IR 05000482/1992030
| ML20125C631 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 12/07/1992 |
| From: | Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| Shared Package | |
| ML20125C633 | List: |
| References | |
| EA-92-191, NUDOCS 9212140016 | |
| Download: ML20125C631 (8) | |
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NUCLEAR REGULATORY COMMISSION f
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HEGION IV
611 HYAN PLAZA OHIVE, SullE 400 o
g *... * _f AR LING TON, T E X AS 76011 8064 DEC 7 1992 Docket No. STN 50-482 License No. NPF-42 EA 92-191 Wolf Creek Nuclear Operating Corporation ATTN:
Bart D. Withers President and Chief Executive Officer Post Office Box 411 Burlington, Kansas 66839 Gentlemen:
SUBJECT:
NOTICE OF VIOL % TION AND PROPOSED IMPOSITION OF CIVIL PENALTY - $50,000 (NRC INSPECTION REPORT NC. 50-482/92-30)
This is in reference to the inspection conducted September 21 through October 6, 1992, at the Wolf Creek Generating Station.
This inspection, which was documented in a report issued on October 27, 1992, focused on the circumstances surrounding Wolf Creek Nuclear Operating Corporation's (WCNOC) discovery on August 27, 1992, of a mispositioned locked, throttle valve in the essential service water system.
Based on potentially significant apparent violations of NRC requirements, an enforcement conference was conducted between representatives of WCNOC and the NRC in NRC's Arlington, Texas, offices en November 3, 1992.
On August 17, 1992, during the conduct of a procedure to measure non-safety related service water flow through component cooling water (CCW) heat exchanger
'A',
plant personnel determined the flow rate through this heat exchanger was approximately 836 gallons per minute (gpm) less than the expected value of 7,200 gpm.
Since safety-related essential service water (ESW)
utilizes the same components and flows through the same heat exchanger, plant personnel developed a procedure to verify that design-basis ESW flow rates could be achieved.
On August 27, 1992, plant personnel implemented this procedure and measured ESW flow through CCW heat exchanger
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at 7,213 gpu, approximately 842 gpm less than the expected value of 8,055 gpm and approximately 80 gpm less than the minimum design basis flow rate specified in the facility Updated Safety Analysis Report 'USAR).
CERTIEIID_. MAIL BETURN RECEIPT REOUESTED 78A221886R8?sS8?o2
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DEC 7 EG2
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Wolf Creek Nuclear-2
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operating Corporation
As part of its investigation of the cause of this low flow
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condition, plant personnel closed valve EF VO58, a manually operated valve that is normally locked open in a predetermined
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position to ensure adequate ESW flow under certain accident q
conditions.
When the valve was closed, a loud noise emanated from the valve actuator and the valvo could not be reopened.
At
the same time, it was also noted that with the valve closed the valve position indicator indicated that the valve was partially open.
Based on the inability to attain sufficient ESW flow (the ESW provides cooling water to many safety-related plant
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components under accident conditions), WCNOC declared train $A'
of the ECCS and CCW systems inoperable and made a prompt report
to NRC's Operations Center in accordance with 10 CFR 50.72.
Further investigation of this event detnrmined that on July 22,
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1992, during preventive maintenance on valve EF VO58, which was intended to involve only the lubrication of the valve operator, a
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plant mechanic made an adjustment to the valve position indicator.
This task was beyond the scope of the Work Request,
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(WR) 51543-92 Written for the job.
This adjustment, which was not documented on the work request or discussed with plant
operations personnel following this maintenance activity, resulted in valve EF VO58 being left in the wrong position at the
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conclusion of this maintenance activity.
As a result, post-
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maintenance testing was not conducted to ensure that valve EF
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VO58 was in the correct position.
Therefore, from July 22, 1992,
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until this condition was discovered and corrected on August 27,
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1992, ESW flow through CCW heat exchanger
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function following a loss of coolant accident.
The NRC recognizes that WCNOC took immediate action to repair valve EF VO58 and restore it to its required position, thus restoring ESW to full operability.
In addition, as discussed at the enforcement conference, WCNOC took additional actions to ensure that similar valves were not affected, developed plans to
review pending preventive maintenance instructions for similar weaknesses to those identified in WR 51543-92, and has an ongoing
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review of work process controls.
i Based on the results of NRC's inspection and the discussions that
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took place'during the enforcement conference, the NRC believes that a violation of requirements related to work requests and
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work instructions directly contributed to this event.
