IR 05000482/1988019

Insp Rept 50-482/88-19 on 880515-0630.Violation Noted.Major Areas Inspected:Plant Status,Allegation followup,10CFR21 Rept Followup,Operational Safety Verification,Monthly Surveillance Observation & Physical Security Verification

ML20207C723
Person / Time
Site:	Wolf Creek
Issue date:	07/29/1988
From:	Bruce Bartlett, Chamberlain D, Skow M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20207C713	List: IR 05000482/1988019 ML20207C709 ML20207C716
References
50-482-88-19, NUDOCS 8808100123
Download: ML20207C723 (15)

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APPENDIX B U. S. NUCLEAR REGULATORY COMMISSION REGION li'

NRC Inspection Report: 50-482/88-19_ Operating License: NPF-42 Docket: 50-482 Licensee: Wolf Creek Nuclear Operating Corporation (WCNOC)

P. O. Box 411 Burling *on, Kansas 66839 Facility Name: Wolf Creek Generating Station (WCGS)

Inspection At: Wolf Creek Site, Coffey County, Burlington, Kansas Inspection Conducted: May 15 through June 30, 1988 Inspectors: //.d? W B. L. Bartlett, Senior Resident Inspector,

_2- / - k Date Projects Section A, Division of Reactor Projects l l

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' M. E. Skow, Resident Reactor Inspector, /Date'

Project Section A, Division of Reactor Projects

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Approved: (

D. D. Chamberlain, Chief, Project Section A, 7/N W8[

Date Division of Reactor Projects j

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Inspection Summary Inspection Conducted May 15 through June 30, 1988 (Report 50-482/88-19,[

Areas Inspected: Routine, unannounced inspection including plant status, allegation followup,10 CFR Part 21 report followup, operational . safety verification, monthly surveillance observation, monthly maintenance observation, onsite event followup, startup testing after refueling,-

radiological protection, and physical security verification, i

Results: Within the ten areas inspected, one violation was identified (failure to follow procedure, paragraph 5.a). One-unresolved item is identified in paragraph >

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DETAILS Persons Contacted Principal Licensee Personnel

• R. M. Grant, Vice President (VP), Quality

• F. T. Rhodes, VP, Nuclear Operations

• G. D. Boyer, Plant Manager

• 0. L. Maynard, Manager, Licensing C. M. Estes, Operations Manager

• R. W. Holloway, Manager, Maintenance and Modifications

• H. G. Williams, Manager, Plant Support

• C, E. Parry, Manager, Quality Assurance (QA)

• A. A. Freitag, Manager, Nuclear Plant Engineering (NPE), WCGS K. R. Peterson, Supervisor, Licensing

• G. J. Pendergrass, Licensing Engineer

• J. M. Pippin, Manager, NPE

• R. H. Belote, Manager, Nuclear Safety Engineering

• C. G. Patrick, Supervisor, Quality Systems

• J. L. Blackwell, Fire Protection Coordinator

• S. D. Austin, Operations Support

• J. L. Houghton, Operations Supervisor

• R. J. Potter, Manager, Supplier / Materials Quality

• H. L. Litch, QA Clerk

• C, J. Hoch, QA Technologist The NRC inspectors also contacted other members of the licensee's staff during the inspection period to discuss identified issue * Denotes those personnel in attendance at the exit meeting held on July 1, 198 . Plant Status The unit was in Mode 1 at 100 percent power for the report perio . AllegationFollowup(92701], (Closed) Allegation 4-88-A-0002: This allegation concerned a recently terminated maintenance supervisor allegedly not following procedure during the installation of the reactor vessel 0-rings during Refueling Outage II. The reactor vessel 0-rings later failed, resulting in a forced outage. During this forced outage, the 0-rings were replaced. The allegation discussed below (4-88-A-0014)

addresses the issue with the same maintenance supervisor not following procedures. The reactor vessel 0-ring installation is addressed in NRC Inspection Report 50-482/88-04 and while enforcement action was initiated regarding inspection of the 0-rings, there was

