IR 05000482/1998013

Insp Rept 50-482/98-13 on 980419-0530.Violations Noted.Major Areas Inspected:Operations,Maint,Engineering & Plant Support

ML20249A035
Person / Time
Site:	Wolf Creek
Issue date:	06/12/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20249A033	List: IR 05000482/1998013 ML20249A032 ML20249A034
References
50-482-98-13, NUDOCS 9806150344
Download: ML20249A035 (16)

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I ENCLOSURE 2 l

U.S. NUCLEAR REGULATORY COMMISSION l REG;ON IV

l Docket No.: 50-482

License No.

NPF-42 Report No.: 50-482/98-13 l

Licensee: Wolf Creek Nuclear Operating Corporation Facility: Wolf Creek Generating Station

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Location: 1550 Oxen Lane, NE Burlington, Kansas Dates: April 19 through May 30,1998 Inspectors: J. F. Ringwald, Senior Resident inspector B. A. Smalldridge, Resident inspector Approved By: W. D. Johnson, Chief, Project Branch B ATTACHMENT: Supplemental Information

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9906150344 990612 PDR ADOCK 05000492

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EXECUTIVE SUMMARY Wolf Creek Genersting Station NRC Inspection Report 50-482/98-13 Ooerations

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Good operator attention to detail led to prompt identification and termination of an inadvertent reactor coolant system leak which occurred following a malfunction of the postaccident sampling system. The operators noticed that the reactor coolant drain tank level increased and the volume control tank level decreased at a rate higher than expected and this prompted an effective evaluation that identified and stopped the leak (Section 01.1).

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Two audit reports contained executive summary conclusions that generally agreed with the assessments described in the audit reports, but also contained notable deficiencie The reports did not clearly and consistently present all audit activities and conclusion One executive summary conclusion could not be supported by the assessment and one report described two weaknesses without describing adequate corrective actions (Section O7.1).

. Contrary to the requirements of the clearance order procedure and Technical Specification 6.8.1.a two clearance orders relied on administrative controls outside of the clearance order to provide personnel and equipment protection. The cause of this violation was procedural noncompliance (Section O8.1).

Maintenance

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The material condition of those plant systems and components evaluated during this inspection period was good, with few equipment deficiencies (Section M2.1). l

. Maintenance department management and supervisory oversight for the removal and replacement of the air oil pump on Main Steam Isolation Valve AB HV0011 was not 1 effective for work on a safety-system component that invoked a short duration Technical l Specification action statement. As a result of delays which could have been minimized I or prevented, the operations department came within 4 minutes of exceeding the 4-hour time limit allowed by limiting conditions for operation, which would have required a forced ,

l shutdown of the reactor (Section M6.1).

. The licensee responded appropriately to a work package planning vulnerability which had increased the potential for human error (Section M6.2).

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The licensee responded appropriately to numerous loose parts monitor alarms, apparently caused by incore thimble movement (Section E1.1).

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'The shift supervisor declared a main steam isolation valve operable with an identified

- deficient condition that was expected to reduce the valve's service life and increase the probability of imminent valve failure. Engineering personnel acknowledged, but did not bound the expected reduction in the valve's service life. A subsequent failed bench test

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of the leaking pump demonstrated the concem regarding the decreased service life of the pump. ' The licensee's subsequent actions to declare the valve inoperable within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> for rework was appropriate (Section E1.2).

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The system engineer displayed a deficiency in system knowledge by not knowing the purpose of the hole in the air pump that the air leaked from (Section E1.2).

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The engineering, operations, and maintenance departments coordinated efforts

!' effectively to successfully troubleshoot and identify the cause of an unexpected increase l in volts-amperes reactive (VARS) cn Emergency Diesel Generator A during testing which resulted in an unplanned entry into a 72-hour Technical Specification action statemen ,

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. This indicated an improvement in interdepartmental cooperation and planning (Section 4.1).~ .)

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Contrary to the requirements of 10 CFR 50.59, in 1992, following the failure of the reactor coolant dissolved hydrogen analysis instrument in the postaccident monitoring system, i the licensee selected the secondary analysis method of performing grab samples which could not be performed within the 3-hour time limit prescribed in the safety analysis. This violation constituted e change to the facility without a safety evaluation having been

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performed to determine if an unreviewed safety question existed (Section E8.1).

