IR 05000482/1997009
| ML20149G360 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 07/21/1997 |
| From: | Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Maynard O WOLF CREEK NUCLEAR OPERATING CORP. |
| References | |
| 50-482-97-09, 50-482-97-9, NUDOCS 9707230169 | |
| Download: ML20149G360 (4) | |
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SUBJECT:
NRC INSPECTION REPORT 50-482/97-09 i
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Dear Mr. Maynard:
Thank you for your letter of July 7,1997, in response to our letter and Notice of Violation dated June 6,1997. We have reviewed your reply and find it responsive to the concerns I
raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and I
will be maintained.
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With regard to your comment regarding Violation 9709-01, our characterization of the amount of material removed from containment as significant in NRC Inspection i
Report 50-482/97-09 was not intended to convey that the material would have prevented the emergency core cooling pumps from performing their design function, but that the material removed was a greater amount than would have been e'xpected to be present in containment for such an extended period given that multiple containment entries and inspections had been performed. Our primary concern is the lack of thoroughness
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demonstrated in performing the required containment inspections.
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Sincerely, l
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- Thomas P. Gwy n, rect r Division of Rea tor roje ts Docket No.: 50-482 License No.: NPF-42 cc w/ enclosure:
Chief Operating Officer Wolf Creek Nuclear Operating Corp.
P.O. Box 411 i
Burlington, Kansas 66839
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9707230169 970721 PDR ADOCK 05000482 G
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Wolf Creek Nuclear-2-Operating Corporation Jay Silberg, Esq.
Shaw, Pittman, Potts & Trowbridge
2300 N Street, NW
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Washington, D.C. 20037 Supervisor Licensing Wolf Creek Nuclear Operating Corp.
P.O. Box 411 Burlington, Kansas 66839 l
Chief Engineer Utilities Division Kansas Corporation Commission j
1500 SW Arrowhead Rd.
Topeka, Kansas 66604-4027 Office of the Governor l
State of Kansas Topeka, Kansas 66612 Attorney General l
Judicial Center 301 S.W.10th 2nd Floor
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' Topeka, Kansas 66612-1597 County Clerk Coffey County Courthouse Burlington, Kansas 66839-1798 Vick L. Cooper, Chief Radiation Control Program Kansas Department of Health
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and Environment i
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 l
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Wolf Creek Nuclear-3 JUL 2 l 1997 l
Operating Corporation i
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l Regiona! Administrator Resident inspector DRP Director SRI (Callaway, RIV)
Branch Chief (DRP/B)
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Project Engineer (DRP/B)
MIS System
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Wolf Creek Nuclear-3-JUL 21 1997
Operating Corporation WWDCD ME5}
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Regional Administrator Resident inspector DRP Director SRI (Callaway, RIV)
Branch Chief (DRP/B)
DRS-PSB.
Project Engineer (DRP/B)
MIS System Branch Chief (DRP/TSS)
RIV File l
DOCUMENT NAME: R:\\_WC\\WC709AK.JFR To receive copy of document, Indicate in box: "C" = Copy without enclosures
"E" = Copy with enclosures "N" = No copy (
RIV:PE:DRP/B[/f C:DRP/B 6)
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OFFIClAL RECORD COPY l
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l WedLF CREEK NUCLEAR OPERATING CORPORATION 7 - @ @ R {! W @."j p Otto h
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President and Chief Executive Officer l
l July 7, 1997
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REGION IV
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U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Mail Station F1-137 Washington, D. C.
20555 Reference:
Letter dated June 6, 1997, from T.
P. Gwynn, NBC, to O.
L. Maynard, WCNOC Notice of Violations Subject:
Docket No. 50-482:
Response u
50-482/9709-01,
-03,
-04,
-06 and -07 Gentlemen:
This letter transmits Wolf Creek Nuclear Operating Corporation's (WCNOC)
response to Notice of Violations 50-482/9709-01,
-03,
-04,
-06 and-07.
l Violation 9709-01 cites a failure to identify and remove debris from containment following fire barrier replacement.
Violation 9709-03 addresses a shift supervisor's failure to complete a
form for documenting debris discovered in the containment building.
Violation 9709-04 cites that corrective action of the identification of an inoperable containment isolation valve was inadequate.
Violation 9709-06 addresses the result of a
miscommunication between engineering and operations personnel regarding cold overpressure mitigation requirements for the normal charging pump.
Violation 9709-07 cites a failure to comply with security escort requirements.
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Violation 9709-01 is characterized as an event which could have potentially l
restricted the emergency core cooling system pump suctions. The report stated
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that a "significant amount of trash and debris" (approximately 180 square inches) was discor3 red in the containment; this represents a potential blockage of 1.9 percent of the inner screen.
