ML20207T129

Insp Rept 50-482/87-03 on 870201-28.Violations Noted:Failure to Perform Activities in Accordance W/Established Procedures,Failure to Lock Valves,Failure to Have Drawings Reflect as-built Status & Failure to Establish Procedures

ML20207T129
Person / Time
Site:	Wolf Creek
Issue date:	03/12/1987
From:	Bruce Bartlett, Cummins J, Hunter D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20207T121	List: ML20207T120 ML20207T124 ML20207T129
References
50-482-87-03, 50-482-87-3, NUDOCS 8703230230
Download: ML20207T129 (12)

See also: IR 05000482/1987003

Text

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APPENDIX B

U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-482/87-03 LP: NPF-42

Docket: 50-482

Licensee: Wolf Creek Nuclear Operating Corporation (WCNOC)

P. O. Box 411

Burlington, Kansas 66839

Facility Name Wolf Creek Generating Station (WCGS)

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

Inspection Conducted: February 1 to 28, 1987

Inspectors _ t/A ,

1244El{ uA

E. Cummins,"Selitor Resident Inspector,

3'Dat'e

/d87

Operations

de ci A J' ~ S~ ~ $? )

B. L. Bartlett, Resident Reactor Inspector, Date

Operations

Approved: _ /Z. 8 7

D. R. Ilunter, Chief, Reactor Project Section B Date

Reactor Projects Branch

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Inspection Summary

Inspection Conducted February 1-28, 1987 (Report 50-482/87-03)

Areas Inspected: Routine, unannounced inspection including plant

status; operational safety verification; monthly surveillance

observation; monthly maintenance observation; onsite event followup;

engineered safety features system walkdown; and an enforcement

conference.

Results: Within the seven areas inspected, four violations were

identified (failure to perform activities in accordance with established

procedures, paragraph 3; failure to lock valves in accordance with

procedure, paragraph 7; failure to have drawings reflect as-built

status, paragraph 7; and failure to establish adequate procedures,

paragraph 3).

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DETAILS

1. Persons Contacted

Principal Licensee Personnel

B. D. Withers, President, Wolf Creek Nuclear Operating Corporation

J. A. Bailey, Vice President, Engineering and Technical Services

F. T. Rhodes, Vice President. Nuclear Operations

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R. M. Grant, Vice President, Quality

• G. D. Boyer, Plant Manager

0. L. Maynard, Manager of Licensing

C. H. Estes, Superintendent of Operations

M. D. Rich, Superintendent of Maintenance

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

Administrative Services

W. J. Rudolph, QA Manager-WCGS

• A. A. Freitag, Manager, Nuclear Plant Engineering-WCGS

M. Nichols, Plant Support Superintendent

K. Peterson, Licensing

• G. Pendergrass, Licensing

• W. M. Lindsay, Supervisor Quality Systems

• C J. Hoch, QA Technologist

R. Flannigan, Supervisor of Compliance Engineering

W. Norton, Supervisor of Reactor Engineering .

• J. M. Pippin, Manager, Nuclear Plant Engineering

• C. E. Parry, Superintendent of Quality Engineering

• J. L. Houghton, Operations Coordinator-Operations

• R. L. Hoyt, Senior Engineering Specialist-Operations

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

March 3, 1987.

2. Plant Status

l The plant operated in Mode 1 during this inspection period.

3. Operational Safety Verification

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The NRC inspectors verified that the facility is being operated safely

l and in conformance with regulatory requirements by direct observation of

licensee facilities, tours of the facility, interviews and discussions

l with licensee personnel, independent verification of safety system

l status and limiting conditions for operations, and reviewing facility

records. The NRC inspectors, by observation of randomly selected

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activities and interviews of personnel verified that physical security,

radiation protection, and fire protection activities were controlled.

By observing accessible components for correct valve position and

electrical breaker position, and by observing control room indication,

the NRC inspectors confirmed the operability of the safety injection

system, the charging system, and the auxiliary feedwater system. The

NRC inspectors also visually inspected safety components for leakage,

physical damage, and other impairments that could prevent them from

performing their designed functions.

