ML20140E382

Insp Rept 50-482/85-38 on 851201-860104.Violation Noted: Failure to Establish Procedures for Certain Activities That Could Affect Performance of safety-related Equipment

ML20140E382
Person / Time
Site:	Wolf Creek
Issue date:	01/22/1986
From:	Bruce Bartlett, Cummins J, Hunnicutt D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20140E374	List: ML20140E369 ML20140E375 ML20140E382
References
RTR-REGGD-01.033, RTR-REGGD-1.003, RTR-REGGD-1.033 50-482-85-38, IEB-85-002, IEB-85-2, NUDOCS 8602030235
Download: ML20140E382 (13)

See also: IR 05000482/1985038

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APPENDIX B

US NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-482/85-38 LP: NPF-42

Docket: 50-482

Licensee: Kansas Gas and Electric Company (KG&E)

Post Office Box 208

Wichita, Kansas 67201

Facility Name: Wolf Creek Generating Station (WCGS)

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

Inspection Conducted: December 1, 1985 to January 4, 1986

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Inspectors: [hn{@d ,

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J. E. Cummins, Senior Resident Inspector, Date

Operations

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B. L. Bartlett, Resident Reactor Inspector,

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Operations

Approved: h[ EM

-D. M. Hunnicutt, Acting Chief, Project

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Section B, Reactor Projects Branch 2

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Inspection Summary

Inspection' Conducted December 1, 1985 to January 4, 1986 (Report 50-482/85-38)

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Areas Inspected: Routine, unannounced inspection including plant status,

followup on previously identified items, operational safety verification,

engineered safety features system walkdown, onsite followup of events, followup

of IE Bulletins, monthly maintenance observation, monthly surveillance

observation, environmental protection, interview of shift advisors, fire

protection, plant tours, and Quality First (Q1) file review.

The inspection involved 229 inspector-hours onsite by two NRC inspectors

including 33 inspector-hours onsite during offshifts.

- Results: Withinthe13areasinspected,oneviolationwasidentified(failure

to establish procedures for certain activities that could affect the

performance of safety-related equipment, paragraph 13).

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DETAILS

1. Persons Contacted

Principal Licensee Personnel

G. L. Koester, Vice President-Nuclear

• J. A. Bailey, Interim Site Director

• F. T. Rhodes, Plant Superintendent

M. Nichols, Supt. of P1 ant Support

• J. A. Zell, Operations Superintendent

• M. G. Williams, Superintendent of Regulatory, Quality, and

Administrative Services

0. L. Maynard, Licensing Supervisor

• K. Peterson, Licensing

H. K. Chernoff, Licensing

• G. Pendergrass, Licensing

-*G. P. Rathbun, Manager, Engineering and Technical Services Support

• R. M. Grant, Director-Quality

• W. J. Rudolph, Site QA Manager

J. J. Johnson, Chief of Security

D. Erbe, Security Shift Lieutenant

• W. M. Lindsay, Quality Systems Supervisor

C. Sprout, Facilities Engineering and Analysis

A. Freitag, Nuclear Plant Engineering

G. Reeves, Supt. of Quality Control

K. Ellison, Compliance Engineer

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

January 7, 1986,

2. Plant Status

The plant operated in Mode 1 during this inspection period.

3. Followup on Previously Identified NRC Items

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(Closed) Unresolved Item (50-482/8302-01): Incomplete Testing of Class 1E

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_4160 Volt Electrical System.

This item involved NRC inspector concerns over the adequacy of the

4160 volt Class 1E system. The NRC inspector reviewed all 4160 volt

Class 1E preoperational test packages, their deficiencies and resolutions

to their deficiencies. This item is closed.

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(Closed) Open Item (50-482/8432-01): Cleanliness Controls in Maintenance

i Procedures

This item tracked a licensee agreement to review and revise, if necessary,

all maintenance procedures to ensure cleanliness controls were specified

in them. Following the licensee's review, the NRC inspector reviewed the

following randomly selected maintenance procedures and verified that

cleanliness controls were specified in them:

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MPM M711Q-02, Revision 1, Primary Manway Covers Removal / Installation

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MPM M712Q-01, Revision 2, Reactor Coolant Pump Seal Inspection

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MPM M713Q-01, Revision 2, Pressurizer Manway Cover and Maintenance

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MCM M221Q-01, Revision 2, 150-300 lb Manually Operated Gate, Globe,

and Swing Check Valves

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MPM M141-01, Revision 2, Crosby Type J0-WR Relief Valve Maintenance

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MPM M72Q-01, Revision 3, Residual Heat Removal Pump Mechanical Seal

Removal and Replacement

i This item is closed.