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no evidence that this maintenance supervisor violated procedures which contributed to the 0-ring failure. This allegation could not be substantiated and is close (Closed) Allegation 4-88-A-0014: This allegation concerned a maintenance supervisor directing his employees to violate procedure Licensee workers advised management of apparent procedural violations directed by a named maintenance supervisor prior to the NRC receiving this allegation. The licensee investigated this matter and substantiated the allegation. The maintenance supervisor was terminated. This same maintenance supervisor is referenced in Allegation 4-88-A-0002. The licensee determined where the procedures had been violated through discussion with employees and performed followup inspections in these (nonsafety) maintenance areas. No indication of procedures for safety-related equipment were foun The NRC inspectors monitored the licensee close out of this allegation and no additional concerns were identified. This allegation was substantiated and is closed, (Closed) Allegation 4-88-A-0007: This allegation was received from a terminated employee who was being processed out. The employee was terminated for falsification of a drug tes The employee denied having falstfied the test and stated there either was a mistake or WCN0C management had falsified the sample in order to get rid of the employe In addition to making this allegation to the NRC, the alleger also talked with Quality First (Q1). The allegation the alleger gave to Q1 only dealt with a possible mistake. The NRC inspectors and Q1 review of this situation showed that the licensee's program for drug testing appeared to have been followed. The specific manager that the alleger feit was responsible has since quit WCN0C to take up employment elsewhere. The position that manager held while he was employed at WCN0C did not have any direct control over the taking of drug samples. This allegation could not be substantiated. This allegation is closed, (Closed) Allegation 4-87-A-0084: This allegation concerned the repair effort on correcting erosion on the retaining ring to Valve EF HV-048. During this repair effort, it was alleged that mechanical maintenance cold sprung the pipe into position and then tried to get quality control (QC) to accept the flange alignment and cleanlines QC refused to accept this condition. It was also alleged that QC is routinely asked to accept items at the end of a shift in order to pressure QC into accepting items. It was also alleged that QC is routinely asked to accept items when the worker knows they are not yet read The NRC inspector toured the area around EF HV-048 and found the hydraulic jacks and chain hoists in the area. Also, the bolts through the flange were loose on top and tight on the bottom. The alleger

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had informed his management of the situation. QC management discussed with maintenance management the apparent adversarial ,

attitude that existed at the working leve l l

Maintenance management agreed to discuss the situation with their l workers. One of the maintenance supervisort has since been l transferred cut of maintenance. In addition, maintenance has been I reorganized and the superintendent of maintenance has been replace l Engineering evaluated the stress'placed on the pipe and had that section cut out, rewelded, and then hydrostatic pressure tested agai l NRC inspectors have evaluated this matcer and believe prompt and effective actions were taken by the licensee. This allegation is substantiated, however, no violations were identified, i

This allegation is closed, (Closed) Allegation 4-88-A-0049: The NRC resident inspectors office received information on June 29, 1988, that there were two security ;

items that should be followed up. The specific allegations, NRC l review actions, and conclusions are addressed below:

1) Allegation: This alleger stated that the licensee had an NRC comitment to a specific number of security officers to be on duty and that this number was routinely not me NRC Review Acticns: The NRC inspectors reviewed NRC Inspection Report 482/87-23, WCNOC's response to this report, WM 87-0333 dated December 11, 1987, and interviewed Region IV security inspectors. The alleger was correct in the specific number of security officers who should be on duty. However, when there are less than the required number who report in for the next shift, some members of the previous shift are held over or officers at stations outside of the protected area are called in when the need arise Conclusion: The allegation was not substantiated. Interviews with the licensee's Chief of Security showed that sometimes there are less than the specific number of officers inside the protected area but that officers outside of the protected area are called in when require ) Allegation: The alleger stated that when officers were on relief week, they would routinely work different shifts, lhis would result in officers being excessively tired from rotating among shift NRC Review Actions: The NRC inspector interviewed four security officers, including one shift lieutenant. All the security officers stated that if they were assigned to work a shift for a

