ML20245J425

Insp Rept 50-482/89-05 on 890201-28.Violations Noted.Major Areas Inspected:Plant Status,Followup on Previously Identified NRC Items,Operational Safety Verification,Monthly Surveillance Observation & Monthly Maint Observation

ML20245J425
Person / Time
Site:	Wolf Creek
Issue date:	04/21/1989
From:	Bruce Bartlett, Holler E, Skow M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20245J388	List: ML20245J384 ML20245J403 ML20245J425
References
50-482-89-05, 50-482-89-5, NUDOCS 8905040126
Download: ML20245J425 (18)

See also: IR 05000482/1989005

Text

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APPENDIX B f

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

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NRC Inspection Report: 50-482/89-05' Operating License: NPF-42 f

Docket: 50-482

Licensee: Wolf Creek Nuclear Operating Corporation (WCN00) .

P.O. Box 411 ')

Burlington, Kansas 66839

Facility Name: Wolf Creek Generating Station (WCGS)

Inspection At: WCGS, Coffey County, Burlington, Kansas

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Inspection Conducted: February 1-28, 1989

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s . Inspectors: !h

B. L. Bartlett, Sen %r Resident Inspector

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Project Section D, Division of Reactor

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M. E. Skow, Residght Inspector, Project Date

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Section D, Division of Reactor Projects

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Approved: -

N/ CPI!ff

E. J.UHoller, Chief, Project Section D Date

Division of Reactor Projects

8905040126 890501

PDR ADOCK 05000482

Q PDC

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' Inspection Summary

Inspection Conducted February 1-28, 1989 (Report 50-482/89-05)

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Areas Inspected: Routine, unannounced inspection including plant status,

followup on previously identified NRC items, operational safety verification,

monthly surveillance observation, monthly maintenance observation, review of

licensee event reports, onsite followup of events at operating power reactors,

and installation and testirg of modifications.

Results: Within the arcas' inspected, three apparent violations, one unresolved.

Item, and one open item were identified. The-violations dealt directly or

indirectly with the auxiliary feedwater system. One violation resulted from

not lockwiring a valve in the neutral position (paragraph 4.b), another

violation resulted from an inoperable fire barrier through one of the walls

enclosing Auxiliary Feedwater Pump "A" (paragraph 4.a), and the third violation

resulted from a failure to have control room drawings reflect as-built plant.

equipment (paragraph 9.a). The unresolved item concerned engineering followup

to an air bubble.in the auxiliary feedwater pump suction (para The

open item concerned updating the Safety Analysis Report (USAR)

to reflect sitegraph 5.b).

conditions (paragraph 9.b).

This . inspection identified an < example.of a: 2-year old minor modification made -

to a safety-system which was not reflected in permanent plant drawings.- In

October 1988, the quality assurance (QA) organization identified similar

. problems with " red 11ning" (color coding) control room drawings. _ The licensee- i

appears to be implementing corrective actions to the findings identified in the

QA audit; however the licensee does not appear to be giving adequate resources

to this corrective action. In addition, the inspector understands that it

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could be 31/2 years before the drawings are permanently changed. This practice

is discussed in paragraph 9.

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. DETAILS

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'1.. ' Persons Contacted

' Principal Licensee Personnel

1*R.,M. Grant,'Vice' President QA-

• J. A. BaileybVice President, Operations

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• G. D. Boyer, Plant Manager

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• R. W. Holloway, Manager, Maintenance and Modifications

• 0. L. Maynard. . Manager, Licensing

• B. McKinney, Manager,~0perations

• M. G. Williams, Manager, Plant-Support

• C. E. Parry, Manager, .QA, WCGS .

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

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• W. M. Lindsay, Supervisor, QA  !

• C. J. Hoch, QA Technologist.- .

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M *JJ Pippin, Manager, NPE

• S. Wideman, Licensing Specialist III

• C. W. r fler,LManager, I&C _

• T. L. . , ester, Manager, Facilities & Modification 1

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• R. S. Benedict,-Manager, Quality Control (QC)

• R. Flannigan, Manager,LNuclear Safety Engineering q -

. *J. L' Houghton,

.- Operations Supervisor

.*J. A. Weeks,-Shift Supervisor

• C. Sprout, Section Manager, NPE Systems

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• S. F. Hatch, Supervisor, Quality Systeins

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

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during the. inspection period to discuss identified issues.