Plant Suncort

. An emergency plan dri!! provided effective training and demonstrated effective interaction and communication between the licensee and state drill participants (Section P1.1).

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. The security department appropriately responded to a failure of the security diesel j generator to pass a weekly surveillance test, taking action to correct the problem while implementing contingency plans (Section S1.1).

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Reoort Details f

Summarv of Plant Status l The plant operated at essentially 100 percent power throughout the inspection perio . Operations 01 . Conduct of Operations .1 pood Ooerator Attention to Detail i

! !nsoection Scone (71707) . i The inspector reviewed the circumstances associated with a postaccident sampling

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system malfunction that created an inadvertent reactor coolant system leak path into the reactor coolant drain tank.

t - b. ' Observations and Fndings On April 24,1998, the radwaste operator noted that the reactor coolant drain tank level l

incieased at 10 gallons per hour, a rate higher than normal. The reactor operator also

. noted a decrease in the volume control tank level that' exceeded the expected rate. Both

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. operators raised their concems to operations supervision, and this prompted an investigation that quickly identified an unexpected alignment of the postaccident sampling system that permitted the reactor coolant system lea While the postaccident sampling system had been in operation earlier that night, the shift chemist rebooted the postaccident sampling system computer due to an error and j' believed that this action would realign the valves to the standby alignment. During the investigation, the shift engineer determined that the system was still aligned to permit the reactor coolant system flow to the reactor coolant drain tank.1he shift chemist entered a

, command into the postaccident sampling system computer that terminated the valve L

lineup and stopped the leak. The chemist subsequently initiated Performance

. Improvement Request 98-1246 to address this is:ue, Conclusions 1

Good operator attention to detail led to prompt identification and termination of an  ;

inadvertent reactor coolant system leak which occurred following a malfunction of the '

. postaccident sampling system.' The operators noticed that the reactor coolant drain tank L level increased and the volume control tank level decreased at a rate higher than

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expected, and this prompted an effective evaluation that identified and stopped the leak.

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-2-07 Odality Assurance in Operations 07.1 Quality Evaluation Self-Assessment Reoort Review Insoection Scoce (71707)

The inspectors evaluated two quality evaluation self-assessment report Observations and Findinos The inspectors reviewed Quality Evaluation Self-Assessment Report K-471, " Technical Specification and Surveillance Testing," dated April 24,1997, and Quality Evaluation Self-Assessment Report K-480,, " Indoctrination and Training (Operations)," dated January 20,199 In Report K-471, ons executive summary conclusion states "The shift supervisor and operations licertsed operators have a proper and good operating philosophy toward the following Tecnnical Specification related topics." The topics included operability determinations. The auditor's assessment of operability determinations relied primarily on central work authority personnel, though this was not clearly described in the repor The auditors minimally addressed the performance of shift supervisors in their assessment. The role of licensed operators in the operability determinations were not assessed at all. Tne inspectors noted that the assessment report did not contain a definition or a description of what is meant by " operating philosophy" and what criteria was used to determine an acceptable level of performance in this are The inspectors generally agreed with the findings and conclusions reported in Report K-471, " Technical Specification and Surveil lance Testing," dated April 24,199 However, much clarification and discussion with licensee quality evaluation staff was required to reach this determination. The report did not clearly demonstrate a clear and complete nexus between conclusions reported in the executive summary and the actual assessment basis and findings contained in the body of the report. As a result, licensee management was not provided with an accurate assessment of the conduct of operability determination Report K-480 evaluated the programs which controlled the training of operations watchstanding personnel including the senior reactor operator, shift technical advisor, reactor operator, and nuclear station operator. The scope and depth of the audit was adequate. The report presented the audit findings in a manner that was adequate but, at times, did not clearly and consistently present all audit activities and conclusions. The inspector needed to engage in substantial discussions with the lead auditor, and the lead auditor needed to research the answers to several of the inspector's questions before the inspector fully understood the audit report conclusions. In severalinstances, the lead auditor acknowledged that the report either did not present the relevant information or did not precent it in a clear manne _ _ _ _ _ _

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-3-The inspector noted two instances where the audit report discussed problems, but did not discuss the resolution of these problems. In one instance, the report mentioned Performance improvement Request 97-1075 and stated that it discussed training IMPACT 95-875 which was referenced in the applicable lesson plan, but the lesson plan did not address the object of concem. The audit report did not mention whether this problem was ever corrected. In the second instance, the auditors interviewed radwasts and water treatment operators. These operators commented that some of their training

. on equipment they used to pe Torm their duties was not sufficiently detailed. The audit report stated that these comments had been voiced previously to the training division, and that training management planned to cover these concems in a future self-assessment.