However, the report continues by stating:
" Design basis allows for up to 50 percent blockage of both screens without effect on the net positive suction head of the pumps."
WCNOC contends that a characterization of "significant" is inappropriate for this small amount of debris.
WCNOC acknowledges that procedure STS EJ-001, " Containment Ir.s pe ct ion, " was violated, but that there is no safety significance to this finding.
WCNOC's response to these violations is provided in the attachment.
If you
have any questions regarding this response, please contact me at (316) 364-8831, extension 4000, or Mr. Richard D.
Flannigan at extension 4500.
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Ver truly s,
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cc:
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Johnson (NRC), w/a j
E. W.
Merschoff (NRC), w/a C
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f RO. Box 411 ' Burhngton. KS 66839 / Phone: (316) 364 8831 An Equal Opportunity Empeyer M F HCcVET I
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Attachment to WM 97-0081 Page 1 of 7
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Reply to Notice of Violations 50-482/9709-01,
-03,
-04,
-06, and -07 Violation 50-482/9709-01:
"A.
Technical Specification 6.8.1.a states, in part, that written procedures shall be established and implemented covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2.
Regulatory Guide 1.33, Appendix A,
Section 8.b, requires procedures for conducting surveillance tests listed in the Technical Specifications.
Following each Containment entry, Technical Specification 4.5.2, Action c.2, requires a visual inspection of the affecteo areas in the containment to verify that no loose debris is present which could be transported to the containment sumps and cause restriction of the' pumps' suctions during a loss-of-coolant condition.
Procedure STS EJ-001,
" Containment Inspection," Revision 9,
Step 8.1.1, requires that the licensee verif y by a visual inspection of all accessible areas that no loose debris is present in the containment.
Contrary to the above, between September 20, 1996, and April 30, 1997, the l
licensee failed to identify and remove debris from the containment.
l This is a Severity Level IV violation (Supplement I) (482/9709-01)."
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Admission _of Violation:
Wolf Creek acknowledges that a violation of Technical Specification 6.8.1 l
i occurred when procedures were not followed.
i Reason for Violation:
On March 20, 1997, during a routine containment entry, an NRC inspector identified concerns with the presence of debris within the Wolf Creek Generating Station 'WCGS) containment.
i This material was left in the containment due to personnel inattention to detail.
Personnel demonstrated inadequate work practices, specifically, the test performers did not conduct adequate containment walkdowns for STS EJ-001,
" Containment Inspection," Revision 10.
Interviews revealed that Health Physics personnel do not have a
clear understanding of Management' s
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expectations on implementing STS EJ-001.
Several of the Health Physics personnel did not demonstrate a clear understanding of where, when, and how to inspect an areat nor what constitutes correct securing of a temporary piece of equipment.
Training on the performance of STS EJ-001 had not previously been provided to Health Physics personnel, i
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Attachment to WM 97-0081 Pege 2 of 7
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I Corrective Steps to Be Taken to Prevent Recurrence:
Management meetings will be held with the individuals who performed STS EJ-001.
The meetings will focus on this issue, the acceptance criteria specified in the procedure, and a restatement of management's expectations on procedural i
adherence, and will be completed by. August 29, 1997.
Training will be
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provided to Health Physics personnel by August 29, 1997.
I Date When Full Compliance Will Be Achieved:
The requirements of STS EJ-001 have been satisfied at this time, and full compliance has been achieved.
Additional corrective actions will be completed by August 29, 1997 i
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Attachment to WM 97-0081
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Violation 50-492/9709-03:
'"B.
Criterion V of Appendix B to 10 CFR Part 50 requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures,'and drawings appropriate to the circumstances t
and shall be accomplished in accordance with these instructions, procedures, or drawings.
Procedure AP 26C-004 requires operability determinations be documented in a log entry that includes a justification for the operability determination and completion of Form APF 26C-004-001.
' Contrary to the above, on April 30, 1997, the shift supervisor documented an operability determination for debris and other material found in containment without providing a justification for the operability determination and
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without completing Form APF 26C-004-001.
This is a Severity Level IV violation (Supplement I) (50-482/9709-03)."
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Admission of Violation:
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WCNOC acknowledges.that on April 30, 1997, a violation of procedure AP 26C-
004, " Technical Specification Operability," Revision 0,
occurred when the shift supervisor did not complete form APF 26C-004-01,
" Technical j
Specification Screening Checklist," Revision 0,
as a supplement to the j
operability decision in the shift supervisor log.
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Reason for Violation:
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On April 30, 1997, debris was found during a routine containment entry.
The discovery of the debris and the concerns expressed by NRC inspectors were
conveyed to the shift supervisor.
The shift supervisor considered the l
information,.and concluded in the shift supervisor log that no Technical l
l Specification ' operability issue existed.as a result of the small amcunt of
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debris.
