ML20076D595
| ML20076D595 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 07/24/1991 |
| From: | Bailey J WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NO-91-0198, NO-91-198, NUDOCS 9107300038 | |
| Download: ML20076D595 (3) | |
Text
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i W9LF CREEK NUCLEAR OPERATING CORPORATION John A. Dailey Vice President Operations July 24,1991 NO 91-0198 U. S. Nuclear Regulatory Commission ATTH:
Document Control Desk Mail Station P1-137 Washington, D. C.
20555
Reference:
Letter dated June 24, 1991 from S. J. Collins, NRC to B. D. Withers, WCNOC
Subject:
Docket No. 50-482: Response to Violation 482/9111-01 Gentlemen:
Attached is Wolf Creek Nuclear Operating Corporation's (WCNOC) response to violation 482/9111-01 which is documented in the Reference.
Violation 482/9111-01 involved a failure to restore battery. charger NK023 to setvice within the specified interval while the plant continued to operate in Mode 1.
If yc2 have any questions concerning this matter, please contact me ot Mr. H. K. Che..aoff of my staff.
Very truly yours,
& a.
+
John A. Bailey Vice President Operations l
JAB /aem Attachment i
cc L. L. Gundrum (NRC), w/a A. T. Howell (NRC), w/a R. D. Martin (NRC), w/a D. V. Pickett (NRC), w/a 2107300036 ?1O M p.DR ADOCf OnOOUN_ '_
Ubbb RO. Box 411 ! Burlington, KS 66839 i Phone: (316) 364-8831
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- J Attachment to NO 91-0198 0
Page 1 of 2 l
Response to Violation 482/9111-01 l
Violation (482/9111-01):
Violation of Technical Specification 3.8,2.1.a and l
3.8.3.1.1 l
Findings j
i Wolf Creek Generating Station Technical Specification (TS) 3.8.2.1.a
- requires, in part, that the 125-Volt Battery Bank NK13 and its associated j
Full Capacity Charger NK23 be operable in Modes 1, 2, 3, and 4 With one of the battery banks and/or full capacity chargers inoperable, restore the j
inoperable battery banks and/or full capacity charger to OPERABLE status j
within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
TS 3.8.3.1.1 requires that-the
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125-Volt DC Bus NK03 be energized from Battery NK13 and Charger NK23.
l t
Contrary to the above, between November 23 and 27,
- 1990, the plant was operated in Mode 1, with the Battery Charger NK23 inoperable.
This resulted when plant operators implemented a Technical Specification interpretation that. allowed the substitution of the spare batter charger (NK25) for NK27.
It was-subsequently determined that certain design requirements were not met
-when NK25 was used as a temporary replacement.
Reason For Violation:
On November 23,
- 1990, battery charger NK023 was taken out of service for correctivo maintenance.
In accordance with procedure MCE E051Q-01,
" Emergency Supply to an NK Bus From Spare Charger NK025",
spare battery charger NK025 was p. aced in service ~as a temporary replacement for battery charger NK023. The inspector's review of this activity identified a concern in that the technical specifications do not address the use of the spare charger.
' Subsequently, Wolf Creek Nuclear Operating Corporation (WCNOC) committed to submitting a license amendment request to clarify the.use of-spare charger NK025.
During the preparation and review of the license amendment request, a
. concern was identified regarding the requirements for cooling the nonvital
-AC switchgear room (NK025 location).
A defect / deficiency report was initiated and a subsequent engineering evaluation determined that certain design requirements were not fulfilled when spare charger NK025 was utilized to power'a safety-related battery bus.
This event was reported to the NRC in License Event Report (LER) 90-026-00 on May 10, 1991.
WCNOC acknowledges - that the plant was operated in r condition prohibited by Technical Specification 3.8.2.1.a.
This condi ion resulted from the implementa' t 'n of procedure MCE E051Q-01.
As discussed in LER 90-026-00, the cause of this event was due to an error i the sefety evaluation for procedure MCE E051Q-01.
The purpose of e.4 procedure was to provide the capability to maintain power on a.125V DC System bus when its normal battery charger failed by utilizing the spare charger NK025 and temporary jumper cables.
w:.. s
' Attachment to NO 91-0198 Page 2 of 2 In accordance with procedure ADM 02-302,
" Technical Specification Interpretations",
a -Technical Specification Interpretation is an approved j
management-auidance document.
A Technical Specification Interpretation is not a procedure or document that allows for reevnfiguring plant components.
-Technical Specification Interpretation Request (TSIR)
No.
004-88 was initiated during the same time that procedure MCE E051Q-01 was being developed.
Based on internal discussions and reviews during the development of the procedure,_it was. believed that NK025 could be considered an operable full capacity batter charger so long as NK025 was energized from the same saf et.y _ train as the charger it was replacing.
TSIR No.
004-88 was written to provide guidance on Technical Specifications 3.8.2.1, 3.8.2.2, 3.8.3.1 and 3.8.3.2 while the procedure and associated safety evaluation provided for-implementing the use of spare charger NK025.
The use of spare charger NK025 was
' governed by procedures not a Technical Specification Interpretation.
Corrective Steps Which Have Been Taken And Results Achieved:
Procedure MCE E051Q-01 was voided on April 30, 1991.
Tne details of this event. and the need to review the applicable reference materials was discussed with' personnel performing ~ safety evaluations in Results Engineering.
TSIR No. 004-88 was formally voided on April 16, 1991.
Corrective Steps Which Will Be Taken To Avoid Violations:
The Safety Evaluation Guidelines used by Results Engineering personnel have been_ changed to remind personnel to review support system functions and the need to review applicable reference materials.
A sample of safety evaluations conducted by Results Engineering personnel from 1985 to 1990 was reviewed to ensure that incorrect-conclusions in safety evaluations was not a generic problem.
Date When Full Compliance Will Be Achieved Full compliance was achieved with the deletion of procedure MCE E051Q-01 on
_ April 30, '1991 and with the completion-of the review of a sample of safety evaluations on June 21, 1991, r
Additional Information:
NRC' Inspection Report 50-482/91-01 identified concerns with the Technical Specification Interpretation process.
As a result of these concerns, procedure MNi 02-302 is. being revised to require better documentation to support Technical Specification Interpretations.
Additionally, the Technical Specification ' Interpretation review process is being enhanced by the inclusion of a representative from Nuclear Plant Engineering on the Technical Specification Interpretation Subcommittee.
The revision to procedure ADM 02-302 will be completed by August 31. 1991.
As'previously_ mentioned, WCNOC had committed to submit a license amendment request to clarify the use of spare charger NK025.
As a result of this L
event, a-license amendment request will not be submitted.
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