ML20086J026
| ML20086J026 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 12/05/1991 |
| From: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| WM-91-0172, WM-91-172, NUDOCS 9112100256 | |
| Download: ML20086J026 (7) | |
Text
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a WMF CREEK NUCLEAR OPERATING CORPORATION 1
Bart D Withers December 5, 1991 ere
- nuna CNet E secutwe Officer VM 91-0172 U. S. Nuclear Regulatory Conunission ATTN Document Control Desk Mail Station Pl-137 Washington, D. C.
205$5
Reference:
Letter dated November 8, 1991 from A.
B.
Beach, NRC, to B. D. Withers, WCNOC
Subject:
Docket No. 50-482:
Response to Violation 482/9126 01, 482/9126-02 and 482/9126-03 Gentlemen Attached is Wolf Creek Nuclear Operating Corporation's (WCNOC) response to violations 482/9126-01
-02 and -03 which were documented in the Reference.
Violation 482/9126-01 identified an inadequate emergency operating procedure.
Violation 4?2/9126-02 concerned the failure to restore a damper following a loss of instrument air.
Violation 482/9126-03 concerned the failure to control work practices resulting in both trains of two systems being inoperable.
If you have any questions concerning this matter, please contact me or Mr. S. G. Wideman of my staff.
Very truly yoitrs,
=Y Bart D. Witheru President and Chief Executive Officer BDW/aem Attachment cci A. T. Howell (NRC), w/a R. D. Martin (NRC), w/a G. A. Pick (NRC), w/a W. D. Reckley (NRC), w/a i
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'O Box 411 1 Burkngton. KS 66839 Phor:e (316) 364-883'
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Attachment'to WM 91-0172 Page 1 of_6 Response to Violation 482/9126-01, 482/9126-02 and 482/9126-03 Violation (482/9126-01): Jnadeouste Emereenev Operatinn Procedur.e Findingst Technical Specification (TS) 6.8.1.b requires that written procedures shall be established, implemented, and maintained covering the emergency operating procedures required to implement the requirements of NUREG-0737 and Supplement 1 to NUREG-0737 as stated in Section 7.1 of Generic Letter No.
82-33.
Administrative Procedure 01-052 Revision 4
" Emergency Procedure Generation Package Wolf Creek Generating Station *,
Step 2.2.1.1, requires that the Final Safety Analysis Report be reviewed as part of the development of plant-specific technical guidelines.
Administrative Procedure 02-022, Revision 7
'Vriters Guide For Emergency Operating Procedures,'
requires that-contingency actions be specified for each circumstance in which'the expected results or_ actions might not be achieved.
Section 15A to the Updated Safety Analysis Report, requires that a control room train, with a failed filtration fan, -be' isolated within 30 minutes to ensure that control room operator, doses are maintained within specified limits _of 10 CFR 50, Appendix A Criterion 19.
Contrary te the above, Emergency Operating Procedure EMG E-0, Revision 2,
' Safety injection," ' Step 13,
' Verify Control Room Ventilation Isolation,'
do'et no*-
address contingency actions to be taken if a control room
' filtration fan fails to operate so that the control room train can be
-isolated within 30 minutes to ensure that control room operator doses are maintained within specified limits of 10 CFR Part 50, Appendix A, Criterion 19.
Reason For Violationt The reason for the violation was the failure to explicitly require the isolation of the control room ventilation train with a failed fan during the development of procedure EMG E-0,
' Safety Injection'.
Administrative Procedure ADM 02-022, Revision 7
" Writers Guide For Emergency Operating Procedures,' provides instructions on creating the Dual-Column format with 1an " Action / Expected Response Column" and a ' Response Not Obtained Column".
-Contingency Actions are to be-placed in the ' Response Not obtained Column' and should be specified for each circumstance in which the expected results or actions might not be achieved.
These. actions should identify as appropriate.-
directions to override Automatic Controls and to initiate MANUALLY what is normally AUTOMATICALLY initiated.
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~, Attachment to WM 91-0172.
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.Page 2 of 6
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' Step 13 -ofl procedure EMG E-0 Jnstructs the operator to verify control-room-ventilation. isolation.-
The_ contingency action for this step is to manually
- align' the system following the_ steps in Attachment C of the EMG as
.necessary.