Selected NRC inspector observations are discussed below:

On February 24, 1987, during a routine tour of the control room,

the NRC inspector observed a chart recorder on the floor recording

thecontainmentnormalsumplevels(LFLI-89andLFLI-94). The

supervising operator (50) thought that it had been connected on

February 20, 1987, when 0FN 00-023. Revision 2, " Loss of 80P

Computer," was entered when the balance of plant computer became

inoperable. According to the 50 log, the 80P was lost and

0FN 00-023 was entered on February 20, 1987, at 3:45 p.m. CST. The

BOP was restored and 0FN 00-023 was exited at 10:18 p.m. CST on

February 20, 1987. OFN 00-023 requires the installation of the

temporary recorder under certain conditions; however, it does not

address the removal of the temporary recorder.

Further, plant ADM 02-101, Revision 16. " Temporary Modifications,"

Step 5.5 states, "The placement of temporary modifications

authorized by approved procedures are excluded from the

requirements of this procedure provided the procedure addresses

installation and restoration of the modification." This failure to

provide an adequate procedure to appropriately install and remove a

chart recorder (temporary modification) is an apparent violation

(482/8703-04).

On February 17, 1987, the NRC inspector observed 3 plastic shields

attached to Centrifugal Charging Pump (CCP) "B" (PBG058) (High

Pressure Safety Injection Pump) with aluminum tape, plastic tie

wraps, and a pi ae clamp. The NRC insacctor determined from

discussions witi licensee personnul t1at the shields had not been

installed in accordance with licensee procedures. TS 6.8.1

requires that, " Written procedures shall be established,

implemented, and maintained covering . . . a. The applicable

procedure recommenced in Appendix A of RG 1.33 Revision 2,

February 1978," Section 9.e of Appendix A states, " General

procedures for the control of maintenance, repair, replacement, and

modification work should be prepared bufore reactor operations is

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begun." TS 6.8.1 also states that, " Major procedures are written

to meet the requirements of ANSI N18.7-1976/ANS 3.2 . . . ."

Section 5.2.7 of ANSI N18.7 states, " Maintenance or modification of

l equipment shall be preplanned and performed in accordance with

written procedures, documented instructions, or drawings ,

appropriate to the circumstances . . . ." This failure to perform >

activities in accordance with established procedures is an apparent

violation (482/8703-01).

4. Month 1.y Surveillance Observation

The NRC inspectors observed selected portions of the performance of

surveillance testing and/or reviewed completed surveillance test

procedures to verify that surveillance activities were performed in

accordance with TS requirements and administrative procedures. The NRC t

inspectors considered the following elements 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 conformed to TS requirements.

Required test instrumentation was calibrated.

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Technical Specification limiting conditions for operation (LCO) 1

were satisfied.

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Test data was accurate and complete. Where appropriate, 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.

The surveillance was perfumed within the required frequency and

the test results met the required limits. l

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

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STS EF-210, Revision 5. "ESW System Inservice Check Valve Test " ,

performed on February 14, 1987  :

STS EJ-100B, Revision 0, "RHR System Inservice Pump 'B' Test "

performed on February 24, 1987

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STS GG-001A, Revisioa 3 " Emergency Exhaust Filtration System Train

'A' 10-Hour Operability Test," performed on October 13

November 13 December 13, 1985, and January 13, 1986

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STS GG-001A, Revision 4, " Emergency Exhaust Filtration System Train

' A' 10-Hour Operability Test," performed on August 13, 1986

STS GG-001A, Revision 5. " Emergency Exhaust Filtration System Train

' A' 10-Hour Operability Test," performed on December 13, 1986

STS GG-001B, Revision 3. " Emergency Exhaust Filtration System Train

'B' 10-Hour Operability Test," perfonned on January 28, 1986

STS GG-001B, Revision 4, " Emergency Exhaust Filtration System Train

'B' 10-Hour Operability Test," performed on April 28, 1986

STS GG-0018 Revision 5. " Emergency Exhaust Filtration System Train

'B' 10-Hour Operability Test," performed on July 25, 1986

STS PE-004, Revision 4. " Control Room Positive Pressure Test and

Control Room Ventilation Isolation Test Signal Response

Verification," performed on December 4,1986, at 2:54 a.m. and  :

4:25 p.m. and on February 12, 1987, at 12:35 p.m. and 1:16 p.m.

