IR 05000482/1988026

Insp Rept 50-482/88-26 on 880926-30.No Violations or Deviations Noted.Major Areas Inspected:Inservice Insp Program & Procedures,Welding & NDE Procedures & Program for Control of Design Changes & Mods

ML20204K002
Person / Time
Site:	Wolf Creek
Issue date:	10/14/1988
From:	Barnes I, Ellershaw L, Gilbert L, Renee Taylor NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20204J992	List: IR 05000482/1988026 ML20204J988
References
50-482-88-26, NUDOCS 8810250317
Download: ML20204K002 (10)

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APPENDIX U.S. NUCLEAR REGULATORY COPNISSION

REGION IV

NLC Inspection Peport:. 50-482/88-26 Operating License: NPF-42 Docket: 50-48?

Licensee: WolfCreekNuclearOperatingCorporation(WCNOC)

P. O. Box 411 Burlington, Kansas 66837 Facility Name: Wolf Creek Generating Station (WCGS)

Inspection At: WCGS, Burlington, Kansas Inspection Conducted: September 26-30, 1988 Inspectors: b W t. E. ETlershaw, Reactor Inspector, Materials

/o /.1)7 Date'

and Quality Programs Section Division of Reactor Safety

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1. GW l0 0 15~

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I., D. Gilbert, Reactor Inspector, Materials Unte/

and Quality Programs Section, Division of I Reactor Safety

/ fcT/ kh EW R. G. Taylor / Reactor Inspector, Materials D/tf and Qualitf Programs Section. Division of Reactor Safety Approved: aa _

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/8//Ykb I Barnes, Chief,~MaterialsandQuahity Date~

rograms Section, Division of Reactor Safety bkN6C : bbb $2 ,

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_ Inspection Sumary Inspection Conducted September 26-30, 1988 (Report 50-482/88-26)

Areas Inspected: Routine, unannounced inspection of the inservice inspection program and procedures Welding and nondestructive examination procedures, the program for the control of design changes and modifications, and the program for control of procurement. These activities were inspected with respect to their relationship to the plant outage scheduled to begin in early October 1988, i

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-3- l OETAILS Persons Contacted Licensee Personnel  ;

• B. D. Withers, President

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• J. A. Bailey, Vice President, Engineering and Technical Support  ;

• R. M. Grant, Vice President. Quality '

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• F. Rhodes. Vice President, Nuclear Operations .

• G. D. Boyer, Plant Manager  !

• C. E. Parry, QJality Assurance Manager  ;

• C, W. Fowler, Manager Instruments and Controls

• B. M. Kinney, Manager. Technical Support

• G. Williams, Manager, Plant Support  :

• T. Foster, Manager Facilities and Modifications

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

• J. Pipping, Manager, Nuclear Plant Engineering

• R. Benedict, Manager, Plant Inspection  !

• C, A. Snyder, Manager, Purchasing and Material Services ,

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• R. J. Po+,ter, Manager Supplier and Materials Quality

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

• C, G. Patrick, Supervisor, Quality Systems >

• K. Peterson, Supervisor Licensing I

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• A. B. Clason, Maintenance Engineering Supervisor l

• R. E. Doty, Material Control Supervisor ,

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• G. J. Pendergrass, Licensing Engineer  :

• C. J. Hoch, Quality Assurance Technician

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T. F. Deddens, Jr. , Outage Manager  ;

NRC Personnel l 1 i i * L. Bartlett, Senior Resident Inspector i j * E. Skow, Resident Inspector  !

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• Denotes those persons that attended the exit interview on September 30,  !

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1 i 1 The NRC inspectors also interviewed other licensee personnel during the {

inspectio ;

! Inservice Inspection f Review of Program (73051)  !

j The NRC inspector reviewed the licensee's program pertaining to inservice inspection (ISI) fer the first 10-year interva The following documents were reywwed for confonnance with the i requirements of 10 CFR Part 50a(g), Technical Specifications, and the

! ASME Boiler Pressure Vessel Code Section XI, 1980 Edition and j Addenda through Winter 1981:

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o Control of Site Vendor Services, Procedure ADM 01-043, !

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o Steam Generator Eddy Current Checklist, Procedure ENG 06-501, 1

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o Steam Generator Tube Inspection, Procedure STS PE-022 Revision 3 ,

l o Reactor Pressure Vessel, Program Ple.,83A1710, Revision 1

o Reactor Coolant System, Program Plan 83A1700, Revision 1W o High Pressure Coolant Injection System. Program Plan 83A1695

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I Review of Precedures (73052)  ;

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The NRC inspector reviewed the following ISI procedures for i l performing nondestructive examinations:

{i o Digital Multi-Frequency Eddy Current Inspection of Inservice !

Heat Exchanger Tubing, Procedure MRS 2.4.2 GEN-28, Revision 3 o Magnetic Particle Examinat1on, Procedure QCI 12.1-502, !

