ML20197A669

Insp Rept 50-482/86-17 on 860706-0802.Violation Noted: Failure to Perform Activities in Accordance W/Specified Procedure

ML20197A669
Person / Time
Site:	Wolf Creek
Issue date:	10/21/1986
From:	Bruce Bartlett, Jamarl Cummings, Cummins J, Hunicutt D, Hunter D, Lummins J, Mullikin R, Greg Pick, Sharkey J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20197A608	List: ML20197A604 ML20197A634 ML20197A669
References
50-482-86-17, NUDOCS 8610270366
Download: ML20197A669 (14)

See also: IR 05000482/1986017

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APPENDIX B

US NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-482/86-17

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License Permit: 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: July 6 to August 2, 1986

Inspectors: Ojd17tA)_ _

/O[c/ f2r.

J. E. Cumins, Senior a Resident Inspector, Date

Operations

(pars. 3, 5, 7, 8, and 13)

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B. L. Bartlett, Resident Reactor Inspector,

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Date '

Operations

(pars. 3, 4, 5, 6, 7, 8, 11, 12, and 13)

\0!M!$l

R. P. Mullikin, Project Inspector Dats

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D. M. Hunnicutt, Chief, Operations Section

/0/A.OlVb

D&te '

Reactor Safety Branch

(pars. 9 and 10)

_ }\ kdMre Gl/ % lO M

G.~ A. Pjft;k eactor Inspector Dath j

l (pars. % a 10)

8610270366 861022

PDR ADOCK 05000482

G PDR

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J. M. Sharkey, Inspection Specialist

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Date

'(pars. 4, 5, 6, and 8)

Approved: L 1h1 /6!2/

Flu ~nter, Chief,, Project Section B

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D. H'. Date

Reactor Projects Branch

Inspection Summary

i Inspection Conducted July 6 to August 2, 1986 (Report 50-482/86-17)

Areas Inspected: Routine, unannounced inspection including plant status;

followup on previously identified NRC items; LER review; operational safety

verification; engineered safety features system walkdown; onsite followup of

events; monthly surveillance observation; QA program annual review; design

changes; core thermal power evaluation; and radwaste processing.

Results: Within the 11 areas inspected, one violation was identified

(failure to perform activities in accordance with specified procedure,

paragraph 4).

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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 Manager

• G. D. Boyer, Deputy Plant Manager

+ R. M.~ Grant, Director-Quality

M. Estes, Superintendent of Operations

'i. D. Rich, Superintendent of Maintenance

+*M. G. Williams, Superintendent of Regulatory, Quality, and

Administrative Services

0. L. Maynard, Manager Licensing

+*K. Peterson, Licensing

+*G. Pendergrass, Licensing

+*W. M. Lindsay, Supervisor Quality Systems

+*C. J. Hoch, QA Technologist

+*W. J. Rudolph, QA Manager-WCGS

+ C. G. Patrick, Superintendent of Quality Evaluations

+ C. E. Parry, Superintendent of Quality Engineering

+*A. A. Freitag, Vanager Nuclear Plant Engineering-WCGS

+ D. A. Liston, Nuclear Plant Engineering

M. Megehee, Compliance Engineer

B. McKinney, Superintendent of Technical Support

+ P. E. Nichols, QA-Wichita

+ L. W. Stevens, ISEG

+ C. F. Kesinger, HP Training Coordinator

M. Isom, Health Physics Supervisor-Radwaste

R. C. Richardson, Radwaste Coordinator

J. Ives, Jr. , Manager Health Physics

• G. A. McClelland, QA Auditor

• S. A. Henry, Chemistry Supervisor

• J. Hawthorne, Chemistry Supervisor

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

August 4, 1986.

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

July 18, 1986.

2. Plant Status

The plant operated in Mode 1 during this inspection period except during

the time periods described below:

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On July 24,1986 the plant was shut down to Mode 3 to repair a stator

cooling water leak in the main generator. During the controlled

shutdown, the reactor tripped.at approximately 13 percent power due to a

1o-10 steam generator water level condition. The plant was returned to

Mode 1 on July 26, 1986.

3. Followup on Previously Identified NRC Items

(Closed) Violation (482/8526-02): Temporary changes not incorporated in

procedure as required.

The NRC inspector verified by review that the licensee's surveillance

procedure cover sheet has been revised to require that the test

performer verify that the latest revision of the surveillance test is

being used. This item is closed.

(Closed) Violation (482/8535-05): Failure to follow housekeeping

requirements.

The licensee took immediate action and cleaned up the areas which

created the housekeeping concerns identified in this violation. On

subsequent walkdowns, the NRC inspectors have observed that housekeeping

was being maintained as required. This violation is closed.

