ML20138Q173
| ML20138Q173 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 02/28/1997 |
| From: | Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Maynard O WOLF CREEK NUCLEAR OPERATING CORP. |
| References | |
| NUDOCS 9703060184 | |
| Download: ML20138Q173 (5) | |
See also: IR 05000482/1996023
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611 RY AN PL AZA DRIVE, SUITE 400
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AR LINGT ON. T E x AS 76011 8064
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FEB 2 81997
Otto L. Maynard, President and
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Chief Executive Officer
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Wolf Creek Nuclear Operating Corporation
P.O. Box 411
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Burlington, Kansas 66839
SUBJECT: NRC INSPECTION REPORT 50-482/96-23
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Dear Mr. Maynard:
Thank you for your letter of January 10,1997,in response to our letter and Notice of
Violation dated December 13,1996. We have reviewed your reply to Violation B and find
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it responsive to the concerns raised in our Notice of Violation. We will review the
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implementation of your corrective actions during a future inspection to determine that full
compliance has been achieved and will be maintained.
After reviewing your response to Violation A and discussing this response in a telephone
conversation involving Mr. Clay Warren of your staff and members of my staff, we have
determined that this violation should be withdrawn. We agree that the correct operability
[
evaluation conclusion was reached following the identification of an oil leak on the oil
system for the Terry turbine in the auxiliary feedwater system and, in this instance, it was
not necessary to identify the leaking component. However, under different circumstances,
correct identification and knowledge of the deficient component may be an important
evaluation factor in determining the operability of a system. The incorrect identification of
the leaking component by the system engineer indicates a weakness in the engineer's
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knowledge of the system. We also believe that it is important that your expectations for
procedure implementation in this area are clearly communicated.
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If you have any questions on this matter, please contact me or Mr. Bill Johnson of my
staff.
Sincerely,
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J. E. Dyer, Acting
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Regional Administrator
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Docket No.: 50-492
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License No.: NPF-42
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9703060184 970228
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ADOCK 05000482
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Wolf Creek Nuclear
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Operating Corporation
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cc:
Chief Operating Officer
Wolf Creek Nuclear Operating Corp.
P.O. Box 411
,
Burlington, Kansas 66839
Jay Silberg, Esq.
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
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, Kansas 66839-1798
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Wolf Creek Nuclear
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Operating Corporation
Public Health Physicist
Division of Environment
Kansas Department of Health
and Environment
Be eau of Air & Radiation
Forbes Field Building 283
Topeka, Kansas 66620
Mr. Frank Moussa
Division of Emergency Preparedness
2800 SW Topeka Blvd
Topeka, Kansas 66611-1287
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Wolf Creek Nuclear
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Operating Corporation
FEB 2 81997
bec to DMB (IE01)
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Regional Administrator
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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DOCUMENT NAME: R:\\_WC\\WC623AK.JFR
To receive copy of document, indicate in box: "C" = Copy without enclosures
"E" = Copy with enclosures "N" = No copy
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Wolf Creek Nuclear
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Operating Corporation
FEB 2 81997
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W@LF CREEK
' NUCLEAR OPERATING CORPORATION
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Neil S. " Buzz" Carns
Chairman, President and
Chief Executive Officer
January 10, 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 13, 1996, from
J. E. Dyer, NRC, to N.
S. Carns, WCNOC
Subject:
Docket No. 50-482: Response to Notice of
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Violations 50-482/9623-01, and -03
Gentlemen:
,
This letter transmits Wolf Creek Nuclear Operating Corporation's (WCNOC)
response to Notice of Violations 50-482/9623-01, and -03.
Violation 9623-01
describes an operability recommendation being provided to the shift supervisor
for the turbine-driven auxiliary feedwater pump based on an evaluation of an
oil leak from the turbine governor system without properly identifying the
leaking governor equipment and properly evaluating the effect of the leak on
this governor equipment.
Violation 9623-03 concerns the failure to properly
establish and maintain Procedure STN FP-204, " Fire Protection System Flow and
Sequential Pump Start Test."
WCNOC's responses to these violations are in the attachment.
If you have any
questions regarding this response, please contact me at (316)
364-8831,
extension 4100, or Mr. Richard D.
Flannigan at extension 4500.
Very truly yours,
.
Neil S.
Carns
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NSC/jad
Attachment
cc:
L.
J.
Callan (NRC), w/a
W.
D. Johnson (NRC') , w/a
J.
F. Ringwald (NRC), w/a
W OS40
J.
C. Stone (IEC), w/a
PO Box 411/ Burlington. KS 66839 > Phone: 1316) 364-8831
An Equal Orportunity Empioyer M F HC VET
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Attachmant to WM 97-0002
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Page 1 of 6
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Ranly to Notice of Violations 50-482/9623-01 and -03
Violation,50-482/9623-01:
The failure to include all the required actions
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to perform an operability evaluation, in that
the licensee did not properly identify the
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affected component
and,
therefore,
did not
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determine the impact of
the
leak on this
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component.
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"A.
Criterion V of Appendix B to 10 CFR Part 50 requires, in part,
that
activities
affecting
quality
shall
be
prescribed
by
documented instructions, procedures, 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 rew irsment or commitment established for the equipment.
Contrary to the above, on November 11, 1996, the system engineer
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provided an operability recommendation to the shift supervisor for
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the turbine-driven auxiliary feedwater pump based on,an evaluation
of.an oil leak from the turbine governor system without properly
identifying the leaking governor equipment and properly evaluating
the effect of the leak on this governor equipment."
