IR 05000482/1998012
| ML20198J085 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 12/18/1998 |
| From: | Howell A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Maynard O WOLF CREEK NUCLEAR OPERATING CORP. |
| References | |
| 50-482-98-12, EA-98-274, NUDOCS 9812300084 | |
| Download: ML20198J085 (4) | |
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.e NUCLEAR REGULATORY COMMISSION REGloN IV 0,, [ 611 RYAN PLAZA DRIVE. SUITE 400
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December 18, 1998 EA 98-274 Otto L. Maynard, President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 l Burlington, hansas 66839
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SUBJECT: NRC INSPECTION REPORT 50-482/98-12
Dear Mr. Maynard:
Thank you for your letter of November 13,1998 in response to our September 29,1998, letter and Notice of Violation concerning a violation of 10 CFR 50.59 (Violation 50-482/9812-01) and a violation of 10 CFR Part 50, Appendix B, Criterion V (Violation 50-482/9812-02). We have reviewed your reply. We found your response to Violation 50-482/9812-01 to be responsive to the concerns 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 will be maintained.
Regarding Violation 50-482/9812-02, we noted that you denied the first example of this violation. During the inspection v s found that Procedure AP 05-0001, " Change Package Planning and implementation," Revision 2, required the preparer of a design change package to identify calculations that are affected by the change. At that time our findings were not disputed by your staff. However, based on the additionalinformation provided in your response letter, we consider it appropriate that the engineer in this case made a conscious decision to not identify the subject calculation (NK-E-003, " Class 1 E 125 V DC Battery Short Circuit Study,"
Revision 0) for revision because the effect of the design change on this calculation was known to be bounded by the existing assumptions. That is, it was known that the short-circuit currents l would decrease and, therefore, not exceed the calculated values. Based on our understanding of the construction and operating characteristics of the new AT&T batteries, we agree that this constituted a conservative decision by the engineer and that Procedure AP 05-0001 was not violated in this instance. Consequently, we have withdrawn this example of the violation.
If you have any questions regarJing this matter, please contact Mr. Thomas Stetka at 817/860-8247.
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Sincerely,
Arthur Howell 111, Director Division of Reactor Safety Docket No.: 50-482 License No.: N.F.-42
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' 9812300084 981218 PDR ADOCK 05000482 G PDR
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a Wolf Creek Nuclear Operating Corporation -2-cc:
Chief Operating Officer Wolf Creek Nuclear Operating Corp.
P.O. Box 411 Burlington, Kansas 66839 Jay Silberg, Esq.
Shaw, Pittman, Potts & Trowbridge 2300 N Street, NW ,
Washington, D.C. 20037 Supervisor Licensing
Wolf Creek Nuclear Operating Corp.
P.O. Box 411 Burlington, Kansas 66839 Chief Engineer Utilities Division Kansas Corporation Commission 1500 SW Arrowhead Rd.
Topeka, Kansas 66604-4027 Office of the Governor State of Kansas
. Topeka, Kansas 66612 Attorney General Judicial Center 301 S.W.10th 2nd Floor Topeka, Kansas 66612-1597 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
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DISTRIBUTION w/coov of licensee's letter dated November 13.1998: '>
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Wolf Creek Nuclear Operating Corporation -3-DISTRIBUTION w/coov of licensee's letter dated November 13.1998:
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- DRP Director SRI (Callaway, RIV)
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DRS Action Item File (98-G-131)(Goines)
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- DOCUMENT NAME: R:\_WC\WC812AK.MFR To receive copy of document, Indicate in box: "C" = Copy without enclosures *E' = Copy with enclosures "N" = No copy RIV:EB E C:DRS\EB E D:DRSM o I *MFRunyan:nh *TFStetka ATHcElllil T
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Otto W$LF CREEK President and Chief Executive Office'
NUCLEAR OPERATING CORPORATION W 131998 hhhhh a
U. S. Nuclear Regulatory Commission ]' jl ATTN: Document Control Desk ",* NOV I T 1998 J l
Mail Station P1-137 Washington, D. C. 20555 f1EGIONIV ._. _
l Reference: Letter dated September 29, 1998, from William D.
