ML20147C971

Insp Rept 50-482/87-33 on 871119-880103.Violations Noted. Major Areas Inspected:Plant Startup from Refueling, Operational Safety Verification,Monthly Maint Observation, Monthly Surveillance Observation & Cathodic Protection Sys

ML20147C971
Person / Time
Site:	Wolf Creek
Issue date:	02/23/1988
From:	Bruce Bartlett, Cummins J, Harrell P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20147C930	List: IR 05000482/1987033 ML20147C925 ML20147C953 ML20147C971
References
50-482-87-33, NUDOCS 8803030205
Download: ML20147C971 (12)

See also: IR 05000482/1987033

Text

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APPENDIX B

U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-482/87-33 License: NPF-42

Docket: 50-482

Licensee: Wolf Creek Nuclear Operating Corporation (WCNOC)

P. O. Box 411

Burlington, Kansas 66839

Facility Name: Wolf Creek Generating Station (WCGS)

Inspection At: Wolf Creek Site, Coffey County, Burlington, Kansas

Inspection Conducted: November 19, 1987 to January 3, 1988

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Inspectors: i

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E. Cumdi % 8qn,iop Resident Inspecto D(te [

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B. L. Bartlett, Resident' Reactor Inspector, /Datfe

Operations

Approved: sJ _

P. an 211, Acting Chief, Reactor Projects Section A D' ate

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Inspection Summary

Inspection Conducted November 19, 1987, through January 3, 1988

.(Report 50-482/87-33)

Areas Inspected: Routine, unannounced inspection including plant ste tup from

refueling, operational safety verification, monthly maintenance observation,

monthly surveillance observation, onsite event followup, physical security

verification, radiological protection, cold weather preparation, and cathodic

protection system.

Results: Within the nine areas inspected, one violation was identified

(failure to report as required by 10 CFR 50.72, paragraph 7).

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._.' DETAILS

l'. Persons Contacted

-Principal Licensee Personnel

• B. D. Withers, President and CEO

. *R. M. Grant, Vice President, Quality

• J. A. Bailey, Vice President, Engineering & Technical Services

• F. T. Rhodes, Vice Presiden_t, Operations

• G. D. Boyer,. Plant Manager

• 0; L. Maynard, Manager, Licensing

C. M. Estes, Superir.tendent of Operations

M. D. Rich, Superintendent of Maintenance

• M. G. Williams, Superintendent of Regulatory, Quality, and

Administrative Services

- W.'J.'Rudolph,-QA Manager-WCGS

A. A. Freitag, Manager,. Nuclear Plant Engineering (NPE), WCGS

M; Nichols, Plant Support. Superintendent

K. Peterson, Licensing

• G. Pendergrass, Licensing

• W. M. Lindsay, Supervisor, Quality Systems

• C. J. Hoch, QA Technologist

• C. E. Parry, Superintendent of Quality Engineering

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• J. M. Pippin, Manager, NPE

The NRC inspectors also contacted other members of the licensee's staff

during the inspection period to discuss identified issues.

• Donotes those personnel in attendance at the exit meeting held on

-January-8, 1988.

2. Plant Startup From Refueling

The NRC inspectors observed selected portions of the plant startup,

following the first refueling outage. Portions-of the activities

discussed below were observed.

o Mode changes performed in accordance with Technical' Specification

requirements and the procedures listed below:

. GEN 00-001, Revision 7, "Mode 5, Fill and Vent of the RCS"

. GEN 00-002, Revision 12, "Cold Shutdown to Hot Standby"

o Portions of three core physics tests listed below were witnessed to

verify that they were performed in accordance with technically

adequate and approved procedures and requirements of Technical

Specifications:

a. Determination of reactor shutdown margin

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Moderator temperature coefficient determination I

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c. Control rod worth measurements-

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For a list of the procedures reviewed see paragraph 6, Monthly

Surveillance Observation.

o The NRC inspectors performed post maintenance walkdowns of the safety

injection system (EM) and main feedwater (AE).

The NRC inspectors review of core power physics test data will bc

documented in a' future inspection report.

No violations or deviations were identified.

4. Operational Safety Verification

The NRC inspectors verified that the facility is being operated safely and

in conformance with regulatory requirements by direct observation of

licensee facilities, tours of the facility, interviews and discussions

with licensee personnel, independent verification of safety system status

and limiting conditions for operations, and reviewing facility records.

The NRC inspectors, by observation of randomly selected activities and

interview of personnel, verified that physical security, radiation

protection, and fire protection activities were controlled.

By observing accessible components for correct valve position and

electrical. breaker position, and by observing control room indication, the

NRC inspectors confirmed the operability of_ selected portions of

safety related systems. The NRC inspectors also visually inspected safety

components for leakage, physical damage, and other impairments that could

prevent them from performing their designed functions.

