WM 12-0023, Reply to Notice of Violation EA-12-135

Reply to Notice of Violation EA-12-135

ML12222A007
Person / Time
Site:	Wolf Creek
Issue date:	08/02/2012
From:	Matthew Sunseri Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-135, WM 12-0023, IR-12-007
Download: ML12222A007 (5)

Text

W~LF CREEK NUCLEAR OPERATING CORPORATION Matthew W. Sunseri President and Chief Executive Officer August 2, 2012 WM 12-0023 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Reference:

Letter dated July 5, 2012, from D. A. Powers, USNRC, to M. W. Sunseri, WCNOC

Subject:

Docket No. 50-482: Reply to Notice of Violation EA-12-135 Gentlemen:

In accordance with 10 CFR 2.201, Attachment I provides Wolf Creek Nuclear Operating Corporation's (WCNOC) reply to Notice of Violation (NOV) EA-12-135 as contained in the reference and described in Inspection Report 05000482/2012007. Attachment II lists five regulatory commitments made in response to NOV EA-12-135.

If you have any questions concerning this matter, please contact me at (620) 364-4008, or Mr.

Gautam Sen, Manager Regulatory Affairs, at (620) 364-4175.

Sincerely, Matthew W. Sunseri MWS/rlt Attachment I - Reply to Notice of Violation EA-1 2-135 Attachment II - List of Regulatory Commitments cc: T. A. Beltz (NRC) w/a E. E. Collins (NRC), w/a N. F. O'Keefe (NRC), w/a Senior Resident Inspector (NRC), w/a t V\

P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HCNET

Attachment I to WM 12-0023 Page 1 of 3 Reply to Notice of Violation (NOV) EA-1 2-135 Descriptions of Violations Identified in NOV EA-12-135

1. Title 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," requires, in part, that in the case of significant conditions adverse to quality, measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.

Contrary to the above, from December 4, 2009, to May 24, 2012, the licensee failed to assure that the cause of a significant condition adverse to quality was determined and corrective action was taken to preclude repetition. Specifically, after a water hammer event on August 19, 2009, the licensee failed to perform an adequate evaluation to determine the cause of water hammers and of internal corrosion in the essential service water system, and did not take corrective action to preclude repetition of additional water hammer events and system leaks. The condition recurred on January 13, 2012. This violation was identified on two occasions by the NRC as NCV 05000482/2009007-03 and VIO 05000482/2012007-03; the licensee failed to restore compliance.

2. Title 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," requires, in part, that measures be established to assure that conditions adverse to quality are promptly identified and corrected.

Contrary to the above, as of May 24, 2012, the licensee had failed to establish measures to assure that a condition adverse to quality was promptly corrected. Specifically, after identifying that safety-related spring-loaded tornado dampers required testing to verify operability, the licensee failed to implement procedures to test these dampers in the emergency diesel generator and essential service water rooms. This violation was previously identified by the NRC as NCV 05000482/2010007-02; the licensee failed to restore compliance.

Reason for the Violations Wolf Creek Nuclear Operating Corporation (WCNOC) management did not effectively develop, oversee or implement priorities and tracking tools to ensure that corrective actions related to regulatory issues are implemented in a timely manner. Additionally, the monitoring of actions that address regulatory issues by WCNOC's Licensing organization has been insufficient.

Licensing initially tracks regulatory issues but has not tracked actions to completion after regulatory issues are entered in the Corrective Action Program.

Attachment I to WM 12-0023 Page 2 of 3 Corrective Steps That Have Been Taken and Results Achieved Violation 1: Failure to preclude repetition of ESW water hammer events and ESW leaks An inspection program for Essential Service Water (ESW) piping has been implemented through procedure AP 23L-001, "Lake Water Systems Corrosion and Fouling Mitigation Program." Inspection requirements, monitoring requirements, specifications for corrosion rates and methods for determining acceptance criteria have been added to procedure Al 23L-005, "Lake Water Piping Integrity," to support prevention of leaks from aboveground and underground ESW piping. Inspections of ESW piping have been performed, repairs have been made as needed and the inspection program continues to monitor for nonconformances.

Violation 2: Failure to implement procedures to test tornado dampers Testing instructions for the safety-related, spring-loaded tornado dampers have been implemented. Two safety-related and spring-loaded tornado dampers, GD-D-0010 in the "B" train ESW pump house and GM-D-0009 in the "B" Emergency Diesel Generator (EDG) room, have been tested.

Corrective Steps That Will Be Taken to Avoid Future Violations Violation 1: Failure to preclude repetition of ESW water hammer events and ESW leaks Action 1-1: WCNOC will revise a controlling procedure to require that Licensing conduct a meeting periodically to review the status of the regulatory issues priority list with Engineering, Operations, Maintenance and other divisions as needed. This action also applies to Violation 2.

Due date: 09/06/2012 Action 1-2: WCNOC will prepare a documented schedule for completion of corrective actions to mitigate adverse effects of column closure water hammer in the ESW system to within acceptable design parameters. Due date: 10/01/2012 Action 1-3: WCNOC will add corrosion coupon test locations to the supply and return lines for both ESW trains at the aboveground to belowground interface in the 1974' elevation of the Control Building.

Due date: 12/15/2012 Action 1-4: WCNOC will mitigate adverse effects of column closure water hammer in the ESW system to within acceptable design parameters. Due date: 04/02/2014

Attachment I to WM 12-0023 Page 3 of 3 Violation 2: Failure to implement procedures to test tornado dampers Action 2-1: WCNOC will test the "A" train EDG and ESW tornado dampers, GD-D-0003 in the "A" train ESW pump house and GM-D-0004 in the "A" EDG room. Due date: 09/03/2012 Date When Full Compliance Will Be Achieved Violation 1: Failure to preclude repetition of ESW water hammer events and ESW leaks Full compliance will be achieved by April 2, 2014.

Violation 2: Failure to implement procedures to test tornado dampers Full compliance will be achieved by September 3, 2012.

Attachment IIto WM 12-0023 Page 1 of 1 LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by Wolf Creek Nuclear Operating Corporation (WCNOC) in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding these commitments to Mr. Gautam Sen at (620) 364-4175.

REGULATORY COMMITMENT DUE DATE WCNOC will test the "A" train EDG and ESW tornado September 3, 2012 dampers, GD-D-0003 in the "A" train ESW pump house and GM-D-0004 in the "A" EDG room.

WCNOC will revise a controlling procedure to require September 6, 2012 that Licensing conduct a meeting periodically to review the status of the regulatory issues priority list with Engineering, Operations, Maintenance and other divisions as needed.

WCNOC will prepare a documented schedule for October 1, 2012 completion of corrective actions to mitigate adverse effects of column closure water hammer in the ESW system to within acceptable design parameters.

WCNOC will add corrosion coupon test locations to the December 15, 2012 supply and return lines for both ESW trains at the aboveground to belowground interface in the 1974' elevation of the Control Building.

WCNOC will mitigate adverse effects of column closure April 2, 2014 water hammer in the ESW system to within acceptable design parameters.