IR 05000482/1996014

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-482/96-14

ML20134M389
Person / Time
Site:	Wolf Creek
Issue date:	11/21/1996
From:	Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Carns N WOLF CREEK NUCLEAR OPERATING CORP.
References
NUDOCS 9611250072
Download: ML20134M389 (5)

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NOV 2 l 1996 i

I r-Neil S. Carns, President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, Kansas 66839

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SUBJECT: NRC INSPECTION REPORT 50 482/96-14.

Thank you for your letter of November 5,1996,in response to our letter and Notice of Violation dated September 23,1996. We have reviewed your reply and find it i ,

! responsive to the concerns raised in our Notice of Violation. We will review the I implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.

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Sincerely, d f

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p J. E. Dyer, Director I -Division of Reactor Projects Docket No.: 50-482 License No.: NPF-42 cc: I

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Vice President Plant Operations i

. Wolf Creek Nuclear Operating Cc l

' P.O. Box 411 Burlington, Kansas 66839  !

Jay Silberg, Es Shaw, Pittman, Potts & Trowbridge 2300 N Street, NW Washington, D.C 20037 9611250072 961121

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PDR ADOCK 05000482 0 PDR g i I

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I Wolf Creek Nuclear Operating -2-Corporation l

Supervisor Licensing I Wolf Creek Nuclear Operating Cor P,0. Box 411 '

Burlington, Kansas 66839 i l

l Supervisor Regulatory Compliance l Wolf Creek Nuclear Operating Cor P.O. Box 411 l Burlington, Kansas 66839

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Chief Engineer l Utilities Division Kansas Corporation Commission 1500 SW Arrowhead R .

Topeka, Kansas 66604-4027

- Office of the Governor I State of Kansas Topeka, Kansas 66612 ,

Attorney General Judicial Center i 301 S.W.10th I 2nd Floor ,

Topeka, Kansas 66612-1597 I County Clerk Coffey County _ Courthous Burlington, Kansas 66839 1798 Public Health Physicist Division of Environment Kansas Department of Health and Environment Bureau of Air & Radiation Forbes Field Building 283 Topeka, Kansas 66620 Mr. Frank Moussa ,

Division of Emergency Preparedness !

i 2800 SW Topeka Blvd Topeka, Kansas 66611-1287 j

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N01' 21 1996 Wolf Creek Nuclear Operating -3-Corporation l

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L. J. Callan Resident inspector DRP Director SRI (Callaway, RIV)

Branch Chief (DRP/B) DRS-PSB Project Engineer (DRP/B) MIS System

' Branch Chief (DRP/TSS) a l V File Leah Tremper (OC/LFDC8, MS: TWFN 9E10)

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l l DOCUMENT NAME: R:\_'NC\WC614AK.JFR

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OFFICIAL RECORD COPY

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L. J. Callan Resident inspector DRP Director' SRI (Callaway, RIV) -

Branch Chief (DRP/B)' DRS-PSB Project Engineer (DRP/B) MIS System Branch Chief (DRPfrSS) RIV File -

Leah Tremper (OC/LFDCB, MS: TWFN 9E10)

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DOCUMENT NAME: R:\ WC\WC614AK.JFR i

. To receive copy Qument. Indicate in boxi"C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy-l C:DRP/B / / D:DRP[/M l lWDJohnsohf~ JEDyer f l-l11/{R /96 / 11/2.1 /96 l OFFICIAL RECORD COPY

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I W@) LF NUCLEAR CREEKOPERATING Neil S. " Buzz * Cams Chairman President and Chief Executue Officer November 5, 1996 WM 96-0120 S

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U. S. Nuclear Regulatory Commission i -

ATTN: Document Control Desk tail Station P1-137

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l Washington, D. )

Reference: Letter dated September 23, 1996, from T. P. Gwynn, NRC, to N. S. Carns, WCNOC l

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Subject: Docket No. 50-482: Response to Notice of Violations 50-482/9614-01, -02, and -03 Gentlemen:

