IR 05000482/1997008

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-482/97-08

ML20148M586
Person / Time
Site:	Wolf Creek
Issue date:	06/11/1997
From:	Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Maynard O WOLF CREEK NUCLEAR OPERATING CORP.
References
50-482-97-08, 50-482-97-8, NUDOCS 9706250047
Download: ML20148M586 (3)

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UNITED STATES g- %g?g NUCLEAR REGULATORY COMMISRION E REGloN iv

• [ 611 RYAN PLAZA oRIVE, SUITE 400 - ,

4 AR LINGToN, T E XAS 760118064 9+...+[ -i

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l June 11,1997 l Otto L. Maynard, President and

Chief Executive Officer Wolf Creek Nuclear Operating Corporation  ;

P.O. Box 411 l Burlington, Kansas 66839 SUBJECT: NRC INSPECTION REPORT 50-482/97-08

Dear Mr. Maynar ,

Thank you for your letter of May 23,1997, in response to our letter and Notice of l l

Violation dated April 25,1997. We have reviewed your reply and find it responsive to the ;

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

Sincerely, Ken E. Brockman for

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Thomas P. Gwynn, Director

? Division of Reactor Projects  ;

i l Docket No.: 50-482 l

License No.: NPF-42 cc w/ enclosure:

Chief Operating Officer k Wolf Creek Nuclear Operating Corp.

l j P.O. Box 411 \ '

l Burlington, Kansas 66839 j

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Jay Silberg, Es !

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Shaw, Pittman, Potts & Trowbridge 2300 N Street, NW Washington, D.C. 20037 ]

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9706250047 970611 PDR ADOCK 05000482 G PDR a

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! Wolf Creek Nuclear -2-Operating Corporation l

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Supervisor Licensing

! Wolf Creek Nuclear Operating Corp.

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Burlington, Kansas 66839  :

Chief Engineer I

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Utilities Division Kansas Corporation Commission )

1500 SW Arrowhead R l Topeka, Kansas 66604-4027 i Office of the Governor State of Kansas Topeka, Kansas 66612 Attorney General Judicial Center 301 S.W.10th 2nd Floor Topeka, Kansas 66Gi2-1597 County Clerk Coffey County Courthouse Burlington, Kansas 66839-1798 Vick L. Cooper, Chief Radiation Control Program Kansas Department of Health and Environment Bureau of Air and Radiation Forbes Field Building 283 Topeka, Kansas 66620 Mr. Frank Moussa Division of Emergency Preparedness 2800 SW Topeka Blvd Topeka, Kansas 66611-1287 i

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-3- JUN I i 1997 Wolf Creek Nuclear Operating Corporation I bcH Io DCD'(IE01)*

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Regional Administrator Resident inspector SRI (Callaway, RIV)

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

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DOCUMENT NAME: R:\_WC\WC708AK.JFR "E" = Copy with enclosures "N" = No copy To receive copy of document. Indicate in box: "C" = Copy without enclosures RIV:PE:DRP/B l C:DRP/B D:DRP ,g l

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i Wf4LF CREEK NUCLEAR OPERATING CORPORATION Otto L. Maynard President and Chief Executive Officer May 23, 1997 WM 97-0064 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station F1-137 Washington, D. Reference: Letter dated April 25, 1997, from Thomas P. Gwynn, NRC, to Otto L. Maynaro, WCNOC

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s Subject: Docket No. 50-482: Response to Notice ot

Violations 50-482/9708-01 (EA 9'<-108), -02, -03, and -05 l

J j Gentlemen:

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

j response to Notice of Violations 50-482/9708-01, -02, -03, and -05.

j Violations 9708-01 and -02 involve failure to follow procedure Violation 9708-03 discusses a violation of Technical Specifications, and violation 9708-05 discusses failure to update the Updated Safety Analysis Report with the latest mi.erial develope WCNOC's response to these violations is provided in the attachmen If you

have any questions regarding this response, please contact me at (316) 364-

8831, extension 4000, or Mr. Richard D. Flannigan at extension 450 Very truly yours,

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JYA Otto L. Maynard OLM/jad Attachment cc: D. Johnson (NRC), w/a E. W. Merschoff (NRC), w/a J. F. Ringwald (NRC), w/a J. C. Stone (NRC), w/a i li ff t h P.O. Box 411 Burkngton, KS 66839 c Phone- (316) 364 8831