No violations or deviations were identified.

5. Monthly Maintenance Observation

The NRC inspector observed maintenance activities performed on

safety-related systems and components to verify that these activities were

conducted in accordance with approved procedures, Technical

Specifications (TS), and applicable industry codes and standards. The

following elements were considered by the NRC inspector during the

observation and/or review of the maintenance activities:

o Limiting conditions for operation (LCO) were met and, where

applicable, redundant components were operable.

o Activities complied with adequate administrative controls,

o Where required, adequate, approved, and up-to-date procedures were

used.

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o Craftsmen were cualified to accomplish the designated task and

technical expertise (i.e., engineering, health physics, operations)

was.made available when appropriate.

o Replacement parts and materials being used were properly certified.

o Required radiological controls were implemented.

o Fire prevention controls were implemented where appropriate.

o Required alignments and surveillances to verify postmaintenance

operability were performed.

o Quality control hold points and/or checklists were used when

appropriate and quality control personnel observed designated work

activities.

Selected portions of the maintenance activities accomplished on the work

requests (WR) listed below were observed and related documentation

reviewed by the NRC inspector:

& Activity

WR 05117-87 Core Subcooling T/C-inspect / repair Ray-Chem splice

WR 04851-87 EBB 01A and B Steam generator possible feedring erosion

caused by J-Tubes

WR 05551-87 KKJ01B Diesel generator-replace item 15 on attached

drawing

WR 05685-87 TKJ04A "A" diesel generator lube oil tank, add oil

No violations or deviations were identified.

6. Monthly Surveillance Observation

The NRC inspectors observed selected portions of the performance of

surveillance testing and/or reviewed completed surveillance test

procedures to verify that surveillance activities were performed in

accordance with TS requirements and administrative procedures. The NRC

inspectors considered the following elemerits while inspecting surveillance

activities:

o Testing was being accomplished by qualified personnel in accordance

with an approved procedure.

o The surveillance procedure conformed to TS requirements.

o Required test instrumentation was calibrated.

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o TS LC0 were satisfied.

o Test data was accurate and complete. Where appropriate, the NRC

inspectors performed independent calculations of selected test data

to verify their accuracy.

o The performance of the surveillance procedure conformed to applicable

administrative procedures.

o The surveillance was performed within the required frequency and the

test results met the required limits.

Surveillances witnessed and/or reviewed by the NRC inspectors are listed

below:

STS IC-502A, Revision 2, "Calibration of Pressurizer Pressure

Transmitters," performed on November 28, 1987

STS RE-004, Revision 7, "Shutdown Margin Determination." performed

December 22 and 31, 1987

STS KJ-001B, Revision 5, "Integrated D/G and Safeguards Actuation

Test-Train B," performed on December 22, 1987

STS BB-004, Revision 5, "RCS Water Inventory Balance," performed on

December 23, 1987

STS CR-002, Revision 7, "Shift Logs For Modes 4, S, and 6," performed

on December 22, 1987

STS EG-201, Revision 6, "Component Cooling Water System Inservice

Valve Test," performed on December 18, 1987

STS RE-002, Revision 5, "Determination of Estimated Critical

Position," performed on December 31, 1987

RXE 01-002, Revision 0, "Reload Low Power Physics Testing," performed

December 31, 1987, and January 1-4, 1988

No violations or deviations were identified.

7. Onsite Event Followup

The NRC inspectors performed onsite followup of nonemergency events that

occurred during this report period. The NRC inspectors reviewed control

room logs and discussed these events with cognizant personnel. The NRC

inspectors verified the licensee had responded to the events in accordance

with procedures and had notified the NRC and other agencies as required in

a timely fashion. The NRC inspectors will review the LERs for these

events and will report any findings in a subsequent NRC inspection report.

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Selected NRC inspector observations are. discussed below:

a. Lost Test Source

On December 18, 1987, the licensee notified the NRC that a

radioactive test source could not be located. The licensee

determined that the source was missing on December 15, 1987, during a

TS required inventory of radioactiva sources. The 400 microcurie ,

Strontium 90 and Yttrium 90 pure beta emitter source was

cylindrically shaped and was 1/2- by 1/4-inch. The source was used

for performing calibration checks of radiation monitoring

instruments. Licensee records show that the source was last

accounted for on August 1,1987.

In

The source

October was

1987, onemounted

of the testinassemblies

a test assembly (made of plexiglass.HPH-182) was

the reactor building when a corner of the plexiglass housing was

broken off. Test Assembly HPH-182 was taken-to the calibration

laboratory to be exchanged with an identical test assembly, HPH-184.

At that time the technician observed that the test source was missing

from assembly HPH-184. The technician then removed the test source

from the HPH-182 assembly and installed it in the HPH-184 assembly.