Johnson, USNRC, to O. L. Maynard, WCNOC Subject: Docket No. 50-482: Response to Notice of Violation 50-482/9812-01 (EA 98-274) and 9812-02 Gentlemen:
This letter transmits Wolf Creek Nuclear Operating Corporation's (WCNOC)
response to Notice of Violations 50-482/9812-01 and -02. Violation 9812-01 identified a failure to pe.rform a written evaluation in accordance with 10 CFR 50.59 that provided the bases for the determination that procedure changes did or did not involve an unreviewed safety question. Violation 9812-02 required response to the first example only, which involved a failure to follow procedures in that a calculation was not updated with a design change as required by procedure. On October 22, 1998, Tony Harris, WCNOC Licensing, requested an extension of the required September 29, 1998, due date from September 29, 1998 to November 13, 1998. This request was approved by Tom Stekta, USNRC.
WCNOC's response to these violations and discussions related to other information contained in Inspection Report 98-12 are provided in Attachment I.
Attachment II provides a list of commitments contained in this letter.
WCNOC is denying that a violation occurred in the first example of violation 9812-02; therefore, a copy of this letter is being provided to the Director, Office of Enforcement. If you have any questions regarding this response, please contact me at (316) 364-4000, or Mr. Michael J. Angus at (316) 364-4077 Very truly yours, l r /1 \
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Otto LJ Maynard OLM/rir Attachments cc: W. D. Johnson (NRC), w/a J. Lieberman (NRC), w/a E. W. Merschoff (NRC), w/a l B. A. Smalldridge (URC), w/a K. M. Thomas (NRC), w/a 99-0147 P.O. Box 411/ Burlington, KS 66833 / Phone: (316) 364-8831 l An Equal Opportunity Ernployer M/F/HCNET
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Attacnment I to WM 98-0118
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Page 1 of 10 Response to violation 50-482/9812-01 (EA 98-274)
Violation 50-482/9812-01:
A. 10 CFR 50.5 9 (a) (1) states, in part, that a holder of a license authorizing operation of a production or utilization facility may make changes in the facility as described in the safety analysis report without prior Commission approval unless the proposed change involves an unreviewed safety question.
10 CFR 50.59 (a) (2) states, in part, that changes shall be deemed to involve an unreviewed safety question (i) if the probability of occurrence er the consequences of an accident or malfunction of equipment important to safety previously analyzed in the safety analysis report may be increased; (ii) if the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report may be created; or (iii)
if the margin of safety as defined in the basis for any technical specification is reduced.
10 CFR 50. 5 9 (b) (1) states, in part, that the licensee shall maintain records of changes in the facility made pursuant to this section, and that these recorcs must include a written safety evaluation that provides the bases for the determination that the change does not involve an unreviewed safety question.
Contrary to the above, on several occasions without prior Commission approval and without performing written safety evaluations, the licensee made changes to the facility as described in the Updated Safety Analysis Report, that involved an unreviewed safety question. Specifically, on April 22, 1992, November 11, 1993, and December 1, 1995, the licensee added operator actions to Emergency Management Guideline ES-12,
" Transfer to Cold Leg Recirculation," a procedure described in the Updated Safety Analysis Report, without performing written safety evaluations that provided the bases for the determination that the changes did not involve an unreviewed safety question. These changes constituted an unreviewed safety question in that they increased the prcbability that cperators would not ce able to complete the switchover of emergency ore coling system pump suction from the refueling water storage tank to the containment sump before depletion of the refueling water storage tank. This increased the prooability of a malfunction of the emergency core cooling system pumps (equipment important to safety).
This is a Severity Level :V violatien (Supplement :) (50-482/9812-01).
Description of Events:
Updated Safety Analysis Report (USAR) Section 6.3.2.2 entitled, " Transfer Allowance - RHR, Charging, SI," discusses that, during a large break loss of coolant accident (LOCA) with the single failure of valve 8812A or 8812B to close on demand, switch-over of the Emergency Core Cooling System (ECCS) from injection mode to recirculation mode can be acccmplisned before the " transfer allowance" of 90,660 gallons is removea from the Peactor Water Storage Tank RWST). Analysis has shown that, beginning with the Residual Heat Removal
'RHR) automatic switch-over at low-low-1, this volume could be removed frem the RWST in approximately eight minutes. However, simulator runs have shown that the associateo steps in emergency procedure Emergency Management Guideline (EMG) ES-12, " Transfer to Cold Leg Recirculation," : currently
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Page 2 of 10 Revision 9) require approximately ten minutes for completion. Therefore, the statement in USAR Section 6.3.2.2 regarding switch-over before use of the
" transfer allowance" of 90,660 gallons is not consistent with procedure EMG ES-12. This same statement also appeared in the Original Final Safety Analysis Report (FSAR).