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

March 7, 1989.

2. Plant-Status ,

The plant operated in Mode 1 (100 percent power) during this inspection

period. On February 2, 1989, the plant tripped from 100 percent power.

The cause'of the trip and the licensee's followup activity is discussed in

paragraph 8. The licensee returned the plant to 100 percent power on l

February 5,1989. l

3. . Followup on Previously Identified NRC Items (92702)-

(0 pen) Violation (482/88200-01): Failure to Take Adequate Corrective )

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Actions - Part three of this item concerned the chlorine monitors in the

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control room ventilation system. The monitors have been replaced and this

part of the violation is resolved. The overall violation remains open  ;

until all parts of the violation can be closed.

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4. .0perational Safety Verification (71707)

The purpose of.this inspection area was to ensure that the facility was

being operated safely and in conformance with license and regulatory

requirements. It also was to ensure that the licensee's management

control system was effectively discharging its responsibilities for

continued safe operation. The methods used to perform this inspection

area included direct observation of activities and equipment, tours of the

facility, interviews and discussions with licensee personnel, independent

verification of safety system status and limiting conditions for

operation, corrective actions, and review of facility records.

Areas reviewed during this inspection included, but were not limited to,

control room activities, routine surveillance, engineered safety feature

operability, radiation protection controls, fire protection, security,

plant cleanliness, instrumentation and alarms, deficiency reports, and

corrective actions.

Routine surveillance and operating activities witnessed and/or reviewed by

the NRC inspectors are listed below:

a. On February 25, 1989, during a routine tour of the auxiliary  !

feedwater (AFW) pump rooms, the NRC inspector observed an unsealed

3/4-inch penetration. The penetration was through the wall

separating Motor Driven (MDAFW) Pump "A" from a hallway. The MDAFW

pump "A" is located in Room 1326 (Fire Area A-14) and the hallway is

, Room 1329 (Fire Area A-33). Upon notifying the control room, the

shift supervisor initiated Work Request (WR) 01066-89 and dispatched

an operator to temporarily plug both ends of the penetration.

Discussions-with licensee personnel and review of fire hazards

analysis showed that if a fire had migrated between Rooms 1326 and

1329, through this inoperable barrier, the safe shutdown of the unit

would not have been affected.

At the conclusion of the inspection period, the licensee had not

determined the origin of the inoperable fire barrier, but had assumed

the penetration was abandoned during construction. Failure to seal

the abandoned penetration or prepare a fire protector impairment

control permit form in accordance with plant procedures is an

apparent violation (482/8905-01) of TS 6.8.1.

b. On February 8, 1989, during a routine tour of the AFW pump and valve

rooms, the NRC inspectors determined that Valve AL HV-12 (TDAFW pump

discharge to steam generator (S/G) "C") was not lockwired in neutral

as required by Procedure CKL AL-120, Revision 11, " Auxiliary

Feedwater Normal Lineup," and Drawing M-13ALO5(Q), Revision 2,

" Piping Isometric Auxiliary Feedwater Pumps Recirculation Piping."

The NRC inspector also found Valve AL V037 (MDAFW Pump "B" discharge

to S/G "D") locked as required by procedure, but the lock could be

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easily removed. When the shift supervisor was notified, operators

were dispatched and corrected the identified problems. Failure to

lock Valve AL HV-12 as required by licensee procedure is a violation

(482/8905-02).

c. On February 15, 1989, during a routine tour of the auxiliary

building, the NRC inspectors identified Valve EG LV-2 (component

cooling water surge Tank "B" fill) as not being properly lockwired in

neutral. The valve did have a lockwire, but it did not prevent the

locking yoke frem being moved. This valve type is the same as

identified in Violation 482/8905-02.

NRC inspectors have identified a previous example of the discharge

valves to the TDAFW pumps not being properly lockwired. This was

documented in Violation 482/8618-02.

The three examples of the violation listed in NRC Inspection

Report 50-482/86-18 and the examples in paragraphs b and c above indicate

a licensee problem in properly locking and maintaining locked valves of

this type. All of the valves identified in the above examples were in

their required positions.