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part of relief week,= that they were given the option of working that shift all week. -Occasionally.someone would work different shifts, but this was minimized. The NRC inspectors reviewed the assignment sheet for the squad on relief for the week of June 27, 1988, and observed that all personnel were working on just one shif Conclusion: The allegation was not substantiated. Although at times officers would work different shifts, this.was minimize This allegation is close , 10 CFR Part 21 Report Followup (92701) (Closed)P21-1987-87-81: Three Nonconformances to Eastern Testing and Inspection Procedures Regarding NDE Documentation were Identifie The licensee's review of testing records determined that Eastern Testing and Inspection has not performed NDE services at Wolf Cree This information was documented in WCGS Technical Information Review and Evaluation (ITIP) No. 0058 (Closed) P21-1987-87-30: Improper Electrical Manhole Dust Seal Desig The licensee determined that the design in question did not exist at Wolf Creek aad that the condenser pit size was adequate to contain potential flooding. Wolf Creek has experienced some minor problems due to groundwater intrusion through manholes. This problem is being addressed by using sump pumps to keep the manholes pumped dow (Closed) P21-1987-87-80: Containment Hydrocen Analyzer Systems-Design Deficiency May cause a Loss Of Calibration Ga The licensee's hydrogen analyzer is not the same as the one described in the Part 21. The licensee's calibration gas is stored at a lower pressure (25 psig versus 750 psig) and is located outside of containment. An annunciator will alann if gas pressure drops to below 15 psig and the bottle can be replace (Closed)P21-1987-87-84: Failure of Fasteners May Cause the Valve Operator to be Unable to bo Opene .

The . .censee's review of this Part 21 has determined Wolf Creek did not ese valves of this design. This information was documented in WCGS ITIP No. 0059 l

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l 7 (Closed)P21-1987-87-46: Tolerance Concerns on Dose Rates Certified by Vendor on Qualification Test The licensee's evaluation showed that the total dose tolerance did not impact the qualification of equipment at Wolf Creek. This information was documented in WCGS ITIP No. 0039 (Closed)P21-1987-87-10: Potential Component Failure In Validyne Standard Transduce The licensee's review of this Part 21 had identified no safety-related parts supplied by Validyne. This information was documented in WCGS ITIP No. 0029 . Review of Licensee Event Reports (LER) (92701)

During this inspection period, the NRC inspectors performed followup on Wolf Creek LERs. The LERs were reviewed to ensure:

o Corrective action stated in the report has been properly completed or work is in progres o Response to the event was adequate, o Response to the event met license conditions, commitments, or other applicable regulatory requirement o The information contained in the report satisfied applicable reporting requirements, o Generic issues were identifie The LERs discussed below were reviewed and closed:

o 86-40, Control Room Ventilation Isolation Signal Due to Error During i Testing. The licensee revised Procedure STS IC-255A, Revision 4. It I requires special verification that the field test performer confirm ,

that he/she is at the proper monitor. Similar requirements were  !

noted in other similar procedure o 86-42, Low-Low Steam ' aerator Level Caused Reactor Trip During Controlled Plant Shut- The NRC inspector reviewed several procedures and found , a they have been revised to clarify intermediate range channel calibratio o 86-44, Partial loss of Off Site Power Caused By Error During Switchyard Maintenance Activity. The relay that was reported as the cause of the event has been removed. Another relay in the substation control building which is mounted on a permanent panel performs a

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similar function. The other relay is not subject to being jarred in a manner similar to this even Valve EF-HV38 was reworked and teste o 86-47, Technical Specification Violation Caused by Leaking Drain Valves. Valve HA-V152 has been repaired and stroke teste o 87-25, Engineered Safety Actuation - Containment Purge Isolation and Control Room Ventilation Isolation Due to Personnel Error During Radiation Monitor Surveillance Testing. The NRC inspector found that the procedures have been revised to perfonn the surveillance tests '

without operating the particular switches that lead to the tri . Operational Safety Verification (71707)

