ML20059M685

Ack Receipt of 900830 Response to Violations Noted in Insp Rept 50-482/90-26.Addl Info Re Troubleshooting Required

ML20059M685
Person / Time
Site:	Wolf Creek
Issue date:	09/28/1990
From:	Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Withers B WOLF CREEK NUCLEAR OPERATING CORP.
References
NUDOCS 9010050196
Download: ML20059M685 (3)

See also: IR 05000482/1990026

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SEP 2 8190 l

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-InTReply; Refer;To.  ;

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-Docket: 1STN.50-482/90-261,

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Wolf. Creek' Nuclear' Operating ' Corporation .

ATTN: Bart D.. Withers

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. > President and Chief Executive Officer

P.O. Box 411 .

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Burlington, Kansas 166839 ,

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, Gentlemen: .

, ,Thank you for your letter of August 30,1990,.in response to our' letter and

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the attached Notice of' Violation dated July 31, 1990. We have. reviewed thel

corrective actions for the violation (482/9026-01) pertaining to the failure to

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.take adequate corrective actions to correct repeated problems with surveillance "

. scheduling and maintenance troubleshooting activities. Based on this-review,

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we find that additional information, as discussed with Mr. Chernoff (during a- .i

telephone call-on September 26,1990) is needed. Specifically, information  ;

should be provided that-describes-your program (s) to ensure that appropriate-

corrective actions have-been taken.- This' information should include a

g ' description of any quality verification functions performed after the'specified

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corrective action .has been implemented and a' description of. the objective

- reviews of proposed corrective actions performed for events.or violations not a

associated with' licensee event reports. Please provide the' supplemental'

information within'30 days:of the date of this letter.- We have also reviewed

the. corrective -actions for the violation (482/9026-02); pertaining' to. the .

1 . reactor ~ posttrip reviews and-found the corrective actions to be responsive to

w theiviolation'.

Sincerely,-

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g Samuel'J. Collins, Director:

, Division of Reactor' Projects

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4' 1 Wolf' Creek Nuclear Operating Corp.

,' ATTN:'- Gary Boyer, Plant Manager

J . sP.O.3 Box'411

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' Burlington, Kansas 66839

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i , ' shawl Pittman,' Potts"& -Trowbr'idge

. ATTN:LJay Silberg,lEsq.

p ,1800 M Street, NW'

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Washington, D.C. 20036

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Wolf Creek Nuclear;0perating. - -2- <

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Corporation 4

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i Public Service Comission-

. ATTN: Chris R. Rogers, P.E.

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Manager ; Electric Department

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~P.O. Box 360-

Jefferson City..Hissouri. 65102

U.S. , Nuclear Regulatory Comission ,

c . ATTN: Regional Administrator,: Region III J

s 799 Roosevelt Roc ..

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' Glen Ellyn,LIllinois; 60137

Woif Creek Nuclear Operating Corp. 4

. ATTN: Otto Maynard, Manager  !

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Regulatory Services <

P.O. Box 411

Burlington, Kansas 66839 j

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< Kansas Corporation Comission .

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ATTN: . ? Robert Elliot, Chief Engineer t

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. . .. ! Utilities Division

= 4th'.. Floor ~- State Office Building:

4 Topeka, Kansas. 66612il571

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~0ffice of the Covernor ,

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Topeka,. Kansas 66612 -

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i Attorney' General

1st' Floor ~'- The Statehouse

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Topeka, Kansas 66612 -

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i ' Chai rman , ? Coffey ' County .Comi ssion

.Coffey. County Courthouse

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" Kansas -Departirant of Health ~ ' '

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-and Environment

LBureau'of Air Quality & Radiation

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ATTN:~ . Gerald Allen, Public

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ATTN: LSeniorRsidentInspector

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8 ' Burlington'," Kansas 66839

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L Wolf Creek' Nuclear Operating . -3-

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,- U.S.~ Nuclear Regulatory Commission .;

.. ATTN: Regional Administrator, Region IV *

611' Ryan Plaza Drive, Suite 1000

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Arlington.. Texas 76011 ,

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bec distrib. by RIV:

R. D.. Martin. Resident Inspector

SectionChief(DRP/D) DRP

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RIV file ' - SRI, Callaway, RIII ':

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MIS System RSTS Operator

ProjectEngineer.(DRP/D) Lisa Shea, RM/ALF

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[' Bart D. Withers

W$t.F CREEK NUCLEAR OPERATING CORPORATION

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Presteent and

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August 30, 199_0 _. ,

MM 90-0155 ,

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U. S. Nuclear Regulatory Cosuaission *

ATTN: Document Control Desk SEP - 41990 q

Mail Station F1-157 " p 1, .