STS SE-001, Revision 6. " Power Range Adjustment To Calorimetric,"

perfonned on February 8,1987

Selected NRC inspector observations are discussed below:

On February 12, 1987, the licensee informed the NRC inspector that

as a result of a quality assurance (QA) audit, it had been

identified that shims placed on Door 36092 in order to enable the ,

successful completion of STS PE-004 on December 4,1986, were

missing. At approximately 12:35 p.m. on February 12, 1987, the

licensee reperformed STS PE-004, with Door 36092 in the as-found

condition and verified that "A" train of the control room ,

ventilation isolation system (CRVIS) was unable to maintain at

least 0.25 inches of water, positive aressure as required by

TS 4.7.6.e.3. Door 35092 was taped slut and at approximately

1:16 p.m. on February 12, 1987, STS PE-004 was successfully '

reperformed. WorkRequest(WR) 00644-87, " Pressure Door No. 36092,"

was written at 1:38 p.m. to document the door repair and later that '

afternoon Temporary Modification Order (THO) 87-022-Z1 was written i

to allow Door 36092 to remain taped closed. The shim that was

added to Door 36092 on Decenber 4,1986, was not controlled, as l

required, under the temporary modification program.

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Violations are identified in the above paragraph which meet the

criteria for 10 CFR Part 2. Appendix C for which a Notice of

Violation will not generally be issued. These violations are of

lesser severity which were identified, reported, and are being

satisfactorily corrected by the licensee, and are not violations

that could reasonably be expected to have been prevented by the

licensee's corrective action for a previous violation. Therefore. I

no Notice of Violation is being issued. Door 36092 has since been l

repaired, the tape removed and STS PE-004 reperformed successfully. I

On February 14, 1987, Surveillance Test STS EF-210 was performed

and Valves EFV046 (Train "A" return from air compressor) and

EFV076 (Train "B" return from air compressor) were determined to

have excessive seat leakage. Due to a suspected faulty test

procedure, the test was suspended without the valves being declared

inoperabic. At 7:50 a.m. on February 16, 1987 Valves EFV046 and

EFV76 were declared inoperable retroactive to February 14, 1987.

After the STS was rewritten and divided into two separate

procedures (A and B train), it was reperformed. Valve EFV046

passed; however, Valve EFV076 failed at 4:55 a.m. on

February 17, 1987. Failure of either or both of these valves does

not appear to make the essential service water (ESW) system

inoperable.

5. Monthly Maintenance Observation

The NRC inspector observed maintenance activities performed on

safety-related systems and components to verify that these activities

were conducted in accordance with approved procedures. Technical

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Specifications, and applicant industry codes and standards. The

following elements were considered by the NRC inspector during the

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observation and/or review of the maintenance activities:

LCOs were met and, where applicable, redundant components were

operable.

Activities complied with adequate administrative controls.

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

used.

Craftsmen were gialified to accomplish the designated task and

technicalexpertite(i.e., engineering,healthphysics, operations)

was made available when appropriate.

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.

Required aligreents and surveillances to verify post maintenance

operability were performed.

Quality control hold points and/or checklists were used when

appropriate and quality control personnel observed designated work

activities.

Selected portiens of the maintenance activities accomplished on the work

requests listed below were observed and related documentation reviewed

by the NRC inspector:

WR 05220-86, " Control Room No. 3604"

WR 00373-87, " Door 36092"

• WR 05513-86, "SGG04A, Spent Fuel Pool Fump ' A' Room Cooler"

WR 00657-87. "EFV046 and EFV076 Excessive Seat Leakage"

WR 00597-87, "Backdraft Dampers /GC0028"

" WR 00620-87, "SGLO9A St Pump Room 'A' Cooler"

llR 00621-117, "SGL10A RHR Pump Room ' A' Cooler"

He violations or deviations were identified.

