ML20196C178

Forwards Safety Sys Outage Mods Insp Rept 50-482/87-32 on 871102-20.Weaknesses in Areas Reviewed Re Adequacy of Mgt Control & Oversight,Engineering Support & Evaluations Noted in App a Should Be Responded to within 60 Days

ML20196C178
Person / Time
Site:	Wolf Creek
Issue date:	02/08/1988
From:	Crutchfield D Office of Nuclear Reactor Regulation
To:	Withers B WOLF CREEK NUCLEAR OPERATING CORP.
Shared Package
ML20196C181	List: IR 05000482/1987032 ML20196C178
References
NUDOCS 8802160005
Download: ML20196C178 (6)

See also: IR 05000482/1987032

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1. pesog.,og UNITED STATES

. 8 p, NUCLEAR REGULATORY COMMISSION

5 <j WASHsNGTON, D. C. 206H

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o,..+ February 8, 1968

Docket No. 50-482

Wolf Creek Nuclear Operating Corporation

ATTN: Bart D. Withers, President

and Chief Executive Officer

P. O. Box 411 Burlington, Kansas 66839

Gentlenen:

SUB4ECT: SAFETY SYSTEMS OUTAGE MODIFICATIONS INSPECTION

50-482/87032

This letter forwards the results and conclusions of the Safety Systems Outage

Modifications Inspection (550MI) at the Wolf Creek nuclear power station

conducted by the NRC's Office of Nuclear Reactor Regulation. The inspection

team was composed of NRC personnel and consultants. The design and procurement

portion of the inspection was conducted November 2-13, 1987, and the installa-

tion and testing portion of the inspection was condt:cted November 9-20, 1987.

The purpose of the design and procurement portion of the SS0MI was to deter-

mine, through an examination of specific work packages, that the design,

engineering, and procurement control was adequate to support the safety-related

modifications and to determine whether services or products acquired to support

the outage were in accordance with your comitments and regulatory

requirements.

The purpose of the installation and test portion of the SSOMI was to determine. l

through an examination of specific work packages, that installetion of the t

selected modifications conformed to design and installation requirements, and to i

verify that the repaired or modified components and systems have the required {

operating configurations and have been adequately tested to ensure that they i

are capable of safely performing their intended functions. i

The inspection team identified significant weaknesses in the areas reviewed

relating to the the adequacy of management control and oversight, engineering

support and engineering evaluations, and corrective actions. Those weaknesses I

are discussed in Appendix A to this letter.

At the conclusion of the inspection, a number of equipment operability concerns I

remained to be resolved prior to unit startup from the refueling outage.

Specifically, the operability of the Control Room Ventilation Isolation System

had not been demonstrated in all anticipated modes of operation, and the single

failure det.1gn of the system had been compromised by an equipment modification;

the operability of the pressurizer safety valves had not been adequately

demonstrated by periodic testing; the pressurizer spray valve had been incor-

rectly modified; several loose and missing piping supports were identified; and

inadequacies were identified with respect to the design of the anti-pumping

logic for the diesel generater output breakers.

8802160005 880208

PDR ADOCK 05000482

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Bart D. Withers -2- February 8, 1988

The NRC Region IV staff monitored your corrective actions, and detemined that

adequate corrective resolution of the identified concerns was achieved prior to

restart of the plant. Some of the items identified by the team may be poten-

tial enforcement findings. Any enforcement actions will be identified by

Region IV in separate correspondence.

In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure

will be placed in the NRC Public Document Room.

You are requested to respond to this oifice within 60 days regarding the

concerns and weaknesses identified in the enclosed inspection report. Your

response should include a discussion of the role of the Wolf Creek organization

responsible for the assurance of quality.

Should you have any questions concerning this inspection, please contact me or

Mr. J. E. Konklin (301-492-0953) .

Sincerely,

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Dennis M. C >rutchfield

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, Director Division of l

Reactor Projects, III/IV/V and Special l

Projects

Office of Nuclear Reactor Regulation j

Enclosure: Inspection Report No. 50-842/87032

cc w/ enclosure: See next page

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Bart D. Withers -3- February 8, 1988

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cc:

Otto L. Maynard, Manager of Licensing

Wolf Creek Nuclear Operating Corporation ,

P. O. Box 411

Burlington, Kansas 66839

Gary Boyer, Plant Manager

Wolf Creek Nuclear Operating Corporation '

P. O. Box 411

Surlington, Kansas 66839

Mr. Robert D. Elliott, Chief Engineer

Kansas Corporation Commission

Fourth Floor, Docking State Office Building

(opeka, Kansas 66612-1571

Kansas Radiation Control Program Director

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APPENDIX A

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EXECUTIVE SUMMARY  !

