ML20140E726

Insp Rept 50-482/97-08 on 970223-0405.Violations Noted. Major Areas Inspected:Operations,Maintenance,Engineering, Plant Support & Plant Status

ML20140E726
Person / Time
Site:	Wolf Creek
Issue date:	04/25/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20140E710	List: ML20140E705 ML20140E718 ML20140E726
References
50-482-97-08, 50-482-97-8, NUDOCS 9704290128
Download: ML20140E726 (18)

See also: IR 05000482/1997008

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ENCLOSURE 2

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-482

License No. NPF-42

Report No.- 50-482/97-08

Licensee: Wolf Creek Nuclear Operating Corporation

Facility: Wolf Creek Generating Station

Location: 1550 Oxen Lane, NE

Burlington, Kansas

Dates: February 23 through April 5,1997

Inspectors: J. F. Ringwald, Senior Resident inspector

J. L. Dixon-Herrity, Resident inspector

G. L. Guerra, Jr., Radiation Specialist

Approved By: W. D. Johnson, Chief, Reactor Projects Branch B

ATTACHMENT: Supplemental information

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9704290128 970425

PDR ADOCK 05000482

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EXECUTIVE SUMMARY

Wolf Creek Generating Station

NRC Inspection Report 50-482/97-08

Operatj ans

The operators exhibited good attention to detail in identifying a small step change in

reactor coolant pump seal flow. The corrective actions taken by tha licensee were

conservative and appropriate (Section 01.1).

• Operator actions and the corrective actions taken in response to the failure of

Component Cooling Water Train A surge tank level indications were appropriate and

in accordance with procedures (Section 01.2).

• The inspector identified an additional example of a violation cited in a previous

report when the shift supervisor failed to recognize that maintenance on a

containment isolation valve would render the valve inoperable, and this condition, l

therefore, required entry into Technical Specification 3.6.3 (Section 01.3). )

• The operators responded appropriately in recognizing the concern with performing I

two radwaste releases in a manner inconsistent with the Updated Safety Analysis ,

Report (USAR) requirements (Section 04.1). I

• Radwaste operators' failure to follow procedures when filling Waste Monitor Tank B i

was identified as a violation (Section 08.1).

Maintenance j

• The system engineer's initiative to recommend component cooling water pump

bearing replacement was considered to be a strength in monitoring and addressing

concerns with the system's performance (Section M1.3).

• An electrical technician exhibited good attention to detailin noting inadequate

surface contact on half of the connections to the bus on a breaker (Section M1.4).

• Appropriate actions were taken by maintenance planning in addressing a missing roll

pin on the diesel generator mechanical governor (Section M1.4).

• The inspector noted a concern in communications within the planning department

when concerns raised during a work critique meeting about planning were not

relayed to planning management (Section M1.5). l

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• The failure to update the operational risk assessment document maintained in the

control room was identified as a violation (Section M1.6).

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• The licensee identified violation of Technical Specification 3.8.1.1 was cited  ;

because the inspector identified that inadequate corrective actions led to a I

recurrence of a related event. In both events, inadequate communication between l

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the shift supervisor and maintenance technicians resulted in the shift supervisor not

understanding the impact of the proposed work on the operability of safety-related

equipment (Section M8.1).

Enaineerina

• The inspector identified an unresolved item associated s A a USAR change which

deleted time response requirements for the control room ventilation radiation

monitors (Section E1.1)

• The failure to update the USAR to reflect the actual plant design for containment

penetrations was identified as a violation of 10 CFR 50.71(e) (Section E8.1).

Plant Suncort

• The licensee found that the chemistry department prepared liquid release permits

which would not have met the USAR requirements for alarm setpoints

(Section 04.1)

• A noncited violation resulted when an engineer and a quality control inspector failed

to follow procedures by entering the radiation controlled area without

thermoluminescent dosimetry (Section R1.1).

• A radioactive source spill caused three personnel to become contaminated when a

check source separated from an area radiation monitor detector due to adhesive ,

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degradation. The initial technician response was appropriate and effective in

limiting the spread of contamination and cleaning up the spill (Section R1.2).

• The licensee identified and appropriately addressed a chemistry technician training I

deficiency (Section R5.1).

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Report Details

Summary of Plant Status

The plant operated at essentially 100 percent power throughout the inspection period.