This= contingency action verifies that the control room ventilation system.has been isolated and verifies that the filtration fan is o~
operating.
Should the flitration fan fall after step 13 o' EMG E-0 has been performed, procedure-ALR 00-063B.
" CTRL RM RAD H1 CRVIS' would be followed upon receipt of a high radiation alarm in the Control Room.
Therefore.
the operator actions -are more appropriately addressed for this event in the 61 arm response procedures.
Wolf' Creek Generating Station (WCGS) Emergency Operating procedures (EMGs).
were generated utilizing the Westinghouse Owner's Group (WOG) Emergency Response Guidelines.
Revision ~1.
These guidelines were_ tailored to meet
- WCGS plant-specific design while retaining the status tree methodology inherent in the_WOG guidelines.
The status tree methodology addresses the direct treatment -of abnormal _ plant symptoms instead
-*1 cients.
This methudology was designed to mitigate multiple faila.e events since it-is impossible _to address all combinationa s.th response guidelines for each event.
-The WOG Emergency Response Guidelines addresses certain multiple E
failures and' relies on the status tree methodology _ for the remaining combinations.
The NRC Staff has approved the WOG-Emergency Response Guidelines for_ implementation. The failure of a control. room filtration fan l-as discussed in Chapter 15A of the. WCGS Updated Safety Analysis Report (USAR) is considered as a multiple failure event.
Operator action times are based on estimated values during actual events and simulator training runs.
Due to the status tree methodology of the guidelines, operatorL manipulations-may occur at times before or after the time:specified in-the analysia, but actions are performed in a sequence designed; to-defeat. challenges to critical safety functions and provide earlier responses to events which develop in an unexpected manne.
This was discussed in letter 0G-159 dated August 29, 1985 from L. D._'Butterfields of l
the WOG to-D. G.
Eisenhut of the NRC..
Therefore, WCGS has not typically incorporated operator action times into the EMGs.-
-Corrective Steps That-Have Been-Taken And Results Achieved:
A. caution statement has been added to procedure _EMG E-0.to instruct the l
operator to refer to-procedure SYS GK-122,
' Manual Cuntrol Room CRVIS Line L
_Up".
In' the event of.a failure of:the control room ventilation' system L
filtration fan.
- Procelure SYS GK-122 vaa revised to, instruct the operator to isolate.the train in which the filtration fan failed.
Alarm response procedure-ALR-063B has also-been revised to refer to SYS GK-122 in the-event of the failure of a control room ventilation system filtration fan.
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Attachment to WM 01-0172 Page 3 of.6
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Corrective Steps That Vill Be Taken To Avoid Further Violationne An_ evaluation was performed to determine if additional time could be allowed for the operator action to take place before the control room doses exceeds the specified limits of 10 CFR $0 Appendix A, Criterion 19.
This evaluation identified that additional time could be allowed without a significant
-increase in control room operator doses.
' Transients and accidents analyzed in the USAR will be reviewed for credit for operator actions.
The Operating Procedures will then be reviewed for their inclusion and changes will be made as necessary.
Date When Full Compliance Will Be Achievgd1 Full _ compliance will be achieved by September 30, 1992.
Violation 9126 02:
Failure to Restore Dan 1ger Followinn Loss of Instrument.
bit TS'6.8.1 states that written procedures shall be established, implemented, and maintained covering the activities referenced in the applicable procedures recommended in Appendix A, of Regulatory Guide 1.33, Revision 2, February-1978. Regulatory Guide 1.33, Appendix A.
Section 6.b, refers to procedures for loss of ir.strument air.
Offnormal Procedure'0FN-00-019, ' Revision 8,
' Loss 'of Instrument Air,"
_provides the actions to be followed in the event a loss of air accident occurs.
Page 54 of the procedure provides -the failure position of the containment purge system components, including Damper GT-HZ8.
Contrary to the above, on October 2,
- 1991, Offnormal Procedure OFN-00-019 was not utilized after a loss of instrument-air to the Containment Purge System. Exhaust Isolation Damper GT HZ8.-
Reason'For Violation:
The reason for this violation was the failure to_ follow procedures by licensed Control Room operators.
As a result of work activities ~being-performed on-the instrament air system, damper GT HZ-8 failed. closed on a-loss of instrument air to containment.