(Closed) Violation (482/8538-01): Failure to establish procedures for

certain activities that could affect the performance of safety-related

equipment.

The NRC inspector, by review of documents and plant walkdowns, verified

the following licensee actions related to this violation:

o Section 5.3.2 of Administrative Procedure ADM 01-034, Revision 8,

" Housekeeping and Cleanliness Control," has been revised to state

that hoist hooks shall be fully raised and ladders returned to

their designated storage location.

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0 Permanent storage brackets for ladders have been installed at

seventeen locations in the plant and have been identified by signs.

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o Storage of ladders was discussed at the safety committee meeting

held on April 2, 1986. Safety meetings were used to train

employees in the use of ladders.

During subsequent plant walkdowns, the NRC inspectors have not

identified any further instances where ladders and hoists could have

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affected the operation of safety-related equipment. This violation is

closed.

f (Closed) Violation (482/8523-01): Failure to follow plant procedures.

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The NRC inspector reviewed the letter which was issued to all

organizations which may be called upon to perfonn work in the plant and

verified that it was discussed with the appropriate personnel. In addition,

since this violation was first identified no other similar violations

have been discovered. This violation is closed.

(Closed) Violation (482/8530-01): Test port not reclosed in accordance

with procedure.

The NRC inspector reviewed five randomly selected procedures which

remove plugs in HVAC test ports and verified the procedures included

clear requirements to reinstall plugs in test ports. In addition, field

inspections by NRC inspectors have failed to identify any similar

violations to date. This violation is closed.

(Closed) Violation (482/8530-02): Inadequate procedure.

The NRC inspector reviewed STS IC-275A and STS IC-275B and verified that

the requirement for damper movement had been removed. In addition, the

sample results of the containment atmosphere drawn at 2100 CST on

July 26, 1985, was reviewed for abnormal results. This violation is

closed.

4. Review of Licensee Event Reports

During this inspection period, the NRC inspectors performed followup on

selected Wolf Creek LERs. The LERs were reviewed to ensure:

o The corrective action stated in the report has been properly

completed.

o Responses to the events were adequate.

o Responses to the events met license conditions, commitments, or

other applicable regulatory requirements.

o The information contained in the report satisfied applicable

reporting requirements.

o That any generic issues were identified,

o The report conformed to the guidelines contained in NUREG-1022 and

Supplements 1 and 2.

The following LERs were reviewed and closed.

o 482/85-041-00, "ESF Actuation and Reactor Trip"

o 482/85-042-00, " Engineered Safety Features Actuation and Reactor

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Trip"

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o 482/85-043-00, "Feedwater Isolation and Auxiliary Feedwater

Actuation"

o 482/85-044-00, "ESF Actuation-Feedwater Isolation, Auxiliary

Feedwater Actuation, Steam Generator Blowdown

and Sample Isolation"

o 482/85-045-00, " Reactor Trip and Engineered Safety Features

Actuation"

o '482/85-046-00, " Engineered Safety Features Actuation and Reactor

. Trip"

o ~

482/86-019-00, " Technical Specification Required Shutdown Due To

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~_ Unidentified Reactor Coolant System Leakage"

o 482/86-033-00, " Technical Specification-Late Verification of Fuel

Oil Properties"

The NRC inspectors had the following comments:

o ApplicableportionsofAdministrativeProcedure'ADM01-033,

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'" Instructions Describing Reportability, Review, and Documentation

of Licensee Event Reports (LERs), and Defect Deficiencies,"

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Revision 15, were reviewed for agreement with LER reporting

requirements,

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o In general, the quality and adequacy of the licensee's LERs has

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been improving. However, minor deficiencies were noted in the LER

information requirements. For example, five out of six LERs

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reviewed did not discuss whether any previous similar events at the

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plant were known to.the licensee. These deficiencies were

discussed with the licensee during this inspection period.

o During an inspection of control room area radiation monitor

instrunentation and chart recorders while following up on LER

482/86-019-00, the NRC inspector noted that Chart Recorder GT RR-58,

t " Unit Ventilation Effluent Release Rate," and GH RR-51, "Radwaste

Building Effluent Release Rate," were not scaled, but did have a tag

saying 0 to 100. None of the licensed operators questioned knew

what units the chart recorders used. Instrumentation and control

informed the NRC inspector that the chart recorders were calibrated

j from 10E1 to 10E13 micro Ci/sec. The licensee committed to install

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the correct scales.