I. Operations

01 Conduct of Operations

01.1 Reactor Coolant Pumo C Seal 1 Dearadation

a. Inspection Scope (71707)

On March 21,1997, operators in the control room noted an unexpected response of

Reactor Coolant Pump C sealleakoff flow after switching charging flow from the

normal charging pump to Centrifugal Charging Pump B. It increased from

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approximately 4.9 to 5.1 gpm, then stabilized at 4.9 gpm. The inspectors observed

the corrective actions taken after the anomaly was identified, reviewed plant

parameters, and reviewed the applicable procedures.

b. Observations and Findinas

The operators reviewed recent history for the leakoff flow parameter in the

computer. They noted step increases from 3.2 to 4.0 gpm on March 9,1997, and

from 4.0 to 4.9 gpm on March 18,1997. In each of these cases, the flow

remained at the higher level, rather than stabilizing back to a lower flow. The

licensee had previously noted that temperature changes in the reactor coolant

system caused flow increases in sealleskoff, but the flow returned to normal when

the system stabilized. The operators reviewed related procedures and contacted

management. Management personnel determined that the current flow did not

exceed the specified maximum flow, but that the condition was not desirable.

Management personnel directed that changes in temperature were to be minimized

and that the manufacturer was to be contacted early Monday morning to discuss

the trend. Plans were also made to set up a contingency plan for a forced outage

to replace the seal.

The inspector reviewed both the Alarm Response Procedure ALR 00-072A, "RCP

Seal No.1 Flow Hi," Revision 7, and Offnormal Procedure OFN BB-005, "RCP

Malfunctions," Revision 2, and noted that there were no actions required for the

current plant conditions. When the flow reached 5.7 gpm, the procedures required

that the manufacturer be contacted. The procedures required that operators

immediately trip the reactor if the flow reached 6 gpm. Seal 1 is a controlled-

leakage film-riding seal with a normal controlled leakage of approximately 3 gpm.

The inspector observed the briefing for the oncoming crew on the evening of

March 22,1997. Relevant procedures and the activities that could affect seal

leakoff flow were discussed. The inspector determined that the briefing on the

concern was thorough and noted that activities that could affect sealleakoff flow

over the weekend were postponed when possible.

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The manufacturer reviewed the problem and suggested that the temperature of

coolant to the seals be lowered and that the seal filter be changed to a finer size

filter. The licensee replaced the 5 micron seal injection filter with a 2 micron filter.

Af ter the filter was installed, the sealleakoff flow decreased to approximately

3.2 gpm. In addition to this action, the licensee developed a procedure to lower the

volume control tank temperature two degrees. The manufacturer reviewed the

results of the actions taken and determined that the cause of the problem was

probably particulate deposition on the seal surface and that no further action was

required for the seal package.

c. Conclusions

The operators exhibited good attention to detail in identifying the small step change

in the seal flow. The inspector determined that the corrective actions taken by the

licensee were conservative and appropriate.

01.2 Component Coolina Water Surae Tank A Loss of Level

a. inspection Scone (71707)

On March 31,1997, at 9:37 p.m., operators in the control room noted that the

level was quickly decreasing in the Component Cooling Water Train A surge tank as

they transferred the nonsafety-related service loop from Train B to Train A. The

inspectors reviewed the licensee's actions associated with the decreasing surge

tank level indication and subsequent corrective actions.

b. Observations and Findinas ,

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The operators appropriately transferred the service loop back to Train B, entered

Procedure OFN EG-004, "CCW System Malfunctions," Revision 1, took Component ,

Cooling Water Train A out of service, placed the pumps in pull to lock, and entered l

Technical Specification 3.7.3. The change in level initiated an auto makeup and i

isolation of component cooling water to the postaccident sampling system and the

radwaste building. Operators toured the auxiliary building and found no component  !

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cooling water leaks or damage. However, operators reported that the suction

pressure gage for Component Cooling Water Pump A was overranged high. An

operator unisolated the Surge Tank A sight glass and reported that the tank was 4

three-quarters full. Operators appropriately isolated makeup to the tank. Operators l

noted that Surge Tank A level indication started working again, the indicated level I

increased to 95 percent, and the level high alarm actuated.

The licensee performed surveillance tests on the instruments and gages involved in

the event and found that they were calibrated. The suction gages that were  ;

overranged high were determined to be operable after the surveillance was i

satisfactorily performed. Engineering personnel performed an inventory balance and l

determined that approximately 2,000 gallons of water were transferred from the

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demineralized water tank to Surge Tank A. Instrumentation and controls personnel

replaced the level transmitter and flushed the sensing line. A small quantity of

sludge was flushed out of the lower instrument tap that connects to the transmitter

high pressure side. The licensee determined that this was the probable cause of the

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decrease in indicated level.

In addition to the above actions, instrumentation and controls personnel performed

a field walkdown, operations personnel verified that the system was vented, and

the licenseu verified that there were no similar events in industry.

c. Conclusions

Operator actions and the corrective actions taken in response to the failure of

Component Cooling Water Train A surge tank level indication were appropriate and

in accordance with procedures.