The following two items were incorrectly numbered when closed in NRC

Inspection Report 50-482/84-55:

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(Closed) Open Item (50-482/8449-05): This item tracked licensee

responce to NRC comments on Administrative Procedures ADM 01-001,

002, and 003. The licensee adequately resolved these comments on

December 3, 1984. This item was incorrectly identified as Item

No. 482/8449-03.

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(Closed) Open Item (50-482/8449-04): This item tracked licensee

response to NRC comments on Procedure SU3-EJ01. The licensee has

resolved the comments to the inspector's satisfaction. This item was

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incorrectly identified as Item No. 482/8449-02.

4. 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 and direct interview, verified that the

physical security plan was being implemented in accordance with the

security plan. The NRC inspectors, by observation and review of

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documents, verified that radiation protection activities were controlled,

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By observing valve pasitions, electrical breaker positions, and control

room indications, the NRC inspectors confirmed the operability of the

component cooling water system, Class 1E 4160 volt AC electrical system

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the the auxiliary feedwater system. The NRC inspectors also visually

inspected safety components for leakage, physical damage, and any other

impairment that could prevent them from performing their designed

function.

No violations or deviations were identified.

5. Engineered Safety Features (ESF) System Walkdown

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

selected accessible portions of the systems. The NRC inspectors verified

valves and electrical circuit breakers were in the required position,

power was available, and valves were locked where required. The NRC

inspectors also inspected system components for damage or other conditions

that could degrade system performance. The ESF systems listed below were

walked down during this inspection report period:

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Residual Heat Removal System

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Safety Injection System

No violations or deviations were identified.

6. Onsite Followup of Events

The NRC inspectors performed onsite followup of nonemergency events that

occurred during this report period. The NRC inspectors discussed each

event with cognizant licensee personnel and reviewed logs and computer

printouts related to the event. When available, the NRC inspectors

observed control room personnel response and instrumentation indicators of

reactor plant parameters. The NRC inspectors verified that the licensee

had responded to the event in accordance with procedures and had notified

the NRC and other agencies when required in a timely fashion.

ESF actuations that occurred during the report period are listed in the

table below. The NRC inspector will review the L; cense Event Report (LER)

for each of these events and will report any findings in subsequent NRC

inspection reports.

Date Event * Plant Status Cause

12/9/85 CRVIS Mode 1 Broken Tape

12/9/85 CRVIS Mode 1 Broken Tape

12/10/85 CRVIS Mode 1 Broken Tape

12/13/85 CRVIS Mode 1 Broken Tape

12/18/85 CRVIS Mode 1 Broken Tape

• CRVIS-Control room ventilation isolation signal

Selected NRC inspector observations are discussed below:

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On December 14, 1985, at approximately 0117 hours0.00135 days <br />0.0325 hours <br />1.934524e-4 weeks <br />4.45185e-5 months <br /> CST, licensee security

personnel reported heavy smoke and flame coming from a paint shop located

outside of the protected area boundary and approximately 900' west of

the radwaste building. The fire brigade was mustered and Off-Normal

Procedure 0FN-00-16, " Fire Response," was entered. At 0126 hours0.00146 days <br />0.035 hours <br />2.083333e-4 weeks <br />4.7943e-5 months <br /> the city

of Burlington Fire Department was called and arrived onsite at 0145 hours0.00168 days <br />0.0403 hours <br />2.397487e-4 weeks <br />5.51725e-5 months <br />.

It required approximately 2,550' of hose, 24,000 gallons of water, and

41 minutes to bring the fire under control. It required an additional

21 minutes to extinguish tne remaining significant hot spots. As stated in

Wolf Creek Event Report 85-135, low temperatures and the distance to a

reliable water source (approximately 600' contributed significantly to

the damage caused by the fire and the difficulty in achieving extinguish-

ment. The fire did not at any time threaten any safety-related equipment

required for.the safe shutdown of the plant.

