ML20072N012
| ML20072N012 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 08/24/1994 |
| From: | Carns W WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| WM-94-0137, WM-94-137, NUDOCS 9409020289 | |
| Download: ML20072N012 (9) | |
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W$) NUCLEAR OPERATI LF CREEK August 24, 1994 Ned s "Bou carns Chairrnan, President and Chmt f afcutim otticar U.
S.
Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, D.
C.
20555
Reference:
Letter dated July 25, 1994, From A.
B. Beach, NRC/RIV, to N.
S.
Carns, WCNOC
Subject:
Docket No. 50-482:
Reply to Notices of Violation 482/9406-01,
-02,
-04 Gentlemen:
Attached is Wolf Creek Nuclear Operating CorporaLion's (WCNOC's) Reply to Notices of Violation 482/9406-01,
-02,
-04 which were documented in the Reference (NRC Inspection Report 50-482/94-06).
Violation 482/9406-01 concerned WCNOC's failure to enter the appropriate Technical Specification limiting condition for operation during postmaintenance testing.
Violation 482/9406-02 concerned WCNOC's failure to perform emergency maintenance activities in accordance with plant procedures.
Violation 482/9406-04 concerned WCNOC's failure to comply with Security Plan procedures relating to patrol guard tours.
WCNOC's response to these Notices of Violation is in the Attachment to this letter.
The corrective actions for these violations are comprehensive and will ensure WCNOC's compliance with the applicable regulations and procedure requirements.
If you shoulo.kave any questions regarding this response, please contact me at (316) 354-9831, extension 4450, or Mr.
R. D.
Flannigan at extension 4500.
Very truly yours, N 11 S.
Car s NSC/jad Attachment cc:
L.
J.
Callan (NRC), w/a D.
N.
Graves (IEC), w/a W.
D. Reckley (tmC), w/a J.
F.
Ringwald (NRC, w/a g 0([ y 94o9020 2 9 940s:4 eO oo,4ii, so,nmoioe. xs ee839 e rmcee <34e> 3e4-883, j
DR ADOCK 050004a2 An Equal opportunity Ernploym M FMCYET PDR l
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Attachment to WM 94-0137 Page 1 Reply to Notings of Violation 9406-01.
-02,
-04 Violation 482/9406-01:
Failure to Enter Correct Technical Specification resulted in missed Surveillance.
"A.
Technical Specification 3.8.1.1, Action b, requires, with one diesel generator of the required AC electrical power sources inoperable, demonstrate the OPERABILITY of the offsite AC sources by performing Technical Specification 4.8.1.1.1 within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter.
Contrary to the above, following postmaintenance testing of Train A essential service water inlet and outlet valves to the Train A component cooling water heat exchanger, on June 16,
- 1994, the inspector identified that control room personnel entered Technical Specification 3.7.3 instead of Technical Specifications 3.7.4 and 3.8.1.1.
Because the control room personnel entered the incorrect Technical Specifications limiting condition for operation, the control room personnel failed to realize that they needed to verify the availability of the offsite power supplies within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, as required by 1schnical Specification 3.8.1.1, Action b."
Admission _nL.yiolationi.
WCNOC acknowledges and agrees that a violation of WCGS Technical Specification occurred when OPERABILITY of the offsite AC sources was not verified within one hour due to control room personnel entering the wrong Technical Specification.
Reason _for violationi.
The root cause of this occurrence was inadequate job scoping of the Motor Operated Valve (MOV) retest sequence.
The failure to identify special conditions led to unanticipated interaction with the Essential Service Water (ESW) system and an inoperable Emergency Diesel Generator (EDG).
The Component Cooling Water (CCW) heat exchangers are cooled by ESW, with an inlet and an outlet MOV on the ESW side.
In parallel with the outlet MOV is a locked throttled manual valve.
The Safeguards positions for the MOVs are the inlet open and the outlet closed.
This arrangement provides proper cooling water flow for the CCW system while balancing the ESW flow to ensure sufficient cooling for other components, in particular the Emergency Diesel Generators.
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The Limitorque actuators on these MOVs were changed out under Plant Modification Request (PMR) 4764.
