ML20154G845
| ML20154G845 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 09/16/1988 |
| From: | Holahan G Office of Nuclear Reactor Regulation |
| To: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| Shared Package | |
| ML20154G849 | List: |
| References | |
| NUDOCS 8809210092 | |
| Download: ML20154G845 (8) | |
See also: IR 05000482/1988200
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NUCLEAR REGULATORY COMMISSION
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SEP 161988
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Docket No. 50-482
Wolf Creek Nuclear Operating Corporation
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ATTN: Bart D. Withers President and
Chief Executive Officer
P.O. Box 411
Burlington, Kansas 66839
Gentlemen:
SUBJECT: QUALITY VERIFICATION FUNCTION INSPECTION AT WOLF CREEK
NRC INSPECTION REPORT NO. 50-482/88-200
The Nuclear Regulatory Comission's (NRC's) report of the sp(WCGS),from June 6
ecial announced
team inspection conducted at Wolf Creek Generating Station
through June 17, 1988, of activities authorized by NRC License No. NPF-42 is
enclosed. The NRC inspection team consisted of R. P. Correia, A. E. Finkel,
P. C. Hopkins, D. R. Hunter, R. L. Moore, S. E. S parks, and P. J. Prescott.
The inspection team's findings were discussed witi Bart D. Withers, F. T.
Rhodes, R. M. Grant, J. A. Bailey, and other members of your staff at the end
of the inspection.
The inspection was the seventh in a series of NRC headquarters-directed quality
verificationfunctioninspections(QVFI)performedundertheguidanceofNRC
Inspection Manual Temporary Instruction 2515/78.
The inspection was performed
to assess your line organization's support and contribution to plant quality
and your quality verification organization's ability to identify, resolve, and
prevent the occurrence of safety-significant technical deficiencies. Another
area of the inspection was to evaluate the effectiveness of management in
ensuring that identified quality deficiencies were responded to promptly and
completely.
Generally, the NRC inspection team determined that your quality verification
organizations were staffed with experienced and capable individuals. The
audits, surveillances, and inspections performed by Quality Assurance and
Quality Control persennel were both technically oriented and performance
oriented, notably in the area of control room operations. We encourage you to
continue performing these audits and surveillances, including backshift reviews
and to consider having quality verification personnel perform plant system
walkdowns, both in conjunction with operations personnel and independently of
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them. The team noted that your Quality Assurance organization will soon be
obtaining the "Performance-based Surveillance and Auditing" training course.
We commend you for taking this positive performance-oriented step and recomend
that all of your quality verification perscnnel receive this training.
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Bart D. Withers
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The NRC inspection team also reviewed the activities of the Nuclear Safety
Engineeringgroup(PSRC).the Nuclear Safety Review Comittee, and the Plant Safety
Review Committee
The ability of these organizations to deal with plaat
equipment and systems problems was assessed.
In that regard, the team deter-
mined that the Nuclear Safety Engineering group and the Nuclear Safety Review
Comittee had capable personnel, acted independently, performed thorough evalu-
ations and reviews, and provided accurate recomendations to plant and corpor-
ate management concerning plant reliability and safety. Although the PSRC also
had capable personnel, the team noted that this comittee had not been con-
sistently effective with their reviews and evaluations. This was evidenced by
their nonconservative recomendation on the operability of the essential
service water system with a through-wall leak and pipe wall-thinning problems.
despite the recomendations made by your eagineering staff.
However, the
inspectors noted that in most of the more ncent PSRC evaluations the comittee
had been heeding the recommendations of engineering and taking prorpt actions
when warranted.
We are concerned with the apparent weakness in your organization's ability to
determine the underlying causes of problems with plant systems and components,
although the team found that your maintenance staff is generally effective in
identifying and resolving specific problems.
Similarly, your line organi M ions
are genera ly effective in ensuring that these identified deficiencies are promptly
addressed, but they do not always ensure that the deficiencies are completely
resolved to prevent their recurrence. An example is the 28 control room ventilation
isolation signal (CRVIS) actuations caused by chlorine monitor failures. We are
concerned that these and approximately 44 other CRVIS actuations may be degrading
other components in the control room habitability system.
The NRC recognizes your
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comitment to have new and more reliable chlorine monitors installed during the
next refueling outage scheduled for September 1988 and expects that the possible
detrimental effects of the CRIVS actuations may have had on components in the
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control room HVAC system will be evaluated to ensure reliable system operations
in the future. The inspection team also was concerned that repetitive failures and
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false alarms from malfunctioning equipment may be desensitizing control room
operators to actual plant problems.
We feel that management attention is
warranted to address and resolve such problems.
The NRC inspection team identified six p(otential enforcement' findings (PEF)
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(see Enclosure 1) rind two observations see Enclosure 2); these are described
in the inspection eport (see Enclosure 3).
