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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-482/96-21
	ML20134K512
Person / Time
Site:	Wolf Creek
Issue date:	02/11/1997
From:	Gwynn T; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Carns N; WOLF CREEK NUCLEAR OPERATING CORP.
References
	EA-96-470, NUDOCS 9702140060
	Download: ML20134K512 (5)
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NUCLEAR REGULATORY COMMISSION

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611 RYAN PLAZA DRIVE SulTE 400

9 . . . . * /.; ARLINGTON. TEXAS 76011-8064

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EA 96-470

Neil S. Carns, President and

Chief Executive Officer

Wolf Creek Nuclear Operating Corporation

P.O. Box 411

Burlington, Kansas 66839

SUBJECT: NRC INSPECTION REPORT 50-482/96-21 AND NOTICE OF VIOLATION

Dear Mr. Carns:

Thank you for your letter of Januaiy 31,1997,in response to our letter and Notice

of Violation dated December 31,19S We have reviewed your reply and find it

respc.nsive to the concerns raised in our Notice of Violation. We will review the

implementation of your corrective actions during a future inspection to determino that full

compliance has been achieved and will be maintained.

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Sincerely,

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homas P Gwynn Di ct

Division of Reacto fety

Docket No.: 50-482

License No.: NPF-42

cc: ;

Vice President Plant Operations ;

Wolf Creek Nuclear Operating Corp. l

P.O. Box 411 !

Burlington, Kansas 66839

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9702140050 970211

PDR ADOCK 05000482

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Wolf Creek Nuclear -2-

Operating Corporation

Jay Silberg, Esq.

Shaw, Pittman, Potts & Trowbridge

2300 N Street, NW

Washington, D.C. 20037

Supervisor Licensing

Wolf Creek Nuclear Operating Corp. ,

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P.O. Box 411

Burlington, Kansas 66839

Supervisor Regulatory Compliance

Wolf Creek Nuclear Operating Corp.

P.O. Box 411

Burlington, Kansas 66839

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Chief Engineer i

Utilities Division !

Kansas Corporation Commission I

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, Kansas 66839-1798

Public Health Physicist

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Division of Environment

Kansas Department of Health

and Environment

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Bureau of Air & Radiation

Forbes Field Building 283

Topeka, Kansas 66620

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l Wolf Creek Nuclear 3-

Operating Corporation

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Mr. Frank Moussa

i Division of Emergency Preparedness

l 2800 SW Topeka Blvd

Topeka, Kansas 66611-1287

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Wolf Creek Nuclear -3-

Operating Corporation

E-Mail report to T. Boyce (THB)

E-Mail report to NRR Event Tracking System (IPAS)

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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

Leah Tremper (OC/LFDCB, MS: TWFN 9E10)

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OFFICIAL RECORD COPY

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Wolf Creek Nuclear -3-

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E-Mail report to T. Boyce (THB)

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E-Mail report to NRR Event Tracking System (IPAS)

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bec distrib. by RIV:

j L. J. Callan Resident inspector

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! Project Engineer (DRP/B) MIS System

Branch Chief (DRP/TSS) RIV File

i Leah Tremper (OC/LFDCB, MS: TWFN 9E10)

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DOCUMENT NAME: R:\_WC\WC621 ak, PAG

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WOLF CREEK ' NUCLEAR OPERATING CCRPORATION

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Clay C. Warren

Chief Operating Officer

January 31, 1997

WO 97-0018

U. S. Nuclear Regulatory Commission

ATTN: Document Control Desk

Mail Station P1-137

Washington, D. C. 20555

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Reference: Letter dated December }7, 1996, from

T. P. Gwynn, NRC, to N. S. Carns, WCNOC

Subject: Docket No. 50-482: Response to Notice of

Violations 50-482/9621-01, -05, and -06

Gentlemen:

This letter transmits Wolf Creek Nuclear Operating Corporation's (WCNOC)

resronse to Notice of Violations 50-482/9621-01, -05, and -06. The first

violation concerns WCNOC's failure to maintain design control, in that, a

configuration change package contained assumptions from out-of-date

calculations. The second violation concerns WCNOC's failure to follow

adminis*,rative procedures for performing operability determinations. The

third violation concerns WCNOC's failure to have procedures which clearly

required the test performer to tighten the mechanical position stops on

specific Chemical Volume and Control System valves as required by Technical

Specifications.