EMG ES-12 cn7tains eleven detailed actions that must be accomplished to complete ECC- switch-over. The initial steps in ES-12 are for Component Cooling Water (CCW) alignment to the RHR heat-exchanger. This is not included in the list of actions in USAR Table 6.3-12. The times assumed in USAR Table 6.3-12 are significantly different' from the actual times required for the actions of ES-12 to be performed.
EMG ES-12 has been revised nine times since 1984. The major changes are itemized below:
Revision Date Changes 2 12/20/88 Mote added prior to Step 1 that FR should not be implemented prior to completion of Steps 1 through 5 (RWST : witch-over).
3 04/22/92 Mote added before Step 6; to be ccmpleted prior to RWST empty (6%).
4 11/11/93 Step 1; Wording changed from " verify" to " establish" CCW flow to RHR heat exchangers.
Step 2; Isolate CCW from spent fuel pool heat exchangers.
Step 3; Verifies switch-over is required.
Order of various steps changed to accommodate above changes.
Steps added to check if Spray Addition Tank should be isolated, to verify flow paths, SI pump injection and core cooling.
7 12/01/95 Added List of Commitments, including USAR Table 6.3-8.
After these rev,isions were made, the action time results frem operating crew training on EMG ES-12 were not compared to the associated times assumed in USAR Tables 6.3-11 and 6.3-12. The regulatory screenings performed for each EMG ES-12 procedure revision failed to identify that the resulting changes in execution time for EMG ES-12 could result in conflict with USAR Section 6.3.2.2 and Tables 6.3-11 and 6.3-12.
WCNOC agrees that for Revisions 3, 4 and 7, of EMG ES-12, Unreviewed Safety Question Determinations (USQDs) should have been performeo to provide the documentation that an .unreviewed safety question (USQ) did not exist. In failing to perform the OSQDs, it was not discovered that an USQ was created.
These changes potentially increased the probability of a malfunction of the ECCS and Containment Spray pumps in that, should the swapover not occur en time, Operator response would be required to shut off the pumps and then turn the Containment Spray pumps back on to control Containment pressure.
Two test runs of this procedure were made on the Wolf Creek simulator in April 1998. In one run the time required for the operators to complete the required steps in EMG ES-12 was nine minutes; in the second run, the time was eleven minutes. Once the discrepancy in the USAR time requirement and the actual performance was discovered, ?!R 98-1008 was initiated and an cperacility evaluation performed. As noted in the Inspection Peport, the cperability evaluation was found to be acceptacle by the inspection team.
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Page 3 of 10 Althougn the changes represented an USQ, the specific concerns are of minimal y safety significance. The fold-out page of EMG ES-12 includes mitigating i
" actions, should the RWST level reach 6% prior to completing the switch-over, that will prevent any damage to the ECCS er ' containment spray pumps. In addition, the RHR pumps, which automatically switen-over to recirculation from i the containment recirculation sump when the RWST Lo-Lo-1 level setpoint is ,
reached, will provide sufficient flow to the core for the post-LOCA transient conditions. One . RHR pump will provide sufficient long-term cooling without the high head and intermediate head ECCS pumps available for the large break
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i- LOCA, wnen these times are critical.
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l The containment integrity analysis relies en the containment spray to help i
mitigate the peak pressure and temperature consequences. The limiting i
pressure and temperature conditions occur early in the transient following a large break LOCA. Near the time of switch-over, the pressure and temperature
i have decreased to much lower values, and the containment spray pumps can be shut off for a significant period of time beginning at the time of switch-over L without compromising pressure and temperature limits. A gradual heat up and l pressurization of containment will occur if the sprays are terminated at the i time of switch-over; however, the peak or limiting conditions would not be approacned for an extenced period of time.