Revision 3 r

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o Liquid Penetrant Examina'. ion Procedure QCI 12.1-501, Revision 1 o Visual Examination, Pro;edure QCI 11.1-001, Revision 7 l No violations or deviations were identified in the review of this program r l are l 3. Welding and Nondestructive Exa aination Activities Rclated to Plant

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Modifications

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j The NRC inspector reviewed Plant Modification Packa e CS-596-W which involved the socket welding of two pipe caps on sma 1 diameter Class 2 i piping for implementing a design change to the reactor coolant system l level indication. Since this activity was ascertained to te the only !

safety-related welding planned for the outage, the NRC inspector i selectively reviewed additional welding and nondestructive examination l procedures which are listed below: Welding (55050)  !

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o ASME Section XI Repair and Replacement Progra Procedure ADM 01-036. Revision 3  ;

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-5-o Control of Welding Operations, ADM 08-300, Revision 3 o Preparation and Qualification of Welding Procedures, Procedure ADM 08-301, Revision 2 o Control of Welding Filler Material, Procedure ADM 08-302, Revision 5 o Qualification of Welders, Procedure AOM 08-303, Revision 4 o Welding of P-8 Materials, Procedure WPS1-0808 Revision 1 o Welding of P-1 Materials, Procedure WPS1-0101, Revision 2 o Welding of P-1 to P-8 Materials, Procedure WPS1-0108 Revision 0 o Inspection of In-Process Welding, Procedure QCI 12.1-007, Revision 1 Nondestructive Examination (57060 and 57070)

o Liquid Penetrant Exami.1ation, Procedure QCI 12.1-501, Revision 1 o Magnetic Particle Examination Procedure QCI 12.1-502, Revision 3 No violations or deviations were identified in the review of this program are . Design Changes and Modifications Program (37702)

The purpose of this area of the inspection was to ascertain whether the licensee has implemented a quality assurance program for the control of design changes and modifications that is in confonnance with regulatory requirements, comitments contained in the Safety Analysis Report, and industry standards. 10 CFR Part 50, Appendix B, Criterion III contains the basic requirements for design controls. The Wolf Creek Updated Safety Analysis Report (USAR), Chapter 17.2.3, Revision 1, contains the licensee's description of the program for control of design changes and rodifications. Table 17.2-1 of the above USAR chapter provides a description of the hierarchy of licensee procedures with "Policy" and

"Directive" documents having the highest authority. Procedures with a

"KGP" prefix are 4dicated as having the next lower level of authority foliowed by depai. mental and section procedures. In general, the procedures gain specificity as they decrease in authority. In order to gain a full understanding af the licensee's program for control of design changes and modifications, ;he NRC inspector reviewed the following procedures:

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-6-o Policy No. 111.25.0, Revision 03, "Configuration Management Policy "

which defines the applicability of the configuration management system. Only very minor plant facilities, such as standard office telephones, are excluded, o Policy No !!.11.0, Revision 02, "Management Systems," defines the organizational responsibilities for configuration control, o Procedure KGP-1131, Revision 6 and Procedure Change Notice (PCN) f,

"Plant Modification Process," essentially defines the plant configuration control system and serves to route changes through the entire process from origination to final clo:eou o Procedure KGP-1132, Revision 2. "Configuration Identification,"

serves to implement Folicy 111.25.0 and provides greater detai o Procedure KGP-1135 Revision 3. "Configuration Verification," defines methodology and assigns responsibilities for verification of i configuration after a change in the plant is completed, o Procedure ADM 01-0532, Revision 6. "Ergineering Evaluation Request,"

allows plant and other personnel to report certain types of problems which may or may not result in an engineering change, o Procedure ADM 01-042 Revision 11. "Plant Modification Request Implementation," provides a mechanism to track the status of any change in the plant and assigns responsibilities as well as methods for control of change implementatio o Procedure ADM 01-057 Revision 12 with PCNs88-373, 88-338,88-346, 88-334,87-427 and 87-349, "Work Request," defines documentation used to authorize and direct any nonroutine work in the plan Such work includes actual implementation of engineering changes, o Procedure KPN-C-301, Revision 7. "Initiation of Plant Modification Requests."

o Procedure KPN-C-307, Revision 4 "Plant Nodifi;ation Request Revisions and Closecuts."

o Procedure KPN-D-302, Revision 5. "Engineering Studies."

o Procedure KPN-D-303, Revision 3. "Determination of Safety Classification." '

o Procedure KPN-0-304, Revis;on 2, "Licensing Review and Safety Evaluation." This procedure addresses methodology for conduct of 10 CFR 50.59, USAR and Technical Specification change reviews relative to eny change J . .

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- 7-o Procedure KPN-D-317. Revision 1. "ALARA." This )rocedure establishes requirements for conduct of ALARA reviews of a c1ange, o Procedure KPN-D-319, Revision 2. "Environmental Qualification Review of Electrical Equipment to 10 CFR 50.49."

o 3rocedure KPN-E-300, Revision 4 and PCN 2. "Design Process." This procedure provides a broad overview of the design process within the engineering departmen o Procedure KPN-E-301, Revision 4 and PCN 1, "Design Interfaces."

I o Procedure KPN-E-302, Revision 2 and PCN 1, "Design Inputs."

o Procedure KPN-E-303, Revision 4 and PCN 1. -"Calculations."  ;

n Procedure KPN-E-306, Revision 3 and PCN 1, "Design Specifications."