Since the shift supervisor did not consider the small amount of l
debris to be an operability question, he did not consider that entry into AP 26C-004 was required, and therefore, the shift supervisor did not complete form APF 26C-004-01,
" Technical Specification Screening Checklist," as a supplement to the operability call in-the shift supervisor log.
The shift supervisor's operability call was correct; however, he did not document operability in accordance with AP 26C-004.
Corrective Steps to Be Taken to Prevent Recurrence:
Shift supervisors have been notified to apply AP 26C-004 to all operability decisions until the guidance on the use of this procedure is revised. AP 26C-
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004 will be revised to provide improved guidance on when Form APF 26C-004-01 must be used. This will be completed by August 15, 1997.
Date When Full Compliance Will Be Achieved:
Full compliance has been achieved.
' Additional corrective actions will be
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completed by August 15, 1997.
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Attachment to WM 97-0081
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Violation 50-482/9709-04:
"C.
Technical Specification 3.6.3 states, in part, that containment isolation valves shall be operable ano, 'with one or more containment-
l isolation valves inoperable, the licensee must restore the valve to ~
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operable status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, isolate.the penetration, or be -in hot 1.
standby within the next 6' hours and in cold shutdown within the
following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Contrary to the above, on March 29, 1996, the licensee entered Mode 4 with i
Containment Isolation Valve EF HVOO34 inoperable and operated in Mode _4 or higher until'the penetration was isolated on October 9, 1996 l
This is a Severity Level',IV violation (Supplement I) (50-482/9709-04)."
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. Admission of Violation:
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The -failure to comply with L Technical Specification 3.6.3 was originally
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identified and reported. by WCNOC in LER 96-010-00, letter ET 96-095, dated November _7, 1997; and LER 96-010-01, letter WO 97-0049, dated April 30, 1997.
Root cause and corrective actions were identified in these LERs; however, j
these LERs failed to address that a PIR had not been initiated.
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WCNOC acknowledges that a violation of Technical Specification 3.6.3 occurred
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when WCGS entered Mode 4 wita Containment Isolation Valve EFHV0034 inoperable.
Reason for Violation:
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Although.an Action Request was initiated documenting a functional failure of
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i EF HV0034, System Engineering did not recognize that a Performance Improvement
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. Request (PIR) should also have'been initiated in accordance with AP 28A-001, j
" Performance Improvement Request," Revision 7,
and AI 23M-001, Maintenance
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t-Rule SSC. Monitoring," Revision O.
Contributing to the reason for this l
violation is that personnel erroneously interpreted the corrective action program and concluded that the effectiveness follow-up on another.PIR could be used rather than generate-a new PIR.
Corrective Steps to Be Taken to Prevent Recurrence:
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9709-04.
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PIR 97-1484 was initiated in response to' Violation j.
PIRs 96-2528, 97-1484,-and-97-1995 address the programmatic needs to document-
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previous 1 dual. indication failures on EF HV0034.
'PIR 97-1484 will'be entered into required reading for System Engineering.
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addition, to further emphasize the importance of ensuring that PIRs are
' initiated appropriately,.each System Engineer Supervisor will discuss with their~ reports the lessons learned from this event.
Completion date for the
required reading and the supervisory discussions is July 25, 1997.
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~ Date When' Full Compliance Will Be Achieved:
Full compliance has been achieved.
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Attachment to WM 97-0081 Page 5 of 7
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Viclation 50-482/9709-06:
"D.
Technical Specification 6.8.1 a states, in part, that written procedures shall be established and implemented covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2.
Regulatory Guide 1.33, Appendix A,
Section 2j, requires general plant
operating procedures for hot standby to cold shutdown operations.
Contrary to the above, on February 11, 1997, licensee personnel failed to properly establish Procedure GEN 00-006 in that it permitted operation of the l
normal charging pump with reactor coolant system temperature as low as 325*F, I
when engineering guidance in Design Change Package 04590 required that the normal charging pump be stopped and placed in pull-to-lock when the plant
operated celow 368'F.
I This is a Severity Level IV Violation (Supplement I) (50-482/9709-06)."
Admission of Violation:
WCNOC acknowledges that a violation of Technical Specification 6.8.1 occurred when a conflict existed in operating conditions for the normal charging pump in procedure GEN 00-006 and Design Change Package 04590.
Reason for Violation:
WCNOC inappropriately revised procedure GEN 00-006,
" Hot Standby to Cold Shutdown," to allow operation of the normal charging pump below the low temperature overpressure protection limits, contrary to the engineering disposition for DCP 04590, Revision 3.
Design Change Package (DCP) 04590 was developed by WCNOC to replace positive displacement pump (PDP) with a centrifugal charging pump (titled the normal charging pump).
