ML20206S288

Insp Rept 50-482/86-13 on 860501-31.Violations Noted: Failure to Properly Document Completed Portion of Surveillance Test,Data Not Recorded on Work Request & Cardboard Containers Stored in Auxiliary Bldg

ML20206S288
Person / Time
Site:	Wolf Creek
Issue date:	07/02/1986
From:	Bruce Bartlett, Cummins J, Hunter D, Mullikin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20206S271	List: ML20206S266 ML20206S274 ML20206S288
References
50-482-86-13, NUDOCS 8607070323
Download: ML20206S288 (12)

See also: IR 05000482/1986013

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APPENDIX B

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US NUCLEAR REGULATORY COMMISSION

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Region IV

NRC Inspection Report: 50-482/86-13

License: NPF-42

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Docket: 50-482

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

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Post Office Box 208

Wichita, Kansas 67201

Facility Name: Wolf Creek Generating Station (WCGS)

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

Inspection Conducted: May 1-31, 1986

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Inspectors:

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J. E. Cummins, Senior Resident Inspector,

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B. L. Bartlett, Resident Reactor Inspector,

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paragraphs 4, 5, 6, and 7

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R. P. Mullikin,~ Project Inspector-Wolf Creek,

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par graph 3 and 8

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Approved:

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D. R. Hunt

, Chief, Project Section B,

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eactor rojects Branch

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Inspection Summary

Inspection Conducted May 1-31, 1986 (Report 50-482/86-13)

Areas Inspected: Routine, unannounced inspection including plant status;

followup on previously identified NRC items; operational safety verification;

monthly surveillance observation; monthly maintenance observation;

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environmental qualification of electric equipment; and survey of biofouling

detection instrumentation on cooling water heat exchangers.

Results: Within the seven areas inspected, three violations were identified

(failure to properly document a completed portion of a surveillance test,

paragraph 5; data was not recorded on a work request as required by procedure,

paragraph 6; and cardboard containers were stored in the auxiliary building

contrary to procedure, paragraph 4).

One unresolved item is identified in

paragraph 7.

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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

• R. M. Grant, Director, Quality

• M. Estes, Superintendent of Operations

M. D. Rich, Superintendent of Maintenance

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

_ Administrative Services

• 0. L. Maynard, Manager, Licensing

• K. Peterson, Licensing

H. Chernof f, Licensing

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• G. Pendergrass, Licensing

• W. M. Lindsay, Supervisor, Quality Systems

• C. E. Parry, Superintendent of Quality Systems Engineering

• C. J. Hoch, QA Technologist

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

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• C. M. Herbst, Project Engineer, Bechtel

M. Megehee, Compliance Engineer

W. J. Rudolph, QA Manager

R. L. Hoyt,-Acting Operations Coordinator

The NRC inspector also contacted other members of the licensee's staff

during the inspection period to discuss identified issues.

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

June 6, 1986.

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Plant Status

The plant operated in Mode i during this inspection period.

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3.

Followup on Previously Identified NRC Items

(Closed) Unresolved Item (482/8420-02):

Inadequate Preoperational Test

Procedures

This item related to the concern that the actual plant conditions and the

methods of attaining these conditions for performing the test steps were

not provided with definitions in selected preoperational test procedures.

The following NRC inspection reports contained a review of selected

preoperational test procedures:

84-26, 84-30, 84-38, 84-43, 84-46, 84-49,

84-55, 84-59, 85-08, 85-11, 85-14, and 85-15.

These inspections did not

identify any concerns related to actual plant conditions during testing.

This unresolved item is closed.

(Closed) Open Item (482/8423-05): Reconciliation of As-Built Drawings

This item required that the licensee reconcile design drawings with actual

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as-built conditions by 90 days after fus1 load. The licensee submitted to

the NRC, within the 90-day limit, the as-built drawings for the plant.

This item is closed.

(Closed) Open Item (482/8423-06): Use of Non-Impact Tested ASTM A-574

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Cap Screws in Mechanical Snubbers

The snubber supplier (Bergen-Paterson) submitted a response to KG&E

regarding this concern and stated that, due to the load and conditions

applied to these snubbers, brittleness and stress corrosion cracking was

not a concern. This item is closed.

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(Closed) Violation (482/8435-02): Failure to Follow Procedures

This violation concerned a failure to follow approved procedures for the

storage of radiographic film, incorporation of changes into design

documents, and maintenance of M&T Measuring Equipment Calibration Log.