This procedure provides guidance on when a design specification '

should be developed and its content '

o Procedure KPN-E-307. Revision 4. "Design Drawings." This procedure provides guidance on when new design drawings should be issued and relates to situations where existing plant drawings cannot be revised to show a design completely,

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o Procedure KPN-E-308 Revision 5 and PCN 1. "Interdisciplinary i Reviews."

o Procedure KPN-E-309, Revision 3 and PCN 2. "Design Verification -  ;

Safety-Related."

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o Procedure KPN-E-310. Revision 4 and PCN 1, "Design Verification -

Special Scope."

o Procedure KPN-E-311, Revision 4 "Design Verification - Non-Safety." {

o Procedure KPN-E-313. Revision 2. "Design Document Change Notice."

f o Procedure KPN-E-#14. Revision 7 "Disposition of Field Change l Documents."

o Procedure QPM-10 Revision 3, "Modifications." This procedure j addresses the quality assurance / quality control involvement in the ,

modification proces l o Procedure QCP-9.1, Revision 9. "Processing Work Requests." This procedure relates to the quality organization's handling of work  ;

requests.

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-8-o Procedure QP 12.1, Revision 3 and PCN 2. "Inspection Planning For Work Activities."

The NRC inspector found that, collectively, the above procedures provide a highly detailed program for the accomplishment of the entire design change and modification process that satisfies regulatory requirements and meets '

industry standard In the area of temporary modifications, the licensee has issued Procedure ADM 02-101 that addresses how such modifications are to be requested, the requirements for review and approval, and the documentation requirements, in addition, the procedure, which is currently at Revision 18 level, provides instructions on verification of initial installation of a modification and varification of the removal of the modification after it has served its purpos In general, this type of modificetion is usually in the electrical and instrumentation area and involves the installation of temporary wiring changes with subsequent restoration to the design basis configuration. Changes required by written surveillance tests required by the Technical Specifications are not considered temporary madifications for the purposes of the above

- procedur l No violations or deviations were identified in the review of this program area.

5. Procurement Program (38701)

The NRC inspector reviewed the following documents to verify that administrative controls exist and that they provide measures to assure that necessary technical and quality requirements are included in procurement documents for safety-related items or services. The documents were also reviewed to verify that controls exist for the selection, approval, and ute of vendors. These documents were further reviewed to assure that responsibilities for implementing the established measures were delineated in writin >

Title Document N Revision Date Plant Modification Process KGP-1131 6 through 9/15/88 PCN 2 l l

Procurement KGP-1250 3 through 8/30/88 l PCN 2 i

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Material and Services KP-2140 2 through 5/19/88 Procurement PCN 1 Plant Modification Request ADM 01-04? 2 through 7/12/88 Implementation PCN 1

To assess the implementathn of these documents, the NRC inspector

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selected the following purchase orders (P0s) and components, it should be

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-9-noted that all of these items were being procured for implementation of design changes / modifications scheduled to be performed during the refueling outage. All of the design changes / modifications are controlled by PHRs (Plant Modification Requests) and are identified to the applicable P0s. All of these documents were reviewed to assure that: (a)all -

required approvals had been obtained; (b) responsibilities had been established to implement the PMRs; (c) detailed descriptions of the '

changes were delineated; (d) affected drawings and other PMRs which might impact the design changes were identified; (e) design bases, considerations,andcalculationswereaddressedandperformed;and(f)the methoJology was consistent and appeared to be prope PMR Purchase- Component N Order N Ordered Quantity 1544 526953 3 line items of protective varying coatings

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1544 526957 6 line items of carbon steel varying material for use with ASME NF Class 1 component supports 1544 527515 4 line items of bioshield gates 1 each 1858 524864 AMSAC panel (with spare 1 each !

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2068 526705 Chlorine sensors with 8 each

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transmitters 2535 525071 Packing box assembly for 1 each

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ASME Section III, Class 1 valve

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Diaphragm valve, ASME 1 each Section III, Class 1 7538 527689 Carbon steel angle 20 feet 2538 527683 Stainless steel reducers, varying bushings, plugs, and tees The procurement dates for the above items occurred between July and September 1988. While some of the controlling procedures were revised subsequent to the procurement dates, this had no impact in tenns of performance relative to these purchases. For the above items, the NRC inspector reviewed all purchase requisitions, P0s, and any applicable revisions for QA review and approval, and verified that technical

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referenced. It was also verified that these documents did impose 10 CFR Part 21 and either Appendix B to 10 CFR Part 50 or Subarticle NCA-3800 of

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Section III of the ASME Code. The NRC inspector verified that the vendors I from whom these procurements had been made were approved in accordance with the procurement progra The procurement program was found to be effective with respect to meeting the committed objectives, and no violations or deviations were identified during review of this program are . E,xit Interview The NRC inspectors met with the licensee personnel identified in paragraph 1 on September 30, 1988, to discuss the scope and findings of the inspection. The licensee did not identify as proprietary any of the information provided to, or reviewed by the NRC inspector _