ML20134K512
| 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) | |
See also: IR 05000482/1996021
Text
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UNITE D STATES
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NUCLEAR REGULATORY COMMISSION
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REGloN IV
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611 RYAN PLAZA DRIVE SulTE 400
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ARLINGTON. TEXAS 76011-8064
FB 1 i W
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.
1
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Sincerely,
-
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.
P.O. Box 411
Burlington, Kansas 66839
9702140050 970211
ADOCK 05000482
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Wolf Creek Nuclear
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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
Chief Engineer
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Utilities Division
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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, Kansas 66839-1798
Public Health Physicist
Division of Environment
Kansas Department of Health
and Environment
Bureau of Air & Radiation
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Forbes Field Building 283
Topeka, Kansas 66620
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Wolf Creek Nuclear
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Mr. Frank Moussa
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Division of Emergency Preparedness
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2800 SW Topeka Blvd
Topeka, Kansas 66611-1287
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DRP Director
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WOLF CREEK
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' NUCLEAR OPERATING CCRPORATION
Clay C. Warren
Chief Operating Officer
January 31, 1997
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
,
Attachment
cc:
L. J. Callan (NRC), w/a
W.
D.
Johnson (NRC), w/a
J.
F. Ringwald (NRC), w/a
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
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.
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
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quality standards are
specified and included in design
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documents.
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Contrary to the above, on October 18, 1996, the design basis
,
was
not
correctly
translated
into
specifications
for
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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
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air
coolers
with
reduced
heat
removal
capacity
used
calculations with an assumed essential service water flow rate
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of 4000 gpm rather than the actual flow rate of 2000 gpm
(
available
i the coolers.
I
This is
Severity Level IV violation (Supplement 1)
(50
482/9621-01)."
Admission of Violation
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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
,
justification is documented in CCP CC00372 (issued March 27, 1993) and Plant
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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
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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
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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
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:
A technical review by the Nuclear Analysis group was not requested;
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Neither PMR 03339, SA-90-030 nor GN-MW-005 had been superseded, revised, or
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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Individuals involved placed prompt completion over technical rigor
The tube plugging criteria or margin was not clearly specified.
Corrective Steps Taken and Results Achieved:
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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
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
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
action is complete.
CCP 07111 has been revised to:
Clarify tube plugging margin information for the SGN01 A,
B,
C,
& D coolers
o
(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),
Supersede calculation SA-90-030, void calculation GN-MW-005 and consolidate
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information into one calculation, GN-M-006;
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Revise the System Description, Design Specification and Vendor Manual
documents to reflect current information;
Update the design information database for supplemental calculation SA-90-
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25; and
Revise the USAR.
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Attachment to WO 97-0018
Page 3 of 7
.
I
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
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
Page 4 of 7
,
.
Reolv to Notice of Violations 50-482/9621-01,
-05,
and -06
I
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
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cooler group
(i.e.,
two coolers) flow rate of 4000 gpm, instead of
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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.
,
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
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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:
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
whenever the Shift Supervisor records a decision concerning operability.
This
detailed log entry will include the basis for the operability decision.
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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1
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
require operators to tighten or verify the
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mechanical position stops for valves BGV-
198, BGV-199, BGV-200, and BGV-201
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" Technical Specification 6.8.1.a states, in part, that written
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procedure shall be established, implemented, and maintained,
covering the applicable procedures recommended in Appendix A
of Regulatory Guide 1.33, Revision 2.
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Appendix
A,
Section
3.n,
requires
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procedures for startup, operation, and shutdown, of the
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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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these valves.
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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.
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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
,
.
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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