As mentioned in Inspection Report 98-12 (on page 3 of the report details), FIR I 97-3483 initially identified the concern of potentially injecting cold CCW flow into an already hot heat exchanger, due to delays in aligning the CCW system. The immediate safety consequences of the potential for voiding on the secondary side of the RHR heat exchanger were evaluated in conjunction with the operability assessment of PIR 97-3483. The conclusion reached in the j operability assessment for PIR 97-3483, that there is reasonable assurance the l
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heat exchanger will be able to perform its intended function, remains valid. '
Although the initial evaluation for PIR 97-3483 was narrow in scope (i.e., did *
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not address the increase in operator response time), the initial cperability and reportability determinations performed for PIR 97-3483 were correct and the actual safety significance minimal.
Reason for Violation:
The regulatory screenings for EMG ES-12 failed to identify that the resulting l Changes in execution time for EMG ES-12 could result in conflict with USAR 3ectica 6.3.2.2 and Tacles 6. 3-11 ano 6. 3-12. This failure occurren because the change process did not contain specific guidance to ensure that assumed l safety significant operator response times in the USAR remain censistent with the actual performance of the cperators. '
Immediate Corrective Steps Taken:
i Upon issuance of PIR 93-1008, the Shift Supervisor requested an cperability evaluation- pursuant to AP 28-001, " Evaluation of Nonconforming Condition of '
Installed Plant Equipment." The evaluation addressed the consequences of the >
RWST reaching the empty level prior to ccmpleting ECCS switch-over. The evaluation concluded that current plant procedures (EMGs) would direct the operators to shutdown the high head and intermeciate head ECCS and : ntainment L spray pumps, and therecy, prevent damage to these pumps.
j Corrective Actions to Prevent Recurrence j'
WCNOC cevelopec a list of safety significant and time critical cperator action ( assumptions that were included in our USAR and our safety analysis. :n all
, other cases, we have verified that the cperator action time is conservative i with respect to these assumptions. The operator actions _ist anc response i
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,, Page 4 of 10 time assumptions were -incorporated into the Engineering !nformation System (EIS) database.
Operator Action Resoonse Time Validation The list of operator actions was derived from approximately 35 scenarios. The majority of these actions will be incorporated into the Systematic Approach to Training (SAT).two year plan and, thereby, routinely validated in the future.
The SAT will ensure that each - of these operator action evolutions and the assumed response time are verified -every two years caring the operator requalification cycle.
For ' the operator action assumptions which cannot be reasonably validated through the SAT (approximately 10 items), a plan will-be developed to ensure routine verification that these evolutions can be performed by plant cperators within the assumed response time. Generally, these are longer term actions which can not be reasonably modeled in the plant simulator. The plan will be developed by July 31, 1999.
Reculatory Screenino Process Although several screening evaluations (prior to 1994) did not identify the need to perform a USOD, no changes to the current regulatory screening process are necessary. The current screening process and the environment for performing evaluations are much more rigorous than the pre-1994 process. This conclusion is further supported by the Auxiliary Feedwater System Functional Assessment wherein many screening evaluations were reviewed and no errors where identified. Similar results were seen from the Essential Service Water System functional assessment. Based on this information no changes are necessary to the screening process.
Corrective Actions Required for Compliance RWST Switch-over Resolution Actions necessary to resolve the operator response time USQ will be completed prior to the end of Refuel Cutage X. !ncluded in the actions necessary to resolve this issue is a Design Change Package {DCP) to automate CCW alignment during switch-over frem ECCS injection to recirculation mode.
Date When Full Compliance Will Be Achieved:
Full compliance will be achieved no later than the end of Refuel Outage X, once the discrepancy between the USAR response times and the actual response times that resulted in an unreviewed safety question has been resolved.
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!' Response to Violation 9812-02
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B. -10 CFR Part 50, Appendix B, Criterion V states, in.part, that
! activities affecting quality shall be prescribed by procecures appropriate to the circumstances and shall be accomplished in accordance with these procedures. Procedures shall be accompanied by appropriate acceptance criteria for determining i: that ' in.portant activities have been satisfactorily accomplished.
Procedure AP 05-001, " Change Package Planning and .
Implementation," Revision 2, Section 6.2.3, required that all programs requiring revision, such as calculations, be identified.
Contrary to the above, the following examples of a failure to follow procedures and an example of inadequate procedures were-identified:
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1. In March 1998, activities were not accomplished in accordance with -Procedure AP 05-001. Revisions to-Calculation NK-E-003, " Class 1E 125 V DC Battery Short Circuit Stucy," Revision 0, to reflect the new fsult contribution from the equipment being installed were not identified by Design Change Paciage 05846, " Battery Replacement," Revisions 0 through 11,' and Design Change Package 05248, "NK- System Swing Battery Charger Installation," Revisions 0 through 9.