WCNOC's response to these violations is in the attachment. If you have any

questions regarding this response, please contact me at (316) 364-8831,

extension 4485, or Mr. Richard D. Flannigan at extension 4500.

Very truly yours,

.

CIAy C. Warren

CCW/jad ,

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Attachment

cc: L. J. Callan (NRC), w/a

W. D. Johnson (NRC), w/a

J. F. Ringwald (NRC), w/a

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J. C. Stone (NRC), w/a

crT- 0 6 3 2

PO Box 411 > Burkngton, KS 66839. Phone: (316) 364-8831

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Attachment to WO 97-0018

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Page 1 of 7

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Reply to Notice of Violations 50-482/9621-01, -05, and -06

Violation 50-482/9621-01: Design basis was not correctly documented

in a Configuration Change Package

A. "10CFR50, Appendix B, Criterion-III, requires, in part, that

measures be established to assure that regulatory requirements

and the design basis are correctly translated into

specifications, drawings, proceduree, and instructions. These

measures shall include provisions to assure that appropriate

l quality standards are specified and included in design +

, documents. i

Contrary to the above, on October 18, 1996, the design basis ,

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was not correctly translated into specifications for

Configuration Change Package 07111, Revision 1, which was

approved with an incorrect essential service water flow rate, ,

Specifically, the basis for the suitability of the containment

l air coolers with reduced heat removal capacity used

calculations with an assumed essential service water flow rate

l of 4000 gpm rather than the actual flow rate of 2000 gpm

( available i the coolers. ;

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This is Severity Level IV violation (Supplement 1) (50

482/9621-01)."

Admission of Violation l

Wolf Creek Nuclear Operating Corporation (WCNOC) acknowledges and agrees that

a violation of Appendix B, Criterion III occurred when an out-of-date.

calculation was used in Configuration Change Package (CCP) 07111, Revision 1.

Reason for Violation

The root cause is personnel error in that engineers failed to identify,

understand, and document all of the relevant supporting design information.

An evaluation of the event has determined that the allowed reduced heat

removal capability of the containment air coolers was technically justified

and consistent with the design basis of the plant. However, CCP 07111 did not

meet management expectations in that several out-of-date references were

inappropriately used and the supporting design information was not properly

researched and documented upon issuance of the CCP.

The reductions in containment cooler heat transfer area allowed by CCP 07111,

, Revision 0, s.lsion 1, & Revision 2 are all technically justified. The

j- justification is documented in CCP CC00372 (issued March 27, 1993) and Plant

Modification Request (PMR) 03339 (issued April 25, 1990) which were referenced

i. as part of the basis for CCP 07111 Revision O. PMR 03339 gave detailed

! guidance and justification regarding how much containment cooler heat transfer

j area could be reduced. The justification for PMR 03339 was performed when the

Essential Service Water (ESW) flow rate to each containment cooler was 2000

l gpm. Calculations SA-90-030 and GN-MW-005 were perrormed to support PMR

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03339. CCP CC00372 stated that tube plugging guidance previously given in PMR

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Attachm it to WO 97-0018

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Page 2 of 7

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Reply to Notice of Violations 50-482/9621-01, -05, and -06

03:139, as supplemented by PMR 03478, was still valid. PMR 03478 reduced the

ESU flow rate to each containment cooler from 2000 gpm to 1000 gpm. It was

supplemented to clarify that the tube plugging criteria given in PMR 03339 was

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still valid. The basis for this supplement to PMR 03478 was a comparison of

the correct cated heat transfer capability of a containment cooler with an ESW

flow rate of 1000 gpm to the much lower assumed heat transfer capability used

in the revised accident analysis (calculations SA-90-057, SA-90-064, & SA-92-

105), This basis, given in PMR 03478, is still valid today.

Contributing factors related to this event are:

e A technical review by the Nuclear Analysis group was not requested; ,

e Neither PMR 03339, SA-90-030 nor GN-MW-005 had been superseded, revised, or I

supplemented when the containment cooler ESW flow rate was reduced by PMR

03478;

e There is a lack of proficiency in using the supporting design information

database;

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e Individuals involved placed prompt completion over technical rigor l

The tube plugging criteria or margin was not clearly specified.

