ML20245J425
| 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: |
| References | |
| 50-482-89-05, 50-482-89-5, NUDOCS 8905040126 | |
| Download: ML20245J425 (18) | |
See also: IR 05000482/1989005
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APPENDIX B
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
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NRC Inspection Report:
50-482/89-05'
Operating License:
Docket:
50-482
Licensee: Wolf Creek Nuclear Operating Corporation (WCN00)
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P.O. Box 411
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Burlington, Kansas 66839
Facility Name:
Wolf Creek Generating Station (WCGS)
Inspection At: WCGS, Coffey County, Burlington, Kansas
Inspection Conducted:
February 1-28, 1989
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. Inspectors:
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B. L. Bartlett, Sen %r Resident Inspector
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Project Section D, Division of Reactor
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Projects
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M. E. Skow, Residght Inspector, Project
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Section D, Division of Reactor Projects
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Approved:
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E. J.UHoller, Chief, Project Section D
Date
Division of Reactor Projects
8905040126 890501
ADOCK 05000482
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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
open item concerned updating the Safety Analysis Report (USAR) graph 5.b).
to an air bubble.in the auxiliary feedwater pump suction (para
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to reflect site
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-
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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
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is discussed in paragraph 9.
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' Persons Contacted
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' 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
- A. A. Freitag,' Manager,. Nuclear Plant Engineering-(NPE), WCGS
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- W. M. Lindsay, Supervisor, QA
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- C. J. Hoch, QA Technologist.-
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- JJ Pippin, Manager, NPE
- S. Wideman, Licensing Specialist III
- C. W. r fler,LManager, I&C
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- T. L. . , ester, Manager, Facilities & Modification
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- R. S. Benedict,-Manager, Quality Control (QC)
- R. Flannigan, Manager,LNuclear Safety Engineering
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. J. L' Houghton, Operations Supervisor
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.*J. A. Weeks,-Shift Supervisor
- C. Sprout, Section Manager, NPE Systems
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- S. F. Hatch, Supervisor, Quality Systeins
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
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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
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February 5,1989.
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3.
. Followup on Previously Identified NRC Items (92702)-
(0 pen) Violation (482/88200-01): Failure to Take Adequate Corrective
)
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
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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
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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
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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.
_ Monthly Surveillance Observation (61726)
5.
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:
Testing was accomplished by qualified personnel in accordance with an
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approved test procedure.
The surveillance procedure was in conformance with TS requirements.
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The operating system and test instrumentation calibration was within
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its current calibration cycle.
Required administrative approvals and clearances were obtained prior
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to initiating the test.
Limiting conditions for operation were met and the system was
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properly returned to service.
The test data was accurate and complete and the test results met TS
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requirements.
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Surveillance witnessed and/or reviewed by the NRC inspectors are listed
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STS SE-001, Revision 8, " Power Range Adjustment to Calorimetric,"
performed February 15, 1989.
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STS 10-255B, devision 5, " Analog Channel Operational Test Control
Room Air Intake Radiation Monitor GK RE-04," performed
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February 15, 1989.
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STS IC-255A, Revis1on 5, " Analog Channel Operational Test Control
Room Air Intake Radiation Monitor GK RE-05," performed
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February 15, 1989.
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. STS ' AL-103, Revision 8, " Turbine Driven Auxiliary Feedwater Pump
Inservice Pump Test," performed February 28, 1989.
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STS IC-203, Revision 5, " Analog Channel Operational Test 7300 Process
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Instrumentation Protection Set III (Blue)," performed
, Februa ry' 21, 1989.
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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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for maintenance engineering to review completed maintenance
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
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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
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Valve AL HV-33 to the down stream check valve (AL V015) is drained
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and the high point vent valve (AL V139) is left open. Thus, that
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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
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possibility that the entrained air may bind the pumps or cause a
waterhamer. This portion of suction pipe was the subject of a
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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
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valve and the check valve be left filled with CST water, leakage from
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the continuous drain line be monitored, and this leakage be
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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
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pump operability, this is considered an unresolved
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item (482/8905-04). The licensee later discovered that S/G water
chemistry and condenser hotwell chemistry were out of specifications
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
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record review.