01.3 Ooerations Miscommunication with Maintenance Technicians

a. Inspection Scope (71707)

The inspector reviewed the circumstances surrounding the failure of a shift

supervisor to log entry into Technical Specification 3.6.3.

b. Observations and Findinas

On March 5,1997, the inspector noted that during Valve Operation Test and

Evaluation System testing on Valve EF-HV0034, the essential service water supply

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to Train B containment coolers inside containment isolation valve, the shift

supervisor did not log entry into Technical Specification 3.6.3. Upon questioning,

the shift supervisor acknowledged that this should have occurred, and made the

appropriate entries to correct the situation. The shift supervisor also directed

operators to make a similar entry into the equipment out-of-service log. Operations

personnel initiated Performance improvement Request 97-0716 which identified that

inadequate communication between the electrical maintenance technicians and the

shift supervisor resulted in the shift supervisor not recognizing that the maintenance

rendered the valve inoperable.

Administrative Procedure AP 21-001, " Operations Watchstanding Practices,"

Revision 4, Step 6.2.3.d, required the shift supervisor's log to contain log entries

for entry into Technical Specification action statements due to major equipment

being out of service for maintenance or due to equipment failure. NRC Inspection

Report 50-482/97-04, Section 08.1, described a violation of this requirement. This

l issue is being considered an additional example of the previously cited violation

l (482/9704-01) because it occurred prior to the issuance of the previous Notice of

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c. Conclusions

The inspector identified an additional example of a violation cited in a previous

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report when the shift supervisor failed to recognize that maintenance on a

containment isolation valve would render the valve inoperable and require entry into

Technical Specification 3.6.3.

04 Operator Knowledge and Performance

04.1 Good Ooerator Recoanition of Liauid Radwaste Release USAR Reauirements

a. Insoection Scoce (71707)

The inspector reviewed the circumstances associated with an operator discovering

that an anticipated liquid radwaste release would not meet USAR release

requirements.

b. Observations and Findinas

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On February 24,1997, a chemistry technician brought Liquid Release

Permit 97-015 to the control room. An operator noted that the expected response

for process Radiation Monitor HB RE-018, liquid radwaste discharge monitor, was

higher than the calculated setting low alarm setting. Consequently, it was expected

that the low alarm would actuate during the release. The operator questioned

whether or not this was permitted by USAR Section 11.5.2.1.2, which described

two alarm setpoints to provide sequential alarms on increasing radioactivity levels.

The shift supervisor recognized the concern, withdrew the release authorization,

and informed the chemistry technician. The operator subsequently initiated

Performance Improvement Request 97-0558 to address this concern.

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On March 24,1997, a chemistry technician brought Liquid Release Permit 97-019

to the control room. While setting the alarms for process Radiation

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Monitor HB RE-018, liquid radwaste discharge monitor, the low alarm setpoint was

determined to be below the background level. Operators again recognized that this

release was not permitted by USAR Section 11.5.2.1.2, and the shift supervisor

again withdrew the release authorization. The shift supervisor also initiated

Performance improvement Request 97-0884.

The inspector discussed this issue with the chemistry manager who explained that

the chemistry department interpretation of USAR Section 11.5.2.1.2 had not been

consistent with the operations department interpretation. However, as a result of

Performance improvement Request 97-0884, the chemistry department changed its

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practice to prepare liquid release permits in the future that will be consistent with

USAR requirements.

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c. Conclusions

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The inspector concluded that the operators responded appropriately in recognizing

the concern wah performing a radwaste release in a manner inconsistent with the

USAR requirements.

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08 Miscellaneous Operations issues (92901)  !

08.1 (Closed) Unresolved item (50-482/9617-02) Failure to Follow Procedures:

Performance improvement Request 96-0646 documented a procedure violation that [

occurred on February 27,1996. Radwaste operators had violated Systems  :

Procedure SYS HB-135, " Liquid Radwaste Dcmin Floor Drain and Waste Holdup

Tanks Processing," Revision 0, and Alarm Response Procedure ALR 702, " Liquid .

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Process Control Panel HB-115," Revision'2, when they exceeded the 90 percent .

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level limit and continued to 95 i 97 percent levelin accordance with their

supervisor's instructions. Scause of plant conditions, radwaste operations was

taking advantage of any extra tank volume, due to the inability to discharge.

Procedure SYS HB-135, Step 4.12, states: "Do not exceed Waste Monitor Tank A

or B (THB07A or THB078) level of 90 percent to prevent an inadvertent overflow."  :

Alarm Respont.e Procedure ALR 702 requires that liquid transfers to Waste Monitor l

Tank 1 (WMT B) be stopped if levei ir greater that 90 percent. Radwaste operators  ;

violated these procedures when thw/ 'ollowed their superv:sor's instructions. The  ;

supervisor did not follow plant adonnistrative procedures to obtain the proper l

authorization to exceed the tank filllimit. The failure to follow procedural guidance  !

is identified as a violation of Technical Specification 6.8.1 (482/9708-01).