The NRC inspectors verified that the facility is 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 i and limiting condities for operations, and reviewing facility record I The NRC inspectors, by observation of randomly selected activities.and interview of personnel, verified that physical security, radiation protection, and fire protection activities were controlle ;

By observing accessible components for correct valve position and 1 electrical breaker position, and by observing control room indication, the i NRC inspectors confirmed the operability of selected portions of safety I related systems. The NRC inspectors also visually inspected safety components for leakage, physical damage, and other impairments that could i prevent them from performing their designed function Selected NRC inspector observations are discussed below: On June 6, 1988, Fire Doors 13261 and 13281 were found by NRC inspectors to be standing open. Both doors were listed in the fire protection manual as fire doors, and were labeled as fire door These doors lead to an auxiliary feedwater pump room and an associated valve room. Surveillance testing was in progress at the time. A technician was found working in the valve room. Neither the pump room nor the connecting hallway were occupied. The NRC inspector also found that neither fire protection impairment control permits nor log entries had been completed for the doors. This was a failure to follow Procedure ADM 13-103, Revision 5, "Fire Protection:

Impairment Control." Thisisanapparentviolation.(482/8819-01)

The NRC inspectors also noted that a previous violation, 482/8706-01, concerned fire door impairments. In their response, the licensee stated that a breach of a fire barrier for any length of time requires an impairment pennit, During a routine tour of the auxiliary building on May 27, 1988, the NRC inspector observed dried boron crystals on several component ' -

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The components were located in the "A" train containment spray pump room and the "A" train safety injection pump room. The components were the flange on Suction Strainer SS02, Valves BG FCV-110A, EM V-032, EM V-033, EM V-034, EM HV-8807A and Orifice EN 005. The NRC inspector informed the shift supervisor (SS). In response to a question from the NRC inspector as to why so many valves appeared to be leaking, the SS performed a computer search of work requests (WR).

The SS found some WRs that had been worked previously and had been closed out. The SS stated the valves could have leaked previously, been repaired, and then the dried boron was not cleaned off. . The SS wrote WRs to address the dried boro In discussions with the plant manager, the NRC inspector was informed that WCN0C intended to have components cleaned after they were repaired and licensee management would ensure that maintenance would clean the components after they were repaire c. During this report period a Quality Verification Functional Inspection (QVFI) was performed. The results of the QVFI will be documented in NRC Inspection Report 482/88-20. During the inspection, the QVFI team became aware of a potential environmental qualification (EQ) enforcement issue. Review of QA Audit TE: 50140 K-192, Corrective Actions, revealed that the licensee had identified nonenvironmentally qualified 0-rings in the solenoid operators of containment post accident sampling system (PASS) containment isolation valves. Licensee discovery of this condition was made in November of 1987, during the performance of Plant Modification Request PMR-1844. During PMR-1844, a maintenance crew mistakenly disassembled the solenoid operator of the wrong valve (GS-HV-013).

The crew realized their error, and also identified the solenoid operator as containing EPR type 0-rings, which are nonqualified 0-rings for that specific applicatio Upon discovery of the nonenvironmentally qualified 0-rings, licensee QA issued a Defect / Deficiency Report (D/DR 87-132), and requested an engineering evaluation (87-SJ-10) to determine the impact cf the

- nonenvironmentally qualified 0-rings on the subject valves. The engineering evaluation concluded that moisture / water that may intrude into the solenoid operator because of failed 0-rings would not affect the valve's pressure retaining function, but may cause the valve to be in the failed safe position upon a containment isolation signal, thus isolating the sampling systems. WRs were issued to inspect similar valves t.nd replace 0-rings as necessary. All of the work requests corresponding to the valves have been completed at this time which included the PASS containment isolation valve Pending further NRC review of this matter, this item will remain unresolved. (482/8819-02)

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n 10 Monthly Surveillance Observation (61726)

