ML20105A608
| ML20105A608 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 09/09/1992 |
| From: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| WM-92-0150, WM-92-150, NUDOCS 9209170110 | |
| Download: ML20105A608 (6) | |
Text
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W$LF CREEK i
NUCLEAR OPERATING CORPORATION Dart D Wahers Pent > dent and cmel tucun<e ottiu.'
Se tember 9, 1492
~
WM 92-0150 U. S. Nuclear Pegulatory Commission ATTN: Document Control Desk Mail Statier. P1-137 Washington, D.
C.
20555 s
Peference:
Letter dated Augnet 10, 1992 from A.
B.
Beach, NRC, to D.
D. Withers, HUNOC
Subject:
Docket No. 50-482:
Response tc Violation 482/9712-01 and 9212-02 Gentlemen:
Attached is Wolf Creek Nuclear Operating Corpora 61on's (WCNOC) res onse to violations 482/9212-01 and 02 which were documented in the Reference.
Violation 482/)212-01 involved the failure to nroperly implement procedures during the testing of the containment spray system and violation 9212-02 Anvolving two examples of a failure to perform technical specification surveillance requirements.
If you have - any. questions concerning this natter, please contact me or Mr. Kevin J. Moles of my staff.
very truly yours, y
Bart D.
Withers President and Chief Executive Officer DDW/jra Attachment
'cc:
.A.
T.
Howell (NRC), w/a
[
J.
Ii. Milhoan (NRC), w/a G..A.
Pick (NRC), w/a W.
D. ReckAey (NRC), w/a 9209170110 920909 t
PDR ADOCK 05000AB2 O
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i P O. Box 4111 lbriington, KS 66833 : Phone. 4316) 364-8831
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j An Ecr1 Oprortunity Emgeyer M r HC VC1 I
. Att a c hme nt to WM 92-0150 Page 1 of 5 Reply to a Notice of Vloistion Violation (482/9212-01):
Milure to Proredy Implement P Leg M utta TindLv.n Technical Specification (TS) 6.8.1.a requires that written procedures shall be established, isnplemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide (RG) 1.33, Revision 2,
dated rebruary 1978.
RG 1.33, Appendix A,
item 8.b (1) requires procedures for surveillance tests of containment heat and radioactivity removal uystems.
This is accomplished, in part, by Procedure STS EN-205, Revision 6,
" Containment Spray System inservice Valve Test."
b Steps 5.2.4 and 5.2.5 of Procedute STF EH-205 require that Valve EN HV-16 be repositionad closed for otroke-time measurement.
Contrary *;o the above, on June 3, 1992, during the implementation of Procedure GTS EN-005,,?teps 5.2.4 and '.
'.5 were not performed.
With Valve EN HV-16 open, a direct path was created from the refueling water storale tank to the spray additive tank when n nonlicensed operetor began to restore the systemn to its normal lineup.
This resulted in the dilutton of the sodium hydn.cxide concentration of the spray additive tank.
h.ason Fordhp Violgian y
On June 3, 1992 during the performance of surveillance procedure STS EN-205,
" Containment Spray Inservice valve Test," Step 5.2.3 hsd been completed ly a nuclear station operator (NSO)
I?rformance of Step 5.2.3 filled and vented the containment spray system is preparation for stroking valve EN HV-16 (Spr ay Additive Tank Outlet to Containment Spray "B"
Isolation Valva).
A Control Room operator was sent locally to independently verify completion of Sr.ep 5.2.3 ir. accordance with the procedure.
The NSO then stored the equipment utilized to fill and vent the system.
Control Room personnel were waiting for notification from the NSO that Step 5.2.3 had been completed before performing St eps 5.2.4 and 5.2.5 which stroke close EN HV-16, when a spray additive tank high pressure alarm was received. The NSO had proceeded to restore the system to normal in accordance with Step 6.0 assuming that Step 5.2.4 and 5.2.5 had been'peLformed by the Control Room.