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An announced NRC Safety Systems Outage Modifications Inspection (SSOMI) was

conducted at the Wolf Creek Nuclear Operating Corporation's Wolf Creek Generat-

ing Station during the period of November 2-13, and November 9-20, 1987.

In addition to the inspection of activities involved in this specific outage,

the SS0MI team also reviewed recent Wolf Creek operational events in order to

evaluate the root causes as they relata to the performance of safety system

modifications. The results and conclusions of this review were discussed with

NRC regional management and will be utilized in Region IV's review of the

events.

Overall Conclusions

The modifications activities inspected by the SSOMI team during the Wolf Creek

outage, including procedures, installed equipment and materials, and workman-

ship by crafts, were generally in accordance with NRC requirements and licensee

commitments. The SSOMI team noted specific strengths related to the acquisi-

tion and control of equipment and materials, the trend analysis of quality

findings and reported deficiencies, and workmanship by maintenance personnel.

However, the team also identified weaknesses in the following areas:

1. Manacement Controls

In a number of cases, management failed to implement the appropriate opera-

tional procedures for the removal and return to service of equipment. The

outage management controls specified in Administrative Procedure ADM 01-108,

"Outage Planning," which provided definitive guidance on the planning, schedul-

ing and performance of major outages were not implemented. Identified defi-

ciencies which impacted the ability of maintenance crafts to perform quality

work, such as wiring discrepancies between "as-built" and vendor's wiring

diagrams, were not promptly resolved. Inadequate maintenance management

involvement was provided for complex tasks such as safety valve bench testing

and was partially responsible for a Quality Assurance Work Hold issued during

repairs to piping in the Essential Service Water System. In addition, modifi-

cation of the Pressurizer Spray Valve for liquid sealant injection, a temporary

modification of the Control Room Ventilation Isolation System (CRVIS) which

defeated the single failure design of the system, and the failure to perform

timely evaluations of operational piping systems with potential wall thickness

problems were further examples of inadequate management support and control of

outage activities.  ;

With regard to the recent operational events, the SSOMI team noted that, during

the removal of Vital Bus NB02 from service for scheduled maintenance on

October 14, 1987, the system operating procedures which specified the require-

ments and precautions for system operation and isolation, including the maximum  ;

, time the isolated buses could be supplied by the station batteries, were not  !

used. The failure to utilize the operational procedures and to intorporate the l

precautions and requirements of the procedures for the removal and return of

equipment from service in accordance with the requirements of the Technical

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, Specifications and 10 CFR 50, Appendix A, resulted in a chain of events which

culminated in the injection of lake water into the steam generators.

2. Engineering Support and Evaluations

The engineering support provided for a number of recent modifications and ,

maintenance activities was found to be inaccurate or lacking in thoroughness.

The SS0MI team identified a number of cases in which engineering evaluations

failed to correctly determine the effects of proposed modifications. Examples

include a wrong estimate of the time of discharge of Battery NK12 prior to the

loss of Vital Bus NB02, failure to prepare for the loss by providing alternate

supplies, failure to provide adequate overpressure protection for the Reactor

Coolant Drain Tank, failure to recognize the single failure design criteria of  ;

the CRVIS system, inadequate design of a diesel generator output breaker -

anti pumping logic which prevented the breaker from closing onto a cleared,

deenergized bus, and a number of inadequately justified or documented engineer-

ing evaluations in modification packages.

3. Corrective Actions

Although, as noted above, the licensee has a good trend analysis program, the

SSOMI team identified a weakness involving the adequacy of corrective actions

for identified deficiencies, including the identification of root causes,

evaluation of related areas for similar deficiencies, and actions to prevent

recurrence. One significant example was identified during the evaluation of

PMR 1903, which involved Essential Service Water pipe wall thinning and

through-wall corrosion. After the deficiency was identified, there appeared to

be no attempt to check for similar deficiencies on the other train, there was

no immediate evaluation of the deficiency to determine whether the thinner

walls violated the Updated Safety Analysis Report commitments, and the correc-

tion of the deficiency did not include a determination of a root cause and

specification of actions to prevent recurrence.

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