The NRC inspectors observed selected portions' of the performance ~ of -

surveillance testing and/or reviewed completed surveillance test procedures to verify that surveillance activities were performed in accordance with TS requirements and administrative procedures. The NRC-inspectors considered the following elements while inspecting surveillance activities:

o . Testing was being accomplished by qualified personriel in accordance-with an approved procedur o The surveillance procedure conformed to TS requirement o Required test instrumentation was calibrated, o Technical Specification limiting conditions for operation (LCO) were satisfied, o Test data were accurate and complete. Where appropriate, the NRC inspectors performed independent calculations of selected test-data to verify their accurac o The performance of the surveillance procedure conformed t'o' applicable administrative procedure o The surveillance was performed within the required frequency and th test results met the required limit <

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

o STS IC-203, Revision 5, "Analog Channel Operational Test 7300 Process InstrumentationProtectionSetIII(Blue)"performed.onMay 26, 1988 o STS SE-001, Revision 8, "Power Range Adjustment To Calorimetric," '

performed June 9, 1988 No violations or deviations were identifie . Monthly Maintenance Observation (62703)

The NRC inspector observed maintenance activities performed on safety-related systems and components to . verify that these activities were conducted in accordance with approved procedures, Technical Specifications, and applicable industry codes and standards. The following elements were considered by the NRC inspector during the observation and/or review of the maintenance activities:

o LCOs were met and, where applicable, redundant components were operabl )

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o Activities complied with adequate administrative control o Where required, adequate, approved, and up-to-date procedures were use o Craftsmen were qualified to accomplish the designated task and technical expertise (i.e., engineering, health physics, operations)

was made available when appropriat o Replacement parts and materials being used were properly certified, o Required radiological controls were implemented, o Fire prevention controls were implemented where appropriat o Required alignments and surveillances to verify post-maintenance operability were performe o Quality control hold points and/or checklists were used when appropriate and quality control personnel observed designated work activitie Selected portions of the maintenance activities accomplished on the work i requests (WR) listed below were observed and related documentation reviewed by the NRC inspector:

i N Activity o WR 50899-88 Inspect Isolation Dampers GKD088, 292 and GK0316 o WR 50898-88 Control Room Filtration / Pressurization Fans l Semi-Annual-Maintenance l

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o WR 02175-88 Namco Limit Switch Verification For PMR-2263 o WR 50762-88 Reactor Trip Breakers SB102ARTA and Bypass Breakers 6 Month Maintenance Selected NRC inspector observations are discussed below:

Block 29 "Retest Instructions" of WR 50898-88 was marked "NA-work does.not affect operability." Supplemental Sheet xx-619, Step 2, has the workers check the condition of the fan belts and to replace ones that were worn or frayed. Replacement of fan belts should have called for reverification of fan flow as part of a retest. Although fan belts were not changed out with this WR, they could be on other similar WRs. Discussions with quality plant support ('!PS) personnel on this issue, revealed that they

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were aware of the need for retests under this situation.. QPS had

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identified the issue several days prior to the NRC inspector and new WRs would contain the appropriate retest instruction No violations or deviations were identifie . Onsite Event Followup (92700)

The NRC inspectors performed onsite followup of nonemergency events.that occurred during this report perio The NRC inspectors reviewed _ control room logs and discussed the events with cognizant personnel. The NRC inspectors verified the licensee had responded to the events in accordance with procedures and had notified the NRC and other agencies as required.in a timely fashion. The events that occurred during this report period are listed in the table below. The NRC inspectors will review the LERs for these events and will report any findinas in a subsequent NRC inspection repor Date Event * Plant Status Cause 6/16/88 CRVIS Mode 1 Broken tape on GK AI-3 (100 percent)

6/28/88 CRVIS Mode 1 Blown fuse on GK AI-3 (100 percent)

• Event CRVIS - Control room ventilation isolation No violations or deviations were identifie . Startup Testing After Refueling (72700)

The NRC inspector reviewed the data from all core physics tests associated with the refueling, including those listed below, and verified that the ,

results met acceptance criteria and that all deficiencies were resolved in t a timely manne o Surveillance of core power distribution limits o Cal .bration of nuclear instrumentation systems o Core thermal power evaluation o Determination of reactor shutdown margin o Isothermal and moderator temperature coefficient determinations o Total power coefficient of reactivity l l