Wolf Creek Generating Station (WCGS) Technical Specifications and related
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procedures governing these activities require that maintenance
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which can affect the performance of safety-related equipment be
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preplanned and performed in accordance with tritten procedures and documented instructions appropriate to the circumstances.
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DEC 7 E
i Wolf Creek Nuclaw-3
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operating cr 9prateon
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Contrar; LG thvev HCGS proc 4 Nres, work beyond the scope of the work rw.wat VM.mW!an% e.no not documented and, as a direct
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r e a u.* t god 'c2 h:t csnic teating was not conducted to ensure that i
valm W V W nsu
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The FR3 in ';0avtrFm about the apparent lack of sensitivity to
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the inp6eaaace of the positioning of this valve reflected by the circumstances surrounding this event.
However, the NRC also
l recognir.es that WCNOC determined subsequent to this event that
the work instructions that were used, while not inadequate, could i
have been of better clarity.
Nevertheless, based on several-j recent violations similar in nature to this case, the-NRC has l
continuing concerns about WCNOC's control of work activities that I
can affect safety-related equipment.
The clarity and accuracy of
procedures as well as compliance with them make up part of this i
concern.
For example, on August 10, 1992, a Notice of Violation
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was issued because specific procedural steps were not performed, l
resulting-in the dilution of the spray additive tank-sodium j
I hydroxide concentration.
On June 30, 1992, a Notice of Violation l
l was' issued for two violations.
One occurred because an
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undocumented minor' maintenance was performed on a valve in a I
j safety-related system without a work request and tho other one
occurred because a procedure that was inadequate resulted in an I
inadvertent release of radioactive gas to the radwaste building.
The latter event occurred despite a previous occurrence of a
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similar nature.
On April 9, 1992, a Notice of Violation was
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issued for three instances in which procedures were inadequate.
These failures appear to reflect a continuntion of a problem f
noted by NRC in the WCGS Systematic Assessunnt of Licensee
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Performance report issued in December 1991.
In assessing WCGS's performance in the functional area of maintenance and surveil-l lance, the report ststed that work process controls were j
generally good, but that several incidents could have rendered
safety-related equipment inoperable.
The report stated, "In
these specific work activities the planning efforts did not result in a close attention to the ramifications of the specific activity."
WCNOC stated at the November 3, 1992, enforcement conference that it viewed the ESW problem as a significant issue,
i but isolated.
The NRC is unable to reach the came conclusion.
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While the NRC believes that WCNOC's corrective actions in this case were appropriate, the relatively limited scope of actions that have been completed provide an inadequate basis for-such a
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conclusion.
Only after pending preventive-maintenance
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instructions are-reviewed, the ongoing review of work process
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controls is-completed, and the findings of those efforts are
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compared with the types of. violations discussed above, will there be enough information to reach a meaningful conclusion.
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The violation of work controls that is the basis for this action
resulted in degraded ossentini service water flow.
As discussed
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during the enforcement conference, WCNOC rolled upon existing l
analyses to conclude that the ESW flow would have boon adequato, despite this degradation, to provido sufficient cooling to plant
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components under all accident conditions.
Although this conclusion mitigates the technical safety significance of the
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violations that occurrod, it does not reduce the regulatory
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significance that NRC attaches to violations of this type.
As i
discussed above, work was performed on a safety-related component apparently without the recognition that the work could defeat the i
functioning of an important safety system.
Additionally, the mispositioning of this valve, which resulted in a significant reduction of the margin of sataty assured by system flow ratos
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higher than necessary to moet donign assumptions, could easily
have resulted in more significant degradation of ESW flow becauso a
the mechanics involved did not recognize that they had affected
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flow by adjusting the valvo position indicator incorrectly.
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Therefore, in accordance with the "Gonoral Statomont of Policy l
and Procedure for NRC Enforcement Actions," (Enforcement Policy)
10 CFH Part 2, Appendix C, the violation is classified at Savority Level III.
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To emphasize the importanco of improving controls over maintenance on safety-related components and aggressively pursuing corrective actions designed to achieve such improvements, I have been authorized, after consultation with the
Director, Office of Enforcement, and the Deputy Executivo Director for Nuclear Reactor Regulation, Regional Operations and
Research, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) in the amount of $50,000 for the Severity Level III violation described above and in the
onclosed Notico.
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The. base value of a civil penalty for a Severity Lovel III i
violation is $50,000.