This concern was self identified and documented in PIR 97-0439.
All corrective actions had been completed, and the PIR was closed prior to this issue being considered an NRC violation.
Upon this concern being identified to Operations as an NRC unresolved concern, PIR 97-1249 was initiated and screened as significant to ensure a root cause analysis was performed.
The root cause of this violation is that responsible personnel were aware of the information in the DCP, but justified interpretations of the information rather than implementing the DCP as literally stated.
The interpretations were based on a knowledge of the previous operational limits for the PDP, and reviews of previous revisions of the General Operating Procedures.
Corrective Steps Taken and Results Achieved:
PIR 97-0439 was initiated.
Operations conducted a review of the concern and determined that adequate documentation was not available to support potential operation outside of the
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NCP requirements specified in DCP 04590.
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Based on the information cbtained in the above performed review, on February 14, 1997, Operations revised the following procedures to establish necessary operational guidance:
1) SYS BB-112 (OTSC 97-0088), 2) SYS BB-113 (OTSC 97-0087), 3) SYS BB-114 (OTSC 97-0086), SYS BG-120 (OTSC 97-0102), SYS BG-201 (OTSC 97-0085), SYS BG-213 (OTSC 97-0084), GEN 00-001 (DRR 97-0527), GEN 00-002 (OTSC 97-0090), GEN 00-006
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l (OTSC 97-0089), ALR 00-049B (DRR 97-0324), ALR 00-049D (DRR 97-0325),
ALR 00-050D (DRR 97-0326), and ALR 00-064B (DRR 97-0327).
PIR 97-0439 was placed in required reading for Operations Support personnel to alert them of a failure to adequately capture a design change, and to aid in
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ensuring future design changes are adequately identified and captured.
On April 25, 1997, PIR 97-1249 was initiated to facilitate a formal root cause analysis for this concern.
l Corrective Steps That Will Be Taken to Prevent Recurrence:
l Operations Management will meet with the Operations Support Group.
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meeting will discuss the errors made in capturing the programmatic changes required by DCP 04590, management's expectations, verbatim compliance, the use of cross disciplinary reviews, and the potential l
consequences of improperly implementing requested procedure changes.
This action will be completed by July 15, 1997 Date When Full Compliance Will Be Achieved:
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Full compliance has been achieved; additional corrective actions will be completed by August 31, 1997.
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Attachment to WM 97-0081 Page 7 of 7
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Violation 50-482/9709-07:
"E.
Technical Specification 6.8.1.c requires that written procedures be established, implemented, and maintained covering the implementation of
the security plan.
The security plan is implemented, in part, by Security Procedure SEC 01-202,
" Personnel Access to Protected Area," Revision 31.
Security Procedure SEC 01-202, Step 6.5.2,6, requires the visitor-to-
escort ratio to be no more than 10:1 in the protected area and 5:1 in
the vital area, but may be increased on a case-by-case basis upon approval of the Vice President Plant Operations or designee.
-Contrary to the above, on May 8, 1997, security escorts escorted more than five visitors into vital areas without specific approval of the Vice President Plant Operations or designee.
This is-a Severity Level IV Violation (Supplement III) (50-482/9709-07)."
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i Admission of Violation:
WCNOC acknowledges that on May 8, 1997, the visitor-to-escort ratio as stated
. in procedure AP 27-001, " Escort of Individuals within the Protected Area,"
i Revision 2,
was exceeded without specific approval of the Vice President Operations or designee.
- Reason for Violation:
On May 8, 1997, an NRC inspector identified two different escorts in vital i.
areas with six visitors each.
The requirement'for escort to visitor ratio in
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a vital area is one to five.
Both non-Security escorts entered the ESF switchgear room, and one of the escorts also entered the Control Room foyer.
The escort to visitor ratio is one escort to 10 visitors in the protected area and one escort to five visitors in vital area.
This is a Security. Plan requirement and is addressed in AP 27-001, " Escort of-Individuals within'the l'
Protected Area," and in Plant Access Training (PAT).
Form APF 27-001-02, " Security Escort Responsibilities," Revision 1, is required to be read and understood by each escort prior to assuming escort responsibilities. The escort to visitor ratio is not included on this form, and this omission is considered the reason for the violation.
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Corrective Steps Taken and Result Achieved:
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The tour groups left the vital area, and PIR 97-1358 was initiated to l_
investigate the cause of this event.
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j Corrective Steps to Be Taken to Prevent Recurrence:
Form APF 27-001-02 will be revised to add escort to visitor ratios.
This will be completed by August 15, 1997.
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Date When Full Compliance Will Be Achieved:
Compliance with procedure AP 27-001 and with the Security Plan was again achieved when the tour groups left the vital areas.
Additional corrective
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actions will be completed by August 15, 1997 l
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