5. _ Monthly Surveillance Observation (61726)

The purpose of this inspection area was to ascertain whether surveillance

of safety-significant systems and components were being conducted in

accordarice with TS requirements. Methods used to perform this inspection

included direct observation of licensee activities and review of records.

Items in this inspection area included, but were not limited to,

verification that:

o Testing was accomplished by qualified personnel in accordance with an

approved test procedure.

o The surveillance procedure was in conformance with TS requirements.

o The operating system and test instrumentation calibration was within

its current calibration cycle.

o Required administrative approvals and clearances were obtained prior

to initiating the test.

o Limiting conditions for operation were met and the system was

properly returned to service.

o The test data was accurate and complete and the test results met TS

requirements.

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

e below:  ;

i o STS SE-001, Revision 8, " Power Range Adjustment to Calorimetric,"

+ performed February 15, 1989.

o STS 10-255B, devision 5, " Analog Channel Operational Test Control

Room Air Intake Radiation Monitor GK RE-04," performed l

February 15, 1989.

o STS IC-255A, Revis1on 5, " Analog Channel Operational Test Control

Room Air Intake Radiation Monitor GK RE-05," performed

( February 15, 1989.

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o- . STS ' AL-103, Revision 8, " Turbine Driven Auxiliary Feedwater Pump

Inservice Pump Test," performed February 28, 1989.

.o STS IC-203, Revision 5, " Analog Channel Operational Test 7300 Process  !

Instrumentation Protection Set III (Blue)," performed

, Februa ry' 21, 1989.

o STS GG-0018, Revision 7, " Emergency Exhaust Filtration System Train

'B' 10 Hour Operability Test," performed February 28, 1989.

' Selected NRC inspector observations are discussed below:

a. The-NRC inspectors reviewed Design / Deficiency Report 89-008 concerning

errors in surveillance tests performed on two circuit breakers in

1986. Procedure STS MT-024, " Functional Test of 480, 240, and 120

Volt Molded Case Circuit Breakers," contained acceptance criteria

errors for~ Breakers NG01BEF3 (ENHV-1, Containment Spray Pump "A"

suction isolation valve) and PG2108 (Pressurizer Heater Coils 5,

6,and27). TheSurveillanceTechnicalSpecification(STS) testing

sequence required a preliminary test to measure the instantaneous-

single-phase trip current. If the results of this test were outside

the acceptance criteria, the test was to be performed on two phases

in series. (The two-phases-in-series test is utilized to conclusively

determine operability of the circuit breakers.) The single-phase

tests for the two breakers .in question were considered acceptable

when, in fact, they were not. Because incorrect acceptance criteria

for the single-phase test was used in 1986, the final two-phases-in-

series tests for the two breakers were not performed.

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As a collateral issue, the NRC inspectors observed that, in response

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to Violation 482/8632-01, the licensee had implemented a directive ,

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surveillance. This corrective action, which was implemented after

the 1986 surveillance discussed above, should catch errors such as

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using incorrect acceptance criteria. However, the directive

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discussing the maintenance engineering review was not circulated to

personnel outside the maintenance organization. Thus, maintenance

engineering depends upon the surveillance coordinator to ensure that

maintenance engineering receives all of the surveillance that they

are supposed to review.

In January 1989, the licensee discovered the acceptance criteria

error regarding the 1986 surveillance tests while entering the data

into a computer data base to be used for trending breaker

performance. The licensee decided to repeat the surveillance tests

for the two breakers. Breaker NG01BEF3 passed the single phase test

and was declared operable. ANSI /IEEE Standard 338-1977, "IEEE

Standard Criteria for the Periodic Testing of Nuclear Power

Generating Station Safety Systems," states that results of a failed

test cannot be negated by a simple successful repetition. Because of

the time interval since the failed test, this action may not have

been inappropriate in this case.