The PEFs are associated with (1)
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six examples of not taking appropriate actions to prevent recurrence of plant
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system and component deficiencies, (2) not having procedures and instructions
appropriate for the bearing reroval activities on a component coolin
pump, (3) not obtaining all app (licable service information l
SIL) from
the emergency diesel generator EDG) vendor and evaluating their relevance to
the Wolf Creek EDGs, (4) not verifying the installation of four seismic and
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vibration control pipe supports on the emergency diesel generator's cooling
water system as required by the vendor's design drawings, (5) not posting a
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fire watch, as required when a fire barrier seal in a penetration was determined
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not to be qualified, and (6) not declaring a loop of the Essential Service Water
System inoperable when it was determined it did not reet its specified design
requirements. The two observations are associated with (1) the apparent lack
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of a feedback mechanism for crafts to report concerns with maintenance procedures
used in maintaining plant equipment and (2) the methodology used to calibrate
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Bart D. Withers
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the resistance temperature detectors for the reactor coolant system.
These PEFs
and observation 1 will be further evaluated by NRC Region IV staff for possible
enforcement and followup actions. Observation 2 will be referred to NRC
Headquarters staff for further evaluation.
In accordance with 10 CFR 2.790(a), a copy of this letter end the enclosures
will be placed in the NRC Public Document Room.
No reply to this letter is
required at this time.
Should you have any questions regarding this inspection, please contact me or
the NRC Region IV office.
Sincerely,
49 W
Gary M. Hola an, Acting Director
Division of Reactor Projects, III, IV,
Y and Special Projects
Office of Nuclear Reactor Regulation
Enclosures:
1.
Potential Enforcement Findings
2.
Observations
3.
Inspection Report No. 50-482/88-200
cc w/encls:
Wolf Creek Nuclear Operating Corporation
ATTN: Otto Maynard, Manager of Licensing
P. O. Box 411 Burlington, Kansas 66839
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Wolf Creek Nuclear Operating Corporation
ATTN: Gary Boyer, Plant Manager
P. O. Box 411
,
Burlington, Kansas 66839
Kansas Corporation Comission
ATTN:
Robert D. Elliott, Chief Engineer
,
Fourth Floor. Docking State Office Building
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Topeka, Kansas 66612-1571
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Kansas Radiation Control Program Director
bec distrib. by RIV:
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Myron Karman, ELD, MNBB (1)
T. O. McKernon
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R. D. Martin, RA Section
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Chief (DRP/A)
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RPSB-DRSS
B. DeFayette, RIII
P.IV File
Callaway, RIII
MIS System
RSTS Operator
Project Engineer, DRP/A
H. Scott, Acting EO
Lisa Shea, RM/ALF
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Enclosure 1
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POTENTIAL ENFORCEMENT FINDINGS
As a result of the Nuclear Regulatory Commission's (NRC's) Quality Verification
Function Inspection at Wolf Creek Generating Station from June 6 through 17,
1988, the following items are being referred to NRC Region IV as potential
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enforcementfindings(PEFs). Section references refer to detailed descrip-
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tionsoftheitemsintheinspectionreport(seeEnclosure3).
1.
Criterion XVI of Appendix B to 10 CFR 50 requires that conditions
adverse to quality, such as equipment failures and malfunctions, are
promptly identified and corrected.
It also states that the causes of sig-
nificant conditions adverse to quality be determined and corrective action
taken to preclude' their repetition.
The licensee's Updated Safety
Analysis Report, Revision 0, paragraph 17.2.16.1, states in part that
corrective action measures have been established to ensure that conditions
adverse to quality are p omptly identified, reported, and corrected to
preclude recurrence.
Significant conditions adverse to quality may
include a recurring condition for which past corrective action has been
ineffective.
Contrary to these requirements:
a.
the licensee has not determined the underlying cause that permitted
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0-rings that were not environmentally qualified to remain installed
in the post-accident sampling system containment isolation valves.
(Section2.2.1)(ItemNo. 88-200-1a)
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b.
the licensee has not taken the corrective actions specified in
engineering evaluation request EE 85-GK-08 (completed November 27,
,
1985) to resolve the electrical breaker malfunctions of the heating,
ventilating (, and air conditioning (HVAC) system in the control
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building.
Section3.2.1.1)(ItemNo.88-200-Ib)
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c.
the licensee has not fully investigated the underlying causes of
the multiple HVAC damper failures in the control building.
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(Section3.2.1.2)(ItesNo. 88-200-1c)
d.
the licensee has not aggressively taken action to resolve a large
number of actuations in the control room ventilation isolation
signal (CRVIS) system that were attributed to the control room
habitability system chlorine monitor malfunctions that began in 1985.
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(Section3.2.1.3)(ItemNo.88-200-Id)
e.
the 11cer.see has not taken actions to correct multiple fire protec-
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tion system failures that resulted from the apparent misapplication
of valve microswitches.
(Section3.4.1)(ItemNo.88-200-le)
f.
the licensee has not aggressively pursued the cause and taken action
to resolve malfunctions in the emergency diesel engine's jackat water
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pressure sensing system that began in 1986.
(Section3.6.1)(Item
No. 88-200-1f)
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2.
