ML20133C083
| ML20133C083 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 12/31/1996 |
| From: | Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Carns N WOLF CREEK NUCLEAR OPERATING CORP. |
| Shared Package | |
| ML20133C088 | List: |
| References | |
| EA-96-470, NUDOCS 9701070030 | |
| Download: ML20133C083 (6) | |
See also: IR 05000482/1996021
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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Gil RYAN PLAZA DRIVE. SulTE 400
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Neil S. Carns, President and
Chief Executive Officer
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Wolf Creek Nuclear Operating Corporation
P.O. Box 411
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Burlington, Kansas 66839
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SUBJECT: NRC INSPECTION REPORT 50-482/96-21 AND NOTICE OF VIOLATION
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Dear Mr. Carns:
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An NRC inspection was conducted October 7-11 and 21-25,1996, at your Wolf Creek
Generating Station reactor facility. The enclosed report presents the scope and results of
that inspection. The overall conclusions of the inspection were discussed with
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Mr. O. Maynard and others of your staff on October 25,1996. An exit meeting was held
with your staff on November 8,1996. In addition, the overall results of this inspection
were discussed with Mr. Terry Damashek, on December 31,1996.
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The inspection team found numerous problems in your implementation of the
10 CFR 50.59 review process, which resulted in the use of incorrect Technical
Specification clarifications, the failure to perform required inservice inspection and testing,
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and operating the facility differently than described in the Updated Safety Analysis Report.
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Design basis notebooks were found to be uncontrolled and out-of-date, which hindered
your stait's ability to access design basis information. As a result, your staff had difficulty
retrieving and communicating design information and using this information to support
subsequent engineering calculations, modifications, adequate surveillance testing, and
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Although system engineer knowledge was excellent, it appeared to be the result of the
personal initiative taken by system engineers and their immediate supervisors, and not the
result of any specific management guidance or administrative requirement. Training
guidance was found to be very general and did not provide a minimum standard for system
engineer training or knowledge. Communication of management expectations for system
engineering had improved; however, the previous NRC engineering inspection performed in
May 1995, found similar weaknesses in the management and supervisory oversight of the
system engineering program, indicating ineffective corrective action.
The inspection identified several violations of NRC requirements involving: (1) failure to
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maintain design control, in that, the containment air cooler heat removal calculations
assumed incorrect essential service water flow rates; (2) the failure to follow administrative
9701070030 961231
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ADOCK 05000482
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Wolf Creek Nuclear Operating
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procedures for performing operability determinations; and (3) the failure to implement
Technical Specification surveillance requirements regarding verification of the correct
position of mechanical position stops. The violations are cited in the enclosed Notice of
Violation (Notice) and the circumstances surrounding the violations are described in detail
in the enclosed report. Please note that you are required to respond to this letter and
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should follow the instructions specified in the enclosed Notice when preparing your
response. The NRC will use your response, in part, to determine whether further
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enforcement action is necessary to ensure compliance with regulatory requirements.
The inspection also identified three apparent violations that are being considered for
escalated enforcement action in accordance with the " General Statement of Policy and
Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600.
Specifically, the first apparent violation involved four examples where your 10 CFR 50.59
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safety review process failed to properly determine that changes to your facility, as
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desenbed in the Updated Safety Analysis Report, and changes to the Technical
Specifications were involved. As a result, a determination that an unreviewed safety
question did not exist or prior NRC approval was not obtained before the changes were
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implemented. The second apparent violation involved plant operation in the cold shutdown
condition for an extended period with two centrifugal charging pumps operable contrary to
Technical Specification requirements. The third apparent violation involved inadequate
corrective action for a quality assurance finding regarding the use of Technical
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Specification interpretations, which failed to identify and correct conflicting positions
between the interpretations and the Technical Specifications. These examples indicate a
potential programmatic breakdown of the design control process, which also involved a
failure of the Plant Safety Review Committee to identify the problem. The examples are
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discussed in detail in Sections E2.2, E2.3, and E2.7 of the enclosed inspection report. In
addition, please be advised that the number and characterization of apparent violations
described in the enclosed inspection report may change as a result of further NRC review.