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Corrective Steps Taken and Results Achieved:

Appropriate engineering personnel were counseled, during work product

evaluations, on the use of design bases information that was not completely

researched, understood and documented in CCP 07111. This corrective action is

complete.

Performance Improvement Kequest PIR 96-2669 addressed concerns raised by the l

Plant safety Review Committee on the difference in the information provided in ]

CCP 07111 Revision 1 and Revision 2. This PIR addressed the questions of heat l

input for ESW warming lines, containment pressure limits and containment

cooler heat removal capacity. The PIR addressed the difference in the margins

between the capacity of the coolers with 1000 gpm ESW flow rate per

con *.ainment air cooler versus 2000 gpm ESW flow rate per containment air

cooler. The review was completed prior to exiting the LCo. This corrective i

action is complete. l

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CCP 07111 has been revised to:

o Clarify tube plugging margin information for the SGN01 A, B, C, & D coolers

(Management recognizes that the issue related to the tube plugging margin

is more generic and an effort is underway by Nuclear Engineering to

establish ownership and management of safety margins),

e Supersede calculation SA-90-030, void calculation GN-MW-005 and consolidate

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information into one calculation, GN-M-006;

! e Revise the System Description, Design Specification and Vendor Manual

documents to reflect current information;

e Update the design information database for supplemental calculation SA-90-

25; and

Revise the USAR.

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Attachment to WO 97-0018

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Page 3 of 7

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Reply to Notice of Violations 50-482/9621-01, -05, and -06

This corrective action is complete.

Corrective Steps That Will Be Taken And The Date When Full Compliance Will Be

Achieved: 1

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Work product evaluations will be revised to reinforce the expectation of i

proper use and review of the design information database and appropriate cross

disciplinary technical review. The revisions will be completed by February

28, 1997.

Training will be provided to applicable engineering personnel on the use of

design information databases for the search and retrieval of supporting

information. The training will be completed by July 7, 1997.

Management recognizes that the available engineering design databases and

information system need enhancement to facilitate search, retrieval and

maintenance of the supporting design information data. A study is presently

underway and improvement recommendations will be considered for implementation

beginning in 199u. The study will be completed by September 30, 1997.

Management recognizes that the individuals involved allowed the need for

promptness to compromise technical rigor. Management does not consider this

acceptable and will communicate their expectations to supervision and

employees by February 28, 1997.

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Attachment to WO 97-0018

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Page 4 of 7

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Reolv to Notice of Violations 50-482/9621-01, -05, and -06

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Violation 50-482/9621-05: An operability determination was not

thoroughly documented in the Shift

Supervisor's log as required by

administrative procedures.

B. " Criterion V of Appendix B to 10 CFR Part 50 requires, in part,

that activities affecting quality shall be prescribed by

documented ins tntetions , procedure, and drawings appropriate to

the circumstances, and shall be accomplished in accordance with

these instructions, procedures, or drawings.

Procedure ADM 02-024, " Technical Specification Operability,"

requires operability determinations to include a determination of

the requirement or commitment established for the equipment.

Contrary to the above, on October 22, 1996, at 2:10 p.m., the

shift supervisor reviewed a statement that listed conflicting

Updated Safety Analysis Report, Technical Specification and

Calculation GN-MW-005 information, which pertained to containment

air cooler essential service water flow rates, and performed an

I operability determination without including the requirement

i established for the equipment. Specifically, the shift supervisor

! relied on an out-of-date calculation, GN-MW-005, which assumed a

f cooler group (i.e., two coolers) flow rate of 4000 gpm, instead of

l determining the actual requirement for containment air cooler

! group essential service water flow rate of 2000 gpm.

This is a Severity Level IV violation (Supplement 1) (50-482/96-

21-05).

Admission of violation ,

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Wolf Creek Nuclear Operating Corporation (WCNOC) acknowledges and agrees that

a violation of Criterion V of Appendix B to 10 CFR Part 50 occurred when the

Shift Supervisor made an operability determination without following

administrative guidance.