This letter transmits Wolf Creek Nuclear Operating Corporation's (WCNOC)

response to Notice of Violations 50-482/9614-01, -02, and -0 The first violatio2 concerns WOTOC's failure to have procedures appropriate to the circumstance The second violation concerns WCNOC's failure to correctly utilize locking hasps. The third violation concerns WOTOC's failure to follow estaolished corrective action procedure This response letter is being submitted after the thirty day due date with the concurrence of the Senior Resident Inspector and Mr. D. Graves, NRC Region IV, per verbal discussion and telecon, with T. Damashek, WCNOC, on October 22, 1996, respectivel WCNOC's response to these violations are in the attachmen If you have any questions regarding this response, please contact me at (316) 364-8831, extension 4100, or Mr. Terry S. Morrill at extension 870 Very truly yours,

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W Neil S. Carns NSC/jad Attachment ec: L. J. Callan (NRC), w/a W. D. Johnson WRC) , w/a J. F. Ringwald (NRC) , w/a J. C. Stone (NRC), w/a 1~b PO. Box 411/ Durtington, KS 66839 / Phone:(316) 364 8831 A9 l.y gi y An Equat opportunity Empt>yer M F HCVET i {3OL! 6 2 (O _ . .

Attachment to WM 96-0120

, Paga 1 of 9 Recly to Notice of violations 50-482/9614-0 , and -03 Violation 50-482/9614-01: Failure to establish procedures appropriate to the circumstance * Criterien V of Appendix B to 10 CFR Part 50 requires, in part, that 1 activities affecting quality shall be prescribed by documented instructions, procedures, and drawings appropriate to the circumstances ,

and shall be accomplished in accordance with these instructions, l procedures, and drawing l l

Contrary to the above, for work performed on July 31, 1996, licensee !

procedures were inappropriate to the circumstances in that they failed to control the planning of that work to specify criterion for when a work planner could mark the permission to start block on a work package

"Not Applicable," and also permitted a single work package task to j require work on both trains of safety-related syste Consequently,

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these programmatic deficiencies contributed to a work package being worked in the field without permission to start from the shift supervisor or central work authority per the approved schedule on Motor-Drive Auxiliary Feedwater Pump A, while Motor-Drive Auxiliary Feedwater

! Pump B was declared inoperable and removed from service, for planned maintenanc This is a Severity Level IV violation (Supplement I) (482/9614-01."

Admission of violation:

Wolf Creek Nuclear Operating Corporation (WCNOC) acknowledges and agrees that a violation of Criterion V of Appendix B to 10 CFR Part 50 occurred on July 31, 1996, when work control procedures inappropriately allowed work to commence without the shift supervisor's permission and allowed one work package task to perform work on both trains of a safety system. This event was discovered by WCNOC system engineering personnel during field inspections associated with the work activit Reason for Violation:

Root Cause:

Two root causes and several contributing factors for this event were identified. The root causes are:

1. Management failed to reinforce previously established requirements pertaining to separation of train related wor . Inadequate placement of physical barrier - the sign placed on the door of the auxiliary feedwater pump room was intended to prevent exactly what happened. Due primarily to its placement it was not effectiv _ _

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,. Attachment to WM 96-0120

. Page 3 of 9 6. When work was approved to restart, all permissions to restart / start had to be re-authorized by the central work authorit Additionally, the following corrective actions were implemented to control work on only the authorized train

1. The daily risk awareness boards (which are posted at the plant entrance, work control center, and the control room) are prominently labeled with the authorized train for work that da Plant personnel have been trained as