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l o -0n July 18,1986,'during a review of completed surveillances

related to LER 482/86-033-00, the NRC inspector observed that

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STS CH-008A, " Emergency Diesel Fuel Storage Tank," performed on

June 1, 1986, was Revision 3 and that the data sheet for STS CH-0088,

, " Emergency Diesel Fuel Storage Tank," had been used. The plant safety

l review conmittee (PSRC) document control records showed that

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STS CH-C08A, Revision 4 had been issued on May 14, 1986. The

records review indicated that the appropriate tank was sampled and

that the sample data met the TS criteria. This failure of the test

performer to use the correct procedure and revision, even though he

had signed off in Section 1 of the cover sheet that he had used the

correct procedure and revision, and failure of the surveillance

ost-performance review cycle to discover this error is a violation.

482/8617-01)

5. Operational Safety Verification

The NRC inspectnrs verified that the facility is being operated safely

and in conformance'with regulatory requirements by direct observation of

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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 the physical security plan was being implemented in accordance

with the security plan and that radiation protection activities were

controlled.

By observing . valve position, electrical breaker position, and control

room indication, the NRC inspectors confirmed the operability of the

residual heat removal system and the emergency diesel generators.

The NRC inspectors also visually inspected safety components for

leakage, physical damage, and other impairments that could prevent them

from performing their designed function.

No violations or deviations were identified.

6. 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 fcr damage or other

conditions that could degrade system performance. ,

The ESF system walked down during this inspection period and the

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documents utilized by the NRC inspectors during the walkdown are listed

below:

System Documents

Essential Service Water (EF) Drawing M-K2EF01, Revision 14, ESW

P&ID(Q)

f Drawing M-02EF01, Revision 10, ESW

P&ID(Q)

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Drawin M-02EF02, Revision 12, "ESW

P&ID Q)"

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STS EF-001, Revision 3, " Essential

Service Water Valve Check"

' Checklist CKL EF-120, Revision 8,

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" Essential Service Water Valve,

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Breaker, and Switch Lineup"

No, violations ~or deviations were identified.

7. Onsite Followup'of Event

The NRC' inspectors performed onsite followup of a reactor trip that

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' occurred on July 24,'1986, due to a 10-10 steam generator water level

condition. The NRC inspectors reviewed logs and computer printouts and

discussed the~ trip.with cognizant personnel. The NRC inspectors

verified the licensee had responded to the event in accordance with

procedures and had notified the NRC as required in a timely fashion.

The reactor trip occurred at approximately 13 percent power during a

controlled reactor plant shutdown to Mode 3 to support maintenance on

the main turbine generator. The 10-10 level in the steam generator was

caused while the steam generator feedwater was being transferred from

the main feedwater regulator valves to the bypasses. The licensee has

experienced this same problem during previous plant startups and

shutdowns and is evaluating methods to eliminate the problem. The

subsequent startup on July 26, 1986, was accomplished with no

significant problems.

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No violations or deviations were identified.

8. Monthly Surveillance Observation

[TheNRCinspectorsobservedselectedportionsoftheperformanceof

E* surveillance testing and/or reviewed completed surveillance test '

procedures to verify that surveillance activities were performed in

I accordance with technical specifications (TS) requirements and

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administrative procedures. The NRC inspectors considered the following

elements while inspecting surveillance activities:

o Testing was being accomplished by qualified personnel in accordance

( with an approved procedure.

o The surveillance procedure conformed to TS requirements.

o Required test instrumentation was calibrated.

i o Technical Specification limiting conditions for operation (LCO)

were satisfied.

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o Test. data was accurate and complete. Where appropriate, the NRC

inspectors performed independent calculations of selected test data

to verify their accuracy,

o The performance of the surveillance procedure conformed to

applicable administrative procedures.

o The surveillance was perfonned within the required frequency and

the test results met the required limits.

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

below:

o STN IC-500, Revision 0, " Channel Calibration Radwaste Building

Corridor Basement Area Radiation Monitor SDRE01," performed

July 23, 1986

o STS RE-006, Revision 2. "E0L Core MTC Measurement," performed

July 11, 1986

o STS SE-001, Revision 5, " Power Range Adjustment to Calorimetric,"

performed July 11, 1986

o STS SE-001, Revision 6, " Power Range Adjustment to Calorimetric,"

performed July 27, 1986

o STS B8-004, Revision 4, "RCS Water Inventory Balance," performed

July 29, 1986

No violations or deviations were identified.

9. Quality Assurance (QA) Program Annual Review

a. QA Program Implementation

Duringapreviousinspection(IR 50-482/86-16) the NRC inspector

had reviewed the WCGS onsite and offsite review committees. The

licensee had a method for informing supervisory persunnel of new

regulatory requirements by routing to them Inspection and

Enforcement Bulletins (IEB), Generic Letters (GL), Information

Notices (IN), and so forth.