The licensee's corrective action was reviewed and found to adequately

resolve this concern. This violation is closed.

(Closed) Open Item (482/8448-05): QA/QC Involvement In the Startup

Testing Program

This item concerned QA/QC involvement during the startup program. The NRC

inspector found that QA performed numerous audits of the startup program.

In addition, NRC Inspection Report 50-482/84-58 documented a review of

this item of concern and noted the item to be resolved. This item is

closed.

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(Closed) Violation (482/8459-01):

Inadequate Preoperational Test Results

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Evaluation and Documentation

The NRC inspector reviewed the licensee's response and found all issues to

be adequately resolved. This violation is closed.

(Closed) Open Item (482/8511-05): Inspection of Selected Components

for Microbiologically Influenced Corrosion (MIC)

This item required that an inspection for MIC be performed prior to

September 30, 1985, for selected components. The NRC inspector reviewed

the completed work requests for the required components and found all

inspections to be completed prior to the due date. This item is closed.

(Closed) Open Item (482/8519-03): Lack of Expiration Date for

Combustible Materials Permit

WCGS ADM 13-102, Revision 4, did not require an expiration date of the

combustible materials permit. The licensee now has an approved change

notice in effect for this procedure requiring an expiration date. This

item is closed.

(Closed) Violation (482/8525-01): Lack of Control of the Modification

Process

This finding identified examples of incomplete modification packages. The

NRC inspector reviewed the licensee's response and found the corrective

action taken to be adequate. This violation is closed.

(Closed) Unresolved Item (482/8526-03): Inadequate Security Procedures

This item related to the concern that the licensee's procedures did not

define the limits under which a security background investigation should

be performed for specific employees under certain conditions. The

licensee has revised ADM 10-006, " Security Screening Procedure," which

adequately resolved this concern. This item is closed.

(Closed) Violation (482/8541-01): Violation of Technical Specification-

Fire Suppression System Surveillance

This violation concerned the fact that monthly surveillances, required by

TS, of fire protection valve positions for Engineered Safety Feature (ESF)

Transformers XNB01 and XNE02 were not being performed due to being lef t

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out of procedures. The licensee corrected this condition and reviewed

other fire protection surveillance procedures for similar discrepancies.

This adequately resolved this concern. This violation is closed.

(Closed) Violation (482/8541-02): Failure to Follow Surveillance Test

Procedure for Electric Motor Driven Fire Pump IFP01FAI

This violation concerned the failure to follow a procedure for the starting

of Electric Motor Driven Fire Pump 1FP01FA. Surveillance Procedure

STS FP-062 was revised to require the S0 or SS to determine the correct

starting method. This violation is closed.

4.

Operational Safety Verification

The NRC inspectors verified that the facility was 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 by reviewing facility records.

The. NRC inspectors, by observation, interview of personnel, and review of

documents, verified that physical security was being implemented in

accordance with the site security plan and that radiation protection

activities were controlled.

By observing valve position, electrical breaker position, control room

indication, and making containment entries, the NRC inspectors confirmed

the operability of the coolant charging system, safety injection system,

and the accumulator safety injection system.

Selected NRC inspector observations:

On May 10, 1986, during a routine plant tour, the NRC inspector

observed approximately 25 heavy cardboard containers in the hallway

on the north end of Elevation 2000' of the auxiliary building.

During a routine plant tour on May 13, 1986, the NRC inspector

observed the containers still present on Elevation 2000'.

Step 3.1.2

of the licensee's Procedure ADM 13-102 prohibits the storage of

combustibles in safety-related areas. This failure to follow a

procedure is an apparent violation (482/8613-03).

On May 29, 1986, licensee personnel informed the NRC inspectors that

on April 29, 1986, during plant startup (Mode 3 at the cine), RHR

Valve EJ HV-8809B, " Train B Discharge Header To Cold Leg Loops 3 and

4," was closed to stop backleakage from the reactor coolant system

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into the RHR system piping. The backleakage was due to the failure

of check valves in the line to seat tightly. Subsequently, the

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licensee initiated an engineering evaluation (EER 86-EJ-02) of the

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RHR system to determine if the system could perform its safety

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function with Valve EJ HV-8809B closed. The engineering evaluation

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determined that the RHR system had not been analyzed in this

condition, and therefore, it could not be verified that the system

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could provide the required minimum flow for accomplishing the

system's safety function assuming a single failure. The RHR system

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was in this lineup (Valve EJ HV-8809B shut) for approximately

49 hours5.671296e-4 days <br />0.0136 hours <br />8.101852e-5 weeks <br />1.86445e-5 months <br /> between April 20-22, 1986. Technical Specification 3.5.2

requires that if one subsystem of the ECCS is inoperable, the

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subsystem must be restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the

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plant must shut down. The licensee is taking the following actions

as a result of this event:

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Procedures are being written to define actions to be taken

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during plant heatup if RHR temperature increases.