2. On January 9, 1998, the inspectors determined that the acceptance criteria for station battery Surveillance Test Procedures STS-MT-021, " Service Test for 125vde Class 1E Batteries," Revision 11, STS-MT-022, " Service Test for
<125vdc Discharge Battery Test," Revision 10, were not appropriate for . determining that activities were accomplished in that the procedure acceptance criteria did-not assure that battery discharge current was consistent I with the load profile, that the battery final terminal voltage was greater than the minimum allowable design value, and that a constant discharge rate was maintained during testing. 1 This is a Severity Level IV violation (Supplement :) (50-482/9812-02).
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- Note: Inspection Report 98-12 did not require a response to 9812-02 example 2. ,
l Basis for Denial l l
l WCNOC contends that no procedure violation occurred in either part of Example l'of this violation. Example 1 of Violation 9812-02, cites two violations of I procedure AP 05-001, " Change Package Planning and Implementation." Page 7 of l the.. Inspection Report details states that Section 6.2.3 of AP 05-001, requires ;
all~ programs requiring revision such as calculations be identified. The T violation contends that due to this step, Calculation NK-E-003 should have ,
been. listed as an affected document for both of the Derign Change Packages '
- DCPs).
[ .. This procedure does not require engineers to identify "affected" documents.
I Step 6.2.3 of AP 05-001, states, "When completing the change Package Review
' Forms, Organizations anall identify all programs, procecures and training l. " requiring" revision as a result of the Change Package in the appropriate i
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section of form APF 05-005-04." Engineering's responsibility regarding this statement is to identify the groups or departments which may have procedures, i programs, etc., impacted by the change. There are no requirements in AP 05-301 applying to calculations. Step 6.2.3 does not mention calculations and 14 directed at groups or departments external to Design Engineering to review the change package and initiate any required changes to their programs, procedures, etc. '
In relation to other more relevant procedural guidance, WCNOC has two procedures which require identifying "affected" documents in change packages:
Procedure AP 05-005, "Dosign Implementation and Configuration Control of Modifications," and Procedure AP 05-002, " Dispositions and Change Packages."
Engineering's calculations are also reviewed in accordance with Procedure AP 05-002, which defines an "affected document" as a. document which requires ,
revision to reflect the modification but is not required to implement or support the modification. WCNOC does not " require" an ' engineer - to update calculations when the change that is being considered is bounded by the related assumptions in that calculation. ,
Procedure AP C5-005, Step 6.2.6.4 requires that, "The C:nfiguration Status Accounting Record System (CSARS) list of affected component and documents must be kept current to avoid interfering with other designs under development."
The procedure goes on to state that, "Affected documents include, but are not limited to Engineering drawings, procedures, specifications, calculations, etc.,-that have been affected by the change." -
In the two examples cited, WCNOC correctly implemented the above procedural ;
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requirements in that neither DCP required ' the revision of NK-E-003. Furthee.
details are provided below for each instance cited in Example 1 of this violation.
Example la: DCP 05846, "NK Battery Replacement" DCP 05846 Revision 0 replaced the existing Class lE GNB rectangular cell -
batteries with AT&T round cell batteries. The Ampere-hour (Ah) ratings of the 4 AT&T batteries were less than those of the GNB batteries (1600 vs. 1650 Ah for '
batteries NK11 and NK14, 364 vs. 900 Ah for batteries NK12 and NK13).
3ince the Ah ratings cf the AT&T batteries were less than those for tne GNB catteries, the engineer responsible for preparation of DCP 05846 knew :nat the calculated currents in NK-E-003 were greater than the currents that the AT&T batteries could produce. Therefore, NK-E-003 was conservative. On this i basis, calculation NK-E-003 did not need to be revised and therefore was not isted as an affected document in the DCP.
Example 1b: DCP 05248, "NK System, Swing Battery Charger Installation" DCP 05248, Revision 0 was released cn December 12, 1995. The cbjective of DCP ,
05248 was the insta11atten of a second spare 125 volt Class 1E battery charger i in addition to existing spare charger (NK25). This DCP requirea procurement )
and installation of associated AC and DC transfer switches. The 125 VDC Output from each spare enarger is connected to the NK system buses via tne DC transfer switches. These switches must be ratec to withstand maximum predicted fault currents, as cetermined in NK-E-003. The switches have a-35,000 Amp withstand current rating at 125 'J DC . NK-E-003 Revision 9 shows maximum fault current to be less than 16,000 amps. The engineer responsible for preparation of CCP 05248 determined that the modification did not affect the calculations in UK-E-003 ano therefere, aid not list it as an affected document.
