ML19224C646
| ML19224C646 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 06/07/1979 |
| From: | Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Koester G KANSAS GAS & ELECTRIC CO. |
| References | |
| NUDOCS 7907060016 | |
| Download: ML19224C646 (1) | |
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NUCLEAR REGULATORY COMMISSION t;, QSwah[.J REGION IV
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June 7, 1979 In Reply Refer To:
RlV Docket No.
STN 50-482/IE Information Notice No. 79-15 Kansas Gas & Electric Co.
Attn:
Mr. Glenn L. Koester Vice President-Operaticas Post Office Box 208 Wichita, Kansas 67201 Gentlemen:
This Information Notice is provided as an early notification of a poacibly significant matter.
It is expected that rec 1,,ients will review the information for possible applicability to their faciliti a.
No specific action or response is requested at this time.
If further NRC evaluations so indicate, an IE Circular, Bulletin, or NRR Ceneric Letter will be issued to recommend or request specific licensee actions.
If you have questions regardir.g this matter, please contact the Director of the appropriate NRC Regional Office.
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'KarlV.Seyfritfl Director
Enclosures:
1.
IE Information Notice No. 79-15 2.
List of IE Information Notices Issued in 1979 cc: w/ enclosures Messrs. Nicholas A. Petrick, SNUPPS D. T. McPhee, Kansas City Power and Light Company Gerald Charnoff, Shaw, Pittman, Potts & Trowbridge E. W. Creel, Kansas Gas and Electric Company
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UNITED STATES NUCLEAR REGULATORY COMMISSION 0FFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D.C.
20555 IE Information Notice No. 79-15 Date:
June 7, 1979 Page 1 of 3 DEFICIENT PROCEDURES Summary On June 2, 1979, at Arkansas Nuclear One - Unit 1, while observing conditions in the control room, an NRC inspector discavered an operational deficiency that could t_ve resulted in the emergency feedwater system remaining isolated during subsequent power operation.
Description of Circumstances On June 2 while Arkansas Nuclear One - Unit I was preparing for startup, an -
NRC inspector in the control room found that during a surveillance test of the main feedwater check valves, the controls of the emergency feedwater system were positioned so that the system could not automatically respond if needed. The NRC inspector found that the test procedure being used by the licensed operators did not include, as it should have, instructions eitter to bypass the emergency feedwater system or to return it to normal. The plant operators, without approved procedures covering this aspect of the test, bypassed the controls that would have started the feedwater system automatically. Lacking a procedural requirement to return the system to normal, there was no assurance that emergency feedwater would be provided automatically if needed.
Following the Three Mile Island accident, the NRC required that operators be trained to initiate promptly the emergency feedwater system manually if it does not come on automatically.
Thus, while no immediate safety hazard existed at the Arkansas Unit 1 plant because of the improper action, the NRC staff is concerned about the potential safety hazard of leaving the emergency feedwater system in the bypassed condition, about the possibility that other procedures at the Arkansas plant may be deficient and about the fact that the operators deviated from procedures in performing the surveillance test.
Arkansas Power and Light Company has returned the plant to cold shutdown.
The June 2, 1979, NRC Order confirmed the requirement for a cold shutdown until the Commission staff is satisfied with the utility's method of. n-trolling the development of operating procedures, the adequacy of existrig procedures, and until there is assurance that operators will not deviate from those procedures.
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IE Information Notice No. 79-15
---Date:
June 7, 1979 Page 2 of 3 The n2ed for including the actions of operators and other staff members in the safety-related procedures of nuclear power plants is identified in the Technical Specifications and in Appendix B to 10 CFR Part 50, Criterion V, Instructions, Procedures, and Drawings:
" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance w'th these instructions, procedures, or drawings.
Instructions, procedures or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."
Further, Pegulatory Guide 1.33, " Quality Assuranr.e Program Requirements (Operation)," endorses American National Standard ANSI N18.7-1976,
" Admin strative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants," which provide. extensive guidance on preparation, contents and use of procedures. This standard reiterates the Appendix B statement in Section 5.3, " Preparation of Instructions and Procedures," and further states:
"These procedures shall provide an approved preplanned cethod of condecting operations.
Procedures shall be prepared and approved prior to implementation...."
NRC thus requires that anticipated actions involving safety-related equipment be planned and prescribed in written procedures.
Therefore, steps should have been included in the test procedures to cover all actions Recognizing that emergency conditions do not always follow an expected course of events, ANSI N18.7 in Section 5.39, "Emerger.cy Procedures,"
states:
"Since emergencies may not follow anticipated patterns, the pro-cedures should provide sufficient flexibility to accommodate variations."
NRC recognizes that unforeseen conditions may be encountered that require quick action and judgement and could involve deviations from established procedures for the safety of the public. These deviations should be documented and reviewed af ter-the-fact and procedures formally changed if necessary.
While circumstances in an emergency can dictate the need to depart from procedures, such action cannot be justified on a routine basis.
Rote following of deficient procedures is not proper.
When a question on procedural requirements arises, the licensee's temporary change procedure should be used whereby the matter should be referred immediately to the proper authorities for resolution and appropriate changes made if needed.
Departures from procedures, either additions cr deletions, cannot be allowed for any routine situation.
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IE Information Notice No. 79-15
Date: June 7, 1979 Page 3 of 3 Each licensee should review his procedures and administrative controls
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for procedures to assure that methods and procedures exist to control safety-related actions.
