IR 05000482/1993016
| ML20045D422 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 06/25/1993 |
| From: | Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| Shared Package | |
| ML20045D423 | List: |
| References | |
| EA-93-129, NUDOCS 9306290014 | |
| Download: ML20045D422 (6) | |
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UNITED STATES
[p3 HCgIg NUCLEAR REGULATORY COMMISSION
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R EGION IV
611 RYAN PLAZA DRIVE. SUITE 400 o
ARLINGTON, T EXAS 760114064
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JUN 2 5 1993 Docket:
50-482 License:
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Wolf Creek Nuclear Operating Corporation
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ATTN:
Bart D. Withers President and Chief Executive Officer P.O. Box 411 Burlington, Kansas 66839 SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY -
S50,000 (NRC INSPECTION REPORT NO. 50-482/93-16)
This is in reference to the inspection conducted May 10-13, 1993, at the Wolf Creek Nuclear Generating Station (Wolf Creek) nuclear power plant, Coffey County, Kansas. This inspection was prompted by a Wolf Creek balance-of-plant operator's discovery on May 9, 1993, with the plant in Mode 3, that the control room handswitches for the motor-driven auxiliary feedwater (AFW) pumps were in the " pull-to-lock" position, rendering them unable to respond to an
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automatic start signal.
A_ report documenting the results of this inspection was issued on May 26, 1993. On June 9.1993 you and other Wolf Creek Nuclear
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Operating Corporation (WCNOC) representatives attended an enforcement conference in the NRC's Arlington, Texas, of fice to discuss NRC's preliminary conclusion that potentially significant violations of NRC requirements and plant Technical Specifications had occurred. This conference was open to public observation in accordance with the terms of a pilot program begun by_
the NRC in July 1992.
Based on the information developed during its inspection and the information gained from the enforcement conference, the NRC has determined that the violations occurred as described in the inspection report.
The violations in the enclosed Nntice of Violation and Proposed imposition of Civil Penalty (Notice) include:
1) a failure to adhere to plant procedures requiring the handswitches for the motor-driven AFW pumps to be placed in their normal position prior to entry into Mode 3; and, as a result, 2) a failure to satisfy plant Technical Specifications by entering Mode 3 with the motor-driven auxiliary feedwater pumps inoperable (Technical Specification 3.0.4).
The remaining four violations identified in the inspection report are not included because they are all enveloped by the cited violations.
These included a failure to satisfy the related Technical Specification action statements (Technical Specification 3.7.1.2), failures on the part of the plant operations staff to perform adequate shift turnover briefings and main control board walkdowns. and a-failure to use the equipment out-of-service log to
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track the status of the motor-driven AFW pumps.
We recognize that it was not your intent to use the equipment out-of-service log in all modes of plant operations.
However, as discussed at the enforcement conference. your procedures required.its use.
We understand that WCNOC plans to correct this-i error.
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9306290014 930625 V
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The circumstances surrounding these violations are described in more detail in the inspection report.
However, it is clear from the discussions.at the enforcement confer.ence that inattention to detail on the part of the plant operations staff is the primary cause of this event.
In its most basic form, this occurred because a supervising operator did not take the time necessary to read and understand what he was certifying, thus failing to recognize that
a checklist designed to ensuce, among other things, the proper positioning of the pump handswitches had not been completed.
Pressure to enter Mode 3 prior to the end of the shift, whether real or perceived may have contributed to the occurrence of this error.
It is of equal concern to the NRC that this error was not detected or recognized by plant operators for more than 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />. despite multiple opportunities during two shift turnovers and routine control board walkdowns.
In addition, WCNOC's investigation of this event _
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revealed that various operators observed the position of the pump handswitches but failed to connect their observations to plant requirements for Mode 3.
The NRC acknowledges that tNe immediate safety significance of this event was mitigated by the fact that the steam-driven AFW pump was available and.would have started automatically, by the fact that the motor-driven AFW pumps couid have been started from the control room, and by the fact that the plant was in
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initial start-up following a refueling outage (low decay heat).
However, as I
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emphasized during the enforcement conference, compliance with prerequisites
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for mode changes has broad safety significance as well as regulatory significance.
The very purpose of ensuring.the operability of such equipment prior to made-changes is-to assure that equipment that is important to safety is available to operate as assumed in the design of the facility and technical specifications..We-note, for example, that the checklist that:was.not properly completed prior to entry into Mode'3 in this case also contains steps for ensuring the proper alignment of the safety injection system.