During this period, the NRC inspector examined the implementation

of the QA audit program and their records program.

b. Audit Program

Through discussions with licensee personnel, review of the

essential elements manual and review of sunmary documentation, an

understanding of the audit program was obtained.

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The basis of the audit program was the essential elements manual,

i which summarizes into 39 topics (essential elements) the licensee's

commitments and/or requirements reflected in 10 CFR Part 50,

ANSI 18.7 (Quality Assurance for the Operational Phase of Nuclear

Power Plants), WCGS TS, and the Final Safety Analysis

Report (FSAR). The essential elements are subdivided into

attributes which can be objectively evaluated.

To audit a plant area, the auditor prepared the audit plan from the

essential elements manual type of concern. Upon completion of the

audit, if any discrepancies existed, methods existed that allowed

execution of corrective actions as appropriate. Quality assurance

audit frequencies, as required by TS, were on a biennial schedule.

The audits were planned on an annual basis; however, if the

essential element was voluminous, the audit may have been scheduled

in segments over a two year period to assure that the minimum audit

requirements would be met. In addition to the mandatory audits,

lower tiered audits and surveillances were scheduled to support the

main audit.

The following audit packages were reviewed:

Audit No. Title

TE 50140-K116 Corrective Action dated 6/4/86

TE 50140-K096 Assignment Of Authority, Organization, and

Program Description

TE 50140-K086 Corrective Action dated 12/9/85

TE 50140-K066 Records Management

TE 50140-K005 Quality Assurance Records

The audits generally lasted four weeks. Auditors conducted

entrance and exit summaries with the plant organization prior to

start and at conclusion of the audit. The audit report clearly

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defined the audit scope and results. Personnel conducting the

audit were qualified as determined by NRC inspector review of

training records. The audit questions and areas of interest

reflected the requirements in the essential elements' manual. The

audited organizations' response to audit findings were in writing,

were timely, and adequately addressed the findings and

recommendations.

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c. Records Program

During this inspection, the NRC inspector reviewed Section 6.10 of

the facility TS, ANSI N45.2.9-1974 (Requirements For Collection,

Storage, and Maintenance Of Quality Assurance Records For Nuclear

Power Plants), and the WCGS procedures listed below:

o ADM 01-045, Revision 3, " Document Control Supervisor Duties

and Responsibilities"

o ADM 07-046, Revision 16, " Records, Administrative, and

Storage"

The WCGS records program was described in ADM 07-406. Maintenance

and retention periods for records were described in the TS and

various procedures. The Document Control (DC) Supervisor was

assigned responsibility of maintaining the QA records and ensuring

implementation of the record storage controls. Responsibilities

had been assigned with controls established to ensure transfer and

retention of construction phase records. The controls (ADM

Procedure 07-406) established for record storage were in accordance

with FSAR commitments; i.e., ANSI N45.2.9-1974. This procedure

described the storage facility; designated the DC supervisor as

custodian of the QA vault; described the filing / retrieval system

utilized; established a method to verify that records were in

agreement with the transmittal document; made provisions for

governing access to files and maintaining accountability of records

removed from storage; established methods for correcting

information, filing supplemental information and disposing of

superseded records with the required reviews and approvals

specified.

Individual section supervisors; i.e., instrumentation and control,

maintenance, et cetera, were responsible for establishing retention

periods of records not covered by the FSAR, TS, 10 CFR, and for

authorizing the disposal of records no longer required.

The NRC inspector verified through discussions with licensee

personnel and a tour of the QA vault that: The environmental

, conditions and fire suppression system were in accordance with

commitments; records were listed on an index; records were readily

retrievable from designated files and were not stored loosely but

were firmly attached in folders; and records were stored in

suitable file cabinets.

No violations or deviations were identified.

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10. Design Changes and Modifications

The NRC inspector reviewed design changes and modifications that the

licensee had determined were not required to be approved by NRC and

verified they were in conformance with TS and 10 CFR Part 50.'59.

a. Design Changes

The NRC inspector selected three design changes that were to be

submitted with the annual report to the NRC that is required by

10 CFR Part 50.59(b). For each of the design changes the NRC

inspector verified: That the changes were reviewed and approved in

a technically adequate manner in accordance with 10 CFR Part 50.59;

that the design changes were reviewed and approved according to TS;

and that established procedures were used.

The three design change summaries follow:

(1) Plant Modification Request (PMR) 01446, Revision 0, was

originated to reinstall flow elements EM-FE924, 925, 926,

and 927, which were originally installed backwards.