6. j),nji_te Event Followu,g

The NRC inspector performed onsite followup of nonemergency events that

oc:urred during thit. report period. The NRC inspector (when available)

observed control room personnel response, observed instrumentation

indicators of retetJr plant parameters, reviewed logs and Computer

printouts, and discussed the event with cognizant personnel. The NRC

inspector verified the licensee had responded to the event in accordance

itith procedures and had notified the NRC and other agencies, as

lequired, in a tinely fashion. Engineered safety feature actuations

that occurred duritig the report period are listed in the table below.

l'liere applicable, the NRC inspector will review the LER for each of

ttese events and vill report any findings in subsequent NRC inspection

reports.

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Date Event Plant Status Cause

2/08/87 CRVIS* Mode 1 Spurious spike

98 percent

• Control Room Ventilation Isolation System

No violations or deviations were identified.

7. Engineer Safety Features (ESF) System Walkdown

The NRC inspector verified the operability of the ESF system by walking

down selected accessible portions of the system. The NRC inspector

verified valves and electrical circuit breakers were in the required

position, power was available, and valves were locked where required.

The NRC inspector also inspected system components for damage or other

conditions that could degrade system performance.

The ESF system walked down during this inspection period and the

documents utilized by the NRC inspector during the walkdown are listed

below:

System Documents

Fuel llandling Building Heating, DrawingM-12GG01(Q), Revisions 0,

Ventilation, and Air Conditioning " Piping and Instrumentation

(HVAC)(GG) Diagram Fuel Building HVAC"

DrawingM-12GG02(Q), Revision 0,

" Piping and Instrumentation Diagram

fuel Building HVAC"

Checklist (CKL)GG-121. Revision 8,

" Normal Fuel Butiding HVAC Valve

Checklist"

CKL GG-131, Revision 4. " Fuel

Building Ventilation Breaker

Checklist"

CKL GG-132, Revision 3. " Fuel

Building Switch and Damper Lineup

Checklist"

SYS GG-121 Pevision 5. "Startup

OfFuelBulldfegHVACSystem"

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The central chilled water bypass line to EGG 09, " Fuel Handling

Area Cooling Coil," has a tranual isolation valve (GGV055) that

was on the checklist but was not on the drawing.

Fuel building supply air units SGG01A and SGG01B have

3/8ths-inch tube vent and drain lines with isolation valves

(GGV030,31,32,and33)whichwerenotshown.

Lines 040-HBD-2 and 042-HDD-2 were shown with 3/8ths-inch

tubing with Valves GGV722 and 721; however, the tubing comes

off of lines 114-HBD-2 and 116-HBD-2, respectively.

c. The following discrepancies related to Drawing M-02GL01(Q),

Revision 14 were identified:

• Component Cooling Water (CCW) Fan Coil Unit SGL17A, Line

147-HBD-1 1/2 has a 3/8ths-inch tube line with a ball valve

that was not shown.

CCW Pump Room Cooler SGL11A(Q), Valve GLV146 is shown normally

open,'it is normally closed.

Auxiliary Building Supply Air Unit SGL01, Valve GLV065 should

be shown as a ball valve.

d. The following discrepancies related to Drawing M-12GLO2(Q),

Revision 0 were identified:

CCW Fan Unit SGL170, Line 271-HBD-1 1/2 has a 3/8ths-inch tube

line with a ball valve that was not shown. t

Aux / Fuel Building Normal Cxhaust Filter Absorber Unit FGLO2

differential pressure instrumnts 42 and 44 do not snare a

coninon tap as shown.

PDI 44 has an unnumbered isolation valve not shown.

Valves GLV726 and 725 should be shown as ball valves.

ThetaystoValvesGLV727and728onGroundFloorFanCoil

Unit 56LOS were reversed.

• Valve GLV754 is tagged as GLV076.

Line 269-HBD-1/2 has a 3/8ths-inch tube line with isolation

valve that was not shown,

i The tags to Valves GLV750 and 760 were reversed.

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The central chilled water bypass line to EGG 09, " Fuel Handling

AreaCoolingcoil,"hasamanualisolationvalve(GGV055)that

was on the checklist but was not on the drawing.