When' instrument air was restored, Control: Room operators failed to refer _to-procedure OFN 00-019,
' Loss of Instrument Air,' when restorind the affected equipment.
OFN 00-019,
' Loss of Instrumet Air,"
when restoring the affected equipment.
OFN 00-019 indicates that GT HZ-8 fails closed on a loss of instrument air and-therefore must'be re-opened following instrument air restoration.
Corrective Steps That Have Been Taken And-Results Achieved Upon discovering that damper GT HZ-8 was closed, the damper was opened to continue with the venting of the pressurizer relief tank.
Consequently, when GT HZ-8 was opened, the accumulated activity in the ductwork was detected by Containment Purge Radiation Monitors (GT RE-22 and GT-RE-33) which resulted in a Containment Purge Isolation Signal and a Control Room Ventilation Isolation Signnl.
The Engineered Safety Features equipment actuation was-reported in Licensee Event Report 91-018 00 on October 28, 11991.
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5 Attachment to WM 91-0172
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Page 4 of 6
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' Corrective Steps-That Vill-Be Taken To Avoid Further Violations:
The Control -Room operators involved in this event were counseled on the
-importance of using all"available resources, including procedures, when returning; systems to operation rather than relying on memory, ' Additionally.
- Operations and Engineering-personnel will discuss various alternate methods for venting the Reactor Coolant System.-
Based on the outcome of these discussions, evaluations of alternate venting methods will be completed and any -necessary; changes to' the venting process will be in place before the next venting evoluation is scheduled in Refueling Outage VI.
Date When Full Compliance Will Be Achieved:
Full compliance has been achieved with the restoration of GT HZ-8 and counseling of the involved Control Room operators.
Violation 9126-031-Failure of Work Control Practices
' TS 3.7.6 states "Two Independent Control Room Emergency Ventilation ( stems shall be OPERA 3LE."
For Mode 1 an action statement is.provides if one system isLJnoperable.
TS 3.7.7 for the auxiliary building states "Two
- independent ' emergency exhaust system shall be 0PERABLE.'
For-Mode 1 an action statement-is'provided if one system is inoperable.
.75 3.0.3-states
'When a-limiting conditions for operation (LCO) is not met, except as prov.ided in the associated ACTION requirements. -within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action shall be.; initiated to place the unit in a HODE in which the specification does not
_ apply.by placing it, as applicable ini (a) 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 />
-(b) At.least HOT SHUTDOWN within the following 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />st and (c)LAt least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.'
L Contrary to the above, on September 9 and 10, 1991, with the plant.-in Mode 1,
- TS-3.0.3.was not entered when the control room emergency ventilation systems and-the auxiliary building emergency exhaust systems were rendered inoperable-when five control room ventilation damper inspection covers.were.
removed for a preventive maintenance activity.
Reason For Violationi The reason for this violation-- is inadequate work-controla.
The work instructions; did not provide directions for. the' sequential removal-and reinstallation of-the ductwork -damper inspection ^ covers during the
' preventative maintenance activities.
Therefore, the Control Room operators were unaware that= the inspection activity required the opening of the covers and therefore, -did not recognize the effect on the Control Room Emergency
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Ventilation System (CREVS) and Auxiliary Building' Emergency Exhaust System (EES) operability..
When' work activities are being performed which breach-the' ventilation systems' pressure boundaries, Control Room operators assign dedicated personnel'whoncan restore the pressure-boundary in the event-plant conditions warrant such actions.
Because the Control Room operators were
Attachment to 501 91-0172 Page 5 of 6 unaware that the covers were to be removed, they did not assign dedicated personnel for boundary restoration.
The work instructions specified the method to be used for cycling the dampers.
Because the normal exhaust fan and the dampers to be cycled were tagged out under the same clearance order, cycling of the dampers could not be accomplished without a change to the clearance order, it was decided to pull the clearance order and then cycle the dampers.
The Electrical Maintenance workers discussed this work planning problem with the on-coming Electrical Maintenance crew during shift turnover but failed to inform the on-coming Electrical Maintenance crew that the covers for these five dampers had not been reinstalled. Therefore, the shift turnover failed to correctly relate the status of the work activity in progrecs.
