feedwater pump packing

Violation I.C instructions

example 1

(03013):

EA 96124, Failure to identify and correct deficient conditions on the

Violation I.C turbine-driven auxiliary feedwater pump

example 2

(03023):

EA 96124, Design errors in ESW warming line ca'culations

Violation li.A

(04013):

EA 96-124, Failure to take appropriate corrective action on the turbine-

Violation ll.D driven auxiliary feedwater pump

(07014):

EA 96124, Failure to follow turbine-driven auxiliary feedwater pump

Violation ll.E work instructions

(08014):

50-482/9603-12 IFl Engineering work prodm weaknesses and raans for self

assessments

50-482/9624-04 URI Cooling lake temperature monitor

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50-482/96-17-00 LER Failure to Comply with Technical Specification Surveillance  !

- Requirement 4.3.3.5.2 j

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50-482/9705 02 NCV Failure to test auxiliary shutdown panel relays in  !

accordanc'e with Technical Specification i

Surveillance 4.3.3 5.2  ;

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DOCUMENTS REVIEWED

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Procedures  ;

AP 05-001, " Change Package Planning and Implementation," Revision 2 i

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AP 05-005, " Design, implementation and Configuration Control of Modifications,"  !

Revision 2 l

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AP 05-007, " Determination of Safety Classification," Revision 2  !

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AP 05A-001, " Design inputs," Revision 0

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AP 16E-002, " Post Modification Testing," Revision 0 l

AP 20E-001, " Industry Technical information Program," Revision 3

' AP 22C-002, " Work Scheduling During Power Operations," Revision 3

AP 26C-004, " Technical Specification Operability," Revision 0  :

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AP 28-001, " Evaluation of Nonconforming Conditions of Installed Plant Equipment,"

Revision 4 ,

AP 28A-001," Performance improvement Request," Revision 6

STN EF-020A, "ESW Train A Warming Line Verification," Revision O

STN EF-0208, "ESW Train B Warming Line Verification," Revision 0

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STN GP-001, " Plant Winterization," Revision 23

STS RP-004, " Auxiliary Shutdown Panel Control Switch Test," Revision 10

STS AL-102, "MDAFW Pump B Inservice Pump Test," Revision 20  !

STS AL-104, "TDAFWP ESF Response Time Test," Revision 5

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STS AL-201B, " Auxiliary Feedwater System Train B inservice Valve Test"

STS AL-210, " Auxiliary Feedwater System Inservice Check Valve Test," Revision 13

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STS IC-203, " Analog Channel Operational Test 7300 Process Instrumentation Protection

Set til (Blue)," Revision 17

STS IC-244, " Analog Channel Operational Test Nuclear Instrumentation System Power

Range N44 Protection Set IV," Revision 8

SYS AL-123, "TDAFW Pump Post Maintenance Run," Revision 3

SYS EF-205, "ESW/ Circ Water Cold Weather Operation," Revision 3

Contingency Plan for Ice Prevention Measures at the ESW Intake

Self Assessments

SEL 95-0049, " Performance improvement Request Program," dated November 30,1995.

SEL 96-010, " Quality of Work Packages"

SEL 96-011, " Auxiliary Feedwater System Functional Assessment," dated December 31,

1996

SEL 96-027, " Operating Experience Feedback Program"

SEL 96-046, " Effectiveness of improved System Engineering / Maintenance involvement"

SEL 96-049, " Semi-Monthly Work Monitoring"

Quality Evaluations audit K-461, " Corrective Action," dated July 30,1996

Quality Evaluations audit K-469, " Corrective Action," dated December 26,1996 )

Incident investigation Team Report 96-001, "TDAFW Pump Trip Throttle Valve (FC-HV-

0312) Retest Failure & TDAFW Pump inboard Packing Failure"

Performance Imorovement Recuegg

95-2761  ;

96-0217

96-0269

96-1044

96-1129

96-1447

96-1735

96-1963  !

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96-2409 -;

96-2413 i

-96-2819 [ j

96-3063

96-3281'  ;

Preventive Maintenance Tasks

Preventive Maintenance Task 35281, "PALO1 A Obtain Shaft Sleeve Nut Measurements" -

Preventive Maintenance Task 35282, "PALO1B Obtain Shaft Sleeve Nut Measurements" -l

Preventive Maintenance Task 25810. "PALO2 Obtain Shaft Sleeve Nut Measurements"- 'i

Work Package 111744 .

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Work Package 111655

Work Package 111396.

Work Package 112004

Work Package 112153

- Work Package 113222 ,

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Evaluations of Nonconformino Conditions on installed Plant Eauipment, AP 28-001

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AP 28-001 for PIR 97-0140, "ASME Pressure Testing of EFEFOST Piping"

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AP 28-001 for PIR 97-0044, " Component Cooling Water Pumps C and D Not Tested Per .