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11. Maintenance

M1 Conduct of Maintenance  !

M 1.1 General Comments on Maintenance Activities

a. Insoection Scone (62707)  ;

The inspectors observed all or portions of the following work activities. l

111643 Task 1 NG003D inspection, cleaning, and testing  :

112834 Task 1 Roll pin missing in mechanical overspeed

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device Emergency Diesel Generator A governor

Troubleshoot discrepancy between local VAR

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117729 Task 1

meter on diesel and control room meter

118088 Task 1 Replace mechanical seals and bearings on

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PEG 01 A, Component Cooling Water Pump A

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119899 Task 2 Calibration of emergency fuel oil storage tank

Level A

b. Observations and Findinqs

Except as noted in Sections M1.3, M1.4, M1.5, M1.6, and M1.7, the inspectors

found no concerns with the maintenance observed.  ;

c. Con _gl

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l Except as noted in Section M1.3, M1.4, M1.5, M1.6, and M1.7, the inspectors

i concluded that the maintenance activities were being performed as required.

l M 1.2 General Comments on Surveillance Activities

The inspectors observed all or portions of the follJwing surveillance activities.

l a. Inspection Scoce (61726)

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! STS BG-201, Revision 15 Chemical and volume control system

l inservice valve test

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l STS IC.912, Revision 18 Containment Hydrogen Analyzer

GS065A calibration test

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STS CR-001, Revision 34 Shift log for Modes 1,2, and 3

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b. Observations and Findinas

The inspectors fcund no concerns with the surveillances observed.

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c. Conclusions

The inspectors concluded that the surveillance activities were being performed as

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M1.3 Component Coolina Water Pumt A Bearina Replacement

a. Inspection Scope (62707)

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The inspector observed portions of the bearing replacement or. Component Cooling

Water Pump A and evaluated the effectiveness of the licensee's critique following

the maintenance.

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b. Observations and Findinos l

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On March 10,1997, operators removed Component Cooling Water Pump A from

service for planned maintenance which included replacing the bearings. The system j

engineer recommended replacing the pump bearings after noting and evaluating an I

increasing trend in the pump bearing vibration. Mechanical maintenance

technicians performed the maintenance smoothly, in accordance with the work

instructions, and completed the work without significant problems. The inspector

noted supervisory presence in the field during the work, and noted that the

maintenance planner properly incorporated vendor guidance using revisions to the

work instructions.

M 1.4 Emeraency Diesel Generator Outaae

a. Inspection Scope (62707)

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The inspectors reviewed the work in progress during a planned outage for

Emergency Diesel Generator Train A. The inspection included a review of the work I

packages being used and the actions taken in response to problems identified. ,

b. Observations and Findinas

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On March 16,1997, the inspector observed maintenance personnel identify and

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resolve two concerns while performing work on Emergency Diesel Generator

Train A. The technicians assigned to reinstall a roll pin on the mechanical portion of

the governor noted that the pin was not installed through the casing and bolt in

accordance with instructions in the package. The inspector reviewed the actions

taken in response to this observation. The planner contacted the manufacturer to

i address the problem. Operability of the governor was not affected because a lock

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nut was designed to hold the bolt in place. This nut was properly installed. The pin

v *as properly installed prior to the end of the diesel generator outage.

While performing maintenance on the Emergency Diesel Generator Train A motor

control center, an electrical technician noted that three of six stab connectors on

the ventilation supply fan breaker failed to make complete contact with the bus

, bars. The technician contacted the system engineer and maintenance supervision

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and informed them of the concern. The operability of the ventilation fan was not

affected because one set of three stabs, which were installed in parallel with the

three that were not in full contact, made full contact with the bus bar. The problem

was appropriately addressed and repaired prior to exiting the equipment outage.

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M 1.5 Critiaue on Comoonent Coolina Water and Emeraency Diesel Generator Eauipment

Outaaes

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a. Inspection Scope (62707)

On March 21,1997, the inspector observed the licensee critique of the work t.iat

occurred on safety-related equipment during a 2-weA period.

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b. Observations and Findinas ,

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The inspector noted that the critique was thorough and very self-critical. A

representative from each group that participated in the three different safety-related

equipment outages that occurred during the two previous weeks attendeu. Most of

the discussions dealt with improvements that could be made in timeliness and

scheduling. One of the more notable concerns addressed dealt with planning. For

example, a system engineer indicated that he provided complete detailed  !

instructions to the planner for work to address a vibration problem on the l

component cooling water pump. These instructions were not used in developing

the work package. As a result, the pump outage was extended to completely

address the vibration concerns. The engineer developed Performance improvement

Request 97-867 to address the concerns with the planning for the component

cooling water work.