The reason for this violation was the failure of the NSO to ensure that the appropriate steps in the surveillance proce.
a had been performed prior to restoring the system.
Co. * -ibuting to this event were poor communicat ions in the directing of the sur eillance test and the perception that the test needed to be completed prior to shift turnover.
Correutive Starft_.That Have Been Taken Ani [Q;njis. Achieved:
The Control Room closed valve EN HV-16 to prevent further dilution of the spray additive tank-with Refueling Water Storage Tank water The containment spray system was declared inoperable until the concentration of the sodium hydroxide solution and the. level of the tank was determined.
Temporary
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i Attachment to WM 92-0150 i
Pago 2 of 5 procedure TP-OP-258,
" TEN 01 Drain / rill" was developed and the tank level drained to approximately-90 percent and 400 gallons of 50 percent by weight sodims hydror.ide solution added to the tank.
The containment spray system was declared operable on June 5, 1992.
1 Corrective Steps That,,,Have Becn Taken To Avoid further violatior.st The personnel involved with this violation were counseled and disciplinary action taken in'accordar.ce with-Human Resources policies,
-Wolf Creek Generating Station (WCGS) Standing Order 7,
" Discussion of. General Operating Philosophy Regarding Plant Evolutione" has been revssed to clarify I
the control of evolutions in progress.
The revised order speci fic.sily requires that - a licensed operator in the Control Room shall be in charge and directing any activity which involve operating equipment or systems.
-The Per fo :. nance -Improvement Request associated with this event has been included in Operations Required. Reading for licensed oporators. and HSOs.
Additionally, the-details of-this event will-be included in licensed operator and NSO requalification training on plant / industry eventa..
l Date When Full CQmplie.nce Will Be Achieved!
Full compliance will - be. achieved by January 15, 1993 with the completion of
-requalification training on plant / industry events.
1 Violation. (482/9212-02) - f ailure *o Pe rfonn Tf,,5,ggyg.illance Requi rement s findinai m Two examples of failure - to perform - required TS Curveillance: Requirements-within the specified surveillance intervals are stated below:
'l.
.r8 4. 2.1.1. a _ requires that each diesel generator shall be -- demonstrated OPERABLE in accordance with the frequency specified in Table 4.8-1,
" Diesel Generator Test Schedule."
Table
- 4. 0-1 specifies that, with the.
- n:nnber of failures in the last 100 valid testa greater than-or equal to 5,.the test frequency shall be at least once per 7 days.
Contrary to the above, C June 26, 1992,.the licensee. determined that, on two - occasions, Emergency Diesel Generator - (EDG) B was ' not teste d within the required 7-day interval. - These tests were' required to be performed because,-on June 8,-'1992, EDG B experienced its fifth valid test failure p_
-inithe last 100 valid tests.
As-a result, EDO B should-have-been tested by June 15 and:23, 1992.
EDG B was not teeted until June 26, 1992.
2.
TS 4.6.1.3.b requires that each containment air lock shall be dentonstrated -
OPERABLE by conducting'an overall air lock leakage test at not less than 48 pounds per square ~ inch and by v9rifying. the overall air lock. leakage rete is within its limit -at least once per 6 mont hs.
This is accomplishedJhy Procedure STS PEW 14A,
" Containment Air Locks Test (Personnel Hatch), " and - Procedure STS PE-014B,
" Containment Air Locks l
Test (Equipme:.t ilatch). "
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Contrary to the above, on July 7, 1992, the license determined that the personr.el and emergency air lock tests were not performed within the zequired 6-month interval.
Procedure STS PE-14A became late on May 26, 1992, and was performed on June 25,
- 1992, 31 days overdue.
Procedure STS PE-14B became late on March 21, 1992, and was perfortned on April 15,_1992, 26 days overdue.
tt,gAq,gn ror Violation 1
'1.
