ML20086A952
| ML20086A952 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 06/21/1995 |
| From: | Carns N WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| WM-95-0099, WM-95-99, NUDOCS 9507050110 | |
| Download: ML20086A952 (6) | |
Text
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3 W$LF CREEK
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NUCLEAR OPERATING CORPORATION
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t Neil S " Bun" Carns Cterman, Pres 6dernt and 1
Chief Executive officer 1
June 21, 1995 i
U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 washington, D. C.
20555
Reference:
Letter dated May 22, 1995, from A. B. Beach, NRC, to N.
S. Carns, WCNOC
Subject:
Docket No. 50-482:
Response to Violation 482/9505-01 Gentlemen:
i Attached is Wolf Creek Nuclear Operating Corporation's (WCNOC) reply to Notice of Violation 9505-01 which was documented in the referenced report by the Resident Inspectors. Violation 9505-01 concerned two failures of licensee personnel to follow surveillance test procedures.
WCNOC's response to this 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.
W. M. Lindsay at extension 8760.
Very truly yours, Nei S.
Carns NSC/jad Attachment cc:
L. J. Callan (NRC), w/a D.
F. Kirsch (NRC), w/a J..F. Ringwald (NRC), w/a J. C. Stone (NRC). w/a 270001 l
9507050110 950621 gDR ADOCK 05000482 l
PDR PO Box All / Burhngton, KS 66839 / Phone- (316) 364-8831
- {l Ari Equal Opporturnty Employer M F/HCNET
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JV Atitechment: to WM 95-0099.
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i Reply to Notice of Violation 482/9505-01 Violationi 482/9505-01:
Two failures of' licensee personnel to follow surveillance test procedures.
During Lan NRC inspection ' conducted March 12 through April 22,. 1995,-
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. violation of NRC requirements was identified..In accordance with the " General l
Statement of Policy and Procedure for.NRC Enforcement ~ Actions," 10 CFR Part'2, j
Appendix C (Enforcement Policy), the two-part violation is' listed below:
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.*A.
Technical Specification 6.8.1.a states, in'part, that written procedures shall be established and implemented covering the applicable ~ procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2.
Regulatory Guide 1.33, Appendix A,
Section 8,
requires procedures. for performing surveillance tests.
(1)
Surveillance Procedure STS IC-618B, " Slave Relay Test K618B Train B-l Safety Injection," Revision 11, Step 8.1.3, requires that Fuse Block FU42 be removed from Auxiliary Relay Panel RP333 prior to proceeding I
with the surveillance test.
Contrary to the above, on April 17, 1995, operators failed to perform Step 8.1.3 of Surveillance Procedure STS IC-618B, resulting in the test tripping of the - only operating condenser air removal pump.
(2)
Administrative Procedure AP 15C-002, " Procedure Use and Adherence,"
Revision 2,
Step 6.6.7,.
permits procedure cover sheets to be annotated to direct the performance of specified sections of a surveillance procedure.
Contrary to the above, on April 18, 1995, instrument and controls-technicians replacing Card BBTYO421L completed Step 5.3.20 of Surveillance Procedure STS IC-500E,
" Channel Calibration DT/TAVG Instrumentation Loop 2,"
Revision 12, a step not specified to be performed on the cover sheet."
d Admission of Violation:
WCNOC acknowledges and agrees that two examples of a violation of Wolf Creek Generation Station (WCGS) Technical Specification (TS) occurred when personnel failed to ensure the appropriate WCGS procedural requirements were followed.
The first example occurred during the performance of surveillance test procedure STS IC-618B, " Slave Relay Test K618B Train B Safety Injection." ~The second example occurred during the performance of surveillance. test procedure STS.IC-500E, " Channel Calibration DT/TAVG Instrumentation Loop 2."
The second example also included failurt to follow procedure AP 15C-002, " Procedure Use and Adherence."
Attachment to'WM 95-0099 Page 2 of 5 4
Raatan for violatigni First Example:
The root cause of this violation is cognitive personnel error.
The operator performing the test had both "A"
and "B"
train procedures open and did not ensure that the "A"
train testing was complete before beginning testing on the "B"
train.
With both procedures open, the operator mistakenly assumed that the proper fuse was already pulled.
Therefore, the operator failed to ensure that plant procedures were adhered to during the performance of surveillance procedures STS IC-618A and STS IC-610B.
On April 17, 1995, at 2231, it was noted that the "C"
Condenser vacuum Pump was tripped.
At that time the operating crew was performing STS IC-610B,
" Slave Relay Test K618 Train B Safety Injection," Revision 11.
During the investigation as to why the "C"
Condenser vacuum Pump was tripped, it was l
discovered that the appropriate fuse had not been pulled.
The STS includes a l
step to pull a fuse to prevent tripping the condenser vacuum pump when the slave relay is energized.
Based on interviews with the operating crews and entries in the Control Room Logs, the following events occurred:
On April 17, 1995, at 2040, the operating crew commenced STS IC-618A, " Slave Relay Test K618 Train A Safety Injection."
The Reactor Operator (RO) commenced the performance of STS IC-618A.
Step 8.1.3 of the procedure states:
8.1.3 Remove Fuse Block FU42 (Top Fuse Block center of rear panel) l in Auxiliary Relay Panel RP332 (2000' Elev. Aux. Bldg. on North Wall) 1.
Fuse Block FU42 removed.
The RO completed the procedure portion of the STS successfully.
The RO knew that STS IC-618B was to be performed next, and restered the equipment for the pre-test alignment of STS IC-6188.