Washington, D. C. 20555 9;j hi._ .. -

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Reference: Letter dated July 51, 1990 from S. J2 Collins, NRC to (

B. D. Withers, WCNOC

Subject: Docket No. 50-482. Response to Violation 482/9026-01

and-482/9026-02  ;

Gentlemen

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Attached is Wolf Creek Nuclear Operating Corporation's (WCNOC) response to

violations 482/9026-01 and A82/9026-02 which 'are documented in the i

Reference. Violation 482/9026-01 concerned multiple examples of inadequate ~

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corrective -actions which have failed to prevent the recurrence of.similar

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events. ' Violation 482/9026-02 concerned several examples of inadequate

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posttrip review: documentation. -

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If you' have any questions concerning this matter, please contact ne or.

Mr. H. K. Chernoff of my staff.

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Very truly yours,

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l Bart D. Withers

President and

Chief Executive Officer

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cca R. D. Martin (NRC), w/a j

D. V.' Pickett (NRC), w/a l

M. E. Skow (NRC), w/a

, -J. S. Wiebe (NRC), w/a #

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P.O. Box 411/ Buriington, KS 66839 / Phone:(316) 364 8831

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Attachmect ts -a 9 0155

Page 1 of 5:

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L Violation (482/9026-01): Inadeauste Corrective Action

Findinn

Criterion XVI of 10 CFR 50, Appendix B, corrective actions, requires, in

, part, that measures shall assure that the cause of the condition is  :

determined and corrective action taken to preclude repetition.

The Licensee Event Report (LER) system described in 10 CFR 50.73, and the

licensee's Administrative Procedure ADM 01-033, Revision 21, ' Instructions  ;

Describing Reportability Review anc Documentation of Licansee Event Reports

(LERs) and Defects / Deficiencies,' paragraph 5.2.7, requires that- an LER A

describs any corrective actions planned as a result of the event, including

those to reduce the probability of similar events occurring in the future.

Contrary to the abovs. .the corrective action specified in LER 90-004, .for

failure to satisfy a Technical Specification (TS) requirement because of.  !

personnel error in scheduling a surveillance test, was not appropriate to-

reduce the- probability of similar events occurring in the future. The

corrective action specified in LER S0-004 was similar to corrective action

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-taken in LER 87-014 to procedurally- require th's review of the past due- ,

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surveillance test report on a weekly basis. This previous corrective action

f ailed to prevent similar events in LERs89-016 and 90-004 from recurring. ,

In addition, the corrective action specified in LER 90-010, .for

inoperability of two' auxiliary feedwater pumps because of a failure to ,

communicate troubleshooting activities on a_ support system to the' licensed l

operators, was not sufficient to prevent a similar event- from . occurring

within;the,next 6 weeks. _On June 18,o1990,

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the control-room operators were

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not adequately informed about troubleshooting activities on the digital rod

position indication system. As a result, several simultaneous alarms and l

indicators were received in the control room which were not expected by the

. operators.

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Reason for Violation:

. This violation identifies two examples of inadequate corrective actions.

The first example.is that the corrective action initiated in response to the

event . discussed in LER 87-014 did not_ prevent. recurrence'of similar events .

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.in LERs89-016 and 90-004. As stated in LER-90-004, the corrective-action

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was' inadequate because' of a failure to continue to check the Past Due

Surveillance Procedures Inquire Report (PDSIR) weekly and to modify. the

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PDSIR as necessary for human factors considerations. This failure to

correctly implement ~ the corrective action was the result of not

proceduralizing the requirement at the time it was developed.

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Attachment to WM 90-0155

Page 2 of 5

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The second example involves situations that developed in conjunction with  ;

troubleshooting activities. LER 90-010 discusses an event in which an  ;

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auxiliary feedwater pump was rendered inoperable because the inspection during l

access door to its associated room cooler had been removed l

troubleshooting. At the time, plant personnel were unaware that removal-of i

the inspection access door rendered-the room cooler ana hence the auxiliary

feedwater pump. inoperable. An event involvine digf5 21 rod position

Troubleshooting

indication (DRPI) system alarms occurred on June 19, .999.

was in progress to identify the cause of previous LAPI am1 functions.z The

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slarms were generated while Instrumentation and Control personnel were

selectively removing cards. This a tivity was being performed with the l

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Shift Supervisor's approval. However, in this instance, not all Control .;

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Room operators: were fully aware of the troubleshooting activities in

This unawareness.

progress and the likelihood of occurrence of DRPI alarms.

is attributed to incomplet6 communications within the operating crew.

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Corrective Steps Which Have Been Taken And Results Achieved

l' As . discussed in. LER' ~90-004, administrative procedure ADH 02-300,, ,

' Surveillance Testing,' has been revised'to require a week 1'y check.for . past -

h. due surveillences using the PDSIR. This report is generated automatically

on a daily basis, and reviewed at least once per week by Surveillance group

. personnel. Since the event discussed in LER 90-004, there have been no

missed scheduled surveillances.

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As discussed in I.ER 90-010 . the fact that inspection access doors must

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remain installed to ensure operability of room coolers throughout the plant In addition..

has been conveyed to Maintenance and Operations personnel.