L L The inspector also noted that the report reviewed licensed ' operator examination test results in several areas of fundamental operator knowledge. The report noted that a large number of licensed operators had low scores in the area of reactor theory, and the audit report identified this as a weakness to be addressed in Performance Improvement Request 98-0149. During an interview with the performance improvement and

- assessment manager, the inspector leamed that the draft report presented to the l manager for signature contained the data suggesting this weakness, but did not identify L ' the result as a weakness. As part of the manager's review, the manager directed the lead auditor to revise the draft to identify the weakness and corrective action. This action on the part of the manager tumed a potential audit deficiency into an audit report strength.

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l Two audit reports contained executive summary conclusions that generally agreed with )

the assessments described in the audit reports, but also contained notable deficiencie > The reports did not clearly and consistently present all audit activities and conclusion One executive summary conclusion could not be supported by the assessment and one report described two weaknesses without describing adequate corrective action >

08 Miscellaneous Operations issues (92901)

08.1 ' (Closed) Unresolved item 50-482/9810-10: Inadequate Clearance Orders. This item

involved concerns regarding clearance orders which did not provide complete isolation of the component to be maintained from all energy sources and the practice of relying on other administrative controls to provide for protection not afforded by the clearance orde The operations superintendent explained that Procedure AP 21E, " Clearance Orders,'

Revision 7, Section 6.1.2.1.h, required that clearance orders not solely rely on other plant activities for establishing system configurations. As a result, the superintendent explained that the clearance orders in question did not meet the requirements of the procedur Given the licensee's explanation of their interpretation of the procedure, the inspector concluded that the clearance order procedure did prohibit the issuance of clearance j orders that did not provide complete protection and relied on other plant activities to d _ - _ - _ _ _ - _ _ _ _ _ _ - _ _ _ - _ - _ - _ - _ - _ _ - _ _ - _ _ . _ _ _ _ _ _ _ _ - . _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ .

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-4-accomplish complete isolation. Clearance Order 98-0250-EF, accepted on March 17, 1998, and Clearance Order 98-0317-EJ, accepted on April 15,1998, failed to provide complete isolation and relied on Procedure MGE EOOP-11 to establish isolation of the breakers from the bus. These are two examples of a violation of Technical Specification 6.8.1.a (50-482/9813-01).

II. Maintenance M1 Conduct of Maintenance M1.1 General Comments on Maintenance Activities Insoection Scooe (62707)

The inspectors observed all or portions of the following work activitie WP 118090 Re Component cooling water Pump B bearing / mechanical seal replacernent WP 122223 Task 2 Spent fuel pool cleanup pump mechanical pump replacement WP 123669 Re Centrifugal charging Pump B auxiliary tube oil pump alignment WP 127742 Task 2 Replace air oil pump on Valve AB HV0011 WP 127742 Task 3 Inservice test of air oil pump on Valve AB HV0011 WP 129493 Task 1 NB00103 breaker inspection WP129493 Task 2 NB00103 breaker inspection postmaintenance WP 129568 Task 1 Remove and reinstall primary lid on Chem-NVC 14-195 cask in support of radwaste shipment on 5/20/98 WP 101433 Task 8 Molded case Breaker NG01 ACR2 replacement

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SYS KJ-123 Re Postmaintenance run of Emergency Diesel Generator A

, Observation and Findinos l Except as noted in Sections M2.1, M6.1, and M6.2, the inspectors found no concerns l with the maintenance observe <

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-5- Cgoginnigan Except as noted in Sections M2.1, M6.1, and M6.2, the inspectors concluded that the maintenance activities were being performed as require M1.2 General Comments on Surveillance Activities Insoecaon Scone (61726)

