ML20235M364

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Insp Rept 50-482/87-20 on 870801-31.Violation Noted.Major Areas Inspected:Plant Status,Operational Safety Verification,Monthly Surveillance & Maint Observations, 10CFR21 Rept Followup & Physical Security Verificaton
ML20235M364
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 09/21/1987
From: Bruce Bartlett, Cummins J, Hunter D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20235M308 List:
References
50-482-87-20, NUDOCS 8710060163
Download: ML20235M364 (12)


See also: IR 05000482/1987020

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APPENDIX B

U.S. NUCLEAR REGULATORY COMMISSION

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' REGION IV

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NRC Inspection Report:

50-482/87-20

License:

NPF-42

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Docket:

50-482-

Licensee:

Wolf Creek Nuclear Operating Corporation'(WCNOC)..

P.-0. Box 411

3

.Burlington, Kansas 66839

Facility Name: -Wolf Creek Generating Station (WCGS)

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

Inspection Conducted:

August 1-31, 1987

Inspectors:

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9 C l 8'7

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J..E.

C~ummins, Senio'

Resident Inspector,

Date

Operations

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B. L. Bartlett, Redident Reactor Inspector,

Date7

Operations

Approved:

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D. R. Hunter, Chief, Reactor Project

Date

Section B, Reactor Projects Branch

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Inspection Summary

Inspection Conducted August 1-31, 1987 (Report 50-482/87-20)

Areas Inspected:

Routine, unannounced inspection including plant status,

operational safety verification, monthly surveillance observation, monthly

maintenance observation, 10 CFR Part 21 report followup, physical security

verification, radiological protection, engineered safety features system

walkdown, allegations followup, and followup on regional requests for

information.

Results:

Within the 10 areas inspected, one violation was identified (failure

to enter Technical Specification (TS) 3.0.3, paragraph 3).

One open item is

identified in paragraph 11 and one unresolved item is identified in

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paragraph 5.

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DETAILS

1.

Persons Contacted

  • B. D. Withers, President

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  • R. M. Grant, Vice President, Quality
  • J. A. Bailey, Vice President, Engineering and Technical Services
  • F. T. Rhodes, Vice President, Nuclear Operations
  • G. D. Boyer, Plant Manager
  • 0. L. Maynard, Manager of Licensing

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  • C. M. Estes, Superintendent 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, Supervisor of Licensing

G. Pendergrass, Licensing

  • W. M. Lindsay, Supervisor, Quality Systems
  • C. J. Hoch, QA Technologist
  • J. A. Zell, Training Manager
  • J. Houghton, Operations Coordinator-0perations

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

during the inspection period to discuss identified issues.

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

September 4, 1987.

2.

Plant Status

The plant operated in Mode 1 during the inspection period.

3.

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

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

prevent them from performing their designed functions.

Selected NRC inspector observations are discussed below:

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On August 18, 1987, during a routine plant tour, the NRC inspector

observed licensee security personnel responding to a possible loss of

security in the fuel building. During maintenance to replace a section of

-fire protection piping, a hole through the side of the fuel building had

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been left after a section of piping had been removed. The personnel

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performing the work failed to realize that the opening left with the pipe

removed could be a security problem and a fuel building pressurization

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problem. The NRC inspector reviewed the circumstances and it was

concluded that the hole created neither a security problem nor a TS

problem; however, it did point out the need to consider the functions of

walls and other boundaries during the preparation of work packages,

particularly when the boundaries are being breached during the work

activity.

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A3 proximately one hour after the above observation, the NRC inspector

o) served that Penetration OP152W1317 (auxiliary building to control room)

had been recently worked on; however, with the help of the shift

supervisor (SS) it was determined that it did not violate the control room

pressure boundary. Discussions with the SS the next day revealed that

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work packages were again found to inadequately address the functions of

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walls when they were breached. The SS had all penetration work stopped

until he felt that the wall penetrations were properly addressed.

Later

that day penetration work was allowed to continue.

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Licensee personnel informed the NRC inspector that even if

Penetration OP152S1317 had been completely breached that it would not

matter since that part of the auxiliary building wall was not part of the

control room pressure boundary. The pressure boundary was actually the

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wall of the electrical cable chase which was inside the control room.