Criteria V of Appendix 8 to 10 CFR 50 requires that activities affecting
quality be accomplished in accordance with documented instructions,
procedures, or drawings of a type appro)riate to the circumstances.
Instructions, procedures, or drawings s1all include appropriate
quantitative or qualitative acceptance criteria for determining that
important activities have been satisfactorily accomplished.
Contrary to the above, NRC inspectors observed during a component
cooling water pump maintenance activity that the licensee's procedures
and instructions provided to the maintenance personnel did not include
appropriate cautions or details for removal of the bearing.
(Section3.1.1)
(Item No. 88-200-2)
3.
Criterion V of Appendix B to 10 CFR 50 requires that activities affecting
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quality be accomplished in accordance with documented instructions,
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procedures, or drawings.
Wolf Creek licensing condition 2.C.(13) describes the licensee's vendor
interface program as part of the r response to NRC Generic Letter 83-28.
e
Wolf Creek Nuclear Operating Corparation Procedure, XGP-1311, Revision 1,
specifies the function of the Industry Technical Information Program
(ITIP).
Part of the ITIP requires that vendor reports shall be reviewed
to determine their applicability to Wolf Creek Generating Station (WCGS)
and, if necessary, a detailed evaluation is to be performed to determine
the effects on WCGS.
Contrary to the above, the licensee did not to obtain three of the service
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information letters (SILs) that were potentially applicable to the emer-
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gency diesel generators (EDGs) supplied to Wolf Creek.
It was further
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determined that the five EDG SILs that the licensee had received had not
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been formally reviewed or evaluated.
(Section 3.5.1) (Item No. 88-200-4)
4.
Criterion X of Appendix B to 10 CFR 50 requires that a program for
inspection of activities affecting quality be established and executed by
or for the organization performing the activity to verify conformance with
the documented instructions, procedures, and drawings for accomplishing
the activity.
Contrary to the above, NRC inspectors found that during construction
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of the EDGs, the licensee had not verified that the safety-related seismic
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and vibration control emergency diesel turbocharger cooling water pipe
supports had been installed as required by the vendor's design drawing.
(Section3.5.1)(ItesNo. 80-200-5)
5.
Technical Specification 6.8.1 requires that written procedures be
established, implemented, and maintained for the fire protection program.
Procedure ADM 13-103, Revision 5, "Fire Protection:
Impairrent Control,"
implements procedures for impaired fire protection equipment.
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Wolf Creek Updated Safety Analysis Report, Section 9.5 Table 9.5.1-3
(sheet 4),requiresthatallfirebarriersandtheirpenetrationssepara-
ting safety-related areas from those that are not safety related or
separating portions of redundant systems important to safe shutdown chall
be operable at all times.
Should one or more be found to be inoperable,
within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> a continuous fire watch must be established on one side of
the affected barrier or an hourly fire waten patrol must be established.
Contrary to the above, the licensee failed to establish the required fire
watch for penetration OP 142S1099 af ter an engineering disposition
effectively rendered the penetration's fire protection capabilities
TheengineeringdispositionwascompletedonMay3,)1988;the
licensee posted the fire watch on June 14, 1988.
(Section4.1.1
(ItesNo. 88-200-6)
TechnicalSpecificationLimitingConditionforOperation(LCO))3.7.4
6.
requires at least two independent Essential Service Water (ESW loops be
In addition LCO 3.7.4 states that with only one ESW loop
operable,theinoperableESWloopmustberestoredtooperablestatuc
within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the reactor must be in at least hot standby within 6
hours and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Contrary to the above, when it was determined that the "A" train loop of
the ESW system did not meet its specified design requirements on
February 19. 1987, the licensee did not declare the loop (Item No. inoperable and
implement the requirements of LCO 3.7.4 (Section 5.1.1)
88-200-8).
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Enclosure 2
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OBSERVATIONS
As a result of the Nuclear Regulatory Commission's (NRC's) Quality Yerification
Function Inspection at Wolf Creek Generating Station from June 6 through 17,
1988 the following items are being referred to Region IV and NRC Headquarters
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staffasobservationsofactivitiesconsideredlessthanoptimum.
They may
require followup reviews during future NRC inspections.
Section references
refer to detailed descriptions of the items in the inspection report (see
inclosure 3).
1.
The NRC inspectors noted during their review of maintenance activities and
the work request program that the licensee had not pitvided a mechanism
for maintenance personnel to report problems or recommendations back to
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procedure (work instruction) writers.
This weakness appears to have
contributed to the problems identified during)the removal of the component
cooling water pump searing.
(Section3.1.1.3
(ItemNo. 88-200-3)
(ReferredtoRegionIV)
2.
The NRC inspectors noted during their review of Nuclear Safety Engiteering
activities that the methodology "sed to calibrate resistance tempera ture
detectors (RTDs) for the reactor coolant system did not include checking
the accuracy of the RTDs to known values of input (temperature)..
(Section 4.3.1) (Ites No. 88-200-7)(ReferredtoNRCHeadquarters
staff)
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