The civil penalty adjustment factors in Section VI.B.2 of the Enforcement Policy wuro considered, but
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resulted in no not adjustment being mado.
WCNOC's identification
of the reduced flow condition in the ESW system, which warranted
a reduction in the penalty by 50 porcent of the base value under the " Identification" factor, was offset by NRC's view that this i
event is indicative of a recurring and uncorrected weakness in
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work control processes, which warranted an increase in the penalty by 50 percent of the base value under the " Licensee
performanco" factor.
The remaining factors were considered but
did not result in any adjustments.
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Other violations that were identified in the inspection report were not considered in assessing the civil penalty because none
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DEC "
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Wolf Creek Nuclear-5-Operating Corporation of them directly contributed to degrading ESW flow.
One apparent violation discussed in the inspection report, involving a December 1991 incident in which valve EF V058 was found mispositioned, is not being cited because it occurred when the ESW system was not required to be operable and when locked valve requirements were not required to be in effect.
The remaining apparent violations identified in the report appear in Section II of the enclosed 1::tice.
With respect to Violation II.A 3, NRC is concerned that the system engineer appeared to scarch for plausible " paperwork" problems rather than believe the indications of reduced system flow that were apparent on August 17, 1992.
Your response to the enclosed Notice should specifically address those actions you have taken or planned to address this concern.
WCHOC is 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 corrective actions, and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice,"
a copy of this letter and its cnclosure will be placed in the NRC Public Document Room.
The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as requited by the Paperwork Peduction Act of 1980, Pub. L. No.96-511.
Sincerely, L 7/RJLa James L. Milhoan k
tegional Admir.istrator Enclosures Notice of Violation and Proposed Imposition of Civil Penalty ec w/ enclosures (see next page)
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Wolf Creek Nuclear-6-operating Corporation
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cc w/enclosuret Wolf Creek Nuclear Operating Corp.
J ATTNt Otto Maynard, Director l
Plant operations
P.O.
Box 411 Burlington, Kansas 66839 l
Shaw,.'ittman, Potts & Trowbridge
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ATTN!
Jay S11 berg, Esq.
2300 M Street, NW Washington, D.C.
20037 Public Service Commission ATTNt C. John Renken Policy & Federal Department P.O.
Box 360 Jefferson City, Missouri 65102 U.S.
Nuclear Regulatory Commission ATTNt Regional Administrator, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
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Wolf Creek Nuclear Operating Corp.
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ATTN:
Kevin J. Moles
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Manager Regulatory Services P.O.
Box 411 Burlington, Kansas 66839 Kansas Corporation Commission ATTNt Robert Elliot, Chief Engineer Utilities Divinic'n 1500 SW Arrowhead Rd.
Topeka, Kansas 66604-4027 office of the Governor State of Kansas Topeka, Kansas 66612
Attorney General
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I ist Floor - The Statehouse Topeka, Kansas 66612 Chairman, Coffey County Commission coffey County Courthouse Burlington,-Kansas 66839-1798 l
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l Wolf Creek Nuclear-7-j operating Corporation
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Kansas Department of Ilealth
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and Environment
l Bureau of Air Quality & Radiation
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ATTN:
Gerald Allen, Public licalth Physicist Division of Environment
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Forbes Field Building 321 Topeka, Kansau 66620 d
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l Kansas Department of floalth and Environment ATTN:
Robert Eye, General Counsel
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j LSOB, 9th Floor j
900 SW Jackson
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Topeka, Kansas 66612 i
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I NO7 Wolf Creek Nuclear-8
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Operating Corporation liq DISTRIBUTION:
PDR SECY CA JSniezek, DEDR TMurley, NRR JPartlow, HRR/ADP JLieberman, OE LChandler, OGC JGoldberg, OGC Enforcement Officers RI, RII, RIII, RV FIngram, PA DWilliams, OIG EJordan, AEOD BHayes, OI JLunhman, OE Day File FA File DCS '.
BLV._ DISTRIBUTIOll:
JMilhoan JMontgoriery ABBeach*TPGwynn Scollins-DChamberlain AHowell-MSatorius GPick, SRI, WCGS JGilliland CHackney WBrown GSanborn*RWise-EAFile LWilliamson, OI RIV Files RSTS Operator MIS Coordinator s
DM,
RA:RIV [ # ( d D 08 hR OE JLushman E
JMilhoan g JLi h an JShesak 11/tO/92 11/3*/92
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11/9/92 11/ h92
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M 3 g' ' D 110024
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