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Details of this event have been made required reading for all

licensee operators so they will be aware of the consequences of

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shutting certain RHR valves.

A licensee event report (LER) will be submitted to the NRC.

The NRC inspectors will review the LER and related activities and

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document their findings in a subsequent inspection report.

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5.

Monthly Surveillance Observation

The NRC inspector observed selected portions of the performance of

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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

inspector considered the following items while inspecting surveillance

activities:

Testing was being accomplished by qualified personnel in accordance

with an approved procedure.

The surveillance procedure conformed to TS requirements.

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Required test instrumentation was calibrated.

TS limiting conditions for operation (LCO) 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.

The performance of the surveillance procedure conformed to applicable

administrative procedures.

The surveillance was performed within the required frequency and the

test results met the required limits.

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

below:

STS EJ-202, Revision 0, "RHR System Inservice Valve Test"

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STS IC-447, Revision 2 " Channel Calibration Nuclear

Instrumentation System Power Range Incore-Excore"

STS IC-214, Revision 2, " Analog Channel Operation Test Nuclear

Instrumentation System Power Range N41 Protection Set I"

Selected NRC inspector observations are discussed below:

On May 16, 1986, the NRC inspector observed a portion of the

performance of STS EJ-202 and then reviewed the completed

surveillance procedure. During this review, the NRC inspector

-observed that the test performer and the independent witness had just

completed testing .'B' Train Valve EJ HV-8809B, but instead of signing

off Steps 5.1.2, 5.1.3 and 5.1.4, both had signed off Steps 5.1.6,

5.1.7, 5.1.8, and 5.1.9, which are the steps for Valve EJ HV-8809A.

This is an apparent violation (482/8613-01).

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Monthly Maintenance Observation

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The NRC inspector observed maintenance activities performed on

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safety-related systems and components to verify that these activities were

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conducted in accordance with approved procedures, TS, and applicable

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industry codes and standards. The following elements were considered by

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the NRC inspector during the observation and/or review of the maintenance

activities:

LCO were met and, where applicable, redundant components were

operable.

Activities complied with adequate administrative controls.

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

used.

Craftsmen were qualified to accomplish the designated task and

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

was made available when appropriate.

Replacement parts and materials being used sere properly certified.

Required radiological controls were implemented.

Fire prevention controls were implemented where appropriate.

Required alignments and surveillances to verify post maintenance

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operability were performed.

Quality control hold points and/or checklists were used when

appropriate and quality control personnel observed designated work

activities.

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Selected portions of the maintenance activities accomplished on the WRs

listed below were observed and related documentation reviewed by the NRC

inspector:

WR 00669-86, " Aux Feed Pump PALO1B, pump is out-of-alignment with

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motor"

WR 02211-86, " Class 'A' Transmitters /xx, inspect instruments .

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to determine method of determination"

WR 02222-86, " Valve EJ HV-8809B, incorrect vendor wire installed on

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Valve EJ HV-8809B"

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WR 02224-86, " Valve EJ HV-8840, unidentifiable vendor wire on Valve

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EJ HV-8840"

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WR 02225-86, " Valve EM HV-8821B, nonqualified terminal block

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installed in Valve EM HV-8821B"

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WR 02324-86, " Inspect and fill as required

'J' boxes with Dow

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Selected NRC inspector observations are discussed below:

On May 16, 1986, the NRC inspector reviewed completed WR 02222-86.

.The NRC inspector observed that, contrary to written instructions

delineated in Block 18 of the WR, the limitorque serial number had

not been written down in Block 39 of the WR.

This failure to follow

procedure instructions is an apparent violation of TS 6.8.1 which

requires that, " Written procedures shall be established,

implemented, and maintained . . . ."

(50-482/8613-02)

7.