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to what the meaning is of this " authorized train" indicatio . The authorized train is prominently discussed as the opening item in both the 0730 hour0.00845 days <br />0.203 hours <br />0.00121 weeks <br />2.77765e-4 months <br /> shift supervisor work meeting and the 0830 plant manager's meetin . The authorized train is prominently displayed on the work group bulletin board by color coded engraved sign These signa are placed on the bulletin board in advance of the maintenance personnu m rting i e work at the beginning of each workda . The workers and the work week manager involved were counseled as to the proper procedures to follow to prevent cross-train wor . Administrative Procedure AP 16C-003, " Work Package Task Planning," was revise This revision clearly establish when the shift supervisor permission to start is required and to provide guidance on separate work package tasks for separate trains, 6. MIB-79 was revised to reflect the guidance placed in AP 16C-003, 7. Training was provided to the maintenance planning personnel to ensure they are aware of the requirements concerning when to notify the s'aif t supervisor prior to starting wor . The work planning requirements were revised, to ensure a clear description of the scope and the train involved are contained in the work packag These requirements are part of the changes to AP 16C-00 The revision ensures that modifications or corrective maintenance which affect both trains, will be implemented by separate work package task . Training was provided to all maintenance f:;rst line .;;upar- W rs, maintenance planners, and work week managers, in the requirensnca to prevent cross-train wor Corrective Steps That Will Be Taken And The Date When Full Compliance Will Be Achieved:

l M.nagement will provide communication of requirements and standards concerning l cc as-train work to all personnel reporting to the chief operating of fice Tras will be completed by November 15, 1996.

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Physical barriers intended to prevent work form being performed on opposite train equipment during LCOs were assessed. These barriers will continue to be utilized where appropriate. They are adequate for use as an aid in reminding

personnel of train work prohibitions, however, t-hey are not the primary means

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to control cross-train wor . . . - .-. .- . - . - . _ _ _ - _ . . - . - . - . ~ . . - - .. __

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, Attachment to WM 96-0120

.. Paga 2 of 9 Contributing Factors:

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l. Work instructions were inadequate. Though the work package contained instructions for work on both A and B trains, the " equipment listing" block of the work instructions only had room to list one trai . Scheduling was inadequate. Because the work package " equipment listing" bl.ock only referred to "B" train, the WCNCC Plan - of the Day (POD) , did not make reference to "A" train work as scheduled work. Thus, improper train work was schedule . Procedure guidance was inadequate. Guidance contained in Maintenance Information Bulletin (MIB-79) on when the shift supervisor's permission was required was reak and did not provide adequate instruction for the planner on when the shift supervisor permission to start block could be marked not

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applicable (N/A). In addition, this guidance was contained in a MIB and

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would have been more appropriacoly placed in the procedur Corrective Stoos Taken and Results Achieved:

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Tha auxiliary feedwater system _ engineer immediately reported the concern to ,

l the shift supervisor and the work control cente Subsequently the mechanical i

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maintenance superintendent, the maintenance manager, and the plant manager were briefe Operability of the "A" train components was immediately assessed as l- satisfactory.

l ll Representatives from operations, the work control center, maintenance, and system engineering met with the plant manage The plant. manager provided l directions on long and short term actions.

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l All technical specification limiting condition for operation (LCO) work was

! immediately halted until the following actions were completed:

1. All packages were reviewed to verify that no additional "A" train work was include . The schedule for the "B" train was reviewed to determine if any other "A" train work was scheduled. No other "A" train work had been scheduled 3. An assessment of ongoing work was conducted to determine if any other cross l train work had occurred. No other cros's-train work had occurre . A " Stand-down" meeting with all craft personnel from the maintenance organization was held to re-empha size s communications, self-checking, questioning attitudes, attention to detail and the prohibition of opposite i

train work.

i 5. Walkdowns weru conducted for the "A" train auxiliary feedwater system, emergency diesel generator system, and the essential service water system by operations pernonnel to verify that no other work had been conducte The "A" train was found to be satisfactory with no other work being performed on it during the period in questio . _ . . . _ _

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, Attachmant to WM 96-0120 Paga 4 of 9-Full compliance has been achieved by implementation of the immediate i corrective actions identified. All long term corrective actions to prevent I recurrence will be ccmpleted by December 1, 199 .