Additionally, the work instructicus did not identify any limitations for working with the covers removed or any provisions to reinstall the covers.
This resulted in Electrical Maintenance personnel having removed the inspection covers for the five dampers at the same time without adequate controls for maintaining the ventilation systems' operability.
The review of the work instructions prior to the performance of the maintenance activities did not identify and correct these deficiencies.
As a preventive maintenance activity, the work instructionu were generated each time the activity was to be performed.
Because the activity had been performed in the past, it is believed the review was not adequately detailed to recognize the deficiencies.
Corrective Steps That flave Been Taken And Results Achieved:
On September 10, 1991 Electrical Maintenance personnel notified the Control Room that five of the ductwork damper inspection covers had not been restored.
Control Room operators requested immediate restoration of the covers and requested an evaluation of the effect of the removed covers on the CREVS operability.
Electrical Maintenance personnel then installed the five ductwork damper inspection covers.
completing the replacement of the covers for Dampers GKD002,
- GDK279, GDK300, GKD309 and GKD310 at approximately 0857 CDT.
Subsequently, it was determined that a pressure test would have to be performed with the five ductwork damper inspection covers removed to show conclusively that the CREVS' excess capabilities were adequate to maintain the pressurization requirement of the system in this configuration.
On September 13, 1991, a pressure test with the five ductwork damper inspection covers removed was conducted.
Dedicated personnel under the direct authority of the Control Room were stationed at the inspection covers for the duration of the test so that the inspection covers could be reinstalled to restore the system to its normal configuration, if so instructed.
The pressure test showed that with the five covers removed CREVS Train
'A' could not meet Technical Specification (T/S) 3.7.6 pressurization.
Evaluation of the pressure test results and the location of the removed ductwork damper inspection covers by Engineering personnel concluded that similar results would be expected for the CREVS Train
'B'.
Therefore, it was concluded that with the five ductwork damper inspection covers removed, both trains of the CREVS were inoperable.
Because T/S 3.7.6 does not contain an action statement for both-CREVS trains inoperable, this condition should have resulted in entry into T/S 3.0.3.
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-Attachment to WM 91-0172
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-Additionally, the pressure test conducted on September 13. 1991, showed that with" the.:five ductwork ' damper inspection covers' removed, the Auxiliary.
Building EES' Train
'A' excess capabilities were not_ adequate to maintain the pressurization requirement of the system. As with the CREVS, evaluation of the pressure test results and the location of-the removed ductwork damper inspection covers by Engineering personnel concluded that similar results would be expected for-the Auxiliary Building EES Train
'B'.
Therefore, it was= concluded that with the five ductwork damper inspection covers removed,
. ere inoperable.
Because T/S both trains of-the_ Auxiliary Building EES w
3.7.7 does not contain an action statement for both Auxiliary Building EES trains inoperable, this condition also should:have resulted in entry ~1nto T/S 3.0.3.
Licensee Event Report 91-016-00 was submitted on October 3, 1991.
a checklist has been developed l for Main *enance As an' interim. measure._
personnel's use in system restoration to-ensure equipment is. restored to its proper configuration prior to signing off that the work is complete.
To ensure that.the workers are_ aware of.the status of equipment that is~being worked on, discussions were held with Electrical Maintenance personnel to stress the importance of proper shift turnover.
Corrective Steps That Will-Be Taken To Avoid Further Violations:
Procedure MPE VD-001,. "M627A Ventilation Damper Maintenance" was-generated to replace;the work instructions used in the past for performing maintenance on ventilation dampers.. This procedure includes a caution to ensure workers are aware that-their activities may effect operability of the ventilation systems and a requirement to maint in adequate controls.to ensure equipment
' operability while the work activitics are in progress. Operations personnel have' revised the clearance orders for tagging out the fans separately from the dampersif or this type of work-activity.
This will-allow the workers to more easily complete cycling of -dampers following damper-inspection.
Following '~the completion of the current refueling' outage, a review of work package. instructions will be initiated and instructions will be revised-where necessary to strengthen the restoratica instructions.
This review and-instruction revision will be-completed by December 31, 1992.
DatelWhen Full Compliance Will Be Achievedt Full compliance will be achieved by December 31, 1992 with the review-and
. revision of work package' instructions as.necessary.
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