The inspectors observed all or portions of the following activitie STS AE-001, Revision 2, Main feedwater isolation valve accumulator discharge test STS BG-005A, Revision 16, Boric acid transfer system inservice Pump A test STS EN-100A, Revision 11, Containment Spray Pump A inservice pump test STS IC-203, Revision 18, ACOT 7300 Process instrumentation Protection Set 111 STS IC-211B, Revision 29, Actuation logic test Train B solid state protection system STS IC-6438, Revision 7, Slave relay Test 643B Train B containment spray Observations and Findinas The inspectors found no concerns with the surveillance observed, Conclusions i

The inspectors concluded that the surveillance activities were being performed as

. require M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Review of Material Condition Durina Plant Tours -

' Inspechon Scope (61726)

During this inspection period, routine plant tours were conducted to evaluate plant material condition.-

~ . Observations and Findinas in general, where equipment deficiencies existed, the deficiencies had been identified by the licensee for corrective actio The inspectors noted that the status of packing leakage on Valve GKV0767 had -

increased from 6 drops per minute when identified on February 16,1998, in Action Request 27487, to a steady stream on May 19,1998. The notch cut in the plexiglass spray guard over the packing area was acting as a weir to the flow from the packing leakage, causing water to back up in the valve packing area. The inspectors determined that the valve is scheduled for repair during the week of August 17-23,1998.

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' ' Conclusions The material condition of those plant systems and components evaluated during this inspection period were good, with few equipment deficiencies.

! M6 Maintenance Organization and Administration M6.1 Manaaement of Limitina Conditions for Ooeration Work on Main Steam Isolation Valve AB HV0011

[ lD8Dection Scone (62707)

The inspector monitored maintenance and management activities associated with limiting conditions for operation work on Valve AB HV0011., Main Steam isolation Valve Observations and Findinas On May 11,1998, the inspector observed the removal and replacement of the air oil

pump on Main Steam Isolation Valve AB HV0011 per Work Package 127742, Tasks 2 and 3. The work required entry into Limiting Conditions for Operation 3.7.7. The maintenance division mechanics performed their work as written, using skill of the craft to make decisions not specifically addressed in the work package.

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which were not directly planned for in the work package.' For example, the workers could not remove the fittings on one component and had to leave the job site to use a vise '

located elsewhere in the auxiliary building to remove fittings. This resulted in an .

unplanned delay in the work accomplishment which, along with several other minor delays, contributed to delayed work completion. The evaluation of the air leak in the newly installed air oil pump combined with the time required to test the operability of the

, - main steam isolation valve using the air oil pump nearly exceeded the 4-hour time limit l' associated with Limiting Conditions for Operation 3.7.7. The Technical Specification action statement was exitad 4 minutes before the time limit was reached. Because of concerns regarding the pump's service life with the air leak, the licensee decided to -

replace the pump a second time after declaring the main steam isolation valve operable.

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! The inspector noted that maintenance department management attention and lf ' supervisory oversight for the work on Valve AB HV0011 was noticeably less than that -

L provided for other work previously ob;erved by the inspector. The inspector observed that, while monitoring the work for approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />; the work week manager was the only supervisor or support person present at the job site prior to identification of an air -  ;

leak on the newly ~ installed air oil pum j During subsequent discussions with maintenance department supervision, the inspector

. questioned the level of management and supervisory oversight for the work on i Valve AB HV0011. The maintenance department response was that management and l

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-7-supervisory oversight for the work on Valve AB HV0011 was not effective and did not meet maintenance department management expectations for work on major equipment l that requires entry into limiting conditions for operatio The inspectors inquired if a root cause analysis would be performed on the defective air oil pump. The acting mechanical maintenance superintendent was not sure if the department was planning to capture this information. After the inspector questioned if the defective pump had been quarantined and whether plans were made to determine the cause of the air leak, the maintenance manager directed maintenance personnel to segregate the defective air oil pump in the "as found" condition until it could be properly evaluated. The inspectors later learned that the mechanical maintenance superintendent had asked that the root cause of the defective air oil pump be determined, but had not specifically asked that the "as found" condition of the pump be preserve Conclusions Maintenance department management and supervisory oversight for the removal and replacement of the air oil pump on Main Steam isolation Valve AB HV0011 was not effective for work on a safety-system component that invoked a short duration Technical Specification action statement. As a result of delays which could have been minimized or prevented, the operations department came within 4 minutes of exceeding the 4-hour time limit allowed by limiting conditions for operation, which would have required a forced shutdown of the reacto M6.2 Work Packaae Vulnerability Insoection Scoce (62707)