Work on the "B"
train valves was performed on May 3,
- 1994, j
and "A"
train on June 15, 1994.
The actuator replacement was accomplished with both the inlet and outlet valves blocked in their respective Safeguards position, maintaining the CCW system OPERABLE.
The clearance order was then lifted, removing the blocks and leaving the valves de-energized in their Safeguards position.
This configuration was desired to begin setting the limit l
Attachment to WM 94-0137 Page 2 switches and for performing required Valve Operation Test and Evaluation System (VOTES) testing.
During the VOTES testing, cooling flow to the CCW heat exchanger would be intermittent.
Therefore, in both instances, Control Room personnel declared the appropriate train of CCW inoperable and entered Technical Specification 3.7.3.
For the "A"
train work, this occurred at 2035 hours0.0236 days <br />0.565 hours <br />0.00336 weeks <br />7.743175e-4 months <br /> CDT on June 15, 1994.
l As the limit switches were being set on the "A"
train outlet valve, EF HV-59, the drive sleeve was driven past the worm gear wnich operates the limit switches.
This rendered the valve incapable of being closed.
The problem was reported to the Control Room at 2140 hours0.0248 days <br />0.594 hours <br />0.00354 weeks <br />8.1427e-4 months <br /> on June 15, 1994.
Subsequent discussion with the ESW System Engineer led to the realization that the ESW Safeguards flow balance was altered and, most limiting, the "A"
train EDG may not have received sufficient ESW flow if it were needed to provide Safeguards power.
The Shift Supervisor declared the "A"
train ESW system and the "A"
EDG inoperable at 2233 hours0.0258 days <br />0.62 hours <br />0.00369 weeks <br />8.496565e-4 months <br /> and entered Technical Specifications 3.7.4 and 3.8.1.1 respectively.
He also ordered that the ESW inlet valve to "A"
train CCW heat exchanger, EF HV-51, be maintained closed.
At 2254 hours0.0261 days <br />0.626 hours <br />0.00373 weeks <br />8.57647e-4 months <br />, EF HV-51 was verified closed and Technical Specifications 3.7.4 and 3.8.1.1 were exited.
During review of this event, WCNOC Operations personnel discovered that on May 3,
1994, a similar event occurred on the "B"
train.
Both events were detailed in LER 94-006-00 submitted to the Nuclear Regulatory Commission on July 15, 1994.
Technical Specification 3.8.1.1, Action statement "b"
requires, in part, that offsite A.C.
power sources be demonstrated OPERABLE within one hour after declaring an EDG inoperable.
This is accomplished through performance of surveillance test procedure STS NB-005,
" Breaker Alignment Verification."
In this case, STS NB-005 was completed satisfactorily at 2323 hours0.0269 days <br />0.645 hours <br />0.00384 weeks <br />8.839015e-4 months <br />.
In planning the PMR implementation for these MOV's, CCW operability was considered but not ESW operability.
The retest activities could have been sequenced so that ESW operability would not be affected.
Ac these activities were actually performed, the appropriate ESW system and EDG should have been declared inoperable at the same time as their related CCW system.
For the "A"
train evolution, entry into Technical Specifications 3.7.4 and 3.8.1.1 should have been made at 2035 hours0.0236 days <br />0.565 hours <br />0.00336 weeks <br />7.743175e-4 months <br /> on June 15, 1994.
As STS NB-005 was not completed until 2323
- hours, Technical Specification 3.8.1.1, Action statement
- b" was not satisfied, Corra.clire_Stena_Taken_And_Regults Achigy_gsli Initially, a hold was placed on all VOTES testing.
The Vice President Plant Operations subsequently authorized such testing to continue provided an evaluation of the conditions required for the work and retest was approved by Operations.
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Attachment to WM 94-0137 Page 3 l
1 Operations coordinated an evaluation of all Limitorque MOV's in the VOTES program in order to determine special conditions and system inter-relationships which may be applicable in testing each valve.
Cggrgetivi. Simps _That will Be Taken to Avoli Furtiler violations :
The results of this evaluation will be included in the Integrated Plant Scheduling database.
All valves in the MOV program which when tested could affect other systems will be identified.