On March 27,1997, the planning supervisor criticized tr.e performance i

improvement request and stated that it failed to adequately explain the concern.

The inspector reviewed the performance improvement request and noted that it

addressed the generic concerns identified during the critique and provided the root

cause that was discussed at the time, a heavy work load in the planning

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department, but did not go into detail on each specific concern. The inspector

l discussed the performance improvement request with the supervisor the next day.

At that point. the supervisor was still not aware of the c.oncerns that the engineer

l had expressed during the critique. The inspector described the concerns that were

! discussed during the critique and expressed concern at the failure of the planning

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representative at the critique to inform planning management of the concerns that

were expressed at the meeting. The supervisor indicated that they were not aware

that the component cooling water work had been added to the critique and did not

have representation for that work item at the meeting. The inspector noted that the

electrical planner for the diesel generator breaker work was at the meeting and

j could have communicated the planning concerns to management. The supervisor

! agreed that this communication should have occurred.

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M1.6 Undatina of Operational Rok Assessment

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On April 2,1997, when Comp 7nent Cooling Water Train A was declared operable,

the central work authority rescheduled many of the work tasks that had been

deferred due to the emergent wo.k on Component Cooling Water Train A. While

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risk was considered during rescheduling, the risk assessment document maintained

in the control room was not updated to reflect the revised scheduling of the work.

Administrative Procedure AP 22C-003, " Operational Risk Assessment Program,"

Revision 1, Step 6.1.3, required that any activities added to or slipped from the

current weekly Revision 0 schedule be assessed and documented on the original

operational risk assessment. When the activities were slipped from the schedule on

March 31,1997, integrated plant scheduling personnel updated the operational risk

assessment to reflect slipping these activities from the schedule. However, on

April 2,1997, when these activities were added back into the schedule, the

operational risk assessment was not updated. This failure to comply with the

requirements of Procedure AP 22C-003 is a violation of 10 CFR 50, Appendix B,

Criterion V (482/9708-02).

M1.7 Conclosions on Conduct of Maintenance

The inspector considered the system engineer's initiative to recommend the bearing

replacement to be a strength in monitoring and addressing concerns with the

system's performance. An electrical technician exhibited good attention to detail in

noting inadequate surface contact on half the connections to the bus on a breaker.

Appropriate actions were taken by maintenance planning in addressing a missing roll

pin on the diesel generator mechanical governor. The inspector noted a weakness

l in communications within the planning department when concerns raised during a

! work critique meeting about planning were not relayed to planning management.

i The failure to apdate the operational risk assessment document maintained in the

l control room was identified as a violation.

M8 Miscellaneous Maintenance issues (92902)

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M8.1 (Closed) Licensee Event Reoort (LER) 50-482/96-008: Inoperability of Essential

Service Water Room Ventilation. This item involved the failure of operators and

instrumentation and control technicians to recognize the impact that a

nolsafety-related surveillance procedure had on the operability of the ventilation

sys!em for the Train A essential service water pump. The licensee determined that

the rod r";ue was an inadequate procedure and a contributing f actor was a

i weakness in the communication between the maintenance worker and the shift

supervisor. The licensee revised the inadequate procedure and the inspector

verified that the revision addressed the inadequacy. Additional corrective actions

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included reviewing allinstrumentation and controls nonsafety-related surveillance

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procedures for similar inadequacies, discussing the importance of clear

. communication and the impact of maintenance on the operability of equipment

during shop meetings, and the development of a checklist to ensure complete

communications between the shift supervisor or work control center and

maintenance personnel.

As discussed in Section 01.3, inadequate communication between electricians and

l operators prior to diagnostic testing on a containment isolation valve resulted in

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testing which rendered the valve inoperable.without the shift supervisor recognizing '

that it would. This additional example of a violation demonstrated that the ,

corrective actions for LER 50-482/96-008 were inadequate to prevent recurrence.

While reviewing the corrective actions described in the LER, the inspector found - r

three deficiencies. .Firsti the checklist to ensure complete communication between f

l the shift supervisor or work control center and maintenance personnel did not  !

j directly question whether the proposed work affected the operability of I

l safety-related equipment. Second, the LER stated that this checklist would be j

l utilized until such time as WCNOC determined that the interim measure was no .

j longer of value. On March 31,1997, the inspector noted that the work control

center stopped using the checklist, although the operations manager believed that 1

the checklist was r;till being used. Third, the corrective actions associated with i

l reviewing procedures for inadequacy and the shop meeting discussions were not )

performed for the electrical or mechenical maintenance grcups.

