ML20085F608

Forwards Response to NRC Re Violations Noted in Insp Rept 50-482/95-06.Corrective Actions:Implementation of Several Mgt Changes within Engineering Dept

ML20085F608
Person / Time
Site:	Wolf Creek
Issue date:	06/14/1995
From:	Carns N WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
WM-95-0097, WM-95-97, NUDOCS 9506190330
Download: ML20085F608 (7)

Text

__ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _

it ,s

~

,' W$LF CREEK NUCLEAR OPERATING CORPORATION ned s Buu carns C%rman. F*eudent and cniee n cut ~. on or June 14,199:.>

WM 95-0097 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, D. C. 20555

Reference:

Letter dated May 19, 1995, from T. P. Gwynn, NRC/RIV, to N. S. Carns, WCNOC (Inspection Report 50-482/95-06)

Subject:

Docket No. 50-482: Reply to Not. ice of

Violation 50-482/9506-01 l Gentlemen

1 Attached is Wolf Creek Nuclear Operating Corporation's (WCNOC's) reply to j Notice of Violation 50-482/9506-01. This violation concerned two examples of WCNOC's failure to implement effective corrective actions for conditions adverse to quality. j WCNOC's response to this Notice 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. William M. Lindsay at extension 8760.

Very truly yours,

. W Neil S. Carns NSC/jad Attachment ec: L. J. Callan (NRC), w/a T. P. Gwynn (NRC), w/a D. F. Kirsh (NRC), w/a J. F. Ringwald (NRC), w/a J. C. Stone (IEC), w/a 9506190330 950614 PDR Q

ADOCK 05000482 PDR

//O{ l

/ i \

] {h}7 PO Box 411/ Burhngton KS f6839 / Phone (316) 304-8831 An iqual opportunity Emsoyer M F/HC. VET

1. ' *~

AttachmentLto WM 95-0097 Paga 1 of 6 Reply to Motice of violation 50-482/9506-01 Violation 50-482/9506-01: Two examples of WCNOC's failure to implement effective corrective actions for known conditions adverse to quality

" Criterion XVI of 10 CFR 50, Appendix B, " Corrective Action," requires, in part, that measures shall be established to assure that conditions adverse to j quality, such as failures, deficiencies, and deviations, are promptly ,

identified and corrected. I e Contrary to the above, from January 25 to February 23, 1995, the licensee .

failed to take prompt and adequate corrective action for a condition l adverse to quality. Specifically, on January 25, 1995, the licensee reviewed a consultant's report which identified 11 safety-related motor- l operated valves which were degraded. The licensee failed to write a performance improvement request to promptly identify and correct the degraded valveo.

• Contrary to the above, from February 9, 1988, to March 8, 1995, the licensee failed to take prompt and adequate corrective action for a condition adverse to quality. Specifically, on February 9, 1988, Reactor l

Trip Breaker Hand Switch SBHS-1 failed to function as designed. The licensee identified that the switch contacts would open and deenergize the I

"A" reaccor trip breaker undervoltage relay when the switch was operated in the closed direction. The licensee failed to take corrective action to resolve the plant problem. As a result, a repeat of the 1988 failure caused an unplanned reactor trip on Maich 8, 1995."

Admission of Violationi i

Wolf Creek Nuclear Operating Corporation (WCNOC) acknowledges and agrees that a violation of Criterion XVI of 10 CFR 50, Appendix B, " Corrective Action,"

occurred when WCNOC failed to document its implementation of corrective actions to correct and prevent recurrence of the above discussed conditions adverse to quality.

Raamon for Violation 1 EQot Cause and Contributing Factors:

Based on an evaluation of the above noted issue it has been determined that WCNOC's failure to implement effective corrective actions has several root causes. The root causes are:

The lack of sufficient personnel awareness and understanding of - what constitutes a degraded / nonconforming condition.

The lack of adequate procedures to address the guidance provided in Generic Letter 91-18, dated November 7, 1991, "Information To Licensee Regarding Two j

Attachment to WM 95-0097 Page 2 of 6 NRC Inspectior N.nual Sections On Resolution Of Degraded And Non-Conforming Conditions Ant 3rability."

The lack of effective management and supervisory oversight and guidance.

The primary root cause of the first example has been determined to be:

Insufficient personnel awareness on the part of engineering resulted in the incorrect interpretation of the classification of *possibly susceptible," and the cubsequent failure to take the conservative approach in the performance and documentation of a formal operability evaluation and proceed with this issue through the formal WCNOC corrective action program (Performance Improvement Request [PIR]).