The following licensee defect / deficiency reports ** were reviewed:

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85-90 - Turbine Trip

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85-91 - Feedwater Isolation System (FWIS)

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85-92 - Reactor Trip

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85-93 - FWIS

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85-97 - CRVIS

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85-98 - CRVIS- 85-102 - Reactor Trip

- 85-103 - CRVIS- 85-108 - CRVIS- 85-123 - Missed Hourly Fire Watch

- 85-148 - Area 5 Floor Drains Capped

- 85-152 - Three Fire Dampers Not Installed

The following Wolf Creek Event Reports *** were reviewed:

- 85-132 - 50 MW Turbine Runback

- 85-135 - Paint Shop Fire

• • A defect / deficiency is an internal licensee report on defects and/or

deficiencies found in design or construction. These reports are issued to

appropriate personnel and agencies.

• • • Wolf Creek Event Reports are events that are not specifically

reportable as a defect / deficiency report but are events which plant

management should be made aware of.

No violations or deviations were identified.

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7. Followup of IE Bulletins (IEB)

The NRC inspector, by review of documents, verified that the IEB discussed

below had been reviewed and appropriately acted upon by the licensee.

6aq: rd) IEB 85-02: Undervoltage Trip Attacb5 ants of Westinghouse DB-50

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iysg_9eactorTripBreakers(RTB).

This IEB informed licensees of re11 ability prc51 ems with Westinghouse

DB-50 Type RTBs and specified additional testing that should be performed

on RTBs that had not yet been modified with an automatic shunt trip. This

IEB is closed based on the following:

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The RTBs at WCGS are not Westinghouse Type DB-50. The RTBs at WCGS

are Type 05-416.

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The RTBs at WCGS have been modified to include a shunt trip feature.

This modification was done in accordance with Westinghouse SAPM

10661, " Addition of Automatic Shunt Trip Feature and Time Response

Test Point." This modification and related testing were reviewed by

an NRC inspector and found to be acceptable. The NRC inspector

review was documented in NRC Inspection Report 50-482/84-44

(paragraph 4, Inspection of Generic Letter 83-28).

No violations or deviations were identified.

8. 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:

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Limiting conditions for operation (LCO) were met and, where

applicable, redundant components were operable.

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Activities complied with adequate administrative controls.

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

used.

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Craftsmen.were qualified to accomplish the designated task and

technical' expertise (i.e., engineering, health physics, operations)

were made available when appropriate.

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Replacement parts and materials being used were properly certified.

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Required radiological controls were implemented.

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Fire prevention controls were implemented where appropriate.

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Required alignments and surveillances to verify post maintenance

operability were performed.

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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

Request (WR) listed below were observed and related documentation reviewed

by the NRC inspector:

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WR 11540-85, Mini Purge System-Visual Inspection and Leak Test per

PMR-1389

No violations or deviations were identified.

9. 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 Technical Specifications (TS) requirements and

administrative procedures. The NRC inspectors considered the following

items while inspecting surveillance activities:

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Testing was being accomplished by qualified personnel in accordance

with an approved procedure.

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The surveillance procedure conforms to TS requirements.

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Required test instrumentation was calibrated.

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Technical Specification limiting conditions for operation were

satisfied.

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Test data was accurate and complete. The NRC inspectors performed

independent calculations of selected test data to verify their

accuracy.

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The performance of the surveillance procedure conformed to applicable

administrative procedures.

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The surveillance was performed within the required frequency and the

test results met the required limits.