Fuel building supply air units SGG01A and SGG01B have

3/8ths-inch tube vent and drain lines with isolation valves

(GGV030, 31, 32, and 33) which were not shown.

Lines 040-H80-2 and 042-H80-2 were shown with 3/8ths-inch

tubing with Valves GGV722 and 721; however, the tubing comes

off of lines 114-HBD-2 and 116-HBD-2, respectively,

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c. ThefollowingdiscrepanciesrelatedtoDrawingH-02GLO1(Q), <

Revision 14 were identified:

• Component Cooling Water (CCW) Fan Coil Unit SGL17A Line

147-HBD-1 1/2 has a 3/8ths-inch tube line with a ball valve

that was not shown.

CCW Pump Room Cooler SGL11A(Q), Valve GLY 146 is shown normally

open, it is normally closed.

Auxiliary Building Supply Air Unit SGL01, Valve GLV065 should

be shown as a ball valve,

d. The following discrepancies related to Drawing M-12GLO2(Q),

Revision 0 were identified:

• CCW Fan Unit SGL178, Line 271-HBD-1 1/2 has a 3/8ths-inch tube i

line with a ball valve that was not shown.

Aux / Fuel Building Normal Exhaust Filter Absorber Unit FGLO2

differential pressure instruments 42 and 44 do not share a

cosenon tap as shown.

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PDI 44 has an unnumbered isolation valve not shown.

• Valves GLV726 and 725 Should be shown as ball valves.

• The tags to Valves GLV727 and 728 on Ground Floor Fan Coil

Unit SGLOS were reversed.

• Valve GLV754 is tagged as GLV076.

Line 269 H00-1/2 has a 3/8ths-inch tube line with isolation

valve that was not shown. ,

The tags to Valves GLV750 and 760 were reversed.

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e. ThefollowingdiscrepanciesrelatedtoDrawingM-02GLO3(Q),

Revision 14 were identified:

The tags to Valves GLV745 and 746 on Penetration Room

Cooler SCL15B(Q) were reversed.

During the field walkdown of the GG system on February 11, 1987 Spent

Fuel Pool Pump SFPP) Room Cooler SGG04A(Q) was found to be

out-of-service 005) with WR Tag 20491 dated December 8,1986. Licensee

management was nformed of the NRC inspector's concern that the room

cooler had been 005 for 2 months even though the SFPP room cooler is not

a TS item. The licensee informed the NRC inspector that the WR was

holding on an engineering disposition to a request to delete the motor

space heater and that the priority of the WR would be increased.

WR 05513-86 was subsequently completed on February 19, 1987.

During the drawing review of the GL system, the NRC ins)ector noted that

ESW vent and drain lines to penetration room cooler (SG.15A) and the CCW

PumpRoomCooler(SGL11A)"A train are locked closed; however, the "B"

train (SGL150 and SGL110) are closed but not locked. The licensee was

informed of the inconsistency.

During the walkdown of the GL system on February 12, 1987, Valve CLV138

ESW drain to Centrifugal Charging Pump FCCP) SGL12B(Q) and Valve GLV132

ESW drain to Safety Injection Pump (SIP) Room Cooler SCLO9A(Q) were

found to be closed but unlocked. The NRC ins)ector informed the reactor

operator (RO) who had the locks replaced. CKL CL-121, Revision 6

requires that these valves be locked closed. This is an appare'nt

violation (482/8703-02). ,

As identified in subparagraphs b, c, and d above, the NRC inspector's

field walkdown identified multii)1e examples of quality (Q) drawings not

accurately showing the GG and G. systems as constructed. This is an

apparent violation (402/8703-03).

8. Enforcement Conference

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On February 20, 1907, an enforcement conference was held in the NRC

Fegion !Y Office in Arlington, Texas. The conference was held so that t

N9C Region IV management could discuss with WCNOC management a concern

related to the handling of a reactor coolant system flow rate problem

ttat had Leon identified by the licensee in January,1987. Details of

the NRC's cuncernt woro reported in NRC Inspection Report 60-482/8/-05.

g. {xjtMeeting

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

findings of this inspection on March 3, 1987.