This will ensure that operability of affected systems is considered when scheduling work on these valves.
This action will be completed as soon as practical, but no later than November 30, 1994.
The corrective actions described above are considered appropriate and sufficient to avoid further similar violations.
DatD_When_Zull Compliance Will Be Achievedi Full compliance will be achieved when the results of the assessment are incorporated into the Integrated Plant Scheduling database, no later than November 30, 1994.
Attachment to WM 94-0137 Page 4 l
l Violation 482/9406-02:
Inadequate Priority 1 work documentation and failure to follow WCGS procedures to verify and perform a second check on local control tags "B.
Technical Specification 6.8.1.a states that written procedures shall be established, implemented, and maintained covering the applicable procedure recommended in Appendix A of Regulatory Guide 1.33, Revision 2,
dated February 1978.
(1)
Regulatory Guide 1.33, Appendix A,
Item 1.c, requires administrative procedures to address equipment control (e.g.,
locking and tagging).
" Clearance Orders, Revision 0,
Step 6.4.2, specifies that the " local control tags shall be verified and second checked as required by Step 6.4.14 prior to any manipulation of the components.
Contrary to the above, on May 19, 1994, electricians began removing terminals from a circuit card in the NK22 battery charger before the AC breaker tag was hung and second checked.
(2)
Regulatory Guide 1.33, Appendix A,
Item 9,
specifies, in part, that maintenance that can affect the performance of safety-related equipment should be performed in accordance with written procedures appropriate to the circumstances.
Procedure ADM 01-057, " Work Request," Revision 30, Step 2.1, specifies that the WR will be used to document and control work performed on plant systems.
Contrary to the above, on May 19, 1994, electricians performed Priority 1 work on the NK22 battery charger without an approved work document."
Admission of violation 1 WCNOC acknowledges and agrees that a violation of WCGS Technical Specifications (TS) occurred when personnel failed to ensure the appropriate WCGS procedural requirements were followed during Priority 1 work on the NK 22 battery charger.
Reason for violation The root cause of this violation is cognitive personnel error in failing to ensure the appropriate plant procedures were adhered to during Priority 1 work.
On May 19, 1994, WCGS Electrical Maintenance personnel were assigned to Priority 1 work on a f ailed NK22 battery charger.
Local control tags were hung during the troubleshooting process on the AC and DC breakers.
However, an individual did not perform the verification and second check prior to the removal of terminals from the DC circuit board.
i
Attachment to WM 94-0137 Page 5 The electricians had taken precautions to check for voltage at the breakers knowing the NG feeder breaker was still energized.
This was verified by taking voltage measurements at the 480 volt terminals in the charger.
The AC input breaker on the charger had been opened and verified.
1 Per procedure AP 4A-001, " Clearance Orders," step 6.4.2.3, "The placement of the Local Control Tag (s) shall be verified and second checked as required by 6.4.1 4 prior to any manipulation of the component (s). "
Due to personnel oversight the j
procedural requirement to perform a verification and second check of the local control tags was not performed.
However, the electricians had previously verified the circuit breakers were opened.
It was also cited that the NK22 battery charger Priority 1 work was not performed with approved work instructiotu,.
As stated in the Notice of Violation, Procedure ADM 01-057,
- Work Request," requires that all wolk be performed with approved work instructions.
The Notice of Violation states that neither the inspector nor WCNOC could find current procedural guidance for the conduct of Priority 1 work which differentiated it from other Priority work.
However, additional review by WCNOC has revealed that Priority 1 work is differentiated from other priority work in procedure ADM 08-206,
" Corrective Maintenance," step 7.1.1 which states that Priority 1 WRs are exempt from j
portions or all of the NORMAL Planning Process.
Additionally, the WR in question was marked " troubleshooting" which per ADM 01-057, Revision 30, step i
2.6.3, permits documentation of the work to be done in a step-by step chronological log as work progresses.
This was accomplished by the electricians and the Electrical Maintenance Supervisor.
CRIIRCLtiYtL_Stepa__That_.liale Been Taken and the Results Achieved:
On May 20, 1994, a critique meeting was held with the personnel involved in the NK 22 battery charger restoration.