A predecisional enforcement conference to discuss these apparent violations has been
scheduled for January 16,1997. This conference will be open for public observation in
accordance with a recent change to the enforcement policy (6 iFR65088). The decision to
hold a predecisional enforcement conference does not mean that the NRC has determined
that a violation has occurred or that enforcement action will be taken. This conference is
being held to obtain information to enatie the NPC to make an enforcement decision, such
as a common understanding of the facts, root causes, missed opportunities to identify the
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apparent violation sooner, corrective actions, significance of the issues and the need for
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lasting and effective corrective action. In addition, this is an opportunity for you to point
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out any errors in our inspection report and for you to provide any information cons erning
your perspectives on: 1) the severity of the violations,2) the application of the factors
that the NRC considers when it determines the amount of a civil penalty thM may be
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assessed in accordance with Section VI.B.2 of the Enforcement Policy, and 3) any other
application of the Enforcement Policy to this case, including the exercise of discretion in
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accordance with Section Vil,
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You will be advised by separate correspondence of the results of our deliberations on this
matter. No response regarding these apparent violations are required at this time.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter,
its enclosure and your response will be placed in the NRC Public Document Room (PDR).
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To the extent possible, your response should not include any personal privacy, proprietary,
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or safeguards information so that it can be placed in the PDR without redaction.
Should you have any questions concerning this inspection, we will be pleased to discuss
them with you.
Sincerely,
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T mas P.
yn , Director
ivision of Reactor Safety
Docket No.: 50-482
License No.: NPF-42
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Enclosures:
NRC Inspection Report
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50-482/96-21
cc w/ enclosures:
Vice President Plant Operations
Wolf Creek Nuclear Operating Corp.
P.O. Box 411
Burlington, Kansas 66839
Jay Silberg, Esq.
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Shaw, Pittman, Potts & Trowbridge
2300 N Street, NW
Washington, D.C. 20037
Supervisor Licensing
Wolf Creek Nuclear Operating Corp.
P.O. Box 411
Burlington, Kansas 66839
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Wolf Creek Nuclear Operating
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Supervisor Regulatory Compliance
Wolf Creek Nuclear Operating Corp.
P.O. Box 411
Burlington, Kansas 66839
Chief Engineer
Utilities Division
Kansas Corporation Commission
1500 SW Arrowhead Rd.
Topeka, Kansas 66604-4027
Office of the Governor
State of Kansas
Topeka, Kansas 66612
Attorney General
Judicial Center
301 S.W.10th
2nd Floor
Topeka, Kansas 66612-1597
County Clerk
Coffey County Courthouse
Burlington, Kar sas 66839-1798
Public Health Physicist
Division of Environment
Kansas Department of Health
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and Environment
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Bureau of Air & Radiation
Forbes Field Building 283
Topeka, Kansas 66620
Mr. Frank Moussa
Division of Emergency Preparedness
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2800 SW Topeka Blvd
Topeka, Kansas 66611-1287
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E-Mail report to D. Nelson (DJN)
E-Mail report to NRR Event Tracking System (IPAS)
bec to DMB (IE01)
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bec riictiib. by RIV:
L. J. Callan
Resident inspector
DRP Director
SRI (Callaway, RIV)
Branch Chief (DRP/B)
DRS-PSB
Project Engineer (DRP/B)
MIS System
Branch Chief (DRP/TSS)
RIV File
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Leah Tremper (OC/LFDCB, MS: TWFN 9E10)
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J. Leiberman (MS O-7H5)
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OE:EA (MS O-7H5)
G. F. Sanborn
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DOCUMENT NAME: R:\\_WC621 RP.CAV
To receive copy of document. Indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy
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OFFICIAL RECORD COPY
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Wolf Creek Nuclear Operating
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E-Mail report to D. Nelson (DJN)
E-Mail report to NRR Event Tracking System (IPAS)
bec to DMB (IE01)
bec distrib. by RIV:
L. J. Callan
Resident inspector
DRP Director
SRI (Callaway, RIV)
Branch Chief (DRP/B)
DRS-PSB
Project Engineer (DRP/B)
MIS System
Branch Chief (DRP/TSS)
RIV File
j
Leah Tremper (OC/LFDCB, MS: TWFN 9E10)
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J. Leiberman (MS O-7H5)
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OE:EA (MS O-7H5)
G. F. Sanborn
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DOCUMENT NAME: R:\\,,WC621 RP.CAV
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To recoin copy of document, Indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy
RIV:. :PBF
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PM:NRR
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JTedrow *
RAzua *
PGoldberg *
FRingwald *
JStone'
12//17/96
12/17/96
12/17/96
12/19/96
12/17/96
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12/16/96
12/19/96
12/1/96
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concurred per telecon / * *previously concurred
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OFFICIAL RECORD COPY
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