Breaker PG2108 did not pass the single phase portion of the repeated

surveillance test. STS MT-024 required the performance of the

two-phase-in-series test if the one-phase test failed; however,

this requirement was missed by the test performer who initiated a WR

to repair the breaker, rather than performing the required

two-phase-in-series test. Subsequent to the repair, the breaker

was retested and passed. This apparent violation of the requirements

of STS MT-024 has not not been cited because it meets the NRC

Enforcement Policy criteria for exercisising discretion in that it

was a self-identified, nonwillful, less significant violation for

which corrective action was taken. The licensee issued a change to

STS MT-024 to clarify the requirement for its two-phase-in-series

test.

b. During the performance of STS AL-103, the NRC inspector observed that

one of the suction lines for the TDAFW pump was below room

temperature. The other suction lines were at room temperature. Some

flow was observed coming from the high point vent line on the cold

suction line. The cold pipe was one of the essential service

water (ESW)supplylinesandwasdownstreamofValveALHV-33. The

licensee later determined that Valve AL HV-33 was leaking by and

issued a corrective WR. The licensee explained that after a

surveillance is performed to stroke test AL HV-33, the pipe from l

Valve AL HV-33 to the down stream check valve (AL V015) is drained l

and the high point vent valve (AL V139) is left open. Thus, that l

section of pipe is left filled with air. This also applies to the

other ESW line for the TDAFW pump and to the ESW lines to the MDAFW

pumps. If the AFW pumps are running and a signal occurs to shift

suction to ESW from the condensate storage tank (CST), there is a 1

possibility that the entrained air may bind the pumps or cause a

waterhamer. This portion of suction pipe was the subject of a l

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letter from the constructor to SNUPPS on March 16, 1981. The letter

proposed to SNUPPS that the section of pipe between the isolation ,

valve and the check valve be left filled with CST water, leakage from j

the continuous drain line be monitored, and this leakage be

periodically sampled. The licensee stated that they were looking {

into this issue and that corrective action was initiated. The

licensee determined that the other three similar ESW supply lines

were filled with CST grade water. They also stated that the

surveillance procedure would be changed to leave the suction lines

filled with water. Pending review of the licensee's evaluation of j

pump operability, this is considered an unresolved j

item (482/8905-04). The licensee later discovered that S/G water i

chemistry and condenser hotwell chemistry were out of specifications l

and trending up. Investigation revealed that Valve AL HV-033 had

leaked by enough to overcome the continuous vent and flow through the

AFW recirculating line to the CST. The licensee adjusted

Valve AL HV-033 to lower its leak rate and commenced cleanup of the

CST.

6. Monthly Maintenance Observation (62703)

The purpose of this inspection area was to ascertain that maintenance

activities of safety-related systems and components were conducted in

accordance with approved procedures and TS. Methods used in this

inspection area included direct observation, personnel interview, and i

record review.

Items verified in this inspection area, where appropriate, included:

o Activities did not violate limiting conditions for operation and that

redundant components were operable.

! o Required administrative approvals and clearances were obtained before

l initiating work.

o Radiological controls were properly implemented.

l o Fire prevention controls were implemented.

o Required alignments and surveillance to verify postmaintenance

! operability were performed.

o Replacement parts and materials used were properly certified.

o Craftsmen were qualified to accomplish the designated task and

additional technical expertise was made available when needed.

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

control personnel observed designated work activities.

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o Procedures used were adequate, approved, and up'to date.

4 ,x , Portions of the selected maintenance activities were observed on the WRs

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listed below and related documents were reviewed by the NRC inspectors:

/ No. Activity

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WR 50246-89 Monthly maintenance on DC emergency

lights

WR 05444-88 Repair Condenser Relief Valve SG K04A

WR 01089-89 GK V765 hydro motor forLSGK04A, repair

oil leak under terminal block

WR 50011-89 Control Room Air Conditioning Unit

SGK04A - 5 year replacement of contactor

WR 50212-89 Turbine building supply fans - semiannual

fan inspection

WR 50213-89 Turbine building supply fans perform

2-month maintenance

Selected NRC inspector observations are discussed below: l

o During the performance of WR 50011-89, the maintenance workers .

observed that the replacement contactor was slightly different from

the old contactor. The workers reverified that they had the correct

part and then commenced the replacement. When the workers attempted

to reland the center lug, they discovered that it would not fit. The

workers. suspended the replacement and contacted maintenance

engineering. Later, the lug was trimmed slightly in accordance with

plant procedures and the contactor replacement was completed. The

workers were observed to perform their associated tasks in a

professional manner and to request assistance as needed.

o The workers performing WR 50212-89 and WR 50213-89 made use of

temporary scaffolding. The temporary scaffolding had been in place

for several years and, to date, there are no plans to install

permanent scaffolding. The licensee informed the NRC inspectors that

an engineering evaluation request (EER) had been issued to install

permanent scaffolding. The EER was issued on November 30, 1988.