As WCNOC stated during the conference, the same mistake under other circumstances could have had more serious safety implications.
WCNOC tookeprompt action to restore compliance with plant Technical-
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Specifications.
In addition, although'WCNOC personnel may not hav7 initially appreciated the significance of this event, WCNOC conducted a thorough investigation to determine the primary and contributing causes, and initiated comprehensive corrective action to address the causes of this event and to prevent a recurrence. These actions include, but are not limited to:
1) a series of memoranda to plant operators and site personnel stressing the need to pay attention to detail, eliminate distractions in the control room during turnovers, control the volume of work activities and eliminate unreasonaDie pressures on control room staff, real or perceived, to complete tasks during their shifts: 2) the conduct of training sessions on shift relief and turnover, and discussion sessions on the specific event to be led by the involved plant operations personnel: 3) enhancements to procedures by moving important requirements from checklists to the-body of the procedures and by itemizing all Technical Specification requirements in one location in the.
involved procedures: 4) the conduct of an evaluation by Quality Assurance of operating crew turnovers and board walkdowns; and 5) the conduct of an
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I Wolf Creek Nuclear Operating-3-
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2 5 1993 Corporation independent assessment of plant operations by a team made up of persons from within and outside the WCNOC organization to identify strengths and weaknesses
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and recommend improvements.
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In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," (Enforcement Policy) 10 CFR Part.2, Appendix C, the violations described above are classified in the aggregate as a Severity Level III problem. To emphasize the importance of ensuring the availability of required safety equipment prior to making mode changes, and the importance of operators paying close attention to detail _in the performance of their duties, I have been. authorized, after consultation with the Director, Office
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of Enforcement, and the Deputy Executive Director for Nuclear Reactor j
Regulation, Regional Operations and Research, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) in the amount of -
550,000 for this Severity Level 111 problem.
The base value of a civil penalty for a Severity Level III problem is $50,000.
The civil penalty adjustment factors in the Enforcement Policy were considered
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and resulted in no net adjustment. The NRC's consideration of the identification factor resulted in a 50-percent decrease because the principal violation was discovered by WCNOC personnel. The NRC also considered WCNOC's
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corrective actions to warrant a 50-percent decrease. These decreases,
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however, were offset by a 100-percent increase because the operations staff had multiple opportunities to discover and correct this noncompliant condition earlier.
The remaining adjustment factors were considered but no further-adjustments were determined to be appropriate.
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 tnis.
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 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 enclosure 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 required by the Paperwork Reduction Act of 1980. Pub. L. No.96-511.
Sincerelp
.I as.s I James L. Milhoan Regional Administrator e
Enclosure:
(see next page)
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JUN~2 5 1993 Wolf Creek Nuclear Operating-4-Corporation
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Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalty
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cc w/ enclosure:
Wolf Creek Nuclear Operating Corp.
ATTN: Otto Maynard, Vice President
' Plant Operations P.O. Box 411 Burlington, Kansas 66839 Shaw, Pittman, Potts & Trowbridge ATTN:
Jay Silberg, Esq.
2300 N Street, NW Washington, D.C.
20037
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Public Service Commission ATTN:
-C. John Renken Policy & Federal Department P.O. Box 360 Jefferson City, Missouri 65102
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U.S. Nuclear Regulatory Commission ATTN:
Regional Administrator, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Wolf Creek Nuclear Operating Corp.
ATTN:
Kevin J. Moles
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Manager Regulatory Services P.O. Box 411 Burlington,' Kansas 66839 Kansas Corporation Commission
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ATTN:
Robert Elliot, Chief Engineer Utilities Division 1500 SW Arrowhead Rd.
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Topeka, Kansas 66604-4027 Office of the Governor State of Kansas l
Tnpeka, Kansas 66612-Attorney General 1st Floor - The Statehouse Topeka, Kansas 66612 i
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M2 5 1993
' Wolf Creek Nuclear Operating-5-Corporation Chairman, Coffey County Commission
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Coffey County Courthouse Burlington, Kansas 66839-1798 Kansas Department of Health and Environment Bureau of Air Quality & Radiation Control ATTN.
Gerald Allen, Public Health Physicist
. Division of Environment Forbes Field. Building 321 Topeka, Kansas 66620 Kansas Department of. Health and Environment ATTN:
Robert Eye, General Counsel LSOB, 9th Floor 900 SW Jackson Topeka, Kansas 66612
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Wolf Creek Nuclear Operating-6-Corporation JUN 251993 bcc w/ enclosure:
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