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Violation 50-482/9614-02: Failure to correctly utilize locking hasp .

" Technical Specification 6.8.1.a. states, in part, that written procedures i l shall be established and implemented covering the applicable procedures l recommended in Appendix A of Regulatory Guide 1.33, Revision Regulatory Guide 1.33, Appendix A, Section requires procedures for equipment control (locking and tagging). ,

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I Administrative Procedure AP 21E-001, " Clearance Orders," Revision 3, Step 5.1.5, requires the 480 volt holded case motvr control center breakers to be l

I physically impaired by a sect. red lock hasp when used as an isolation device l for a clearance order prior to the acceptance of the clearanc l Contrary to the above, on August 2, 1996, the electricians failed to install a secured lock hasp to 480 volt molded case Motor Control Center Breaker l NG04DDF3 prior to maintenance technicians accepting the clearanc This is a Severity Level IV violation (Supplement I) (482/9614-02)."

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Admission of violations Wolf Creek Nuclear Operating Corporation (WCNOC) ackncwledges and agrees that a violation of Technical Specification 6.8.1.a, Replatory Guide 1.33, and Administrative Procedure (AP) 21E-001 occurred on August 2, 1996, when the electricians failed to utilize the required locking hasps . This event was discovered by WCNOC operation's personnel during normal building watch tours, i l

Reason for Violation:

Root Cause The root cause of this violation is cognitive personnel error, in that, the responsible electrical maintenance personnel failed to demonstrate and use adequate attention to detail /self checking techniques during the breaker verification process for clearance order 96-1157K Contributing Factor Form APF 21E-001-01, " Clearance Order," did not contain a locking hasp instellation signoff block that would remind the indisidual performing the verification that the hasp must be hung prior to accepting and signing the clearance order.

l Corrective Stoos Taken and Results Achieved l

l Immediately upon discovery of the missing locking hasp the shift supervisor I

and supervising operator were notifie The shift supervisor contacted electrical maintenance to re-verify breaker NG04DDF3 was de-energized and ordered a locking hasp be immediately installed on the breake . . . . . . . . - ..... -.-. - - ~- . - - - - - - . . . . . . . - . . ~ . . ~ . - . . . . . ~ . .. . -~

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. Attachment to WM 96-0120

. Page 6 of 9 Performance improvement request 96-1942 was initiated to document the concern and its root cause and the appropriate corrective action The appropriate disciplinary actions were implemented for the individuals who ,

failed'to install and verify installation of the locking has '

A meeting was held by the Chief Operating Officer (COO), with the Electrical Maintenance Superintendent, the responsible individual and the responsible individual's superviso This meeting was held to reinforce the Coo's position on clearance order error ,

Form APF 21E-001-01 was revised, by On The Spot Change 96-079 This change -

added a signoff block for the installation of the locking hasp.

i-l Corrective Stens That Will Be Taken And The Date When Full Comoliance Will Be ( Achievad:  ;

l-l The above corrective actions have'been reviewed and determined to be adequate j to prevent recurrence of this violatio Full compliance with the above noted requirements has been obtained- and all corrective actions to prevent recurrence have been completed.

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. Attachment to M4 96-0120 -

, Page 7 of 9 Violation 50-482/9614-03: Failure to follow established corrective action procedure " Criterion V of Appendix B to 10 CFR 50 requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, and drawings appropriate to . the circumstances and shall be accomplished in accordance with these instructions, procedures, and drawing Administrative Procedure AP 28A-001, " Performance Improvement Request,"

Revision 5, Step 5.1.3, requires personnel to immediately notify the duty shift supervisor / central work authority if a problem has the potential to affect plant operabilit Contrary to the above, on August 21, 1996, the shift supervisor was not informed after a maintenance engineer discovered that a safety-related switchgear breaker cubicle door to Breaker NB0114 opened when it was pushed by hand, bringing into question the corrective actions taken to address failed door latches repaired earlier in August 199 This is a Severity Level IV violation (Supplement I) (482/9614-03)."