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Since the corrective actions for this LER were inadequate to prevent recurrence of i

j this type of event, the violation reported in this LER did not meet the criteria in the l

l NRC Enforcement Policy to not cite the violation. The failure of the licensee to

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! perform Technical Specification Surveillance 4.8.1.1.1 within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of the  !

inoperability of Emergency Diesel Generator A is a violation of Technical i

Specification 3.8.1.1, Action b (482/9708 03). I

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Ill. Enaineerina

E1.1 Resoonse Time Discrecancy With Control Room Ventilation Radioactivity Monitors

a. Insoection Scoce (37551)

The inspector reviewed the licensee's response to identifying a discrepancy

between the USAR and the plant test practices.

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b. Observations and Findinas i

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USAR Table 7.3 7 stated that the response time of the control room ventilation

radioactivity Monitors GKRE04 and GKRE05 was less than 3 seconds. These

devices continuously monitored the supply of air of the normal heating, ventilation,

and air conditioning system for particulate, iodine, and gaseous radioactivity. Their

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purpose was to protect control room operators from high airborne radioactivity by

initiating a control room ventilation isolation when they detected activity above the i

setpoint described in the licensing basis.

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The licensee was never able to show the response time of Monitors GKRE04 and l

j -05 to be less than 3 seconds. Further, the only respor'se time test performed on i

j the monitors was during preoperational testing. The response time reported for the

J. monitors was approximately 4 seconds.

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After identifying the concern, on February 21,1997, the licensee approved USAR

Change Request 97-0081 to remove USAR Table 7.3-7. After reviewing the

10 CFR 50.59 evaluation, the inspector noted that the argument used to justify

deleting USAR Table 7.3-7 was the same argument that could be used to justify the  !

removal of Radiation Monitors GKRE04 and -05 from the facility. The licensee

emphasized that this was not the intent, and that they have no plans to remove the

monitors. The inspector noted that, if the time response were not important to

operator safety, the radiation level in the air intake to the control room could rise  :

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above trip setpoint and yet not result in a control room ventilation isolation for a

very long time,

in addition, the licensee was not able to determine where the 3-second time

response USAR requirement came from and could not justify why the preoperational

testing was satisfactory without meeting this requirement.

The 10 CFR 50.59 evaluation noted that none of the accident analyses described in

the USAR took credit for the control room ventilation isolation signal from Radiation

Monitors GKRE04 and -05. However, it was not clear from the USAR

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accident-analysis descriptions whether the control room ventilation was presumed

to be in a recirculation alignment or not. If a recirculation alignment was assumed,

it was not clear when this recirculation alignment was assumed to have occurred.

While the licensee asserted that those accidents which assumed a control room i

ventilation isolation would get the isolation signal from some source other than from i

Radiation Monitors GKRE04 and -05, the licensee offered no documentation to l

demonstrate this and it was not clearly stated in the USAR.

The inspector will continue to review this issue. Pending completion of this review

including an understanding of the basis of the licensee's assertions, this item will

remain an Unresolved. Item (482/9708-04).

c. Donclusions

The inspector identified an unresolved item during the review of a USAR change

which deleted time response requirements for control room ventilation radiation

monitors.

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! E8 Miscellaneous Engineering issues (92903)

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E8.1 (Closed) Unresolved item 50-482/9614-04: USAR Discrepancies. Two issues were

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identified in this item. The first dealt with the centrifugal charging pump discharge j

[ header flow control valve inlet isolation valves. The system drawing in the USAR l

i did not reflect the licensee's practice. The licensee plans to change the note on the

drawing to allow the discharge header flow control valve inlet isolation valve on

{ either train to be locked closed, rather than limiting it to one. The drawing change

package has been developed and is scheduled to be implemented the week of

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The second issue dealt with several inconsistencies between USAR Figure 6.2.4-1,

" Containment Penetrations," and the current plant design. The inspector reviewed

Performance Improvement Request 96-2216, USAR Change Request 97-089, and

the changes that are to be made to the USAR figure. The licensee completed a I

review of the figure and identified eight additional discrepancies. In all but one  ;

case, the changes were completed prior to completion of plant construction and the I

architect engineer failed to update the USAR. In the remaining case, the licensee

changed the configuration and failed to update the USAR.

The inspector determined that the corrective actions taken or planned were

appropriate. The failure to maintain the USAR is a violation of 10 CFR 50.71(e)

(482/9708-05).