While observing a molded case circuit breaker replacement, the inspector noted a vulnerability in the work package and reviewed the licensee's respons b. Observations and Findinos On April 15,1998, the inspector observed the electricians repla:e Molded Case Breaker NG01 ACR2. While reviewing the work package, the inspector noted that the bill of materials list contained parts applicable to more than one style of molded case breaker. As a result, the maintenance program relied on the electrician's skill of the craft to ensure that the proper materials were selected and used. While this was an acceptable method of providing for safety-related parts, the inspector noted that this increased the vulnerability for human error. The electrical maintenance supervisor responded by directing maintenance planners to delete several entries from the bill of materials for future molded case breaker replacement work to ensure that, when special circumstances require different materials, additional reviews will be required to help minimize 'he potential for human erro _ _ _ _

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-8- Conclusions The licensee responded appropriately to a work package planning vulnerability which had increased the potential for human erro Ill. Enoineerina E1 Conduct of Engineering

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E Loose Parts Monitorina System I Inspection Scoce (37551)  ;

l The inspector reviewed the licensee's actions in response to spurious alarm > Observations and Findinos Following Refueling Outage 9, the licensee experienced loose parts monitor alarms at a  !

rate of approximately two per shift on Channel 2. Engineering recorded and evaluated l the noise from Channel 2 and determined that this was caused by the movement of an

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incore thimbie tube A vendor also listened to tapes of this noise and concurred with the evaluation.

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Instrumentation and control technicians periodically calibrated the sensor channel by initiating a calibrated impulse noise on the reactor vessel while adjusting the sensor  !

channel to respond to the impulse noise. Engineering determined that variations in the

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location for performing this impulse noise adjustment resulted in corresponding variations l in the channel sensitivity to incore thimble noise. After verifying that the noise was not j caused by a loose part, engineering directed instrumentation and control technicians to  !

temporarily raise the alarm setpoint above the level that caused the spurious alarm Performance improvement Request 98-0192 was written to address these concerns, and j engineering determined that the corrective actions will include improved guidance to  !

provide some standardization in the calibration metho Conclusions The licensee responded appropriately to numerous loose parts monitor alarms, apparently caused by incore thimble movement.

j E1.2 Main Steam Valve Operability and System Enaineer Knowlecae l

l- Insoection Scooe (37551) l The inspector evaluated the engineering involvement in evaluating the operability of a main steam isolation valv i f

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. Observations and Findinas On May 11,1998, engineering provided technical support to operations in evaluating the operability of Valve AB hV0011, Main Steam isolation Valve D, following the maintenance discussed in Section M6.1 of this report. The, sir-driven oil pump functioned, but exhibited an air teak from the hole used by the setscrew to prevent the air operator from cnscrewing and separating from the oil pump Operators based the initial operability on the fact that the pump passed the postmair% nance test. Consideration for the impact of the leak involved discussions between the shift supervisor and the system engineer. The system engineer knew that ine pump had successfully passed the test; however, the air leak demonstrated that air was getting past the air actuator 0-ring. This meant that the O-ring had either been repositioned cut of its designed location or had been cut. If it had been cut during reassembly, it wa3 not litely to have passed the shop test. If it had mispositioned, it had en increased potentia! to shift completely out of the seat and this would have resulted in failure of the puup. During subsequent discussions, j the system engineet expressed conce rns that tha pump could be sbject to imminent 1 failur Since the pump passed the test, the shift supervisor declared We valve operable, but made a statement in the shift supevisor's log regarding concem over ks expected service life. When the inspector questioned the shift supeeviscr and the system engineer I

whether this reduction had been either quantified or bound 6d, they acknowledged that it had not When the inspector questioned if they:sxpected the pump to fail'on the next stroke," they said that they did not expect this since it passed the test. However, when the inspector questioned if the valve had an increased potential of failure such that it could fail on the next stroke, they acknowledged that this was possible and the probabiW of this sort of failure was increase On May 29,1998, mechanks perforrned another bench test of tha pump with the air leak. During this test, the pump failed the test by failing to produce oil prescure above 200 psig. As a result of schedule concerns, the licensee defe#ed subsequent q troubleshooting until after the end of the inspection perio ;