Admission of Violation:

. Wolf Creek Nuclear Operating Corporation (WCNOC) acknowledges and agrees that a violation of Criterion V of Appendix B to 10 CFR 50 and AP 28A-001 occurred on August 21, 1996, when the maintenance engineer discovered a latch for a safety-related breaker cubical failed to correctly restrain the cubical door and he did not immediately notify the appropriate WCNOC personne Reason for Violation:

Root Cause:

The root cause of this violation is cognitive personnel error, in that, the responsible electrical maintenance personnel failed to comply with the requirements as established in Procedure AP 28A-001, " Performance Improvement Request."

Contributing Facto-

-The failure on the part of management to enforce the fundamental company requirements, in such a manner as to ensure employee knowledge / understanding of programmatic requirements and promote modification of employee behavio Corrective stens Taken hnd Results Achieved:

Corrective Actions - For Latch Related Concerns:

On August 22, 1996, the control room was notified of the condition observed on August 21, 199 On August 22, 1996, the failed latch was repaire ;

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, Attachment to WM 96-0120

. Page 8 of 9 l Action Requests 16912 and 16913 were initiated to place all 4160 volt safety-

related switchgear doors in conformance with manufacture's design requirement Additionally, the crimp nuts were adjusted on all doors as neede Work packages 114777 and 114678, and MSR 960165 were implemente These packages reworked the cubicle door latches and replaced parts as needed, returning the doors to manufacture's design requirement Procedure MPE E009Q-01, "13.8kv and 4.16kv Switchgear Inspection and Test,"

was revised, on September 26, 199 This revision added a requirement to ensure door latch mechanisms will be inspected for proper function, during the routinely scheduled preventative maintenance activitie Corrective Actions - For Failure To Notify Control Room:

The activities associated with this event were discussed in a meeting with maintenance planner This discussion included the need to prevent becoming

"over" familiar with equipment, the need to notify the control room prior to and upon completion of any inspection, and to inform the control room of any unusual condition or change to plant equipment which may have been noted during the inspectio The Plant Manager, on September 6, 1996, issued letter WO 96-126 to all site personnel. This letter was also included in the site weekly news-letter (called CURRENTS). This letter reiterated, to all site personnel, the importance/ requirement to notify the control room when any change of plant equipment is identifie Training was held with all maintenance personnel to reiterate the management expectations initially conveyed by letter MD 96-0031. This training stressed the importance of notifying the control room when doing work on safety-related equipment, to immediately notify the control room when a concern is safety-related equipment is identified, and/or to notify the control room when performing troubleshooting activities on safety-related equipment as proceduralized in AP 16 C-00 Further, this training reiterated the importance of notifying the control room when all work activities are complete The planner involved in this event received disciplinary actio To correct this and provide a basis for current and future behavioral modification needs, letter WM 96-0107, dated September 25, 1996, by the President and Chief Executive Officer, regarding fundamental company requirement An example of these requirements, the relocation of a radiological barrier and posting by an unqualified individual, was provided in the lette Corrective disciplinary action was also shared to emphasized the importance of these fundamental requirement Administrative Policy, HR-160,

" Standards Of Conduct, Rules And Discipline," was recommended for review to

identify other personnel behaviors serious enough to warrant disciplinary actio This policy covers any conduct of WCNOC personnel and contractors that might have an adverse affect on the operation of this facility and its employees, or its relationship with the publi Communication between the

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managers, supervisors, and employees was encouraged to ensure questions were

, answere To further convey the message contained in this letter a copy of l the letter was published in CURRENTS.

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Attachment to WM 96-0120 Page 9 of 9

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Corrective Stoos That Will Be Taken And The Date When Full Compliance Will Be l Achieved:

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Full compliance with the above noted requirements has been obtained and all corrective actions to prevent recurrence have been completed.

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