Items verified in this inspection area, where appropriate, included:
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Activities did not violate limiting conditions for operation and that
redundant components were operable.
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Required administrative approvals and clearances were obtained before
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initiating work.
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Radiological controls were properly implemented.
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Fire prevention controls were implemented.
Required alignments and surveillance to verify postmaintenance
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operability were performed.
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Replacement parts and materials used were properly certified.
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Craftsmen were qualified to accomplish the designated task and
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additional technical expertise was made available when needed.
Quality control hold points and/or checklists were used and quality
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control personnel observed designated work activities.
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Procedures used were adequate, approved, and up'to date.
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:
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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
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Selected NRC inspector observations are discussed below:
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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.
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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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. Corrective action stated in the report ha's been properly completed or
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' work is in progress.
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Response to the event was. adequate.
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Response to the event met license conditions, commitments, or other
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applicable regulatory requirements.
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The'information contained in the report satisfied applicable
reporting requirements.
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Generic issues /were-identified.
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'The following LER was. reviewed and closed:
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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.
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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:
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87-032, " Engineered Safety Features Actuation - Control Room
Ventilation Isolation Signal Caused By Paper Tape Breaking On
Chlorine Monitor"
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87-035, " Engineered Safety Features Actuation - Control Room
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Ventilation Isolation Signals - Two Events - Caused By Malfunctions
Of The Chlorine Monitors"
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87-053, " Engineered Safety Features Actuation - Control Room
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Ventilation. Isolation Signal Caused By Paper Tape Bunching Up On
Chlorine Monitor"'
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88-003', " Engineered Safety Features Actuation - Control Room
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Ventilation Isolation Signal Caused By Paper Tape Spurious Spike On
Chlorine Monitor"
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88-005, " Engineered Safety Features Actuation - Two Control Room
Ventilation Isolation Signals Caused By Malfunctions Of The Chlorine
Monitors"
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88-006, " Engineered Safety Features Actuation - Control Room
Ventilation Isolation Signal Caused By Paper Tape Spurious Spike Of A
Chlorine Monitor"
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88-008, " Engineered Safety Features Actuation - Control Room
Ventilation Isolation Signal Caused By Paper Tape Breaking On
Chlorine Monitor"
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88-010, " Engineered Safety Features Actuation - Control Room
Ventilation Isolation Signal Caused By Loss Of Power To Chlorine
Monitor"
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88-011', " Engineered Safety Features Actuation - Control Room
Ventilation Isolation Signal Caused By Paper Tape Breaking On
Chlorine Monitor"
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88-012, " Engineered Safety Features Actuation - Control Room
Ventilation Isolation Signal Caused By Failed Photocell On Chlorine
Monitor"
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88-013, " Engineered Safety Features Actuation. ' Control Room
' Ventilation Isolation Signal Caused By Paper Tape Bunched Up On
Chlorine Monitor"
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88-022, " Engineered Safety Features Actuation - Control Room
Ventilation Isolation Signal Caused By Loss Of Power To Chlorine
Monitor"
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88-026, " Engineered Safety Features Actuation - Control Room
Ventilation Isolation Signal Caused By Paper Tape Bunched Up On
Chlorine Monitors"
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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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Observing plant status,
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Evaluating the significance of the events, performance of safety
systems, and' actions taken by the licensee.
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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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. Evaluating the need for further or continued NRC response to the-
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events.
The following items were considered during the followup:
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Details regarding the cause of the event.
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Event chronology.
Functioning of safety systems'as required by plant conditions.
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Radiological consequences and personnel exposure.
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Proposed licensee actions to correct the cause of the event.
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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
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(100% power)
Selected NRC inspector observations are discussed below:
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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
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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
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each recirculating line; however, test instrumentation
(flow-indicators) had to be installed and removed for each test.
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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
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the Fall 1986 refueling outage.
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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
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isometric drawings.
In addition, Step 5.8.1.1.5 on QC has the QC
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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
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of the surveillance test and . test results. The surveillance includes
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
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Work Request Package 03159-86, Install Flow Indicators AL FI-49, -50, and
-51
Field Change Request KN84-088-I-002
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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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