On J,ano 26, 1992, while reviewing past failures of Fmergency Diesel Generator (EDG)
- B" to support the writing of Special Repo:t 0-002, the utility engineer responsible for monitoring diesel reliability oiscovered that the _ testing _frequancy fot EDG
'B" should have bsen increased to at
-least once per seven days in.accordance with technica3 Specification Tables-4.8-1 following the valid failure on June 8, 19F The rcot cause-of-this ovent was a - combination of cognitive personnel error-and patocedural weakness.'
The-utility engineer failed to formally review the number of -failures in the last 20 and 100 valid tests immediately following the valid failure on June 8, 1992.
This utility engineer is responsible for determining the number of failures related to Technical Specification Table
-4.8 and notifying the appropriate l
organizations _ if, the. testing frequency needs to be~ increased.
The engineer did__not -_ formally review the number of ~ failures because the engineer was aware that the failure had been properly classified as a i
valid failure and believed that the appropriate organ 3zations were taking the proper actions.
Also, the utility engineer was aware ti.at the valid fai14re on_ June.8, 1992 was the first failure in the last 20 valid tests but was.not aware that. between March of 1987 and. June of 1992 100 valid ~
tests had been conducted with five. valid failures.
-Frocedure ADM 01-0244, "EDG Reliability Monitoring. Program," monitors ~ EDG-reliability to meet the requiremento -- of -_10 CrP_50.63.
Thla procedure required - the -
number if. failures in-the'last 20 valid tests to be listed on a form for all valid failures, but.not for-the last 100:valif tests since it was not developed' for' the.
purposes of meeting -Technical Speci-fication -
requirements.
Also, procedure. ADM 01-244 did not require that this information bej completed within a certain. tims - f rame ;
This event. was reported in Licensee Event Report 92-011-00.
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July-7,'
- 1992,
_at-approximately-1300
- CDT, while updating-the survelliance database and the twual' surveillance tracking system, the surveillance group discovered that the due dates and late dates for the last. performances of test ' STS PE-014A and B,
" Containment Air -Lochs Test," ; had been. miscalculated.
The surveillance detabase is used to track the performance.of survelliance. ' test s.
A.- manual surveillance tracking system is kept updated us3rm due-dates and late dates calculated.
- by the: computerized scheduling program.
This manual system is maintained in the event that the computerized _ scheduling progran becomes unavullable or corrupted. _ The miscalcultted due -. dates and-late dat es resulted in
- tcats. STS PE-014A and STS PE-014B not being accomplished within the-Technical Specification surveillance - allowable interval of at least once=
per six months.
Test. STS PE-014A should have been performed by May 26, 1992 inntend ' of July 12, 1992 and test STS. PT-014B should have been performed'by Mrreh.21, 1992 instead of May 6, 1992 M
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An investlystion following this event revealed that the late dates calculated for tests STS PE-014A and STS PE-014B by the computerized scheduling program which automatically calculated the next due date and lato date based on the previous parformance dates were based on a PS percent extension which is specified in Technical Specification 4.0.2.
Technicel Specification 4.0.2 requires that each outveillance requirement be performed within the specified surveillance interval with a maximum allowable extension not to exceed 2$ percent of the specified interval.
However,. the provisions of Technien1 Specification 4.0.7 are not applicable to surveillance procedure STS PE-014A and B.
The data field in the surveillance database that contains an identificr for surveillance procedures which are not governed by Techa.ical Specification 4.0.2 was discovered blank during a review of this event.
A review of. past records indicates that this identifier was present in December 31, 1990, but was missing on July 1,
1991.
Because of the length of time between the time of the event and discovery. an exact cause
,4 for the missing identifier could not be determined.
However, it appears that in April of M91 the identifier was erased when the information in L
an unrelated data field was manually deleted in.the surveillance database by a - Computer Services Syetems Analyst.
This event was reported in Licensee Event Report 92-012-00.