_.- f An Equal Opportunity Employer M F HC VET

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Attachment to WM 97-0064 Page 1 of 8

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Reply to Notice of Violations 50-482/9708-01, -02, -03, and -05 violation 50-482/9708-01 (EA 97-108):

" Technical Specification 6. states, in part, that procedures be established, implemented, and maintained covering the activities reference in Regulatory Guide 1.33, Revision 2, February 197 Appendix A Section 7 (a), requires procedures for the liquid radioacti.ve waste syste Systems Procedure SYS HB-135, " Liquid Radwaste Demin Floor Drain and Waste Holdup Tanks Processing," Revision 0, Precaution Step 4.12, states, "Do not exceed Water Monitor Tanks A or B (THB07A or THB07B) level of 90 percent to prevent an inadvertent overflow."

Alarm Response Prccedure ALR 702, " Liquid Process Control Panel HB-115,"

Revision 2, Attachment S, "702-08A, Waste Monitor Tank 1 HI-LO Level,"

requires that liquid transfers to Waste Monitor Tank 1 (WMT B) be stopped if the level is greater than 90 percen Contrary to the above, on February 27, 1996, radwaste operators did not follow the above procedural guidance and disregarded the panel alarm when they were instructed by their supervisor to exceed the precautionary 90 percent fill limit and fill the waste monitor tank to the 95- percent leve )

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This is a Severity Level IV violation (Supplement IV) (482/9708-01) (EA j

- 97-108). t Admission of Violation:

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Wolf Creek acknowledges that a violation of Technical Specification 6. ,

occurred when procedures were not followe j Reason for Violation:

On February 27, 1996, instructions to fill the Waste Monitor Tank (WMT) to greater than 90 percent capacity were given by the Radwaste Supervisor to the day shift radwaste operator and then transferred to the night shift radwaste l operato The supervisor was focused on maximizing storage capability by i

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conserving radwaste hold-up volume due to the inability to discharge effluents at the tim Procedure SYS HB-135, " Liquid Radwaste Demin Floor Drain a id Waste j Holdup Tanks Processing," was open and in use during the processing evolution '

and contained a precaution step to limit the level to 90 percent ful This precaution was not followed by the operator The operators did not use alarm response procedure, ALR 702, " Liquid Process l Control Panel HB-115," because they knew the Radwaste Supervisor's instructions ,

would cause an alarm and they were expecting i They believed that they did i not need the ALR to troubleshoot as this was an expected alar The operators did not question that the Radwaste Supervisor's direction was contrary to procedure The Radwaste Supervisor failed to follow administrative requirements for use and adherence to procedure Additionally, the Radwaste Supervisor did not make changes to procedures when required and continued to give instructions that were contrary to procedures.

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l Attachment to WM 97-0064 Page 2 of 8

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Corrective Stops Taken and Results Achieved:

The Radwaste Supervisor received appropriate disciplinary actions in accordance with WCNOC' polic To increase oversight and provide full-time supervision, the Radwaste and Water Treatment operators have been integrated into the Operating Crew On January 14, 1997, the radwaste and water treatment operators were coached and counseled about:

o the importance of maintaining a questioning attitude and their right to :

call for a " time out" e

not placing themselves in a posture of blind compliance to procedures or supervisory authority

• reviewing procedures when making decisions to ensure that decisions are compatible with requirement WCNOC Senior Management held a site-wide stand-down meeting on February 28, l 1997, to ensure that all WCNOC personnel understand their expectations for i literal compliance with procedure Date When Full Compliance Will Be Achieved:

All of the above listed corrective actions are complete and full compliance has been achieve ,

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Attachment to WM 97-0064 Page 3 of 8

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Violation 50-482/9708-03:

" With one required diesel generator inoperable, Technical Specification 3.8.1.1, Action b, requires the performance of surveillance testing to demonstrate the operability of offsite alternating current sources by performing Technical Specification Surveillance 4.8.1.1 within 1 hou Contrary to the above, on May 16, 1996, maintenance personnel inadvertently rendered Emergency Diesel Generator A inoperable, and the licensee f ailed to perform Technical Specification Surveillance 4.8.1. within 1 hou This is a Severity Level IV violation (Supplement 1)(482/9708-03)."