No violations or deviations were identified.

7. Review of Licensee Event Reports (LERs) (92700)

During this inspection period, the NRC inspectors performed followup on

WCGS LERs. The LERs were reviewed to ensure:

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L o . Corrective action stated in the report ha's been properly completed or

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o Response to the event was. adequate.

o' Response to the event met license conditions, commitments, or other

l applicable regulatory requirements.

H -o The'information contained in the report satisfied applicable

reporting requirements.

,o Generic issues /were-identified.

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'The following LER was. reviewed and closed:

o 89-004, " Loose' Terminal Connections:Cause Main Steam Isolation' Valve

Closure Resulting in Reactor Trip." This LER is discussed in

paragraph 8 and is closed.

During the refueling outage in 1988, the licensee replaced the chlorine

monitors in the' control room ventilation system. These chlorine monitors

.have been the. subject of several LERs reporting engineered safety feature-

actuations/ control room ventilation isolation signals. In most cases, the-

problems were because of chlorine' sensitive paper tape malfunctions. The-

paper tape would break or bunch giving false indications. Frequently, no

specific-root cause of the paper problem was found and the licensee

' decided to replace the chlorine monitors. The new monitors have been.in

service for approximately 2 months and have not caused any false 6ctuation

signals. The chlorine monitor issue was also discussed in NRC Inspection

Report 50-482/88-17, although no specific inspection finding was issued.

The following'LERs all relate to the replaced chlorine monitors and are

"Iclosed:

o 87-032, " Engineered Safety Features Actuation - Control Room

Ventilation Isolation Signal

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Caused By Paper Tape Breaking On

Chlorine Monitor"

• o 87-035, " Engineered Safety Features Actuation - Control Room

h Ventilation Isolation Signals - Two Events - Caused By Malfunctions

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Of The Chlorine Monitors"

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, o 87-053, " Engineered Safety Features Actuation - Control Room  !

Ventilation. Isolation Signal Caused By Paper Tape Bunching Up On

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Chlorine Monitor"'

o 88-003', " Engineered Safety Features Actuation - Control Room

Ventilation Isolation Signal Caused By Paper Tape Spurious Spike On

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Chlorine Monitor"

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o 88-005, " Engineered Safety Features Actuation - Two Control Room

Ventilation Isolation Signals Caused By Malfunctions Of The Chlorine

Monitors"

o 88-006, " Engineered Safety Features Actuation - Control Room

Ventilation Isolation Signal Caused By Paper Tape Spurious Spike Of A

Chlorine Monitor"

o 88-008, " Engineered Safety Features Actuation - Control Room

Ventilation Isolation Signal Caused By Paper Tape Breaking On

Chlorine Monitor"

o 88-010, " Engineered Safety Features Actuation - Control Room

Ventilation Isolation Signal Caused By Loss Of Power To Chlorine

Monitor"

o 88-011', " Engineered Safety Features Actuation - Control Room

Ventilation Isolation Signal Caused By Paper Tape Breaking On

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Chlorine Monitor"

o 88-012, " Engineered Safety Features Actuation - Control Room

Ventilation Isolation Signal Caused By Failed Photocell On Chlorine

Monitor"

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o 88-013, " Engineered Safety Features Actuation. ' Control Room

' Ventilation Isolation Signal Caused By Paper Tape Bunched Up On

Chlorine Monitor"

o 88-022, " Engineered Safety Features Actuation - Control Room

Ventilation Isolation Signal Caused By Loss Of Power To Chlorine

Monitor"

o 88-026, " Engineered Safety Features Actuation - Control Room

Ventilation Isolation Signal Caused By Paper Tape Bunched Up On

Chlorine Monitors" q

8. Onsite Followup of Events at Operating Power Reactors (93702)

The purpose of this inspection activity was to provide onsite inspection

of events at operating power reactors. Specific inspection activities

included:

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o Observing plant status,

o Evaluating the significance of the events, performance of safety

systems, and' actions taken by the licensee.

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o Confirming that the licensee had made proper notification of the

events and of any new developments or significant changes in plant

conditions.

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, o . Evaluating the need for further or continued NRC response to the-

events.