Enclosed is a copy of the Order issued to Arkansas Power and Light Company.
This Information Notice provides details of a significant occurrence.
No written response is req' aired.
If y-desire additional information regarding this matter, contact the Director of the appropriate NRC Regional Office.
Enclosure:
Order Issueu s_ sas Power and Light Company
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION -
In the Matter of
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ARKANSAS POWER AND LIGHT COMPANY
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Docket No. 50-313 (Arkansas Nuclear One - Unit No. 1)
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ORDER I.
The Arkansas Power and Light Company (the " licensee") is the holder of Facility Operating License No. DPR-51 (the " license") which authorizes operation of the Arkansas Nuclear One Unit No. 1 (the " facility") at steady reactor power levels not in excess of 2568 megawatts thermal (rated power).
The license was issued on May 21, 1974, and has an expiration date of December 6, 2008.
The ~acility consists of a Babcock and Wilcox designed pressurized water recc. tar (FWR), located at the licensee's site in Pope County, Arkansas.
II.
In the course of authorized return to power from a cold shutdown condition, operators deviated from the e tablished but apparently deficient pro-cedure for routine surveillance test of the check valves in the main feedwater system. The procedure was deficient because it did not specify that operators bypass and return the emergency feedwater system to normal.
The plant staff bypassed the controls to automatically start EFS by placing the control switches in a position that would defeat emergency feedwater.
The plant was in a hot shutdown condition pre-paring for startup and the operators apparently took this action because pumping of emergency feedwater for this test would be undesirable and unnecessa ry.
Lacking a procedural requirement to return these switches to normal there was no assurance that emergency feedwater would be provided automatically, if needed, later during power operation.
In view of these circumstances, which were discovered by an NRC inspector, the facility should be temporarily placed in a cold shutdown condition.
In a telephone conversation on June 2, 1979, the licensee Vice President, Mr. William Cavanaugh, III, agreed to immediately proceed to a cold shutdown condition and to remain in that condition until confirmation by the Acting Director, Office of Inspection and Enforcement, that the conditions for startup set out in Part III below, have been satisfied.
It is desirable to confirm by order the licensee's agreement to proceed to cold shutdown.
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In light of Part II above, IT IS IlEREBY ORDERED TilAT, pursuant to 10 CFR Parts 2 and 50, the licensee shall proceed to, and remain in, a cold shut-down condition and shall not restart until the Acting Director, Office of Inspection and Enforcement, has confirmed in writing, that the following actions have been satisfactorily accomplished:
(1) the licensee shall evaluate and modify as appropriate its methods for the development, review and approval of pro-cedures for all modes of plant operation; (2) the licensee shall evaluate existing procedures to assure that such procedures include all actions necessary for safety; and, (3) the licensee shall take appropriate steps to assure that all plant personnel adhere to approved procedures and do not add unauthorized steps to any procedures.
FOR TIE NUCLEAR REGULATORY COMMISSION John G. Davis Acting Director Office of Inspection and Enforcement Dated at Bethesda, Maryland this 2nd day of June, 1979.
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- June 7, 1979 LISTING OF IE INFORMATION NOTICES ISSUED IN 1979 Info rmation Subject Date Issued To Notice No.
Issued 19-01 Bergen-Faterson Hydraulic 2/2/79 All power reactor Shock and Sway Arrestor facilities with an Operating License (OL) or a Construc-tion Permit (CP) 79-02 Attempted Extortion -
2/2/79 All Fuel Facilities Low Enriched Uranium 79-03 Limitorque Valve Geared 2/9/79 All power reactor Limit Switch Lubricant facilities with an Operating License (OL) or a Construc-tion Permit (CP) 79-04 Degradation of Engineered 2/16/79 All power reactor Safety Features facilities with an Operating License (OL) or a Construc-tion Permit (CP) 79-05 Use of Improper Materials 3/21/79 All power reactor In Safety-Related Components facilities with an Operating License (OL) or a Construc-tion Permit (CP) 79-06 Stress Analysis of 3/23/79 All Holders of an Safety-Related Piping Reactor Operating License (OL) or a Construction Permit (CP) 79-07 Rupture of Radwaste 3/26/79 All power reactor Tanks facilities with an Operating License (OL) or a Construc-tion Permit (CP)
Enclosure
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Page 1 of 2 r -
IE Information Notice No. 79-15
. June 7, 1979 79-08 Interconnection of 3/28/79 All power reactor
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Contaminated Systems with facilities with an Service Air Systems Used Operating License As the Source of Breathing (OL) and Pu Proces-Air sing fuel facilities 79-09 Spill of Radioactively 3/30/79 All power reactor Contaminated Resin facilities with aa Operating License (0L) 79-10 Nonconforming Pipe 4/16/79 All power reactor Support Struts facilities with a Construction Pe rmit (CP) 79-11 Lower Reactor Vessel Head 5/7/79 All Holders of Reactor Insulation Support Problem Operating Licenses (OLs)
Construction Permits (cps) 79-12 Attempted Damage to New 5/11/79 All fuel facilities, Fuel Assemblies research reactors, and power reactors with an Operating Licensee (OL) or a Construction Permit (CP) 79-13 Indication of Low Water 5/29/79 All Holders of Operating Level in the Oyster Creek License (OL) or Reactor Construction Permit (CP) 79-14 NUC Position of Electrical 6/11/79 All Power Reactor Cable Support Systems facilities with a Construction Permit (CP) and applicants Enclosure Page 2 of 2
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