ML20077L161
| ML20077L161 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 01/06/1995 |
| From: | Carns N WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| WM-95-0004, WM-95-4, NUDOCS 9501110236 | |
| Download: ML20077L161 (7) | |
Text
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.4-W$LF CREEK NUCLEAR OPERATING CORPORATION Ned S Duzz" Carns January 6, 1995 Chairman President and WM 95-0004 Ch4ef EmeCutsve Offu:er U.
S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, D.
C.
20555 i
Reference:
Letter dated December 8, 1994, from T.
P. Gwynn, NRC/RIV, to N. S.
Carns, WCNOC
Subject:
Docket No. 50-482: Reply to Notices of Violation 482/9411-02 and 482/9411-04 Gentlemen:
Attached is Wolf Creek Nuclear Operating Corporation's (WCNOC's) reply to Notices of Violation 482/9411-02 and 482/9411-04 which were documented in the Reference (NRC Inspection Report 50-482/94-11).
Violation 482/9411-02 concerned inaccurate information documented within two of WCNOC's surveillance reports.
i Violation 482/9411-04 concerned WCNOC's failure to follow plant procedures which require a written explanation for the use of *not applicable" in a procedure if not specifically permitted in the body of the procedure.
WCNOC's response to these Notices of Violation is in the Attachment to this letter.
If you should have any questions regarding this response, please contact me at (316) 364-8831, extension 4000, or Mr.
R.
D.
Flannigan at extension 4500.
Very truly yours, Neil S. Carns NSC/jad Attachment cc L. J.
Callan (NRC), w/a D. D.
Chamberlain (NRC), w/a J. F. Ringwald (NRC), w/a J.
C. Stone (NRC), w/a i
9501110236 950106 PDR ADOCK 05000482 Q
PDR l
PO Box 411/ Burlington, KS 66839 / Phone (316) 364-8831 An Equal Opportunity Employer M T/HC/ VET
i e
- Attachment'to WM 95-0004
'Page 1 of 6 f
1 Rapiv to Motices of violation 9411-02. and -04 l
Violation 482/9411-02:
Inaccurate Information Documented in two Surveillance Reports
- A.
10 CFR 50.9(a) states, in part, that information required by the Commission's regulations to be maintained by the licensee shall be complete and accurate in all material respects.
Contrary to the above, surveillance reports of contractor eddy current examination activities during 1991 and 1993 refueling outages, for which j
Criteria XVII and XVIII of Appendix B to 10 CFR Part 50 were applicable,.
included inaccurate information with respect to the software used for analysis of eddy current data."
1A=4mmion of violations t
WCNOC acknowledges and agrees that a violation of 10 CFR 50.9(a) occurred when inaccurate information was documented in the 1991 and 1993 surveillance reports of contractor eddy current examination activities.
Reason for Violations The root cause of this occurrence was inattention to detail in that the information for the documentation of the software used for eddy current data analysis was obtained from purchase order documents and not validated through direct field observation or personnel interviews by the Quality Evaluator.
Procedure QAP 18.3, "Surveillt.nce Procedure,"
- requires, in part, that objective evidence be collected through direct observation,- documentation review and/or personnel interviews.
The information about the type of sof tware was obtained strictly from the original purchase order without any further validation.
In this case a combination of documentation review and direct observation or personnel interviews should have been used.
6 The surveillance reports contained inaccurate information regarding the computer software used by contractor personnel to perform secondary analysis of the eddy current data.
The Quality Evaluator indicated on both the 1991 and the 1993 surveillance reports that DDA-4 software had been used for performing the analysis, when in fact Westinghouse used ANSER software for primary analysis and Conam used Zetec Eddynet for secondary analysis.
The Quality Evaluator obtained the information from the original purchase order which specified the use of DDA-4 software.
l CQIractive Etapa Taken and Ramulta Achievedt Performance Assessment management discussed this issue with the Quality i
Evaluator responsible for each report and reiterated that information contained within surveillance and audit reports must be substantiated by objective evidence and the basis for the conclusions documented in the report.
The two surveillance reports with incorrect software referenced were revised to remove the specific type of software used.
It was determined that these inaccuracies would not have changed the conclusions reached in the
1 Attcchment to WM 95-0004 Page 2 of 6 surveillance reports, thus these inaccuracies have no impact on plant or public health and safety.
A Performance Improvement Request (PIR) 94-1804 was initiated to document the error, determine the root cause and corrective actions, and evaluate if there were any generic implications.
As part of the PIR evaluation, a review of 25 audits and 78 surveillance reports from January 1, 1993 through October 20, 1994, was conducted by non-Quality Assurance personnel to determine potential generic implications.
The timeframe was selected since it represented twenty-two months of the current twenty-four month audit cycle and surveillance activities from two refueling outages.