The following items were considered during the followup:

o Details regarding the cause of the event.

o Event chronology.

o Functioning of safety systems'as required by plant conditions.

o Radiological consequences and personnel exposure.

o Proposed licensee actions to correct the cause of the event.

o, Corrective actions taken or planned prior to resumption of facility

operations.

. The event that occurred.during this report period is listed in the table

below:

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Date Event Plant Status Cause

- 02/02/89. Reac. or Trip Mode 1 Loose screw

(100% power)

Selected NRC inspector observations are discussed below:

o un February 2, 1989, at 1:22 p.m. /CDT) the plant tripped on low-low

water level in Steam Generator "f." The cause of the low level was a

pressure spike resulting from the tast closure of "C" main steam

isolation valve (MSIV).

An' instrumentation and control technician was performing work inside

one of,the solid state protection system (SSPS) cabinets and

apparently contacted a plastic cable raceway housing the wiring for

the actuation logic for "C" MSIV. Loose screws inside the housing

caused a single train fast closure signal to be generated. All

equipment functioned as designed with two exceptions:

a. Immediately following .the reactor trip, crtrol room

instrumentation indicated that MSIV "C" hE not fully closed. A

senior' reactor operator (SRO) dispatchM i the MSIV observed

what he thought was MSIV "C" going slow closed. Licensee

troubleshooting efforts identified indications that the valve

did fast close and the SRO had seen normal valve pulsations.

The MSIV passed surveillance testing and was returned to

service.

b. As would be expected for an MSIV closure at full power, the

licensee observed two main steam code safety valves lift and

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reseat. One valve, however, was observed to have some slight

seat' leakage. After evaluation of appropriate accident

scenarios, the licensee concluded that this slight leakage did

not endanger public health and safety and was acceptable for a

plant restart. The leakage has since_ stopped.

The licensee was unable to determine the root cause of the Icase

screw. However, the licensee did perform a check of all other vendor

connections in the SSPS cabinets, balance of plant engineered safety

features cabinets, process / control cabinets, reactor trip breaker

cubicles, main control boards, and other control room cabinets.

Overall, the number of loose screws was less than 1 percent.

Generally, the licensee considered as loose any screw which could be

tightened by a technician more than 25 percent of a turn. Most of.

the SSPS cabinet connections were loose; however, there have been no

surveillance failures attributable to these loose screws. A check of

these screws will be added to the preventative maintenance program.

LER 482/89-004 is closed.

No violations or deviations were identified.

9. Installation and Testing of Modifications (37828)

The purpose of this inspection was to evaluate onsite activities and

hardware associated with the installation of plant modifications and to

ascertain that related modification activities, which are not submitted

for approval to the NRC, are in conformance with NRC requirements. The

NRC inspectors examined installed hardware to selectively verify that the

modifications conformed to licensee drawings. This included confirmation

of equipment model or serial numbers, dimensions, materials, sizes, heat

numbers, and lot numbers.

Two plant modification requests (PMRs) were se M ted for review. One PMR

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required field installation work and one PMR required documentation

l change.

Selected NRC inspector observations are discussed below;

a. PMR 00264/KN84-088, " Aux Feedwater Pump Recirculation Flow

Indication" - TSSR 4.7.1.2.1.a requires that, at least once per

31 days, one of the AFW pumps be tested on recirculation flow for

proper discharge pressure. The original system design had a flow

orifice and connection points for a differential pressure gauge in

l* each recirculating line; however, test instrumentation

(flow-indicators) had to be installed and removed for each test. ,1

PMR 00264, Revision 1, installed permanent flow indicators'(actual

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< field work was done under WR 05000-86 and WR Package 01359-86) during

ib the Fall 1986 refueling outage. .j

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I The NRC inspector's field walkdown identified one discrepancy.

Installation Drawing PMP CS-545-W-J-14AL26(Q), Revision 0, for Flow

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Indicator AL FI-49, and Drawing PMP CS-545-W-J-14AL28(Q), Revision 0,

for AL FI-51, both specify that the instrument tubing slope be at

least 1 inch per foot (i.e., greater than or equal to 0.083). The

NRC inspector's measurements showed that for AL FI-49 the high side

tubing had a slope of 0.058 and the low side tubing had a slope of

0.044 and that for AL FI-51 the high side tubing had a slope of 0.057

and the low side tubing had a slope of 0.058. Procedure CNT-700,

Revision 0, " Fabrication and Installation of Instrumentation,"

Step 4.8.1.1.c states that a horizontal and/or vertical roll of up to

(+ or -) 1 1/2 inches can be used and that the vertical roll shall

not violate the minimum slope criteria specified on the instrument j

isometric drawings. In addition, Step 5.8.1.1.5 on QC has the QC

insp6 verify that tubing is sloped per design drawings. However,

the s_; +ry of the tubing run is such that changes to the slope

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could occur because of maintenance or other activity in the vicinity

of the tubing after installation.