[ have been reminded- to thoroughly discuss

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troubleshooting activities with the Shift Supervisor prior to commencement

of the activity.

The program for troubleshooting activities has been reviewed and discussed

at the Plant Safety Review Committee meeting. This review has determined

that the program provides an adequate level of control over plant equipment

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while allowing sufficient latitude to perform efficient troubleshooting. l

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-The Manager Operations has held discussions with each operating crew

concerning' Control Room personnel being kept a6equately informed of plant

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activities in progress. These discussions emphasized the importance- of

conveying information to each operator, particularly when troubleshooting

activities are involved.

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Attachment to WH 90-0155

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The process for identifying corrective actions has also been reviewed. It

was identified that corrective actions are occasionally event-specific and

therefore are not completely effective in preventing recurrence of somewhat

abnilar events. In an effort to ensure identification of corrective actions

of a more general nature when apprcpriate, the Compliance group which

reports to the Manager Plant Support is now performing objective reviews of-

proposed . corrective actions- associated with Licensee Event Reports and

providing management with recommendations for improvement.

Corrective Steos Which Will Be T,sIf,9,To Avoid Further Violations:

A licensed operator with assistance from computer. services personnel are

reviewing- the logic flow charts associated with the serveillance~ scheduling

program. This review is intended to identify enhancements to the existing

surveillance scheduling program. Implementation of enhancements identified

- will require changes to existing computer software.

Date When Full Comoliance Vill Be Achieved:

The review and. program enhancements identified by this review will be fully

. implemented by April 19, 1991.

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Attachment to WM 90-0155

Page 4 of:5

Violation (482/9026-02): Influre to Follow Procedures

Findinn:

TS require that written procedures shall be established, isiplemented, and

maintained covering those activities recommended in Appendix A of Regulatory

~ Guide (RG) 1.33.-Revision 2, February 1978. RG 1.33 requires, in part, that j

there be. administrative procedures covering the authorities and 4

responsibilities for safe operation and shutdown.

Procedure ADH 02-400, Revision 7 'Posttrip P.eview,' Section 6.5.1 states '

that strip-chart recordings must accurately reflect real time to have

meaningful information. Section 6.12.1 requires that the actual or

suspected cause of the trip and any abnormal or degraded indication

identified during the transient shall be documented in Part 6 of the

posttrip review report. Sections 5 1.1 and 1.2' state that the posttrip. 1

review. will permit a determination to be made as to the readiness of the

plant to' safely restart.

, contraryLto the above, the stripcharts included in tbIe posttrip reviews for

May 14, 17, and 19,.1990, did.not~ reflect real~ times Part 6 of the posttrip ~' .1 ,

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review for May 14, 1990, was not completed;and the posttrip review for May '

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17, 1990,- did not completely document corrective actions taken or efforts. i

-taken to look for other contributing causes.- 1

Reason for Violation:

WCNOC purchases strip-chart paper with divisions that relate to the- actual  ;

speed of the chart recorder. The chart. recorders are marked once a day with i

a-date'and time at approximately midnight. Additionally, comparisons of' '

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parameter state changes on the Sequence of Events and:the Time History Event

Recorder printcuts with the strip-chart recordings are utilized to determine

at .which time events occurred. In preparation of the posttrip review

package, copies of pertinent sections of the ' strip-chart recordings are

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made.: Annotation of date and time on the-pertinent sections of the strip . j

chart recordings-in the posttrip review packages was not being performed.  ;

The failure to complete Part.6 of the posttrip review for May 14, 1990 and

the failure to documert all the actions taken.to correct the known cause of. 1

the trip for' May 17, 1990 was due to licensed operator personnel error.

Operations personnel incorrectly assumed that since the information was

identified elsewhere in the posttrip review package or' addressed on other

vork documents that this information need not be identified specifically in

the appropriate parts of the posttrip review package. i

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Attachment to WM 90-0155

Page 5 of 5

Corrective Stoos Which liave Been Taken And Results Achieved:

The Manager Operations has discussed this violation with the, Shift *

Supervisors to ensure they are cognisant of the procedure requirements for

documenting each Part of the posttrip review package.

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Corrective Stoos Which Will Be Taken To Avoid Further Violations:

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Yrocedure ADM _02-400, 'Posttrip Review,' will be revised to require

annotating a date and time on the sections of strip-chart- recordings

included with the pos'. trip review package. Part 6 of this procedure will be-

revised to include documenting corrective actions t. ken and identification

of the individual responsible for completing Part 6 of the procedure.

WCNOC will review the additional concerns associated with ADH 02-400 noted

'in the NRC Inspection Report as part of the revision ' effort identified '

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above.

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Date When Full Comollance Will Be Achieved:

Review .and complete-- -revision of ADH 02-400, 'Posttrip. Review' to r

in'orporate

c the corr'ective action above as'well as other enhancements- will - "-- <

be completed by December 31, 1990.

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