Step 9.3 of STS IC-618A states:
" Inform SS or SO of completion and status of this testing."
Step 9.4 on the next page of the procedure calls for the installation of Fuse FU42.
The RO informed the SO of test completion and initialed step 9.3.
The RO then commenced the performance of STS IC-618B.
During the performance of the STS the RO came to j
step 8.1.3 which states:
8.1.3 Remove Fuse Block FU42 (Top Fuse Block center of rear panel) in Auxiliary Relay Panel RP333 (2026' Elev. Aux. Bldg. on East Wall by Elevator).
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Fuse Block FU42 removed.
The RO looked at the step and remembered that FU42 had been removed during the performance of STS IC-618A and had not been reinstalled.
The RO continued with the testing and inadvertently tripped the "C" Condenser Vacuum Pump when the slave relay was energized.
The RO f ailed to recognize that STS IC-618A pulled fuse FU42 in Panel RP332 and that STS IC-618B pulled fuse FU42 in Panel RP333.
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' Attachment to WM 95-0099 l=
~Page 3 of-5 Contributing Factors:
Substep 8.1.3.1 did not indicate the panel numt therefore, the procedure j
substeps for both trains were identical.
Procedure step. 9. 3 indicated that the procedure was complete when the fuse still needed to be reinstalled.
J Corrective Stans That Have Been Taken and the Resulta Achievedt Immediate corrective actions taken were to start the "B" Condenser Vacuum Pump and evaluate the tripping of "C"
Condenser Vacuum Pump since the cause of the
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trip was not fully understood until the procedure was thoroughly reviewed and the system electrical prints were reviewed.
PIR 95-0899 was initiated to document the tripping of the "C" Condenser Vacuum j
Pump during the performance of STS IC-618B.
The analysis of this event indicated that the trip occurred as a result of personnel error, with the major contributing factor being the performance of two procedures at one time.
PIR 95-0899 was closed June 16, 1995.
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Operations Management issued letter OP 95-0037, dated May 18, 1995, to all l'
licensed individuals to reinforce the need for continued attention to detail
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during Slave Relay Testing.
This includes a management expectation that testing on a train shall be completed before beginning the testing on the opposite train, 1
Enhancementa That will Be Tnitiated and the Date of C - lation 1
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i The corrective steps described above are considered approprfate and sufficient to avoid further violations of this nature.
The following enhancements are being implemented as part of WCNOC' S procedure enhancement process, and are not considered corrective action to prevent recurrence of this violation, nor are they commitments to the NRC.
These enhancements include:
All of the Slave Relay Tests were reviewed and revised prior to performance to incorporate enhancements.
PIR 95-0906 was initiated to track this action, and was completed June 20, 1995.
Step 8.1. 3 of STS IC-618A and B was revised so that the panel number is moved to the beginning of the step.
This action was completed on June 16, 1995.
. Step 9.3 of STS IC-618A and B,
which indicates that the procedure is complete, was moved to follow step 9.4, which reinstalls fuse FU42.
This j-action was completed on June 16, 1995.
Training on slave relay testing shall be provided to Licensed operators by I
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August 18, 1995.
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Attechment to WM 95-0099' Page 4.of 5-4 i
Raamon for violationt
_ gecond Examniee The root cause of this violation is cognitive personnel error in failing to ensure appropriate plant procedures were adhered to as required in AP 15C-002,
" Procedure Use and Adherence," during the performance of STS IC-500E, " Channel Calibration DT/TAVG Instrumentation Loop 2".
During the partial performance of Surveillance Test Procedure STS IC-500E, the-7 steps.to be performed were flagged, and the steps not to be performed should' have had clear administrative controls, such as being N/A'd.
. Step 5.3.20, i
when inadvertently entered, was not clearly N/A'd.
The only step flagged to be performed on that page was 5.3.19.
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t Though not specifically included in the Notice of Violation, the inspector j
noted a concern that the technicians involved did not initiate a PIR until l'
after the inspector questioned licensee management.
PIR 95-0919 was subsequently initiated to evaluate and track corrective actions.
Contributing..Factorsa Investigation has revealed two situations relative to this instance that can.
he categorized as weaknesses within the Instrumentatien and controls (I&C) 4 organization.
1.
Inconsistency with respect to the standardization of partial procedure setup and administration.
2.
Inadequate written guidance with respect to the PIR
" initiation
'f threshold" within the I&C organization.
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Corrective Steps That Have Been Taken and the Results Achiavadt 1.
PIR 95-0919 and AP 15C-002 were entered into the I&C required reading I
program.
2.
Written guidance on the threshold of initiation of PIRs 'has been incorporated into the Expectations Document for the I&C Department.
This action was completed May 2, 1995, and was entered into the I&C required reading program.
This supplements company guidance in AP 28A-001,
- Performance Improvement Requests."
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3.
The Assistant to the Vice President Operations conducted a meeting with I&C personnel during the stand down day May 19, 1995.
Major topics discussed included management expectation for the initiation of PIRs, self-checking philosophy, and supervisory involvement.
The discussion
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included an extensive question and answer period.
The Superintendent I&C and the First Line Supervisors in I&C reinforced these topics in smaller group meetings held the same day.
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Attachm:nt to WM 95-0099.
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Corrective Stens That Will Be Taken and
- ha Data trh== Full C - liance Will Be l
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Achieved:
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The' corrective steps described above are considered appropriate and sufficient
-to avoid further violations of this nature, j
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