The inspector asked the system engineer to describe the purpose of the hole from which the leaking air escaped. The engine er stated that the hole was used to permit d(olaced air on the opposite side of the air picton to move in and out of the actuator, thus anowing free movement of the air piston. During additional reviews of the techr?ical manual and discussions with the mechanics, the inspector teamed that the hole was not for this ;

purpose, but simply to hold a setso ow used to pre'/ent r6tation and removal of the air pump from the oilpum As discussed in Section M6.1 of this report, the licensee declarad the pump operable on May 11,1998, at 12:24 p.m. and then declared it inoperable at 3:19 p.m. for the second replacement of the air-driven hydraulic oil pump.

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-10- Conclusions The shift supervisor declared a main steam isolation valve operable with an identified deficient condition that was expected to reduce the valve's service life and increase the probability of imminent valve failure. Engineering personnel acknowledged, but did not bound the expected reduction in the valve's service life. A subsequent failed bench test of the leaking pump demonstrated the concem regarding the decreased service life of the pump. The licensee's subsequent action to declare the valve inoperable within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> for rework was appropriat The system engineer displayed a deficiency in system knowledge by not knowing the purpose of the hole in the air pum E Engineering Staff Knowledge and Performance E4.1 Trout.:;;hcotina and Cause Determination of VARS Steo Chance on Emeroency Diesel Generator A insoection Scone (37551)

The inspectors reviewed the licensee response to an unexpected VARS step change during an increase in excitation voltage setpoint to Emergency Diesel Generator A while the generator was synchronized to the gri b.- Observations and Findinas On May 14,1998, at 1:48 a.m., the reactor operator identified an unexpected increase in VARS while adjusting the excitation voltage setpoint to Emergency Diesel Generator A during the performance of Procedure STS KJ-005A, " Manual / Auto Start, Synchronization, and Loading of Emergency Diesel Generator NEO1," Revision 30. The shift supervisor subsequently decided to maintair, the diesel generator status as inoperable pending the outcome of an investigation for the cause of the step-change increase in VARS. Technical Specification 3.8.1.1, a 72-hour shutdown action -

statement, was in effect. The control room staff contacted the work control group and system engineering in order to facilitate coordination and focus for the investigatio The inspectors noted that, throughout the next 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />, the engineering department coordinated efforts with the operations and maintenance departments and offsite contractors. The licensee developed and carried out a plan to troubleshoot and identify the root cause of the unexpected step increase in VARS. Engineering personnel effectively controlled the troubleshooting process and fully reviewed and understood the results of different phases of data collection before proceeding to the next step in the-proces The licensee determined that the cause of the unexpected increase in VARS, which occurred while adjusting the excitation voltage setpoint to Emergency Diesel Generator A, was electromagnetic interference induced noise from

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-11-Handswitch NEHS0013A. This control room switch is used to raise / lower the excitation voltage setpoint in the manual mode of operation with the diesel generator synchronized to the grid. Handswitch NEHS0013A has no function in the emergency start mode of the diesel generator. in the emergency start mode, the predetermined value voltage is set and not controlled by the operator On May 16,1998, at 1:33 p.m., Emergency Diesel Generator A was declared operable after the cause of the unexpected increase in VARS, while adjusting the excitation voltage setpoint, was identified, and it was determined that the circuit in question had no impact on the emergency diesel generator's safety function, Conclusions The engineering, operations, and maintenance departments coordinated efforts effectively to successfully troubleshoot and identify the cause of sn unexpected increase in VARS on Emergency Diesel Generator A during testing which resulted in an j unplanned entry into a '72-hour Technical Specification action statement. This indicates an improvement in interdepartmental cooperation and plannin E8 Miscellaneous Engineering issues (92903) i