Admission of ViolatioE

' Wolf Creek acknowlOdges that a violation of Technical Specification (TS) ,

occurred when Technical Specification Surveillance 4.8.1.1.1 was not completed

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within one hour after one diesel generator was rendered inoperable. This TS

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violation was reported in Licensee Event Report (LER) 96-008-00. During the closure of LER 96-008-00 the Senior Resident Inspector determined that the stated corrective actions would not orevent recurrence and were inadequate and the LER closed with a cited violatio Reason for Violation:

The excerpt below from LER 96-008-00 is provided for background information.

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On May 16, 1996, troubleshooting Work Package (WP) 112603 was initiated on the computer point for the "A" Train Essential Service Water (ESW) room temperature indicator. The Control Room reviewed and approved the work package to be worke g' At approximately 1035 on May 16, 1996, as part of WP 112603, surveillance M4 procedure STN IC-465, " Channel Calibration ESW Pump Room Temperature Control Loop," was commenced on the "A" Train ESW supply fan; this procedure lifted lead RP053AC for the fan, kaeping the fan from starting on any signals, thus causing the ESW train "A" to oe inoperable. It was not recognized that this procedure

affected the operability of the ESW fan. Technical Specification 3.7.4 should have been entered; additionally, Technical Specification surveillance 3.8. should have been performed when the ESW train was inoperable for greater than one hou The Diesel Generator Technical Specification 3.8. for the "A" Train should have been entere I

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On May 17, 1996, the troubleshooting activities on the computer point were continued, with the lifting of lead RP053A This again made the ESW "A" supply

', fan inoperable. Coinciding with these events, an oil line broke on the Control Building Air Conditioner unit, SGKC48, which caused the "3" train Control Room

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Emergency Ventilation System (CREVS) to be inoperable. Therefore, both "A" and

"B" trains of CREVS were inoperable for ten to fifteen minutes, contrary to Technical Specification 3. 7. 6, and Technical Specification 3.0.3 should have been entere j The LER corrective actions were stat'i as follows:

Immediate:

1. STN IC-465 was revised to include cautions that during the performance of this procedure, the supply fan will be inoperabl . The importance of clear communications with the shift aupervisor, and the importance of understanding the effects of the work they perform on equipment j operability have been emphasized during I&C group meeting I

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4 Attachment to WM 97-0064 4 Page 4 of 8 ,

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I l Long-term:  !

1. All I&C STNs will be reviewed for potential impact to equipment operability, prior to any use. This review will be completed entirely by September 20,

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1996.

l l 2. A checklist of questions and considerations will be generated that the shift  !

supervisor and Work Control Center should ask when a troubleshooting request, *

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' communication takes place, and to address operability question This checklist will be utilized until such time as WCNOC determines that this

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interim measure is no longer of valu September 16, 199 The checklist will be completed by

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Inspection Report 97-08 documented three deficiencies with the above corrective .

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1) The checklist to ensure complete communication between the shift supervisor i or the work control center and the maintenance personnel did not directly  ;

[ question whether the proposed work affected the operability of safety related '

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As stated in LLR 96-008-00, the checklist questions should be asked when a

troubleshooting request or a request to perform a procedure is received, to j ensure that complete communications take place, and to address operability

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Supervisor (SS) or Supervising Operator (SO) to ask Maintenance personne. if  ;

l they considered thc work to effect operability. At WCNOC, operability can only  ;

be determined by the S The checklist does state under the preparation section  !

to " Review equipment status and system operability including any pre-planning i checklists that apply." The checklist questions were intentionally written to I be open-ended in order to prompt further thought, discussion and investigation, j 2) LER 96-008-00 stated that the checklist would be utilized until such time as l WCNOC determined that the interim measure was no longer of value. On March  !