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. As described above, in each ~ example, the engineers questioned the safety-implications of each DCP ' and concluded that _ the. calculation bounced the condition. Had the. DCPs changed the assumptions such that they no longer enveloped the change, or changed the c:nclusions in MK-E-003 it would have been listed as an affected document, Therefore, WCNOC does not believe that a-violation of procedures occurred with respect to either part of Violation 9812-02,. Example 1.
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Attachment I to WM 98-0118
,, Page 8 of 10 Additional Information Minimizing Emergency Core Cooling System Leakage During Emergency Operations Page 4 of the Inspection Report Details contains a discussion about minimizing j
- Emergency Core-Cooling System (ECCS) leakage during emergency cperations. The j inspection report states that the team cbserved no sense of urgency on the part '
of the licensee to identify and expedite the repair of ECCS leaks.
Although WCNOC has been monitoring ECCS leakage through boron crystallization for many years. An -aggressive, focused program for identifying, inspecting, and trending ECCS leakage was inititted in spring 1998. The WCNOC Maintenance Department assigned a focal person to perform a drip bag inspection at least every.other week. Part of this inspection includes verification of component number, location e.g., building and elevation, date of drip bag installation, active leaks, status of any current work request to repair this leak, and integrity of bag and rope or ribbon that are securing the drip bag are logged.
Should the inspection identify' any new leaks or increasing leakage from ,
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identified leaks Health Physics .is notified and a work request is written.
Depending on the job scope,'the Fix It Now (FIN) team may be assigned and if possible fix the leak immediately. If not, a sub-work Orcer is written and prioritized based on significance and then scheduled into the next available train window as part of our thirteen week rolling schedule. The WCNOC work control process considers the maintenance rule, allowed outage times, availability of equipment and other work to be performed when prioritizing and scheduling items.
To provide further guidance, Maintenance has developed procedure AI 12-001,
" Control of Drip Bags." The scope of the procedure includes installing,
.m no itoring, and removing drip bags, and establishment of routine surveillances to verify the integrity of installed drip bags. In addition to the inspection ;
activities, maintenance compiles a monthly report on the status.of drip bags in the plant and maintains a performance indicator which is reviewed by management. Our goal is to have 19 drip bags by the end of 1998. There are l currently 20 drip bags in use at the plant. i Cperations. personnel quantify total ECCS leakage, in accordance with Procedure l AP 25C-001, "WCGS Leak Reduction. of Primary Coolant Sources outside of Containment." In accordance with this procedure, total leakage is required to be less than 1 gpm. If the total leakage is greater than a gpm, the corrective work to reduce ~ the leakage is treated as emergent work until the total rate
. leak is reduced to less than 1 gpm. The 1 gpm leakage limit is within the Updated Safety Analysis Report (USAR) chapter 15 accident analysis ECCS leakage limit of 2 gpm.
Purchase and Installation of Equipment Page 8 of the Inspection Report Details includes a discussion cn the battery charger purchase specification whereby a m fferent specification was used to purenase two spare batteries. Specifit. aon E-051 (Q) , (for chargers NK-21 through NK-25) specified a regulation of +/- 0.5%; whereas Specification E-051A ,
- A (Q) , (for NK-26) specified a regulatica of +/- 1.0%. The difference was not evaluated in the design change package. l Althougn the inspection report 1 identified this event as a weakness in the design process, a review of corrective acticn documents has shown this to ce an isolated incident and not reflecttve of program weakness in either the cesign er the purchasing program.
The specificaticn will be revised with the correct -/- 0.5% regulation (
requirement by Cecember 15, 1998.