Upon notification of the NRC inspector's findings, the licensee

dispatched QC and construction personnel to evaluate the tubing.

Using more accurate methods, the licensee determined that the tubing

for AL FI-49 did meet acceptance criteria and that the tubing for

AL FI-51 was sloped at 0.9 inches per foot and 0.6 inches per foot.

Licensee personnel stated that the slight deviation did not invalidate

the design pu gose of the pipe slope. The licensee issued

WR 01217-89 to ask for an engineering disposition of this condition

and issued Programmatic Deficiency Report PQ 89-02 to address

programmatic concerns.

During the procurement phase of PMR 00264, the licensee identified

inconsistencies between the measured monthly surveillance flowrates

and the design flowrates. This became readily apparent during

attempts to use the new instrumentation. Using design flowrates, the

flow instruments that were installed had a range of 0 to 100 gallons

per minute (gpm). Flow rates during surveillance are up to 135 gpm.

The new flow indicators for the MDAFW pumps were unusable and test

instruments had to be used again. The flow indicator for the TDAFW

pump was 0 to 200 gpm, and was not overranged. The licensee

identified three issues:

(1) The new instruments were unusable;

(2) Too much flow might be going through the recirculating line

during normal injection lineups and preventing a proper amount

of flow from being injected into the steam generators; and

(3) The high recirculating flows could be causing erosion / corrosion

of the recirculating lines.

The licensee's engineering evaluation of Issue No. 2 showed that, at

present, the AFW pumps were supplying the required flow to the S/Gs.

However, over time, normal wear of the pumps would cause flows to be

reduced. Issue No. 3 and the long-term portion of Issue No. 2 caused

the licensee to consider adding throttle valves in the recirculating

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line. This would reduce the flow rate through the recirculating line

and, thus, the erosion / corrosion rate. It would also reduce the flow

rate to a point within the range of the newly installed

instrumentation.

This new design was identified as PMR 00264, Revision 2, and was

originally planned to be implemented during Refueling Outage III.

However, the modification was not perfomed and engineering failed to

realize this until the NRC inspector asked for a copy of Request For

Engineering / Design Assistance (REDA) N-P-8136-AL, Revision 1. Block 3

of the REDA states, in part, that the existing design is not an

acceptable long-term solution. Block 5, required date of completion

states, that the design is to be implemented by Refuel III. Upon

realizing that a recommended modification was not completed on time,

the licensee analyzed the existing flows to ensure that all AFW pumps

still met their required flows and performed ultrasonic inspection of

critical areas of the AFW recirculating piping. No erosion / corrosion

areas were found. The licensee currently plans to perform PMR 00264,

Revision 2, during Refueling Outage IV, scheduled to start in March

of 1990.

PMR 00264, Revision 1, had been completed in December 1986, however,

as of the date of this inspection, plant drawings still had not been

updated to show this modification. When questioned, the licensee

stated that because the PMR was still being implemented, the drawings

had not been "as-built." Because Revision 2 may not be completed

until mid-1990, this could mean that control room drawings would be

" redlined" for 31/2 years, before having Revision 1 incorporated.

In addition, upon checking the control room drawings to ensure that

they had been properly " redlined," the NRC inspector determined that

the " redlining" was missing. When the licensee was notified, the

drawings were promptly " redlined." Failure to color code (" redline")

drawings to reflect changes in accordance with licensee procedures is

an apparent violation (482/8905-03).

In October of 1988, licensee M Surveillance TE: 53359 S-1659,

" Redlining Control Room Drawings," identified licensee failures to

keep control room drawings up to date. QA issued violations and the

licensee initiated corrective actions. While the " redlining" of

drawings has improved dramatically, the results of this inspection

show that there are problems that still remain to be corrected. In

addition, the NRC inspectors believe that the practice of not

updating drawings in a timely fashion contributes to " redlining"

problems such as cluttered or, in the worst case, illegible drawings.