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

below:

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STS AL-102, Revision 2 - Motor Driven Auxiliary Feedwater Pump 'B'

Inservice Pump Test

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STS EJ-100, Revision 4 - Residual Heat Removal System Inservice

Pump Test (Train A Only)

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STS BB-004, Revision 3 - RCS Water Inventory Balance

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STS CR-001, Revision 3 - Shift Log For Modes 1, 2, and 3

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STS IC-601A, Revision 4 - Slave Relay Test K601 Train A Safety

Injection

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STS IC-913, Revision 3 - Containment Hydrogen Analyzer GS-065B

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STS IC-260, Revision 2 - Analog Channel Operational Test Auxiliary

Feedwater Pump Suction Pressure Low

Transfer to ESW

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STS PE-017, CKL PE-045, Revision 0 - Local Leak Rate Test

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STS IC-209A, Revision 1 - 4KV Degraded Voltage T.A.D.0.T. NB01

Bus-Separation Group 1

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STS IC-209B, Revision 1 - 4KV Degraded Voltage T.A.D.0.T. NB02

Bus-Separation Group 4

NRC inspector observations are discussed below:

On December 18, 1985, the NRC inspector observed portions of the

performance of Surveillance Procedure STS AL-102, Revision 2, " Motor

Driven Auxiliary Feed Water Pump 'B' Inservice Pump Test," and had the

. following two concerns related to the way the test was conducted:

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A temporary flow gage had been installed for the surveillance with a

" calibrate before using" sticker on its face.

Licensee personnel performing the surveillance had immediately

identified the problem with the flow gage and had contacted cognizant

instrumentation and control personnel to correct the problem. The

wrong gage had been installed due to human error.

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Due to delays caused by replacing the temporary flow gage and pump

packing adjustments, the individual performing the surveillance

terminated the original copy of the surveillance procedure, obtained

a new copy, and started the surveillance over from the beginning.

Contrary to licensee procedural requirements, the partially completed

original was torn up and thrown away after being terminated. The

discarded procedure was later retrieved from the trash by the

supervising operator and terminated properly in accordance with

licensee procedures.

The NRC inspector discussed these two events with appropriate licensee

personnel. The licensee appears to have adequate procedures established

and implemented to correctly perform (including terminating)

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surveillances. The individuals involved in the events were reinstructed

in the correct method for accomplishing the above tasks. The method for

properly terminating a surveillance was made required reading for all

operations personnel.

No violations or deviations were identified.

10. Environmental Protection

On December 17,'1985, during a routine inspection of the control room, the

NRC inspector observed an internal licensee letter from environmental

management to WCGS control room concerning operation at elevated condenser

cooling water temperature (delta Ts). Due to operational problems, only

two condenser circulating water pumps were running, thus requiring

increased delta Ts if the plant were to remain at or near full power. In

discussions with the Office of Nuclear Reactor Regulation, it was agreed

that no significant increase in aquatic mortality would exist with an

increased condenser delta T and thus a letter was issued December 16,

1985, from environmental management to the control room effectively

removing environmental delta T limitations. As stated in Section 3.1 to

Appendix B to Facility ' Operation License No. NPF-42 issued June 4,1985,

"The licensee may make changes in station design or operation . . .

affecting the environment provided such activities do not involve an

unreviewed environmental question and do not involve a change in the

Environmental Protection Plan (EPP)." The NRC inspector requested a copy

of the completed unreviewed environmental question determination (UEQD)

from the licensee. Several days later on December 20, 1985, the UEQD was

provided. The licensee informed the NRC inspector that, although the UEQD

was signed on December 20, 1985, the actual determination had been

performed prior to issuing the December 16, 1985, letter and there was

simply a delay in completing the EPP design or operational change

evaluation form (KSF-LE3A). The licensee committed to ensure the

evaluation forms were completed prior to any future changes affecting the

environment.

No violations or deviations were identified. ,

11. Interview of Shift Advisors

License Condition 2.C(6) of Wolf Creek Generating Station Facility

Operating License NPF-42 required KG&E to have a qualified shift advisor

in the control room until a KG&E licensed senior operator on each shift

had fulfilled the experience requirements delineated in Attachment 2 to

the license. By Letter KMLNRC 85-255, dated November 19, 1985, KG&E

notified the NRC that the experience requirement of License

Condition 2.C(6) had been met and the use of shift consultants in the

control room would be terminated on December 20, 1985.

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The NRC inspectors interviewed the six shift consultants to determine if

they had any concerns about the way the plant was being operated. All of

the consultants stated that they were confident the personnel on the

shifts they had worked with were capable and were operating the plant

safely.

No violations or deviations were identified.