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Attacnment I to WM 99-0113
,, Page 9 of 10 Poor Quality Calculation Page 9 of. the Inspecticn Report retails discusses the poor quality cf calculation NK-E-002, " Class 1E Battery Si:ing." Furtner, on Page 9 in the Conclusions section, the report notes that calculations and other design products in the electrical area were of inconsistent _ quality and contained errors. NK-E-002. is currently under revision to correct the inconsistencies noted in the calculation. WCNOC had previously recognized that some of the electrical documentation reviewed were not up to present day standards. A Calculation Standards Team was initiated in May 1998. -The purpose of the team
.is to establish and maintain standards for calculational models, input assumptions, revision requirements, training and independent reviews.
Safety Significance Classification Page 56 of the Inspection Report Details includes a discussion on the Performance Improvement Request (PIR) process of classification. The team-noted that there were no instructions or examples in the procedure for how calculation errors should be assessed for significance or aadressed for resolution. The team was concerned that this could result in the misclassification of issues and was therefore 'considerea a weakness in the process, although no examples of misclassificaticn were found.
Corrective Action is one of WCNOC's top five priorities. Management's expectations regarding usage of the program have been well communicated and enforced. Personnel at WCGS comply with Procedure AP 28A-001, " Performance Improvement Request," which does not limit the type of discrepancies that are included in the process. Though examples of safety analysis and calculation errors are not provided, Engineering errors are identified en PIRs and evaluated. The PIR procedure states that the initiator should include the following information in the. description of the issue: the consequences or potential consequences, impact of ability of a system or component to perform its function, generic implications, reportability concerns, work process and activity being performed, immediate actions taken to address the problem and possible causes. The Central Work Authority (CWA) uses the information provided to. screen the PIR. If the CWA cannot determine significance basec cn the information provideo, he then contacts supporting organizations, such as engineering, to provide him more details. The CWA looks at eacn issue for impact en plant systems, :peracility, anc reportatility.
Regarding the comment that there were no instructions or examples in the procedure for how calculation errors should be assessed for significance er addressed for resolution, Procedure AP 28A-001 contains explicit detail en the evaluation requirements for each significance level. The responsible manager or designee is required to review the evaluation and corrective actions for suoject matter suitability. For PIRs designatec a level III for wnich root cause is not required, procedure Step 6.6.1.1 requires the evaluator to verify that level III is the apprcpriate significance level anc that reviewing similar events may. help to identify the appropriate scope of the evaluation.
.?rocedure AP 29A-001, Otep 6.2.3.3, states taat the responsible nanager may change classificaticns f rom wnat was initially assigned in the PIR review if available information warrants such a change. Therefore, cased on knowleage of the issue'the manager may decide that a root cause evaluation is necessary and upgrace the PIR level. In acdition, pursuant to AP 29A-001, Step 6.3.1, if the PIR evaluator identifies additional information during the scope :f :he evaluation that affects the ability of an SSC to perform its intended function, reportability, or significance or scope of :ne PIR, the evaluatcr shall promptly notify the Control Room er the CWA, if necessary initiate a new PIR, and should discuss the information with management.
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Attachment I to WM 99-0112
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Page 10 of 10 Therefore, WCNOC believes that the information in our procedures provides-adequate guidance, and no program weakness exists.
Non-cited Violations The inspection report contains discrepancies in the description of non-cited violations and the total '. is t e c in the Supplemental Items section of the report.
Item 1 It appears that an item numbered 50-482/9812-12 was closed on page 4 of the Supplemental Informatien, when only eleven items were opened from the inspection. It was WCNCC's understanding from discussions with the SSEI team, and information in the Inspection Report, that two fire protection issues were being ccabined into one non-cited violation. Pages 65 and 68 of the Inspection Report Detail identified the NCVs both as 9812-11, which was consistent with earlier discussions. On Page 2 of the Supplemental Information 9812-11, an NCV was opened li. sting both issues under cne item: however, en the closed item list, the .4.ssues were separated and numbered incividually.
One of the items closec in NCV 9812-011 was LER 97-016-00, including '
supplements -01 and -02. However, WCNOC received inspection report 50-482/98-017, dated October 22, 1998, in which another NCV was issued for the closure of LER 97-016-00, -01 and -02. WCNOC ;equests that the NCV cited in Inspection Report 50-482/98-017 be rescinded.
This item was discussed with David Graves of the NRC Region IV staff.
Item 2 On Page 62 of the inspection report details, a NCV is discussed in the conclusions to section F5, " Fire Protection Staf f Training cnd Qualifications,"
however, in the Observations and Findings Section it is discussed as a minor violation. No NCV relating to this item was found on the open item list.
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