The usage of local control tags outside of procedural guidance was reviewed.
The need to verify and second check each local control tag to ensure that it is placed on the correct component before commencement of work was discussed with the personnel involved.
As the procedural guidance for Priority 1 work was not easily found and limited in scope, WCNOC revised Attachment 1 to procedure ADM 01-028A, "Prioritization of Wolf Creek Activities," Revision 0, on June 30, 1994, to clarify the actions necessary for implementation of Priority 1 work including clearance order requirements.
Attachment to WM 94-0137 page 6 COIrmatire_ Steps That Will._heJaken to Aygid Further violationn:
The corrective actions described above are considered appropriate and sufficient to avoid further violations of this nature.
Therefore, all corrective actions are completed and WCNOC is in full compliance with WCGS TS 6.8.1.a and the associated WCNOC procedures.
DAte_Ehen Full._Complignae Will be lchiere.d1 All corrective actions related to this violation were completed by J2ne 30, 1994.
Full compliance with the associated regulatory requirement has already been achieved.
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Attachment to WM 94-0137 Page 7 Violation 482/9406-04:
Failure to follow Security procedures and enter seven rooms to perform visual inspections during a vital area guard tour.
"D Teca tal Specification 6.8.1.c require written procedures shall be established, implemented, and maintained covering the Security Plan implementation.
Procedure SEC 01-103,
" Patrol," Revision J4, Step 7.1.2.1, specifies, in part, that doors shall be opened and the area inspected within operational constraints.
Contrary to the above, on June 15, 1994, the inspector identified that on May 30, 1994, a security officer failed to enter seven rooms and perform visual inspections during a Patrol-2 vital area guard tour."
Admission of Violation 1 WCNOC acknowledges and agrees that a violation of WCGS Technical Specifications (TS) occurred when personnel failed to perform vital area guard tours as specified in the WCGS Security Plan.
EnAson for violation 1 The root cause of this violation is cognitive personnel error in failing to ensure appropriate Security Plan procedures were adhered to during vital area guard tours, Through discussions with the officers involved it was apparent that some officers were not aware of all the requirements in Security Procedure SEC 01-103, " Patrol," Revision 14.
It is apparent that some officers were under the misconception that a thorough tour was only required on the first round through the area, and that a cursory l
check would be sufficient for all remaining patrol' tours during the remainder of their shif?.
Additionally, lack of identification that these tours were not completed adequately showed a lack of oversight on the part of the on-duty Security Shift Lieutenant.
CQIrmatiYe StepE_That_.liaym_.Bagn Taken and the Reiults Achieved:
1 WCNOC Security management has discussed the expectations and procedural requirements of each patrol with each security Shift Lieutenant to ensure their review of patrol activities.
It was also clarified to Security personnel that
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cursory room checks do not meet the intent of the procedure, and that they must j
enter the area and inspect it unless prohibited by operational constraints.
l The WCNOC Security Administrative Coordinator met with each squad during their first training week and discussed the violation of Security Procedures, and the ensuing corrective actions.
Additionally, the procedural requirements for actions to be taken while on patrol were reviewed, i
Attachment to WM 94-0137 Page 8 To ensure that all similar events were documented, WCGS Security personnel i
reviewed the previous two patrol tours for all officers.
When discrepancies were noted the responsible officer was contacted and counseled on the patrol procedure and appropriate actions to be taken while on patrol.
To prevent future occurrences, WCGS Security Procedure, SEC 01-103, " Patrol" was revised on August 4,
1994, requiring the Security Shift Lieutenants to perform random weekly reviews of officer patrol tours.
CQKISS11YA_.J11liRg_That Will Be TAhen to Avoid Fur 1her Violationgi l
The corrective actions described above are considered appropriate and sufficient to avoid further violations of this nature.
Therefore, all corrective actions are completed and WCNOC is in full compliance with WCGS TS 6.8.1.c and the associated WCNOC procedure.
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DAtg_Hhen Full Compliance Will Be Achieved:
1 All corrective actions related to this violation were completed on August 19, 1994.
Full Compliance with the associated regulatory requirements has already been achieved.
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