On August 20, 1987, during a routine plant tour of the control room, the

NRC inspector observed Door 36171 propped open. Door 36171 is the access

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door to the southeast electrical chase and as noted above is a part of the

control room pressure boundary. The NRC inspector notified the SS who

immediately implemented appropriate administrative controls.

Interviews

with the personnel who had propped the door open to perform penetration

work revealed that the door had been open off and on all morning and

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afternoon but for less than 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> at any one time. The review by the

NRC inspector determined that the licensee inspection activities in the

area of the door were limited to the previous 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

With the control room pressure boundary violated, the ability of either

train of the control room emergency ventilation system to maintain the

control room at a positive pressure of greater than or equal to .25 inches

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of water was violated. With both trains of the control room emergency

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ventilation system inoperable, the licensee should have entered TS 3.0.3.

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This failure of the licensee to recognize entry into TS 3.0.3 is an

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apparent violation (482/8720-01).

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4.

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 elements 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 instrumenhtion was calibrated,

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Technical Specification limiting conditions for operation (LCO) 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.

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

below:

o

STS PE-013, Revision 5, " Personnel Air Lock Seal Test," performed on

August 26, 1987

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STS RE-012, Revision 1, "QPTR Determination," performed on August 26,

1987

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STS SE-002, Revision 0, " Manual Calculation of Reactor Thermal

Power," performed on August 26, 1987

o

STS EJ-1008, Revision 1, "RHR System Inservice Pump 'B' Test,"

performed on August 26, 1987

o

STS EG-100A, Revision 2, " Component Cooling Water Pumps A/C Inservice

Pump Test," performed on July 10, 1987

o

STS EG-100B, Revision 2, " Component Cooling Water Pumps B/D Inservice

Pump Test," performed on July 10, 1987

No violations or deviations were identified.

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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, 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

LCOs were met and, where applicable, redundant components were

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operable,

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Activities complied with adequate administrative controls,

o

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

used.

o

Craftsmen were qualified to accomplish the designated task and

technical expertise (i.e., engineering, health physics, 0perations)

was made available when appropriate,

o

Replacement parts and materials being used were properly certified,

o

Required radiological controls were implemented,

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Fire prevention controls were implemented where appropriate.

o

Required alignments and surveillance to verify post maintenance

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:

No.

Activity

WR 02972-87

Piping Line EF-134-HBC-16, UT thickness examination

WR 02892-87

Foam penetration closures, auxiliary building

WR 02888-87

Foam penetration closures, auxiliary

building-inspect and rework as required

Selected NRC inspector observations are discussed below:

On August 21, 1987, the licensee determined by ultrasonic testing (UT)

that Section EF-134-HBC-16 of essential service water (ESW) Train "B"

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piping had less than the allowable minimum wall thickness of .328 inches.

.The lowest thicknesses measured were .125 inches.

This section of piping

was located directly downstream of throttled butterfly Valve' EF V090.

The

licensee has determined that piping downstream of throttled butterfly

valves was subject to a possible high erosion rate.

The licensee

performed the UT on the pipe in accordance with a recently implemented

preventive maintenance erosion / corrosion monitoring program.

On August 21, 1987, when this piping wall was identified to be less than

minimum, in accordance with licensee Procedure ADM 08-212, Revision 0,

" Erosion / Corrosion Monitoring Program," Work Request (WR) 02972-87 was

written to get an engineering evaluation of the minimum wall condition and

to provide instructions for any necessary repairs.

On August 24, 1987, the engineering evaluation determined that the pipe

would not meet seismic and ASME Code compliance requirements.

Based on

this evaluation, the licensee declared the ESW Train "B"

inoperable and

entered TS 3.7.4, which allowed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to either make the component

operable or to shut down the plant.

The section of pipe was repaired

within the 72-hour action of TS 3.7.4 by overlay welding on.its outer

surface which increased the wall thickness to greater than the required

minimum.

During the refueling outage from October-December 1986, this

same section of piping had been repaired to correct a through wall leak.

Activities related to the repairs to ESW piping that was less than the

required minimum wall thickness due to erosion were discussed in NRC

Inspection Report 50-482/87-15, paragraph 5.

Unresolved Item 482/8715-04 was written pending NRC review of whether or

not the licensee should declare a component inoperable immediately upon

determination that it fails to meet ASME Code requirements.