E8.2 (Closed) LER 50-482/96-006: Actuation of Engineered Safety Features Due to l

Failure of Steam Generator C Feedwater Regulating Valve. A 3/16-inch roll pin in l

the feedwater regulating valve (Valve AE FCV-530) failed resulting in the plug of the

valve separating from the valve stem. The plug dropped into the closed position,

stopping feedwater flow to Steam Generator C. The reactor tripped in response to l

low level in the steam generator. The design of the valve had been changed to

include a solid pin in lieu of the roll pin in 1988 in response to a similar event at

Callaway. However, when the design change was made, the licensee failed to

ensure that spare parts in the warehouse and future procurements were. modified to i

reflect the change. When the valve internals were replaced during March 1996, the l

parts contained the roll pin in lieu of the solid pin. The licensee identified the

inadequate design modification procedures as the root cause of the event. This  !

same modification was made on the main feedwater regulating bypass vahres, but

spare parts were not addressed. The valve assemblies in two of four bypass valves

were replaced in May 1990, with assemblies that contained roll pins. 3

The immediate corrective actions taken were to replace the roll pins in three of the

four main feedwater regulating valves. The fourth valve still contained the solid pin

that was installed in 1988. The roll pins in the two main feedwater regulating

bypass valves are to be replaced with solid pins during the next outage. The

licensee placed a hold on all spare parts that contained roll pins. These parts were

to be returned to the vendor or modified prior to use. The inspector reviewed the

design and procurement procedures and material codes and noted that they were

revised to assure that spare parts and equipment are addressed in design

modifications and changes made in the plant The vendor manuals and drawings

were revised to reflect the changes made in the valves.

The licensee plans to perform assessments of four safety and four nonsafety-related

systems to determine whether design changes offectively addressed spare parts and

procurement and were correctly reflected in vendor manuals and drawings. Those

systems include: auxiliary feedwater, main feedwater, essential service water,

service water, component cooling water, main generator, residual heat removal, and

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main turbine systems. The auxiliary feedwater system functional assessment was

reviewed in NRC Report 50-482/97-05. l

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IV. Plant Support

R1 Radiological Protection and Chemistry Controls

R 1.1 Personnel Entrance into Hiah Radiation Area Without Reauired Dosimetry

a. Insoection Scone (71750)

On March 20,1997, an engineer and a quality control inspector entered the

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pipechase in the 1988 foot level of the auxiliary building, a high radiation area, I

without wearing the required thermoluminescent dosimeter. The inspector reviewed

the performance improvement request, radiation protection procedures, and the

corrective actions taken in response to the personnel failure.

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b. Observations and Findinas

Procedure AP 25A-001, " Radiation Protection Manual," Revision 2, Step 6.8.1,  !

requires that individuals wear their issued radiation dosimetry devices in the l

radiation controlled area at all times. The individuals did not sign on to the radiation

work permit for the task they were to perform using the automated method because

they had not been added to the computer database yet. The individuals had been

authorized for the radiation work permit. The health physics technician assigned to ,

monitor the task identified that the individuals were not wearing their i

thermoluminescent dosimeters after they had been the area approximately I

10 minutes. The individuals were wearing alarming dosimeters, as required by the '

radiation work permit. These dosimeters indicated that the two individuals had

received 1 and 2 mrem of exposure.

The inspector reviewed the corrective actions taken or identified by the licensee. ,

The licensee initiated significant Performance Improvement Request 97-0844. The l

licensee indicated that the root cause of this event was personal error. The licensee

canceled the individuals' access to the radiation controlled area until the radiation

protection manager counseled the individuals. This licensee-identified and corrected

violation is being treated as a noncited violation, consistent with Section Vll.B.1 of

the NRC Enforcement Policy (482/9708-06).

c. Conclusions 1

A noncited violation resulted when two engineers failed to follow procedures by

entering the radiation controlled area without thermo!uminescent dosimetry. j

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R 1.2 Personnel Contamination Due To Check Source Leakaae

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a. Inspection Scone (71750)

The inspector reviewed the licensee's response to check source leakage and a

i subsequent personnel contamination event.

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b. Observations and Findinas

On February 27,1997, a radiation protection technician discovered that the check

source in Area Radiation Monitor SD-RE-047, postaccident sampling system area

radiation monitor, separated Trom the swing arm due to adhesive degradation. Two

instrumentation and control technicians removed the detector electronics package

from the area radiation monitor for the postaccident sampling system in order to

take it to the instrumentation and control shop for calibration. During the survey to

permit a conditional release of the detector electronics package, the check source

fell to the floor, spilling Strontium-90. This led to the three technicians becoming

contaminated. Radiation protection technicians contained the spill, decontaminated

the in?trumentation and control technicians, and cleaned up the contamination.

Radiation protection personnel initiated Performance improvement Request 97-0640

to address the contamination.

The check source in this particular area radiation monitor had been held in place

only by an adhesive. Degradation of this adhesive resulted in the source separation

from the swing arm. Area Radiation Monitor SD-RE-047 is the only area radiation

monitor of this type installed at Wolf Creek. All other area radiation monitors use a

later model detector which utilizes a set screvv to affix the source to the swing arm.

While this issue has no generic applicability at Wolf Creek, the radiation protection

manager is evaluating whether generic industry notification would be appropriate.