The technician failed to. notify anyone that the test source was

missing.

The licensee made a search of the areas the source could have been

used in, stored in, or transported through. The licensee's

investigation of this matter is continuing,

b. Diesel Generator Governor Settings

On December 9,1987, at 8:20 a.m. (CST), the licensee declared the

"A" emergency diesel generator (D/G) inoperable. This was because an

operator had discovered that the mechanical governor settings were

different from where they had been left. A D/G vendor representative

onsite informed the licensee of the possibility of tampering. At

this time the reactor was in cold shutdown with "A" train residual

heat removal (RHR) in operation and "B" train RHR out-of-service for

maintenance. The licensee notified NRC, state and county officials,

-and the FBI. The licensee initiated their own investigation. The

D/G was declared operable at 12:22 p.m. (CST) on December 9,1987,

af ter the governor was reset. On December 11, 1987, during a test

run the "A" D/G mechanical governor controls were observed to move.

Investigation by the licensee, in consultation with the governor

vendor, revealed a previously undetected failure in the governor.

After consulting the governor vendor, the licensee suspended the

tampering investigation.

The licensee informed NRC that the governor settings were changed due

to the failure of the governor and not due to tampering,

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On December 9, 1987, at'3:32 p.m. (CST), the licensee made a report

to NRC as required by 10 CFR 50.72(b)(2)(vi). Review of this event

by NRC has determined'that this event should have been reported as

required by 10-CFR 50.72(b)(2)(i) within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

10 CFR 50.72(b)(2)(i) required the reporting of "Any event, found

while the reactor.is shut down, that, had it been found while the

reactor was in operation, would have resulted in the nuclear power

plant, including-its principal safety barriers, being seriously

degraded . . . ."

As stated above D/G "A" was declared inoperable at 8:20 a.m. (CST),

thus the requirements of 10 CFR 50.72(b)(2)(i) should have been

completed no later than 12:20 p.m. (CST).

This failure to comply with 10 CFR 50.72(b)(2)(i) is an apparent

violation (482/8733-01).

c. Spent Fuel Pool Pumpdown

On December 22, 1987, the licensee accidentally reduced the water

level in the spent fuel pool (SFP). Listed below is a sequence of

events:

o On December 17, 1987, the SFP cleanup system was secured from

cleaning the refueling water storage tank (RWST). The valve

lineup was left in the RWST cleanup mode,

o After the performance of STS KJ-001B on December 22, 1987, the

SFP cleanup suction valves (BN HCV-8800 A and B) were left

closed.

o At 11:40 a.m. (CST) on December 22, 1987, SFP cleanup was

, established per Procedure SYS EC-120, "Fuel Pool Cooling and

Cleanup System Startup." This procedure, however, does not

verify the position of the '/alves to the RWST.

o At 12:29 p.m. (CST) on December 22, 1987, SFP cooling pump "A"

tripped,

o At 12:34 p.m., SFP cooling pump "A" was restarted,

o At 12:37 p.m., SFP cooling pump "A" tripped again.

o At 12:54 p.m., SFP cooling pump "B" was started and an operator

was sent to investigate why "A" tripped.

o At 1:10 p.m. , the operator informed the control room of low SFP

level and went to close Valve V-002.

o At 1:31 p.m. , SFP cooling pump "B" was secured.

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o At 2:17 p.m., commenced filling SFP from RWST.

o .At 3:21 p.m., secured filling SFP.

The'cause of the pump down was that Valve BN V-002 was left open.

BN V-002 is the manual isolation valve from the SFP cleanup system to

the RWST. Major contributors to the pumpdown was that the SFP level

indicators and low-level a'nnunciator located in the control room have

been inoperable since December 31, 1986. When SFP cooling pump "A"

tripped, it was caused by its low water level protective circuitry.

However, with their level indication inoperative, the control room

operators had no immediate means to determine this. The licensee's

investigation has shown that the SFP level was below the TS limit of

at least 23 feet above the fuel for approximately 90 minutes. The

action statement states the level should be returned within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

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'The lowest SFP level was approximately one foot below the 23-foot

minimum. Passive design features would have prevented the pumpdown

of the SFP below 22 feet above the' fuel even if the operators had not

secured SFP cooling pump "B" and if it had failed to automatically

trip on low-level. After the level was returned to normal, the pumps

low-level trip setpoint was verified to be accurate. The

investigation irito why SFP cooling pump "A" tripped early is still

ongoing.