31, 1997, the inspector.noted that Work Control Center personnel had stopped using the checklist, although the Manager Operations believed that the checklist was still being use The checklists were made into laminated cards and distributed to Operations

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personnel, however, no clear communication or direction concerning their usage  !

was provide Interviews with Operations personnel determined that .most [

personnel found the cards useful, however, it was not understood to be a i regulatory commitment, and was not consistently use An evaluation to ,

determine if the checklist was of value was not performed necause it was not  !

desired to discontinue its us Inconsistent checklist implementation was  :

caused by inadequate communication among the groups in'olved and lack of j management expectations regarding usc of the car i 3) The corrective actions associated with reviewing procedures for inadequacy  !

and the shop meeting discussions were not performed for the electrical or mechanical maintenance group )

i Non-Instrumentation and Controls (I&C) maintenance procedures and personnel were not included because all Electrical and Mechanical Maintenance surveillance .

procedures were thought to be performed after issuance of a clearance order I isolating the equipment being teste Further research concluded that there are l some Electrical Maintenance procedures that are performed on on-line or l energized equipmen The reason for this oversight was that the review of I procedures .was inadequate and did not uncover all applicable procedures and l organization I

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Attachment to WM 97-0064

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Corrective Steps to Be Taken to Prevent Recurrence:

Integrated Plant Scheduling and Operations Management will proceduralize their expectations regarding the usage of the checklist card by June 27, 199 ,

In order to broaden the scope of the corrective .m : ; ions from LER 96-008-00, a i review of all Maintenance surveillence procedures will be performed to ensure technical specifications are properly reterenced. This review will be completed i by June 27, 1997 '

Data when Full Compliance Will Be Achieved:

All Corrective Actions will be completed by June 27, 1997 l

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! Violation 50-482/9708-02: 'j

" Criterion V of Appendix B to 10 CER Part 50 requires, in part, that activities affecting quality shall be prescribed by documented

, instructions, procedures, and drawings appropriate to the circumstances,

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and shall be accomplished in accordance with these instructions, procedures, or drawing Administrative Procedure AP 22C-003, " Operational Risk Assessment l Program," Revision 1, requires the performance of- operations risk assessments for equipment removed from service for maintenance activitie Step 6,1. 3 of Procedure AP 22C-003,' requires any activities added to or l slipped from the current weekly Revision 0 schedule be assessed and documented on the original operational risk assessmen Contrary to the above, on April 2 and 3, 1997, the licensee added activities which had been slipped from the weekly Revision 0 schedule without documenting an assessment of risk on the operational risk assessmen This is a Severity Level IV violation (Supplement 1)(482/9708-02)."

Admission of Violation:

Wolf Creek acknowledges that a violation of Criterion V of Appendix B occurred when personnel failed to update the operational risk assessment as required by procedur Reason for Violation:

Procedure AP 22C-003, " Operational Risk Assessment Program," step 6.1.3 requires any activities added to or slipped from the current weekly Revision 0 schedule be assessed and documented on the original operational risk assessmen On' March 31, 1997, an annotation on_the operational risk assessment was made to indicate that the "A" train Component Cooling Water (CCW) was inoperable and that the planned work on the "B" train CCW would be put on hold until the "A" train was operabl On April 2 and 3, 1997, after the "A" train CCW was restored, WCNOC performed "B" train CCW activitie When these activities were performed the operational risk assessment was not update The operatic,nal risk assessment was not updated because personnel interpreted AP _l 22C-003 to apply to activities removed from that week's operational risk I assessment, and not to activities placed on hol The definition of " slipped" from the schedule was unclea The reason for this violation is that the inst ructi ons in AP 22C-003 were ambiguous and the procedure details were less -l than adequat ;

Ccr: setive Steps That Will Be Taken to Prevent Recurrence:

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Procedure AP 22C-003 will be revised by May 27, 1997, to include detailed i instructions for addressing slippage within the current. wee Step 6.1.3 will

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be revised to clearly specify when and how adds, slips, and changes will be l l documente Required reading will be routed to Shift Supervisors and Supervising Operators, Work Week Managers, and the Central Work Authority by June 30, 1997, to inform them of the procedure change Date When Full Compliance Will Be Achieved:

A11' corrective actions will be completed by June 30, 199 _ - . -

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Attachment to WM 97-0064 Page 7 of 8,

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Violation 50-482/9708-05:

" CFR50.71(e) requires that each person licensed to operate a nuclear power plant reactor update periodically the Final Safety Analysis Report to assure that the information included in the Final Safety Analysis Report contains the latest material develope The Updated Safety Analysis Report is to include the effect of all changes made in the facilit Contrary to the above, as of September 23, 1996, the licensee had not updated the Updated Safety Analysis Report Figure 9.3-8-03, " Piping and Instrumentation Diagram Chemical and Volume Control System," to reflect actual plant practices regarding Valve BG 8384A or Updated Safety Analysis Report Figure 6.2.4-1, " Containment Penetrations," to reflect the following changes:

• On Sheet 17, Valve EJ V16'i was identified as a containment isolation valve, but was never installed in the plan Valve EJ V124 was not shown in the same location as actually installed. Valves EJ V177 and-V178 are shown reversed from their actual orientation in the plan * On Sheet 23, Valve EJ V166 was not shown, but is installed in the plant

• On Sheet 36, Valves EM -V164, -V166, and -V168 were not shown in the proper orientatio * On Sheet 38, Valve EJ -V116 was not shown in the correct location

• On Sheet 4 2b, Valve SJ -V114 was not identified on the diagram as a containment isolation valv * On Sheet 43, Valve EM HV200 was identified, but was never installed in the plan * On Sheet 53, Valves EG V397 and -V126 were shown in the wrong locatio * On Sheet 54, Valves EG V371, -V377, and -V369 were shown in the wrong locatio * On Sheet 56, Valve EJ V152 was identified, but was never installed in I the plan * On Sheet 58, Valves EJ V171 and -V172 are shown reversed from the actual installation in the plan * On Sheet 64, Valve BB V1 is identified as BB V-05 l

• On Sheet 66, Valve EM V0038 is shown open but it is maintr.ined locked l and closed in the plan ;

h This is a Severity Level IV violation (Supplement I)(482/9708-05). j Admission of Violation:

WCNOC acknowledges that a violation of 10 CFR50.71(e) occurred when the Updated Safety Analysis Report was not ~aintained with the latest material develope Reason for Violation:

The reason for the inaccuracles in the sheets associated with Updated Safety Analysis Report (USAR) F:gure 6.2.4-1 and Figure 9.3-8-03 is personnel erro Updated Safety Analysis Report (USAR) Figure 6.2.4-1 contains 74 sheets, with each sheet showing a cor.tainment penetration figur Except for one example, the errors in Figure 6. 2. 4-1 were made prior to Wolf Creek's operating license in 198 The exception was made three years ago when the originator of a Plant l Modification Request (PMR) revised the affected P&ID USAR Figure but apparently overlooked USAR Figure 6.2.4- All the errors involved design changes that resulted in the revision of the associated USAR P&ID figure, however, the USAR containment penetration Figure 6.2.4-1 was overlooke The purpose of USAR Figure 6.2.4-1 is to illustrate WCNOC's provisions for l meeting 10CFR50 Appendix A, design criterion 54, 55, 56 & 57 including containment isolation configurations that have been demonstrated acceptable

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• l Attachment to WM 97-0064 Page 8 of 8

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! based on "other defined bases". Performance Improvement Request (PIR) 96-2216 l that documented the inaccuracies, found no errors that would invalidate or cause

) questions as to whether WCNOC meets these criteria or the criteria / guidance

! contained in Regulatory Guide 1.141 and ANSI N 271-76.

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The inaccurate wording in Note 13 on Figure 9.3-8-03 regarding BG8384A was also made prior to the operating licens The operating procedure correctly implemented the intent of the note which is to ensure that at least one charging pump is aligned to support the Emergency Core Cooling System, however the error in the Note was not discovere i Corrective Steps Taken and Result Achieved:

i As part or PIR 96-2216, all 74 sheets of USAR Figure 6.2.4-1 were reviewed in detail and all discrepancies corrected inside the containment isolation envelop PIR 97-0711 was written to document and evaluate the discrepancy with drawing M-12BG03 Note 1 This evaluation determined that it is acceptable to have either valve BG8483A or valve BG8483C locked closed depending on which charging pump is aligned to support ECCS and that Note 13 needed to be clarifie WPT 118280-09 was initiated to revise M-12BG03 Note 1 l I

Corrective Steps to Be Taken to Prevent Recurrence:

A USAR change request will be initiated to revise Figure 9.3-8-03 (M-12BG03)

Note 13 by August 1, 199 A review of all P&ID's notes for locked valve information for accuracy and appropriateness will be performed by August 1, 1997 l

Procedure AP 21G-001, " Control of Locked Component Status," will be revised by {

September 1, 1997, to include a USAR reference when the components are described 1 as being locked by the USA Date When Full Compliance Will Be Achieved:

All corrective actions will be completed by September 1, 199 l l

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