In this

instance ESW Pipe Section EF-134-HBC-16 was determined to be below minimum

wall thickness by the licensee at 3:41 p.m. (CDT) on August 21, 1987, as

documented in the shift supervisor's log.

However, the NRC inspector

determined from discussions with licensee personnel that the engineering

evaluation was not performed until Monday, August 24, 1987.

The

engineering evaluation determined that the section of pipe would not have

withstood upset conditions (seismic event) as required and ESW Train "B"

was declared inoperable.

Pending completion of the NRC review of the question of the operability of

a component that fails to meet ASME Code requirements, this will remain an

unresolved item (482/8720-02) and will be reviewed as a part of Unresolved

Item 482/8715-04.

As a part of this event, the Office of Nuclear Reactor Regulation (NRR)

granted temporary relief so that the licensee did not have to perform the

radiographic test of the repair weld as required by the ASME Code.

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performance of the test would have required a plant shutdown.

The relief

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was based on the satisfactory ic.agnetic particle examination of each weld

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layer and an ultrasonic test of the completed repair which verified that

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the pipe wall thickness was greater than the minimum required.

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6.

10 CFR Part 21 Report Followup

a.

The NRC inspector, by review of documents and discussions with

licensee personnel, verified that the'10 CFR Part 21 reports

discussed below had been reviewed and appropriately acted on by the

licensee.

(Closed) P21-1987-87-19:

Design Defect in Limitorque Valve Operators

Manufactured Prior to 1975

The licensee determined that the limitorque operators at Wolf Creek

Generating Station (WCGS) were manufactured after 1975 and that they

have a machined notch in the belleville spring assembly to prevent

the hydraulic locking problem reported in the 10 CFR Part 21 report.

This information was documented in WCGS Industry Technical

Information Review and Evaluation (ITIP) No. 00360.

(Closed) P21-1987-87-06:

Stationary Sleeve on MSIV Thrust Bearing

Eg ending Past Rotating Face

This 10 CFR Part 21 report reported a defect in reverse seating check

valves manufactured by Atwood and Morrill Company, Inc. and used as

main steam isolation valves (MSIV).

The MSIVs at WCGS were

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hydraulically activated, bidirectional, double disc gate valves

manufactured by a different vendor, therefore, this 10 CFR Part 21 is

not applicable to WCGS.

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b.

The NRC resident inspector provided a copy of the 10 CFR Part 21

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report listed below to the licensee for review and action, if

required.

P21-1987-87-65: Wolfe & Swickard-Inner Bearing Race Missing on OG

Air Start Motors

7.

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

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security personnel.

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The NRC inspectors by observation of randomly selected activities verified

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 when

equipment is inoperable.

No violations or deviations were identified.

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8.

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:

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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,

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" Frisking out" of the RCA, and

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Wearing of appropriate anti-contamination clothing where

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required.

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Inspected postings of radiation and contaminated areas.

o

Discussed activities with radiation workers and health physics

supervisors.

Selected NRC inspector observations are discussed below:

On August 28, 1984, the licensee received from Science Applications

International (SAI) a boron analyzer which had a fission chamber in it

that contained approximately 2 grams of Uranium 235 (U235).

This analyzer

was part of the post-accident sampling system.

At the time the analyzer

was shipped and received the fission chamber did not get classified as

special nuclear material (SNM) and therefore the transaction was not

documented in accordance with the instructions in NUREG/BR-0006,

Revision 2, " Instructions for Completing Nuclear Material Transaction

Reports." NUREG/BR-0006 requires that the shipper, in this case SAI,

initiate a DOE /NRC Form 741 and send it to the receiver, in this case the

licensee, with the SNM.

The receiver then fills out the appropriate

section of the DOE /NRC Form 741 and distributes it per the instructions in

NUREG/BR-0006.

Recently, licensee personnel questioned whether or not the

fission chamber should have been treated as SNM and in subsequent

discussions with SAI, it was decided that it should have been.

SAI on

August 19, 1987, sent the licensee a DOE /NRC Form 741 for the fission

chamber which the licensee filled out and distributed in accordance with

NUREG/BR-0006.

No violations or deviations were identified.

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Engineered Safety Features (ESF) System Walkdown

The NRC inspectors verified the operability of ESF systems by walking down

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selected accessible portions of the systems.