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Reason for Violation:

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Evaluation and root cause analysis of the event determined that the Shift

Supervisor was correct in his determination that no operability /reportability

f concerns existed. However, the root cause is personnel error in that the

! Shift Supervisor did not meet the expectations of the Manager Operations or

l the procedural requirements of ADM 02-024, (since superseded by AP 26C-004) ,

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' Technical Specification Operability," in that the basis for the operability

determination was not documented in the Shift Supervisor's log.

Corrective Steps Taken and Results Achieved: l

Performance Improvement Request (PIR) 96-2737 which documented this event, was

placed into Operations personnel required reading to remind Shift Supervisors

of management's expectation for detailed log entries.

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, Attachment to WO 97-0018

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Page 5 of 7

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Roolv to Notice of violations 50-482/9621-01. -05, and -06

As referenced in the inspection report, during the past year there were three

similar examples of poorly supported operability determinations. The

operations Manager expects that log entries will be detailed and able to

support any conclusions reached. To correct this problem, adm nistrative

procedure, AP 26C-004, " Technical Specification Operability," was revised to

clearly reflect that a detailed log entry will be made by the Shift Supervisor l

whenever the Shift Supervisor records a decision concerning operability. This

detailed log entry will include the basis for the operability decision. l

Additionally, an operability screening checklist was added to AP 26C-004, to

ensure thoroughness of evaluation and consistency in documentation.

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. Attachment to WO 97-0018

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Page 6 of 7

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Reply to Notice of violations 50-482/9621-01, -05, and -06

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Violation 50-482/9621-06: 'frocedure STS BG-004 did not specifically l

require operators to tighten or verify the i

mechanical position stops for valves BGV-

198, BGV-199, BGV-200, and BGV-201 i

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C. " Technical Specification 6.8.1.a states, in part, that written

procedure shall be established, implemented, and maintained, l

covering the applicable procedures recommended in Appendix A l

of Regulatory Guide 1.33, Revision 2. i

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Regulatory Guide 1.33, Appendix A, , Section 3.n, requires '

l procedures for startup, operation, and shutdown, of the 1

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chemical and volume control system.

Procedure STS BG-004, *CVCS Seal Injection and Return Flow

Balance," Revision 4, provides procedural guidance for

setting the position of seal injection throttle valves BGV-

198, BGV-199, BGV-200, and BGV-201, and performing Technical

Specification Surveillance Requirement 4.5.2.g. (verifying

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the correct position of the mechanical position stops) for

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l Contrary to the above, on October 23, 1996, Procedure STS

BG-004 did not specifically require operators to tighten or

verify the mechanical position stops for valves BGV-198,

BGV-199, BGV-200, and BGV-201.

l This is a Severity Level IV violation (Supplement 1) (50-

l 482/96-021-06)."

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Admission of violation

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Wolf Creek Nuclear Operating Corporation (WCNOC) acknowledges and agrees that

a violation of Technical Specification 6.8.1.a occurred as procedure STS BG-

004, "CVCS Seal Injection and Return Flow Balance," did not provide adequate

instructions on how to tighten, nor to verify tightened, the Chemical Volume

and Control System (CVCS) mechanical position stops.

Reason for Violation:

The root cause is inadequate procedural guidance. Procedure STS BG-004, *CVCS

Seal Injection and Return Flow Balance," failed to provide adequate

instructions. This procedure did not require the performers to tighten, nor

verify tightened, the lock-nuts (mechanical position stops) on CVCS valves BG-

V198, BG-V199, BG-V200, BG-V201, and BG-V202.

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A contributing factor was that procedure AP 21G-001, " Control Of Locked

Component Status," failed to define " mechanical stop" and what constitutes a

mechanical stop at WCNOC.

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. Attachment to WO 97-0018

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Page 7 of 7

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Reply to Notice of violations 50-482/9621-01. -05, and -06

Corrective Steps Taken and Results Achieved:

A review of the applicable procedures was performed to identify areas for

improvement. The results from that review included revision of procedure AP

21G-001 to incorporate a clear definition of " mechanical stop" and what

constitutes a mechanical stop at WCNOU. Additionally, procedure STS BG-004

was revised to incorporate instructions to assure the mechanical position

stopu are tightened and/or verified tightened.

Date when Full Compliance was Achieved:

The above listed corrective actions were completed by January 30, 1997.

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ML20134K512

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