The initial skin dose assessment calculation estimated the skin dose based on

Strontium activity alone and failed to consider dose from Yttrium. This calculation

was performed using the Varskin Mod 1 computer program by a technician who had

little experience performing skin dose assessments. The more experienced

technician who normally performed skin dose calculations was not available during

the initial assessment, but returned in time to identify the error upon review. After

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correcting the assessment, radiation protection personnel assigned a maximum skin

dose equivalent exposure for this event of 1.96 Rem to the finger of one technician,

well!ess than the 50 Rem limit of 10 CFR Part 20.

In response to the error in performing the skin dose assessment, the radiation

protection manager initiated Performance Improvement Request 97-1000 to address

programmatic enhancements to reduce the probability of future similar errors. The

radiation protection manager decided to shift to Varskin Mod 2, and initiated the

necessary programmatic changes. Completion of the transition is expected by

September 1,1997.

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c. Conclusions

The inspector concluded that the initial radiation protection technician response to

the spill was appropriate and effective in limiting the spread of contamination and

cleaning up the spill. While the initial dose assessment error initially underestimated

the skin dose, the licensee identified and corrected the error and initiated corrective

actions to address this error.

R5.1 Chemistry Trainina Error

a. Inspection Scope (71750)

The inspector reviewed the circumstances that resulted from improper analysis

results for reactor coolant system activity samples,

b. Observations and Findinas

On February 17,1997, and February 21,1997, a chemistry technician reported

reactor coolant system specific activity at 1.099 and 0.8018 micro-curies per cubic

centimeter. These analyses results were subsequently determined to be inaccurate

because the technician who performed the analyses placed the sample directly on

the detector rather than on the proper shelf corresponding with a calibrated

geometry within the detection chamber,

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The technician who performed these analyses recently transferred from radiation

protection to chemistry. During the training for this technician, chemistry personnel i

assumed that since radiation protection technicians also utilized this counter,

detailed training on sample placement would not be needed.

The chemistry supervisor initiated Performance improvement Request 97-0554 and

Reportability Evaluation Report 97-020. Reportability Evaluation Report 97-020  ;

concluded that this event was not reportable because the samples were actually j

taken and counted, and subsequent chemistry analysis was able to bound the

sample results for the incorrect geometry to demonstrated that the analysis results

were actually within Technical Specification requirements and consistent with

previous and subsequent activity analysis results.

The chemistry manager described planned corrective actions for Performance  ;

improvement Request 97-0554, including specific on-the-job training requirements I

which will require technicians to demonstrate familiarity with the detector shelves

and the use of calibrated geometries in the analysis.

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c. Conclusions

, The inspector concluded that chemistry management responded appropriately by

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identifying and correcting this training deficiency.

, V. Manaaement Meetinas

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X1 Exit Meeting Summary

The inspectors presented the inspection results to members of licensee management at the

conclusion of the inspection on April 4,1997. The licensee acknowledged the findings

presented. .

The inspectors asked the licensee whether any materials examined during the inspection

should be considered proprietary. No proprietary information was identified.

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ATTACHMENT

SUPPLEMENTAL INFORM ATION

PARTIAL LIST OF PERSONS CONTACTED

Licensee

C. W. Fowler, Manager, integrated Planning and Scheduling

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

R. L. Sims, Manager, System Engineering

C. C. Warren, Chief Operating Officer

INSPECTION PROCEDURES USED

IP 71707 Plant Operations

IP 37551 Onsite Engineering

IP 61726 Surveillance Observations

IP 62707 Maintenance Observations

IP 71750 Plant Support Activities

IP 92901 Followup - Plant Operations

IP 92902 Followup - Maintenance

IP 92903 Followup - Engineering

ITEMS OPENED, CLOSED, AND DISCUSSED

Onened

9708-01 VIO Failure to follow procedure-liquid transfers to waste monitor

(Section 08.1)

9708-02 VIO Failure to update operational risk assessment

(Section M1.6)

9708-03 VIO Failure to perform Technical Specification surveillance

when emergency diesel generator was inoperable

(Section M8.1)

9708-04 URI Response time discrepancy with control room ventilation

radioactivity monitors (Section E1.1)

9708-05 VIO USAR discrepancy (Section E8.1)

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Closed

50-482/96-006 LER Actuation of engineered safety features due to failure of

Steam Generator C Feedwater Regulating Valve

(Section E8.2)

50-482/96-008 LER Inoperability of essential service water room ventilation

(Section M8.1)

50-482/9614-04 URI USAR Discrepancies (Section E8.1)

50-482/9617-02 URI Failure to follow procedures (Section 06.1)

Opened and

Closed

9708-06 NCV Personnel Entrance into high radiation area without

' required dosimetry (Section R1.1)

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