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o Control rod worth measurements o Reactor coolant system flow measurements o Control rod drop time measurements The specific surveillance reviewed were:

o RXE 01-002, Revision 0, "Reload Low Power Physics Testing,"

performed on December 31, 1987 o STS10-447, Revision 3, "Channel Calibration Nuclear Instrumentation System Power Range Incore-Excore," performed December 31, 1987, January 18, 1988, and April 13, 1988 o STS RE-007, Revision 3, "Rod Drop Time Measurement," performed on February 11, 1988 o STS 1C-441, Revision 2 "Channel Calibration NIS Power Range N41,"

performed on November 23, 1987 o STS 1C-442, Revision 2, "Channel Calibration NIS Power Range N42,"

performed on December 7, 1987 o STS RE-003, Revision 1, "Shutdown Margin By Minimum Bank Height,"

performed on January 4,1988 o STS IC-443, Revision 2 "Channel Calibration NIS Power Range N43," performed on December 8, 1987 o STS IC-444, Revision 2. "Channel Calibration NIS Power Range N44," performed on December 9, 1987 i o STS RE-012, Revision 1, "QPTR Determination," performed .

on May 17, 1908 l o STS IC-435, Revision 3, "Channel Calibration NIS Intermediate Range N35," performed on December 1, 1987 o STS RE-013, Revision 1, "Incore-Excore Detector Calibration,"

performed on January 18, 1988 l 0 STS10-436, Revision 3. "Channel Calibration NIS Intermediate l Range N36," performed on November 11, 1987 o STS RE-005, Revision 2, "Core Reactivity Balance," performed on April 29, 1988 o STS RE-009, Revisicn 1, "Heat Flux Hot Channel Factor Measurement," performed on April 29, 1988 l

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o STS RE-011, Revision 2 "RCS Total Flow Rate Measurement,"

performed on January 11, 1988 o- STS IC-648A, Revision 1, "Boron Oilution Flux Doubling Actuation Test," performed on December 4,1987 o STS IC-648B, Revision 1, "Boron Dilution Flux Doubling Actuation Test," performed on December 4,1987 o STS RE-010, Revision 1, "RCS R Calculation," performed on April 29, 1988 t

o STS 1C-432, Revision 4, "Channel Calibration NIS Source Range N32," performed on December 14, 1987 o STS IC-431, Revision 4, "Channel Calibration NIS Source Range N31," performed on December 14, 1987 No violations or deviations were identifie . Radiological Protection (71709)

By performing the following activities, the NRC inspectors verified that radiologically related activities were controlled in accordance with the licensee's procedures and regulatory requirements:

o Reviewed documents such as active radiation work permits and the health physics shift 'urnover log, o Observed personnel activities in the radiologically controlled area (RCA)suchas:

. Use of the required dosimetry equipment,

. "Frisking out" of the RCA, and

. Wearing of appropriate anti-contamination clothing where require o Inspected postings of radiation and contaminated areas, o Discussed activities with radiation workers and health physics supervisor No violations or deviations were identifie . Physical Security Verification (71881)

The NRC inspectors verified that the facility physical security plan (PSP)

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The NRC inspectors by observation of randomly selected activities verified :

that search-equipment is. operable, that the protected area barriers and vital area barriers are well maintained, that access control procedures are followed and that appropriate compensatory measures are followed when -

equipment is inoperabl No violations or deviations were identifie . Unresolved Item Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. One unresolved item disclosed during the inspection is discussed in paragraph . Exit Meeting The NRC inspectors met with licensee personnel to discuss the scope and findings of this inspectior, on July 1, 1988. Mr. D. D. Chamberlain also 4 attended the meetin _ . _ - _ _ . ~ . , . - _ . . . - - - _ _ . ,_ , . _ . _ . _ . . _ . _ _ . . _ , . _ _ . -_ _ .