Environmental Qualification of Electric Equipment

Instrument Transmitters

While performing routine maintenance work on safety-related pressure

transmitters that were located in a harsh environment area (steam and

feedwater piping room), licensee personnel observed that some of the

pressure transmitter field splice (FS) boxes had terminal boards for

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making wire terminations rather than splices, which were specified for

wire terminations in environmentally qualified electric equipment located

in a harsh environment. Sheet 5 of Specification E-17000A, page 5,

" Termination Of Selected Class 1E Devices." (harsh environment) delineates

the accepted method for making these terminations,

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Based on this observation, the licensee inspected 12 pressure transmitters

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and 4 valve controller FS boxes and determined that terminal boards in

lieu of splices were used in 10 of the 16 FS boxes inspected. The problem

appears to have been caused by errorn made in both design and

installation. The following is a summary of the type problem identified

in each instrument.

Six main steam pressura transmitters FS boxes had terminal boards

installed due to a design error in that the wrong specification was

provided on installation / inspection insttuctions. The affected

transmitters were AB-PT-0525, AB-PT-0526, AB-PT-0535, AB-PT-0536, and

AB-PT-0545. Specification E IR8900, " Raceway, Notes, Symbols, and

Details," (non-harsh environment) was called for rather than

Specification E-17000A.

Two atmospheric relief valve controllers and three main steam

pressure transmitter FS boxes had terminal blocks installed even

though the installation instructions specified splices. The affected

instruments were AB-PY-0002, AB-PY-0004, AB-PT-0534, AB-PT-0524, and

AB-PT-0515.

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The FS box for Main Steam Pressure Transmitter AB-PT-0546 had splices

(which is right) in it even though the installation / inspection

instructions called for terminal boards.

Based on the above findings, the licensee performed an inspection on 101

additional instruments, and found the following deficiencies in the

indicated instrument's FS box:

Connection boxes for 8 containment recirculation sump level

instruments were not filled with silicone fluid as required by

Installation Drawing J-481-0002, " Installation Specifications

Transmitter Wiring and Mounting." The affected instruments were

EJ-LE-0007A, EJ-LE-0007B, EJ-LE-0008A, EJ-LE-0008B, LF-LE-0009A,

LF-LE-0009B, LF-LE-0010A, and LF-LE-0010B.

Connection boxes for 8 level instruments for monitoring water level

in the RER pump rooms and the auxiliary building sumps were not

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filled with silicone fluid as required by Installation Drawing

J-481-0005, " Installation Specifications Transmitter Wiring and

Mounting." The affected instruments were LF-LE-0101A, LF-LE-0101B,

LF-LE-0102A, LF-LE-0102B, LF-LE-0103A, LF-LE-0103B, LF-LE-0104A, and

LF-LE-0104B.

Connection box terminations for 4 containment cooler temperature

elements did not have potting compound applied to terminal blocks as

required by Installation Drawing J-558B-0008, " Installation

Specifications Transmitter Wiring and Mounting." The affected

instruments were GN-TE-0060, GN-TE-0061, GN-TE-0062, and GN-TE-0063.

The licensee is presently expanding the walkdown inspections of

environmentally qualified electrical equipment to include a sample of all

special connections (i.e., splices) located in this equipment. Pending

further review and inspection of the licensee's evaluation, the matter is

considered an unresolved item (482/8613-04).

No violations or deviations were identified.

8.

Survey of Biofouling Detection Instrumentation on Cooling Water Heat

Exchangers

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The NRC inspector interviewed licensee personnel and reviewed the Final

Safety Analysis Report (FSAR) to determine whether instrumentation was

available on safety-related equipment cooled by open-cycle service water

system (essential cooling water) which would detect biofouling.

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The containment air coolers were found to be the only pieces of

safety-related equipment that were being monitored for cooling water flow.

However, this instrumentation was not online but was used to measure flow

at least once per 31 days as part of the TS surveillance requirement for

the containment cooling system. Operability was demonstrated by a flow

rate of equal to or greater than 2200 gpm to each cooler group. A flow

rate less than this on one or more cooler groups required the operator to

enter the TS action statement.

The licensee was found to be concerned by the problem of biofouling. This

was evident by their program of inspecting, at 6-month intervals,-

selected components using service water and essential cooling water.

Included in this sample was fire protection piping.

No violations or deviations were identified.

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Exit Meeting

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

findings of this inspection on May 7, 1986. The NRC inspector.also

attended entrance / exit meetings of other NRC region based inspectors

identified below:

Inspection

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Inspection

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Inspector

Inspected

Report No.

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J. Kelly

Security

86-12

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5-12/16-86

D. Norman

Equipment

86-14

Qualification

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