Corrective Ster;LTnat Hava,1ttg A ken And Results Aghieved:
1.
On' June 26, 1992 at 1551 CDT, the Control Room was notified of the failure to increase the testing frequency. of EDG "B"
The _ EDG was declared inoperable and -Technical Specification 3.8.1.1 was entered.
. Technical Specification 3.8.1.1 requires, in part that the inoperable EDG must be restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or.the unit meat be placed in 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 w3 thin the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. At 2356 CDT, t;DG-"B" was declared operable after the successful.parformance of surveillance test procedure STS KJ-005B,
" Manual / Auto ' Start, - Synchronization, and Loading of Emergency Diesel Generator'NE02."
Also, the schedule for tenting EDG "3"
was changed to once per seven. days.
On August 21, 1992. the increased testing frequency for EDG *B" was removed in accordance with Technical Specification Table-4.8-1,
- 2..Upon discovery'of this event,-immediate steps were taken to identify data and confirm the ' integrity of the identifier and its calculated dates.
'The identifier - and the. calculated dates were reloaded into the surveillance database.
A review _ of other surveillance tests affected by the missing data - in the surveillance dstabase did not reveal any other Technical = Specification violations.- Provisions have been made to prevent manual modifications to production data in the curveillance database.
Corrective Steos That W'll'Be TalgD To Avoid fyrther Violations:
i 1.
Procedure ADM 01-244 was revised on August 19, 1992 to indicate that the procedure is for mnitoring _ f ailures for Technical Specification Table 4.8-1 and provide requirements to have the form, completed within five days which will allow' the seven day testing frequency to be met if accelerated testing is required.
Also, in order to maintain a better awareness of how many failures have occurred, the form has been modified r
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to require the numLer of failures in the last "O and 100 valid tests to be entered for all eterts.
1 2.
A. computer program will be required to be written and tested priot to being used on the computerized scheduling database to make modifications i
to production data.
In addition, a quarterly cwparison will be made of the infortnation nerently in the surveillance database compared to what was in the database the previous quarter.
An evaluation is currently being conducted to evaluate the methods and controle used to make modifications to data in production applications and determine if those. methods and conteois are appropriate for all Computer Services supported applications.
If these methods and controls are deemed inappropriate, the necessary steps to correct this situation will be accomplished by December 1, 1992.
RAktLJ!htJ1 fM11_.Compiiance _Will_Rg._AchigysdL L
h 1.
Full complit nce on this portion of the violation 'has been achieved.
2.
Full compliance will be achieved by December 1,
- 1992, i
add 1112119.1 IIltomitt.isill Wolf Creek Huclear Operating Corporation (WCNOC) is considering a ticenst.
Amendment Request to Table 4.8-1, Diesel Generator Test Schedule.
This table provides the criteria for determining whether an EDG should be tested at the normal frequency.of every 31 days or at an accelerated frequency of every 7
. days.
The criteria for accelerated testing.are either 2 or more failures of the last.20 tests or 5 or more failures of the last 100. tests.
The change being-considered would eliminate the 5 of 100 critorion from the table and the implied requirement s for performing as ieany as 99 tests at the accelerated test frequency..
.In order. to ensure WCNOC 'is addressing the overall root - causes for the
[
aurveillauce problems. experienced at Wolf Creek Generating ' Station, the
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.following acti w was taken.
All Licensee Event Reports (LER) associated with aurveillance problems since the beginning of 1990 were reviewed to look foz common rout causes.
Performance Improvement Aequests ' (PIR) dealing with surveillance problems. were ' also reviewed-to see if f urther de tails could be identified to-show common areas t.a be addressed.
This review and the actions to be~taken will be documented on PIR OP 92-0652.
The Plant Trending group, L
in the ares of corrective actions, will continue to' trend FIRS to monitor the effectiveners of the actione taken and ;to identify any new trends which should be-addressed.
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