The licensee's procedure for startup of the SFP is being changed to

verify the positions of appropriate valves prior to starting SFP

cooling pumps.

d. Reactor Vessel 0-Ring Leakage

On December 30, 1987, at 2:00 a.m. (CST), during a routine phone call

to the shift supervisor, the NRC resident inspector was informed of a

leaking o-ring. At 8:12 p.m. (CST), on December 26, 1987, the

temperature indicator in the vessel o-ring indicated high. The valve

to the inner o-ring was closed isolating the leakage. The valve to

the outer o-ring was then opened placing its leakoff line inservice.

The licensee has committed to the NRC that if the outer o-ring

develops a leak that WCNOC will immediately initiate an orderly

shutdown and cooldown to prepare for replacing both seai ,ings. This

commitment was documented in Licensee Letter ET 88-0006, dated

January 6,1988, from John Bailey to NRC.

No violations or deviations were identified.

8. Physical Security Verification

The NRC inspectors verified that the facility physical security plan (PSP)

is being complied with by direct observation of licensee facilities and

security personnel.

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Th'e NRC inspectors observed randomly selected activities.to verify that

, search equipment _is operable, that the protected area barriers and vital

area barriers are well maintained,'that access control procedures are

followed and that appropriate compensatory measures are followed if

required.

No violations or deviations'were identified.

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9 .' Radiological Protection

By performing the following activities, the NRC inspectors verified that

radiologically related activities were controlled in accordance with the

licensee's procedures and regulatory requirements: ,

o Reviewed documents.such as active radiation work permits and the

health physics shift turnover log.

o Observed personnel activities in the ' radiologically controlled

area (RCA) such as:

. Use of the required dosimetry equipment

. "Frisking out" of the RCA

. Wearing of appropriate anti-contamination clothing where

required

o Inspected postings of radiation and contaminated areas.

o Discussed activities with radiation workers and health physics

supervisors.-

No violations or deviations were identified.

10. Cold Weather Preparation

The NRC inspectors verified by discussions with licensee personnel and

i review of licensee Procedure STN GP-001, Revision 2, "Plant Winterization"

(performed on November 9-10, 1987) that the licensee had taken action to

protect vital areas and equipment that could be subjected to freezing

conditions. The procedure documented that heating systems and heat

tracing were available and energized where appropriate to the areas and

equipment. The NRC inspector walked down the areas adjacent to the

refueling water storage tank, condensate tank, the reactor make-up water

storage tanks, and verified that heating and instrument lines were

insulated where they could be subjected to freezing conditions. Where

appropriate heat was being supplied to the area.

No violations or deviations were identified.

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11. Cathodic Protection System

The NRC inspectors reviewed licensee activities related to problems with

the cathodic protection system. From discussions with licensee personnel,

review of documents and observation of components in the field; the NRC

inspectors determined that there had been a problem with maintaining

certain areas of the cathodic protection system in a fully operational

status. This resulted in galvanic corrosion to a number of underground

pipes. The following are two examples where the cathodic protection

system not being fully operational could have been a contributing factor

to failure of the pipes:

o In September 1986, a 1!s-inch auxiliary boiler fuel oil line developed

thru wall leaks apparently due to galvanic corrosion. Plant

Modification Request 02141 documented repair of this line.

o In June 1987, an 8-inch fire protection line developed a thru wall

leak, apparently due to galvanic corrosion. Repair / replacement of

this line was documented on Work Request (WR) 1164-87.

In September 1986, Nuclear Plant Engineering and the Maintenance

Department initiated actions to correct problems with the existing

cathodic protection system. These actions included the following:

o Selected areas were excavated so that pipes could be inspected.

o Repairs were made to cathodic protection power supplies, header

cables, and anode beds,

o Damaged pipes were repaired / replaced,

o A program to help insure the cathodic protection voltage levels were

maintained at the level (0.85 volts) recommended to prevent galvanic

corrosion was implemented.

On October 8, 1987, Nuclear Plant Engineering issued engineering study

"Engineering Piping at Wolf Creek Generating Station," Revision 0. This

study determined, based on pipe corrosion data obtained from six

excavations, that carbon steel when imbedded adjacent to piping of a

different metal (i.e., ductile iron) appeared to be most susceptible to an

accelerated galvanic corrosion rate. This problem apparently was also

intensified when the cathodic protection system for the area in which the

pipe was located had not been maintained at the recommended level. The

study also delineated further excavations to bS performed during the fall

1987 refueling outage. The purpose of these additional excavations was to

inspect pipes in areas where conditions for accelerated corrosion rates

existed. Another purpose was to confirm that conclusions, based on

previous excavations, were accurate. The study concluded that further

degradation of the piping system could be mitigated by an adequate

cathodic protection system. The NRC inspectors will continue to monitor

licensee activities in this area.

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No violations or deviations were identified.

12. Exit Meeting

The NRC inspectors met with licensee personnel to discuss the scope and

findings of this inspection on January 8, 1988.