IR 05000482/1990034

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Forwards Notice of Violation Re Insp Rept 50-482/90-34 & Summary of Enforcement Conference on 901106
ML20197H638
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 11/09/1990
From: Collins S
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Withers B
WOLF CREEK NUCLEAR OPERATING CORP.
Shared Package
ML20197H643 List:
References
EA-90-185, NUDOCS 9011200031
Download: ML20197H638 (4)


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N0i -91990

. Docket No.'STN 50-482/90-34 License No. NPF-42

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EA 90-185 f

Wolf Creek Nuclear Operating Corporation ATTN: Bart D. Withers *

President and Chief Executive Officer P.O. Box 411 Burlington, Kansas 66839 Gentlenen: .

SUBJECT: NOTICEOFVIOLATION(NRCINSPECTIONREPORTNO.LTN 50-482/90-34)

This refers to the special inspection conducted September 26 through October 5, 1990, at Wolf Creek Nuclear Operating Corporatica's (WCNOC) Wolf Creek Generating Station (WCGS) and to the aiscussions of the results of that inspection with you and other WCNOC reprvsentatives at an enforcement-conference in the NRC's Arlington, Texas, office on November 6,1990. The

'NRC's~1nspection report was issued on October 23, 1990.

! On October 1,1990, with WCGS operating in Mode 1, the turbine-driven auxiliary feed pump (TDAFP) was declared inoperable because of an indeterminate seismic qualification status of.the DC control cable to the electrohyoraulic valve (EHV)

actuator on the TDAFP turbine. The potential failure of this cable in a

' seismic event would result in an overspeed condition and subsequent trip of

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the TDAFP. This condition existed since November 2,1989, when a maintenance

technician inadvertently broke a coupling which attaches the DC control cable conduit and elbow coupling to the EHV valve actuator. Although the DC control cable remained connected to the EHV actuator, the degraded condition could have affected the- seismic qualification and, therefore, operability of the TDAFP

'because the exposed.DC control cable was supporting the weight of the conduit'

elbow coupling. As a result, this condition was classified in our report as an i_ apparent violation of Technical Specification 3.7.1.2 that requires at least L ' three' independent steam generator auxiliary feedwater pumps and associated flow paths to be operable with the plant operating in Modes 1, 2, and 3. At the

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November 7,1990, enforcement conference, you and other WCGS representatives

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indicated that the seismic qualification status of the DC control cable would be determined by testing and that the preliminary results of this test would be available on December 4, 1990 As a result, this apparent violation is considered an urgesolved item pending the results of the TDAFP seismic qualification tes lA second apparent violation was identified in NRC Inspection Report 50-482/90-34 involving the failure of the WCGS corrective action program to evaluate the operability of the TDAFP as well as correct the degraded condition in a timely manner. This is a violation of 10 CFR 50, Appendix B, Criterion XVI, which l

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Wolf Creek huclear Operating -2-Corpor:, tion requires, in part, that neasures shall be established to assure that conditions adverse to quality are promptly identified and corrected. This degraded condition existed for approximately 11 months before short-tenn corrective action was taken to repair the degraded electrical coupling. Although the broken electrical coupling associated with the TDAFP was identified by WCGS personnel in hovember 1989 and brought to the attention of the control room shift supervisor, it was not corrected until NRC questioned the condition of the ICAFP. This violation appears to have occurred as the result of inadequacies in WCGS's work control process in that there was no programmatic mechanism to require engineering involvenent in assessing the effect of the degraded TDAFP condition on its operabilit The NRC recognizes the relatively low safety significance of the broken eltetrical coupling. We note that WCGS tested the TDAFP satisfactorily when the broken coupling was first reported and that, in all likelihood, the TDAFP would have performed as expected under virtually all, and oerhaps all, design basis conditions. Nevertheless, the lack of timeliness in correcting this condition is of concern to the NRC because it and other relatively recent problems at WCGS appear to have resulted from weaknesses in work control and corrective action processe The lack of timeliness in correcting the degraded TDAFP condition, other problems occurring in 1990 that were not promptly identified to management, and the NRC's concerns about these problems were discussed with WCN0C's representatives at the enforcement conference. The causes and contributing factors associated with these problems vary, but most involve the lack of prompt notification of pro 51 ems to the appropriate level of management. The NRC is primarily concerned with your organization identifying and correcting the cause or causes of thit declining tren You and other WCNOC representatives at the enforcement conference described corrective actions that are designed to ensure that hardware problems are promptly evaluated for operability. The NRC encourages WCNOC to implement these actions and address other factors, such as other corrective action processes, to ensure that significant conditions adverse to quality are promptly resolve The violation in the enclosed Notice has been classified at Severity Level I However, WCNOC should be aware that repetitive violations of this nature may lead to monetary civil penalties or other escalated enforcement action, as deemed appropriat You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure the continued safe operation of WCG _ _ _ _ _ - _ _ _ _ _ _ - _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _-.

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i l- Wolf Creek Nuclear Operating -3-Corporation In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of

this letter and its enclosures will be placed in the NRC Public Docunent Roo In addition to the Notice, a copy of WCNOC's enforcement conference handout and a list of enforcement conference attendees are enclosed. The responses directed by this letter and the enclosed Notice are not subjtet to the clearance procedures of the Office of Management and Budget as required by Paperwork Reduction Act of 1980, Pub. L. No. 96-51 ,

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Sincerely, OrloinalSignad By:

Thomas P.Gwym Samuel J. Collins, Director Division of Reactor Projects

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Enclosures: Notice of Violation WCN00 enforcement conference handout List of enforcement conference attendees cc w/ Enclosures:-

Wolf Creek' Nuclear.0perating Cor ATTN: Gary Boyer, Plant Manager P.O. Box 411 1 Burlington, Kansas 66839 Shaw, Pittman, Potts & Trowbridge <

ATTN: Jay Silberg, Es M Street, NW Washington, D.C. 20036 Public Service Comission ATTN: Chris R. Rogers, .

Manager, Electric Department P.O. Box 360-Jefferson City, Missouri 65102 l U.S. Nuclear Reoulatory Comission

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ATTN:- Regional Administrator, Region Ill 799 Roosevelt Road Glen Ellyn,_ Illinois 60137 l' Wolf Creek Nuclear Operating Cor ATTH: Otto Maynard, Manager L Regulatory Services P.O.' Box 411 Burlington, Kansas 66839 l

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Wolf Creek Nuclear Operating -4-Corporation Kansas Corporation Commission ATTN: Robert Elliot, Chief Engineer Utilities Division 4th Floor - State Office Building Topeka, Kansas 66612-1571 Office of the Governor State of Kansas Topera, Kansas 66612 Attorney General 1st Floor - The Statehouse Topeka, Kansas 66612 Chairrran, Coffey County Commission Coffey County Courthouse Burlington, Kansas 66839 Kansas Department of Health and Environment Tureau of Air Quality & Radiation Control

ATTN: Gerald Allen, Public Health Physicist Division of Environment m

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Forbes Field Building 321

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. Topeka, Kansas 66620 bec to DMB (IE14)

r bec distrib. by RIV:

R. D. Martin Resident Inspector

' Section. Chief (DRP/D) DRP DRSS-FRPS SectionChief(RIII,DRP/3C)

RIV File SRI, Callaway, RIII MIS System RSTS Operator

. Project Engineer (DRP/D) Lisa Shea, RM/ALF DRS G. Sanborn, E0~

R. Wise, AC C. Hackney, RSLO J. Lieberman, DE L. P11sco, NRR'

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