12. Fire Protection

On December 11, 1985, the NRC inspector observed a fire drill and attended

the followup critique. The simulated fire was in an electrical load

center located in the turbine building. Fire brigade members responded

promptly to the fire equipment lockers, donned appropriate fire protective

clothing, checked personal equipment, obtained backup equipment as

necessary, and proceeded to the simulated fire. Applicable

procedures were used and the fire brigade members and other onshift

personnel responded in a professional manner.

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13. Plant Tours

At various times during the course of the inspection period the NRC

inspectors conducted general tours of the reactor building, auxiliary

building, radwaste building, fuel handling building, control building,

turbine building, essential service water building, and the secured area

surrounding the buildings. During the tours, the NRC inspectors observed

housekeeping practices, fire protection barriers and equipment, and

maintenance on equipment. The NRC inspectors also discussed various

subjects with licensee personnel. The WCGS operations superintendent

accompanied the NRC inspectors on a tour of the auxiliary building on

December 12, 1985.

Selected NRC inspector findings are discussed below:

During plant tours, the following conditions which could have affected the

performance of safety-related equipment were observed by the NRC

inspectors:

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On December 23, 1985, a stepladder (approximately 6' long) was

observed that had been abandoned above the control room suspended

ceiling. The ladder could have fallen on operators and/or

safety-related components.

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On December 12, 1985, an unattended stepladder (approximately 6'

long) was observed on a catwalk approximately 30 feet above emergency

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diesel generator 'B' . The ladder could have fallen and damaged

components of the emergency diesel generator system.

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On December 12, 1985, an extension ladder (approximately 12' long)

was observed being supported by safety-related conduit 3J1025. The

conduit is located on the 2000' level in the northeast corner of the

auxiliary building. On December 18, 1985, an extension ladder

(approximately 12' long) was observed being supported by residual

heat removal system piping. Improperly secured ladders above

seismically qualified components presents unanalyzed conditions if a

postulated Safe Shutdown Earthquake should occur.

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Numerous equipment hoists mounted on monorails over the top of

safety-related equipment were observed with the lifting hooks hanging

in a lowered position where they could possibly strike and damage

safety-related equipment (i.e., valves, pumps).

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On December 12, 1985, the NRC inspectors observed hoist lifting hooks

hanging in the lowered position adjacent to the following

safety-related equipment:

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Main Steam Isolation Valves AB HV-11, AB HV-14 and AB HV-17

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Coolant Charging Pump 'A'

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Safety Injection Pump 'A'

Section 9.a, Appendix A of Regulatory Guide 1.33, Revision 2, February

1978, " Quality Assurance Program Re*quirements (0perations)," requires that

procedures be established and implemented for maintenance activities that

can affect the performance of safety-related equipment. The failure to

establish and implement procedures for the activities described above -

which could have affected the performance of safety-related equipment is a

violation. (50-482/8538-01)

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The above conditions were discussed with appropriate licensee personnel,

who took action to eliminate these potential hazards to safety-related

equipment.

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A task force of licensee personnel was established whose function was to

tour areas which contained safety-related equipment, identify housekeeping

problems and potential hazards to safety-related equipment components, and

to initiate actions to correct any problems identified.

14. Quality First File Review

On December 13, 1985, the NRC inspectors reviewed 12 Quality First (Q1)

files. The files contained 20 concerns that had been re.ceived by Q1

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during September, October, and November 1985. At the time of the review,

two of the files were still being worked by Q1 and had not been closed.

< The NRC inspectors verified the following during the review of each file:

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Documentation contained adequate information to support conclusion.

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Conclusion adequately addressed concern.

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Response to concerned individual was documented.

To further verify adequacy of Q1 conclusions, the NRC inspectors selected

two concerns for followup field review. If any NRC findings result from

the followup review of these two concerns, they will be documented in a

j future NRC inspection report.

No violations or deviations were identified.

15. ' Exit Meeting

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

findings of this inspection on January 7,1986. The NRC inspectors also

attended entrance / exit meetings of NRC region-based inspectors

, identified below:

Inspection Lead Area Inspection

Period Inspector Inspected Report No.

12-2/5-85 J. Kelly Security 85-44

. 12-2/5-85 B. Spitzberg Environmental

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Monitoring 85-43-

12-9/13-85 D. Chaney Radiation 85-38

Protection

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