The NRC inspectors informed the licensee that having modifications

made to the plant for 3 1/2 years before drawings were updated was

not, in their view, a good practice. The licensee is encouraged to

review its policy regarding this practice.

Licensee documentation reviewed during the performance of this part

of the inspection is listed in Attachment 1.

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b. The NRC inspectors reviewed PMR 2736 which revised the surveillance

testoftheultimateheatsink(UHS). This, in turn, led to a review )

of the surveillance test and . test results. The surveillance includes I

checks for movement of the UHS dam, sedimentation of the UHS, and

sedimentation of the intake channel to the ESW intake structure. The

surveillance was compared with TS surveillance requirements and the

USAR. In the " Periodic Inspection Report for Ultimate Heat Sink and

Associated Safety Related Structures" approved April 5,1988, the

licensee discussed an approximately 23 acre-feet (A-ft)

sedimentation. USAR Section 2.4.11.6 states that the maximum

estimated sedimentation is 33 A-ft/ square mile over 40 years. The

UHS was sized for two units and the licensee.had a study performed on

this issue. The new study, according to the April 5, 1988.

inspection report, showed that only 24 A-ft could be lost to

sedimentation and still support a two-unit shutdown; however,

129 A-ft could be lost and still support one unit shutdown. The

results of this study have not been reflected in the USAR. This is

considered an open item pending the licensee's revision.of the USAR

(482/8905-05).

10. Exit Meeting

The NRC inspectors met with licensee representatives (denoted in

paragraph 1) on March 7,1989. The NRC inspectors summarized the scope

and findings of the inspection. The licensee did not identify as

proprietary any of the information provided to, or reviewed by, the NRC

inspectors.

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ATTACHMENT 1

PMP-CS-545-W-J-14AL26(Q), Revision 0, " Turbine Driven Auxiliary Feedwater

Pump Flow-Instrument Isometric Drawing"'

PMP-CS-545-W-J-14AL27(Q), Revision 0, " Motor Driven Auxiliary Feedwater

Pump "A" Flow-Instrument Isometric Drawing"

PMP-CS-545-W-J-14AL28(Q), Revision 0, " Motor Driven Auxiliary Feedwater

Pump "B" Flow-Instrument Isometric Drawing"

J-07G37(Q), Revision 2, " Instrument Tubing Clamp Mounting Q Instrument

Installation"

J-07G17(Q), Revision 7, " Instrument Tubing Support"

J-07D12(Q), Revision 3, " Instrument Mounting Detail D.P. Indicator

(Barton) Packless Manifold"

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J-07G05(Q), Revision 6, "Five Valve Manifold Auxiliary Mounting Brackets"

J-07G01(Q), Revision 10, " Instrument Mounting Structure Floor Stand"

M-13ALO5(Q), Revision 2, " Piping Isometric Auxiliary Feedwater Pumps

Recirculation Piping"

J-07G22(Q), Sheets 1 and 2, Revision 11, " Bill of Materials "Q" Instr.

Installations"

C-1037(Q), Revision 0, " Civil Structural Standard Details Sheet No. 34"

M-12AL01, Revision 0, " Piping & Instr. Diag. Aux. Feedwater System"

KGP-1131, Revision 6, " Plant Modification Process"

CNT-700, Revision 0, " Fabrication and Installation of Instrumentation"

ADM 01-042, Revision 12, " Plant Modification Request Implementation"

Work Request 05000-86, Install Flow Indicators AL FI-49, -50, and -51

3

Work Request Package 03159-86, Install Flow Indicators AL FI-49, -50, and

-51

Field Change Request KN84-088-I-002 i

Plant Modification Request 00264/KN84-088, Revision 1, " Aux Feedwater Pump

Recirculation Flow Indication"

Nonconformance Report M-1318, Revision 0, " Items received built to a

different code edition"

Field Change Request KN84-088-C01

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QA Surveillance TE: 53359 S-1659,." Redlining Control Room Drawings"

QA Surveillance TE: 53359 S-1629, " Plant Modification Requests"

QA Audit TE: 50140-K?.11, " Modifications"

PMR 00264/KN84-088, Revision 2, draft

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