The NRC inspector verified

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valves and electrical circuit breakers were in'the required position,

power was available, and valves were locked where required.

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inspectors also inspected system components for damage or other conditions

that could degrade system performance.

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The ESF system walked down during this inspection period and the documents

utilized by the NRC inspectors during the walkdown are listed below:

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System

Documents

Component Cooling Water (EG)

Drawing M-12EG01(Q), Revision 2,

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" Piping and Instrumentation Diagram

Component Cooling Water System"

Drawing M-12EG02(Q), Revision 1,

" Piping and Instrumentation Diagram

Component Cooling Water System"

Drawing M-02EG03(Q), Revision 17,

" Piping and Instrumentation Diagram

Component Cooling Water System"

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Checklist (CKL) EG-120, Revision 8,

" Component Cooling Water System Valve,

Switch, and Breaker Lineup"

SYS EG-120, Revision 5, " Component

Cooling Water System Startup"

SYS EG-203, Revision 5, " Chemical

Addition to Component Cooling Water

System"

SYS EG-201, Revision 4,." Transferring

Supply of CCW Service Loop and CCW

Train Shutdown"

STS EG-001, Revision 4, " Component

Cooling Water Valve Check"

STS EG-100A, Revision 2, " Component

Cooling Water Pumps A/C Inservice Pump

Test"

STS EG-1008, Revision 2, " Component

Cooling Water Pumps B/D Inservice Pump

Test"

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Selected NRC inspector observations are discussed below:

o

Three 4-inch drains with flanges on each train of CCW were not

included in CKL EG-120.

o

Drain Valves EG-V381, 382, and 384 were not in CKL EG-120.

o

Flow Indicator EG F1-64 was not reading zero when that portion of the

system was isolated.

The observations noted above were given to the licensee.

No violations or deviations were identified.

10. Allegation Followup

(Closed) Allegation (4-87-A-065): An alleger stated that when the plant

was under construction, stainless steel welds were quenched with water.

Findings: The NRC inspector interviewed licensee engineers and determined

that in May 1983, Quality Surveillance Report SR-437M was initiated to

document craft personnel applying a saturated cloth to a stainless field

weld. Although this was standard recommended practice and did not violate

code and/or procedural criteria, it was not being done in accordance with

an approved procedure. The licensee issued guidance for the welders to

use in quenching; however, the licensee subsequently decided to

discontinue quenching.

Conclusion:

The allegation that Wolf C:eek construction quenched welds

was substantiated; however, quenching the stainless steel welds had no

impact on safety.

11.

Followup on Regional Requests for Information

During this inspection period, Region IV management informed the NRC

inspectors of a containment temperature problem at another nuclear power

plant.

It appeared that for a number of years the ambient air temperature

inside containment had been excessively high and the licensee at that

facility failed to adequately address the causes of the high temperatures,

their affect on equipment qualification (EQ)e and on the accident

analysis.

WCGS TS 3.6.1.5 requires that the primary containment temperature be

determined by averaging the temperatures of the four containment coolers

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inletsandthatitnotbegreaterthanf20F. During this inspection

period, the average temperature was 101 F.

When questioned further by the

NRC ;nspector, licensee personnel stated that the temperatures of

individual compartments inside containment could not be determined;

however, Plant Modification Request (PMR) 1975 had been written to place

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some temporary' temperature probes insideLcontainment to monitor'various

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locations during the next cycle.

This item will remain open pending NRCs.

review of the next cycle temperature data (482/8720-03).

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Open Items

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Open items are. matters which have been discussed with the licensee, which

will be reviewed further by the inspector, and which involve some action

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on the part of the NRC or licensee or.both.- One open item disclosed

Lduring the inspection'is discussed in paragraph 11.

13.

linresolved Items

Unresolved items are matters about which more information is required in

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order to ascertain whether they are acceptable items, items of

noncompliance, or deviations.

One unresolved item disclosed during the

inspection is discussed in paragraph 5.

14. -Exit Meeting

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

findingstof-this inspection on' September 4, 1987.

The NRC inspectors also

attended-entrance / exit meetings of.the NRC region-based inspectors

identified below:

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Inspection

Lead

Area-

Inspection

Period-

Inspector

Inspected

Report No.

8/3-7/87

R. Stewart

Temporary

87-18

Instruction

Followup.

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