The review looked specifically for inaccuracies in the technical data of the reports.
Technical data included items such as procedure references, work request information, equipment identification and other specific references.
A final total of 864 information/ data points were verified in both the audits and the surveillances. Only one inaccurate statement was determined to affect the conclusions reached in an audit report.
This inaccuracy pertained to a management corrective action goal. The audit report incorrectly stated the goal was achieved, when in actuality the goal had only been established and not achieved. This audit report has been corrected.
Since only one inaccuracy of significance was identified out of 864 items verified, it is evident that Quality Assurance audits and surveillance reports written since January 1, 1993, contain a high level of accuracy with regard to the conclusions reached.
Based on the results of the review, Performance Assessment management decided additional review (prior to January 1, 1993) was not warranted.
The identified inaccuracy did not impact plant safety and public health and safety were assured at all times.
The Manaaer Performance Assessment has personally reinforced his expectations with ea h member of the Quality Evaluations Group with respect to making factual statements in reports, providing the basis for each conclusion, and continually maintaining a questioning attitude and careful attention to detail during the evaluation and reporting process.
The general issue of attention to detail at Wolf Creek has been discussed at the daily morning management meeting and is receiving special emphasis by senior management.
Correctlyf Steps That Will Be Taken to Avoid Further Viglgtigng:
The corrective actions described ai ve are considered appropriate and sufficient to avoid further similar violacions.
Date When Full Comoliance.Was Achieved Full compliance was achieved on November 2, 1994.
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Attachment to WM 95-0004 l --
Page 3 of 6 l
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- =alv to Moticam of violatinn 9411-02.
=ad
-04~
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-Violation 482/9411-042-Failure to follow Operations Procedures while filling the B and C Steam Generators for wet' layup.
i
- B.
Criterion V of Appendix B to 10 CFR 50 requires, in part, that activities affecting quality shall be accomplished in accordance with procedures of a type-that are appropriate to the circumstances.
Step 4.5 of Procedure SYS AQ-320, Revision 18, requires the addition of chemicals to the steam generators while performing Steps 4.6 through 4.13 of the procedure.
Step 4.6 of the procedure pertains to raising the water level of the steam generators from F4 to 90 percent using a i
condensate pump or, alternatively, an auxiliarf feedwater pump in accordance with the requirements of Procedure SYS AL-120.
j contrary to the above, chemicals (i.e., hydrazine) were not added to Steam Generators B and C until the following day after performing Step 4.6 of Procedure SYS AQ-320, Revision 18, using an auxiliary feedwater f
pump in accordance with Procedure SYS AL-120."
[
ad=4maion of violationt WCNOC acknowledges and agrees that a violation of Criterion V of Appendix B to 10 CFR 50 occurred during the performance of Procedure SYS AQ-320, " Placing i
the Steam Generators in Wet Layup," 'davision 18.
Licensed Operators failed to properly document the use of "not appilcable" as required by Procedure AP 15C-l 002, " Procedure Use and Adherence."
l Reason for Violations The root cause of this occurrence was inattention to detail by Licensed i
Operators during the performance of Procedure SYS AQ-320, in that they did not
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properly document their actions while transitioning from Procedure SYS AQ-320 l
to Procedure SYS AL-120,
" Feeding Steam Generators With A Motor Driven or Turbine Driven Auxiliary Feedwater Pump."
On October 8,
1994, Operators started Procedure SYS AQ-320 to put Steam Generators B and C into wet layup.
At step 3.9, Chemistry was contacted and 7
verified the adequacy of the makeup water chemistry.
The procedure was completed through step 4.4.3.
.The next step.
4.5, directs the Operators to add chemicals to the steam generators using the Feedwater Chemical Addition System, while performing Steps 4.6 through 4.13, and references the Operators to Procedure SYS AQ-121, "Feedwater Chemical Addition to the Steam Generators." The Operators are then directed in step 4.6 to raise the water level in all applicable steam j
generators to 80 to 90 percent wet layup using the Feedwater Bypass Valves and l
a Condensate Pump or the Auxiliary Feedwater Pump.
After completing step 4.4.3, Operators determined that they should not add chemicals because maintenance was still in progress on the Steam Generator Blowdown System. This system is required to properly recirculate chemicals in j
the steam generators.
Procedure SYS AQ-320 was suspended and left as an open i
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. Attachment to WM 95-0004
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Page 4 of 6 procedure on the Supervising Operator's desk until all maintenance was completed.
This practice is periodically done when plant conditions do not allow continuing the procedure at that time.
This practice is considered acceptable as long as the Supervising Operator reviews the plant configuration and determines, as was done in this case, that there are no plant safety concerns associated with suspending the procedure and the duration of such a suspension is not excessive.