TS 4.7.3.b.2"

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AP 28-001 for PIR 96-1594, "Possible insufficient Torque Values for MOV Actuator" l

AP 28-001 for Work Package 114038, "ESW Pumphouse Ventilation Damper Failure"

AP 28-001 for Work Package 113331, "Nonsafety-Related Packing installed in MDAFW

Pump "

AP 28-001 for Work Package 117488, " Cable Tray Hardware Missing" '

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AP 28-001 for Work Package 113723, "Trico Oiler Level Low on Component Cooling -

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Water Pump"

l. AP 28-001 for Action Request 18099, " Containment Cooler Tube Leak"

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AP 28-001 for Action Request 16560, "ESW Leak on EDG Intercooler Heat Exchanger

Drain Line"  ;

AP 28 001 for Action Request 16548, " Cooling Coil Struck ALV0031's Handwheel"

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Enaineerina Calculations i

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AL-07-W, " Auxiliary Feedwater Pumps," Revision W-0 f

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AL-16-W, " Determine the Available NPSH for the Auxiliary Feedwater Pumps," l1

' Revision W-0

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M AL-30 WC, "AFW System Setpoints: Pump Suction Pressure, Automatic ESW 'l

Swit'chover, and CST Low Level," Revisicn W-2 l

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M AL-31, "AFWP Turbine Exhaust Evaluation," Revision 1 i

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AN-95-034, TDAFP Stearn Flow Requirements," Revision O l

M-EG-13, " Component Cooling Water Radiation Monitor Flow Orifices"

. M EG-11-W, " Component Cool:ng Water Heat Exchanger and Bypass Pressure Drop"

SA-92-109, " Steam Generator Level Setpoint Analysis ITIP O2006," Revision 0

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Desian Chanae Packaaeg l

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Configuration Change Package 06546 l

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Configuration Change Package 06512  !

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Design Document Change Notice M-021-00061 W13-10

Design Change Package 06349, increase ESW Warming Line Flow l

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Design Change Package 06355, Deletion of One ESW Warming Line Valve  !

Design Change Package 06447, ESW Temperature Instrumentation

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Design Change Package 05849, "KFCO2 Exhaust Line Upgrade," Revision 0

Design Change Package 06279, " Trip and Throttle Stroke Time Increase," Revision O  ;

Design Change Package 07039, "TDAFWP R 1 Resistor Upgrade," Revision O I

Design Change Package 07171, " Aux Feedwater Pump / Turbine Water in Lube Oil

~ Corrective Actions," Revisions 1 and 6

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E-11010, "DC Main Single Line Diagram," Revision 2

E 13AB01(Q), Schematic Diagram, " Main Steam Supply Valve to Turbine Driven Aux

Feedwater Pump," Revision 1

E-13AB01 A(O), Schematic Diagram, " Main Steam Supply Valve to Turbine Driven Aux r

Feedwater Pump," Revision O

E-13ALOSA(Q), Schematic Diagram, " Aux Feedwater Pumps, Discharge Control-Air

Operated Valves," Revision O

E-13ALO5B(O), Schematic Diagram, " Aux Feedwater Pumps, Discharge Control-Air

Operated Valves," Revision O

E-13NN01(Q), " Class 1E Instrument AC Schematic," Revision 0

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E-13RLO3(O), Schematic Diagram, " Main Control Board Sections RLOO3/RLOO4 &

RLOOS/RLOO6125VDC and 120VAC Distribution," Revision 1

M-12AB02, " Piping & Instrumentation Diagram Main Steam System," Revision 6

M-12ALO1, " Piping & Instrumentation Diagram Auxiliary Feedwater System," Revision 6

8756D37 sheet 19, "SNUPPS Process Control Block Diagram," Revision O

Miscellaneoua

WCNOC letter WO 96-0118 dated August 22,1996

WCNOC Letter WM 96-0081, dated July 31,1996

Letter MD 96-0012

Completed Engineering Work Product Evaluation Forms (six completed)

Vendor Manual M-021-00061, " Instruction Manual for Auxiliary Feedwater Pumps"

Operations Information Report 96 EF-001

Engineering Tracking and Scheduling Business Rules (White Paper June 1996)

Industry Technical Information Program reviews 3231 and 3312

USAR Change Request 97-007

Nuclear Safety Committee meeting 96-02 minutes, September 25,1996

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Corrective Action Review Board meeting minutes for the neriod November 11,1996 to

January 31,1996

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Information Notice 96 01, " Potential for High Post Accident Closed Cycle Cooling Water

Temperature to Disable Equipment important to Safety";

Information Notice 96-05, " Partial Loss of Shutdown Cooling Flow From the Reactor

Vessel"

Bulletin 96-02, " Movement of Heavy Loads Over Spent Fuel, Over Fuel in the Reactor

Core, or Over Safety-Related Equipment"

INPO Significant Operating Experience Report SOER 96-1, " Control Room Supervision,

Operational Decision-Making, and Teamwork"

INPO Significant Operating Experience Report SOER 96-02, " Design and Operating

Considerations for Reactor Cores"

Operating Plant Experience OE 7624, " River Water Expansion Joint Failure"

Operating Plant Experience OE 7625, " Remote Shutdown Panel Found Degraded Due to

inadequate Testing and Design"

Operating Plant Experience OE 7693, "Isophase Bus insulatir g Boot trouble"

Mechanical Maintenance Training Plan MM 13 20100, " Centrifugal Pump Packing" )

Westinghouse Letter SAP-92-186 dated June 18,1992, " Steam Generator Level Process

Measurement Accuracy (PMA) Term inaccuracies" ,

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