Additional Information:

Engineering gathered all of the appropriate organizations to review the results and finalize resolution for each area impacted by the consultant's report. This meeting occurred on January 25, 1995, following receipt of final report from the consultant on January 17, 1995. Within this period of time, the report was also reviewed in detail as a verification of the consultant's efforts. The formal WCNOC corrective action program was not entered because this issue was not perceived to create a nonconforming or indetenainate condition. Long term action plans to resolve the concern were developed during the January 25, 1995 meeting. However, because tae procedures  !

addressing nonconformances were not entered, the necessary operability l l

evaluations were not formally performed and documented.

It was not until the Vice President Engineering discussed this issue with the Nuclear Rt.gulatory Commission (NRC) that one of the contributing factors to I the root cause was identified. The NFC felt that this phenomena was representative of a nonconforming or degraded condition as depicted in Generic Letter 91-18. After review of this document, it was determined that the standard ANSI definition of nonconformance/ nonconforming used in WCNOC's procedures did not reflect the guidance of this generic letter. Corrective 1 actions have since been taken to update the %:NOC procedural definitions to l conform with Generic Letter 91-18.

The primary root cause of the second example has been determined to be The root cause of the reactor trip was determined to be Wolf Creck Nuclear Operating Corporation's (WCNOC) failure to implement all needed corrective actions. In 1988 WCNOC identified that Switch SB HS0001 was not functioning properly. At that time WCNOC revised Surveillance Test Procedures STS IC-211A, "Actuatio: Logic Test Train A SSPS" and STS IC-211B, " Actuation Logic Test Train B S5aS," requiring that the breaker manipulations associated with this testing be performed locally, instead of using Switch SB HS0001.

However, WCNOC failed to revise procedures STS IC-746A/B " Reactor Protection System Reactor Trip Breaker "A/B" Time Response Testing," to delete the use of Switch SB HS0001 and require local closure of the breakers. STS IC-746A/B were only performed during outages in 1988. They were later revised to be performed at power. As additional knowledge and experience with the operation of the switch was gained, the priority for its replacement was reduced. This

\

Attachment to WM 95-0097 Page 3 of 6 lack of communication and questioning attitude was a problem in the 1988 time period at WCNOC. This is an area where WCNOC has made improvement, as noted during several recent NRC inspections.

The cause of the Reactor Trip Manual Actuation Switch (SB HSL?;1) failure was ,

determined to be the slip contacts did not maintain continuity when the switch i was moved from the " normal after close" position to the " closed" position. ,

This intermittent continuity problem caused both the Main Reactor Trip Breaker "A" and Bypass Reactor Trip Breaker "B" to open simultaneously, resulting in a reactor trip.

Corrmatire Stana_TAkBD _And_ERAults Achieved 1 1

Actions implemented to correct the generic failure to implement effective corrective actions included:

• Implementation of several management changes within the Engineering i Department. These changes brought personnel who better understand and support the WCNOC corrective action program to key positionc witt.in Engineering.

• The new Engineering Management personnel have held informal meetings to clearly express their expectations for engineering personnel support and use of the WCNOC corrective action program.

• The WCNOC industry information review program has been revised to require the initiation of a PIR for all incoming industry issues that previously were only documented via the industry information review program. This i I

action will ensure that the operability concerns will be addressed expeditiously by the Plant Trending and Evaluation group and the corrective action evaluation program will be entered as mandated by plant procedures for all industry issues.

• The applicable WCNOC procedures have been evaluated and revised to accurately define nonconforming and degraded conditions in accordance with the guidance provided in Generic Letter 91-18. The revisions provided enhanced guidance and will help ensure more conservative actions for questionable conditions.

Specific corrective actions implemented to correct the first example included:

• Calculations were performed during the inspection that provided a justification for continued operability. Long term resolution evaluations and enhancements will be documented and implemented in accordance with WCNOC's industry information review and corrective action programs.

• Procedures AP 28-001, " Evaluation of Nonconforming Conditions of Installed Plant Equipment," AP 28A-001, " Performance Improvement Request," and ADM j 02-024, " Technical Specification Operability," were evaluated and revised to accurately define nonconforming, indeterminate, and degraded conditions in accordance with the guidance provided in Generic Letter 91-18. The

+

Attachment to WM 95-0097 Page 4 of 6 revisions provided enhanced guidance and will help ensure more conservative actions for questionable conditions.

• The WCNOC industry information review program was revised on March 3,1994, to require the initiation of a PIR for all incoming industry issues that previously were only documented by the industry information review program.