The suspension of Procedure SYS AQ-320 was not documented in the remarks section on the cover page of the procedure or in the Control Room Logs. Documenting a procedure suspension is not required, but it is a good practice and is an expectation of management.
Operators considered adding chemicals without recirculation cap 6.tlity, 2:a determined that the incomplete mixing of chemicals and the po c, t M for stratification of pure water and highly concentrated chemicals war m
undesirable condition.
Operations and Chemistry personnel concluded that filling the steam generators, while not being able to add chemicals, was no more detrimental than the existing wetted condition with a humid atmosphere.
The above decisions were not documented in the remarks section of the procedure or in the control Room Logs.
Documenting decisions is not required, but it is a good practice and is an expectation of management.
Operators, Outage Management personnel, and Health Physics personnel later discussed the benefit of filling the steam generators for ALARA reasons, since a number of maintenance activities were ongoing within the bio-shield. Health Physics personnel actively pursued this as an ALARA concern because filling the steam generators would reduce personnel exposure.
On October 8,
1994, Operators used Procedure SYS AL-120 to fill the water level in the steam generators and reduce radiation levels to personnel in Containment.
Procedure SYS AL-120 is the normal method for adding water to the steam generators and is used several times during every outage to adjust steam generator water levels.
On October 9, 1994, when recirculation capability was restored, Procedure SYS AQ-320 wac recommenced and step 4.5 initialed and dated.
Step 4.6 was marked "not applicable" because the water level had been raised the day before using Procedure SYS AL-120.
The operator's thought process in marking the step as "not applicable" was correct, but the operator failed to document the use of
" Procedure Use and Adherence."
Chemicals were properly added prior to the completion of step 4.13, as required by step 4.5, and the procedure completed.
The lack of documentation of both the use of "not applicable" and of the suspension of the procedure shows an apparent lack of compliance with Procedure SYS AQ-320 since the steam generators were filled without adding chemicals.
However, since Procedure SYS AQ-320 was in suspension, and the steam generators were properly filled using another procedure, there was not a violation of Procedure SYS AQ-320.
There was, however, a violation of the requirement to document a valid use of "not applicable."
WCNOC personnel determined that filling the steam generators was technically acceptable and warranted because of ALARA conditions.
WCNOC also acknowledges, when conditions permit, that filling while adding chemicals would be the optimal solution.
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.Attechment to WM 95-0004 Page 5 of 6 CQIInctive stana Tahan =ad namulta kehieved:
Although filling the steam generators without chemicals was a conscious decision based on plant conditions and worker protection, WCNOC identified the need to review overall steam generator management relative to other work activities during refueling outages.
Thir. was documented on Performance Improvement Request (PIR) 94-1807.
Procedure SYS AL-120 was enhanced to require a verification of makeup water chemistry before raising the level in the steam generators.
Procedure SYS AQ-320 was enhanced to provide for the potential that the steam generators may already be filled prior to entry into the procedure.
Operations management has placed a letter in Required Reading reinforcing the need to document actions in the remarks section of procedures or in the Control Room Logs.
The letter stressed the importance of procedure compliance with respect to documenting the use of "not applicable."
The letter also emphasized management's expectations of documenting actions on procedure cover sheets and in the Control Room Logs.
Corrective steps That will Be T=han to Avoid Fur &har Violatia===
This occurrence is an example of lack of attention to detail and failure to follow procedure.
In this case, there were no significant consequences to the steam generators since they were properly filled and not placed in a detrimental condition.
The corrective actions identified in WCNOC's reply to Notice of Violation 482/9412-03, WO 94-0221, dated December 30,
- 1994, provides additional corrective action to resolve this violation. These corrective actions will be completed by January 30, 1995.
Corrective actions on reply to Notice of Violation 482/9412-03:
WCNOC will set aside a day, January 13, 1995, dedicated to the subject of the "Use of Procedures."
During this day, there will be meetings with all groups where the Vice President Plant Operations will reemphasize management's expectations for the use of procedures and review the disciplinary actions for failure to follow procedure.
Managers and supervisors will meet with their personnel to review selected procedures which are frequently used to ensure everyone is aware of their requirements.
Additionally, management's expectations will be discussed to ensure plar.c personnel have a clear understanding of these expectations.
During these meetings, the disciplinary policy will be reviewed to ensure all personnel have a clear understanding of the consequences of not following procedures.
The Vice President Plant Operations has also established a " Topic of the Week" program.
This program will focus management attention on procedures which personnel have not followed properly or other topics that may need special emphasis.
This program will be used as long as it is deemed appropriate by plant management.
The implementation of this program is considered by WCNOC as an enhancement to the operation of the station and not as a regulatory commitment.
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.Attcchment to WM C5-0004 Page 6 of 6 Date when Full C - liance Will Be Achieygd Full compliance will be achieved by January 30, 1995.
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