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E (Closed) Unresolved item 50-482/9804-04. Uncompensated postaccident sampling system inoperability. This item involved the licensee's discovery that the grab sample backup for the inoperable postaccident sampling system analysis equipment for analysis of dissolved hydrogen in the reactor coolant system did not meet the Updated Safety Analysis Report, Chapter 18.2.3, " Post Accident Sampling System," requirement for analysis within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. The analyzer had been out of service since 1992, and the licensee incorrectly assumed that grab samples could be taken and analyzed within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. On Januery 30,1998, the system engineering personnel determined that the analysis could not be completed within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> because the sample would have to be taken offsite and the results would not be available for approximately 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> The extended inoperability of the analysis instrument without an adequate backup analysis methodology represents a de-facto modification to the postaccident sampling system. The licensee did r ot treat this as a modification and, therefore, did not perform a

.10 CFR 50.59 evaluation for this modification. The failure to perform this required 10 CFR 50.59 evaluation is a violation (50-482/9813-02).

The licensee's resultant evaluation determined that the safety significance of this issue was minor due to the fact that the reactor vessel head vents and reactor vessel level indicating systems were operational and would mitigate the consequences of postaccident hydrogen production on reactor vessel flow.- As part of their corrective actions, the licensee submitted a request for NRC approval of a change to their Updated l' Safety Analysis Report, Chapter 18, NUREG 0737, commitment to eliminate the requirement for the reactor coolant system dissolved hydrogen inline monitoring and grab sample capability.

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-12-IV. Plant Support P1  : Conduct of Emergency Preparedness Activities P Conduct of Quarteriv Emeroency Plan Drill insoection Scone (71750)

The inspector observed the second quarter emergency plan drill at the emergency operations facilit Observations and Findinas On May 12,1998, the inspector observed the second quarter emergency plan drill from -

the emergency operations facility. The inspector noted that the drill effectively exercised

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' the licensee and the state of Kansas personnel in carrying out coordinated emergency response activities at the emergency operations facility and that communication and interaction between the licensee and the state of Kansas personnel was particularly good. The inspector noted that, while command and control at the emergency operations facility started out just adequate at the beginning of the drill, it improved notably throughout the remainder of the drill as managers at the facility focused on this

' aspect of performanc ' Conclusions An emergency plan drill provided effective training and demonstrated effective interaction and communication between licensee and state drill participant S1' Conduct of Security and Safeguards Activities S1.1 ' Security Dehaiiii.ent Resoonse to Failed Security Diesel Surveillance : Insoection Scoos (71750)'

The inspectors reviewed the security department response to a failed security diesel surveillance."

Observations and Findinos On May 12,1998, the security diesel generator failed to automatically load during the

. weekly performance of Procedure SE 01-108, " Security Systems Device Testing,"

Revision 43. The inspectors noted that the security department immediately obtained assistance from the maintenance department to troubleshoot and repair the diesel and

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implemented a plan to manually load the diesel in the event it was needed. The .

= automatic loading function of the security diesel generator was repaired and operability restored that same day.

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l-13- Conclusions The security department appropriately responded to a failure of the security diesel generator to pass a weekly surveillance test, taking action to correct the problem while implementing existing contingency plan V. Management Meetings X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusions of the inspection on June 2,1998. The licensee acknowledged the findings presente The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie !

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e SUPP!.EMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee M. J. Angus, Manager, Licensing and Corrective Action G. D. Boyer, Chief Administrative Officer J. W. Johnson, Manager, Resource Protection O. L. Maynard, President and Chief Executive Officer B. T. McKinney, Plant Manager R. Muench, Vice President Engineering W. B. Norton, Manager, Performance improvement and Assessment C. C. Warren, Chief Operating Officer INSPECTION PROCEDURES USED IP 37551 Onsite Engineering IP 61726 Surveillance Observations IP 62707 Maintenance Observations IP 71707 Plant Operations IP 71750 Plant Support Activities IP 92901 Followup - Operations IP 92903 Followup - Engineering ITEMS OPENED AND CLOSED Opened 50-482/9813-01 VIO Inadequate clearance orders (Section 08.1)

50-482/9813-02 VIO Uncompensated postaccident sampling system inoperability (Section E8.1)

Closed 50-482/9804-04 URI Uncompensated postaccident sampling system inoperability (Section E8.1)

50-482/9810-10 URI Inadequate clearance orders (Section 08.1)

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