(2) Safety Evaluations (SE) 86-SE-31 was originated to reverse

the wires on Terminals TB4-8-01 and TB4-8-04 in Panel RP05BC

for the emergency diesel generator "A" day tank level control

circuit to make the wiring agree with the schematic.

(3) SE 86-SE-44 was originated to demonstrate the operability of

reactor coolant system pressure isolation valves BB PV8702A

and EJ HV8701A by verifying that the measured leakage meets

the requirements of TS 4.4.6.2.2.

b. Temporary Modifications

The NRC inspector reviewed the WCGS program for temporary

modifications through review of Procedure ADM 02-101, Revision 15,

" Temporary Modifications." The NRC inspector verified that

temporary modifications were reviewed and approved according to

Section 6 of the TS and 10 CFR Part 50.59. The procedure assigned

each group supervisor responsibility for approving the temporary

modification as correct, necessary, and required the use of

detailed approved procedures. WCGS ADM Procedure 02-101 required:

That a temporary modification log be maintained; that all

outstanding temporary modifications were reviewed periodically; and

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that temporary modifications be evaluated to determine the need for

independent verification.

No violations or deviations were identified.

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11. Core Thermal Power Evaluation

The NRC inspector verified that the licensee's calculation of core

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thermal power was correct and that the procedure used was technically

adequate. On July 18, 1986, at 0610 CDT, the NRC inspector performed a

manual calorimetric using licensee Procedure STS SE-002, Revision 0,

" Manual Calculation of Reactor Thermal Power." At that time computer

point REV1118 was indicating 3407.3 MWth which corresponds to

99.89 percent of licensed full power. The NRC inspector calculated a

power level of 99.82 percent of full power. The NRC inspector then

verified that all nuclear instrumentation channels were reading greater

than 99.89 percent, but within acceptable margins. The NRC inspector

reviewed STS SE-002 for technical adequacy, proper initial conditions,

appropriate prerequisites and good engineering practice. The three

typographical errors and one usage of incorrect units found were given

to the Superintendent of Operations for correction. The correction

factor of 0.4 percent for reactor coolant pump (RCP) heat added was

found to be incorrect by 0.0254 percent, since this is within instrument

error, this difference is not significant and the reactor engineer was

notified of the difference. The proper correction factor for RCP pump

heat is 0.3746 percent or 43.6 10E6 BTU /HR as identified in the

preoperational test procedure results report for SU9-0025, Revision 0,

" Reactor Coolant System Heat Loss." The NRC inspector on a random basis

verified the correct number was used in Startup Test SU7-SC03.2,

Revision 1, " Thermal Power and Statepoint Data Collection at 30 percent

Power," and SU7-SC03.8, Revision 1, " Thermal Power and Statepoint Data

Collection at 100 percent Power." The NRC inspector randomly reviewed

TS Surveillance STS SE-001, Revision 5, " Power Range Adjustment to

Calorimetric," performed on June 14-16, 1986, and verified that the

power range nuclear instruments were properly adjusted to agree with the

results of the heat balance and that data was reasonable, consistent

with previous data and properly recorded.

The NRC inspector by review of the STS master schedule verified that the

frequency of calorimetrics was as prescribed by the licensee's TS.

The NRC inspector by review of the appropriate surveillances verified

that the plant instruments and computer points used for calorimetrics

were calibrated in a traceable manor and that evaluation results were

reviewed, approved, and documented in accordance with procedures.

No violations or deviations were identified.

12. Radwaste Processing

During this inspection period, the NRC inspectors observed activities

and reviewed procedures related to the processing of radwaste. A vendor

was onsite processing primary and secondary evaporator bottoms

concentrates. A licensee procedure was to provide valve lineups for

supplying the radsaste to the vendors processing equipment. The vendor

would then use his own procedures to process the radwaste.

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In discussions with cognizant licensee personnel, the NRC inspectors

pointed out that the vendor's procedures and the licensee's procedures

had not been integrated together in that they did not reference each

other and that there was no definitive vehicle by which the vendor's

procedures were implemented or controlled for use onsite.

The licensee resolved this observation by establishing and implementing

Procedure STS HC-227, Revision 0, " Vendor Processing of Primary Resins

and Concentrates," which addressed interfaces with vendor procedures.

No violations or deviations were identified.

.13. Exit Meeting

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

findings of this inspection on August 4, 1986. The NRC inspectors also

attended entrance / exit meetings of other NRC region based inspectors

identified below:

Inspection Lead Area Inspection

Period Inspector Inspected Report No.

7/14-18/86 D. Hunnicutt QA Program and 86-17

Design Changes (pars. 9

and10)

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