This action will ensure that the operability concerns will be addressed expeditiously by the Plant Trending and Evaluation group and the corrective action evaluation program will be entered as mandated by plant procedures for all industry issues.

• Individual PIRs have been generated to track the long term corrective actions for Valves BBPV8702A/B, EJHV8701A/B, EJHV8840, EMHV8802A/B, EJHV8811A/B, and ENHV0001/7. The necessary procedural changes resulting from the PIRs were completed on May 1, 1995. Interim operability prior to completion of these corrective actions can be described by the following:

Valves BBPV8702A/B and EJHV8701A/B were identified as potentially susceptible to thermal binding in the consultant's report, and Valves EJHV8840 and EMHV8802A/B were also identified as potentially susceptible to pressure locking. The consequences of thermal binding of Valves BBPV8702A/B and EJHV8701A/B has no significant impact on nuclear safety.

These valves are not required to bring the plant to a safe shutdown condition. It is highly unlikely that Valves EJHV8840 and EMHV8802A/B would become pressure locked post-loss of coolant accident (LOCA) based on the history of hot leg RCS check valve sealing, and industry operating experience. The consequences of not achieving hot leg recirculation when desired does not impact core cooling capability, since cold leg recirculation remains unaffected. Operational procedures currently address generic actions necessary in the case that hot leg recirculation valves do not open.

Procedure reviews in regard to pressure locking of EJHV8840 and EMHV8802A/B have been completed. Long term actions are to reclassify the hot leg recirculation function as a maintenance function, not essential for sustaining coolant flow.

The four valves isolating the containment sump from the residual heat removal system and the containment spray suction (EJHV8811A/B and ENHV0001/7) are possibly susceptible to pressure locking. For short term assurance the containment sumps have been fi_ led with borated water.

Engineering has demonstrated that this action, along with evidence that the valves have sufficient opening capability, will prevent potential pressure locking of these va:ves. WCNOC will evaluate the feasibility of modifying the valves during the eighth refueling outage as part of a long term resolution plan. Industry resolution of the concern for potentially susceptible valves will be monitored by WCNOC for the most effective modification or resolution.

• • ~.'

Attcchm:nt to WM 95-0097 Page 5 of 6 Specific corrective actions implemented to correct the second example included:

• In addition to the generic corrective actions discussed above WCNOC personnel, as a whole, have a better understanding of the corrective action program, management's expectations relative to the use of the corrective action program, and an improved support for and use of the formal corrective action program.

• Procedures STS IC-746A, STS IC-746B, STS IC-215, " Trip Actuation Device Operational Test Of Manual Reactor Trip, Trip And Bypass Breaker UV/ Shunt Trip, Turbine Trip On Reactor Trip and P4," and SYS SF-120, " Rod Control System Operation," have been revised. These revisions require breaker manipulations to be performed locally, rather than using Switch SB HS0001.

With these revisions all procedures that manipulate the Switch SB HS0001 to the " closed" position have been reviewed and revised.

• An Operator Aid (a placard) was placed at the Reactor Trip Manual Actuation Switch (SB HS0001). This Operator Aid states - "WITH ANY RODS WITHDRAWN DO NOT OPERATE SB HS0001 TO THE CLOSED POSITION."

CQrrggtive Steps That Will Be Taken to Avoid Further violations:

Corrective actions planned to correct the generic failure to implement effective corrective actions included:

• Establish written management expectations and measures of excellence for Engineering personnel. These enhancements will ensure Engineering personnel understanding of personal accountability for accuracy, communication and vision of how to make engineering a world class performer. This action will be completed by July 7, 1995.

• Management will informally discuss the written expectations and measures of excellence with all engineering personnel. This action will be completed by July 28, 1995.

• Training will be provided on the WCNOC corrective action program for all of Engineering. This training activity will be incorporated into the ongoing training program for engineering personnel by August 31, 1995.

Specific corrective actions planned to correct the first example included:

• WCNOC will evaluate the feasibility of modifying the valves during the eighth refueling outage as part of a long term resolution plan.

• Industry resolution of the concern for potentially susceptible valves will be monitored by WCNOC for the most effective modification or resolution.

i

.' Attachment to WM 95-0097 Page 6 of 6 Specific corrective actions planned to correct the sen.nd example included:

• WCNOC will replace the switch during the eighth refutling outage, in the spring of 1996.

DAte When Full Compliance Will Be Achieved:

Full compliance with Criterion XVI of 10 CFR 50, Appendix B has been achieved.

All corrective actions associated with the specific examples and their generic implications will be completed shortly after the eighth refueling outage, in the spring of 1996.

l 4

i l

I I

l l

s t-