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Danfal of violatient
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Wolf Creek Nuclear Operating Corporation (WCNOC) denies that a violation of
Criterion V of Appendix B to 10 CFR Part 50 occurred on November 11,
1996,
when the system engineer provided an' operability recommendation to the shift
supervisor on the turbine oil system.
The operability evaluation, as
performed,
was consistent with procedural requirements of ADM
02-024,
" Technical Specification Operability."
Backgrounds
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operability of the oil system was noted in the control room / shift Supervisor
logs on three separate occasions on November 11,
1996, all with the same
conclusion that the equipment remained operable.
The first mention of the oil
leak was at 0230.
The Shift Supervisor 0230 log entry stated "TB [ Turbine
Building] watch identified oil on TDAFWP governor pilot assembly and down on
pump pedestal.
Oil level in sump is sat.
The leak appears to have occurred
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at a compression fitting on the governor pilot assembly.
AR #18526 written
and this will be an SS concern in the morning.
The pump was run on 11/7/96
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and I believe that is when the leakage occurred as no active leakage is
currently occurring.
The pump remains operable as I feel the leakage
occurring when the pump runs is very small and oil level in the sump is within
operable range."
The control room log entry at 0230 stated " Turbine building operator noted oil
on the TDAFP governor pilot assembly and pooling on pump pedestal directly
underneath the oil pump and pilot assembly.
The pump run for operability was
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Attachm:nt to WM 97-0002
Page 2 of 6
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completed November
7,
1996, at 0119.
Oil level in the turbine oil sump is
adequate.
Oil leaks appear to be at compression fittings on the governor
pilot assembly.
AR #18526 written.
There does not appear to be an
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operability concern at this time."
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At approximately 0930 on November 11, 1996, the system engineer was informed
and asked to look at the leak on the Terry Turbine.
The system engineer went
with Management and Instrumentation and Control personnel to visually verify
the quantity, location, and if appropriate, to correct the leak.
The system
engineer observed the leak location at two pipe thread connections.
It was
conservatively estimated that the leak rate was approximately one ounce per
hour while the system was in operation and it was noted that the leak was not
active when the system was static. Observations revealed that oil system
connections would have to be removed and thread sealant added to completely
seal the leak.
Performance of such a rework evolution would require the Terry
Turbine to be removed from service.
At approximately 1045 on November 11, 1996, the system engineer updated the
control room and stated that he did not have any concern at that time, but
that he would continue to look into the issue.
The control room logs at 1045
indicate
"[ System engineer, name omitted] reported to SS on TDAFW Pump.
Fitting that is leaking oil can not be tightened without CO [ Clearance Order)
on pump.
No operability concern exists."
The Shift Supervisor logs at 1057
indicste "[Name omitted] System Engineer (TDAFWP) did local evaluation on oil
leak (0230 entry) and found oil seepage at piping connections.
His evaluation
was that the connections could not be tightened without plant support.
Contact with Work Week Manager to schedule a meeting at 1300 today in the
Integrated Plant Scheduling Conference Room to plan and evaluate maintenance
approach to TDAFWP."
The meeting at the Integrated Plant Scheduling Conference Room was held,
ooerability was reviewed, and a plan to evaluate a maintenance approach was
discussed.
Members attending were from Operations Management, Control Room
personnel,
Instrumentation and Control
Supervision,
Instrumentation and
Control personnel, Plant Ma-igement,
Integrated Planning and Scheduling,
System Engineering Supervision, and the System Engineer.
One of the considerations at the meeting on November
7,
1996, was that the
Terry Turbine Pump successfully completed STS AL-103, "TDAFWP Pump Inservice
Pump Test," which monitors oil pressure.
Had the oil pressure not been
sufficient, the pump would have failed STS AL-103.
The oil leak was estimated
at one ounce per hour, with the Terry Turbine being required to run for four
hours in an emergency situation. The loss of the estimated four ounces of oil
from the total
capacity of approximately seven gallons
is
considered
insignificant.
Even if the oil level in the Terry Turbine were at the low
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mark (where an Action Request is generated to restore level), there is
considerably more oil that can be lost before the Turbine is declared
The final determination was made by the involved personnel that the Turbine
and its associated oil system would be able to perform its safety function.
The 1450 Shift Superviser log entry stated "TDAFWP meeting (see 1057 entry)
with [ names omitted) attending evaluated that the leak rate is minimal enough
that the pump will be able to perform its safety function.
It is planned that
the leaking fittings will be sealed and tightened during the next LCO."
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Attachment to WM 97-0002
Paga 3 of 6
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On November 12, 1996, the following morning, the system engineer showed the
Resident Inspector the physical location of the leak while touring the Terry
Turbine room.
The Resident Inspector asked the name of the particular oil
system sub-component and the system engineer identified it as the Electronic
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Governor-Remote Servo (EG-R) when, in fact, it was the auxiliary oil sump for
the EG-R. The identification of the sub-component by its proper name was not
the basis for and did not alter the basis for the determination of
operability.
Discussion:
Further explanation is provided below on the conclusions reached during the
system engineer's evaluation.
These were the facts that the system engineer
considered before giving a recommendation on operability.
Documentation of
the facts were not required since procedure AP
28-001,
"E 7aluation of
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Nonconforming Conditions of Installed Plant Equipment," was not invoked by the
Shift Supervisor.
The italicized words below are from procedure ADM 02-024, " Technical
Specification Operability". The responses are the facts that the system
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engineer considered before giving a recommendation on operability and provides
substantiation that requirements of procedure ADM 02-024 were met.
The system
engineer did identify the nature of the oil leak and evaluated the effect of
the leak on the Terry Turbine oil system.
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1.
Determine what equipment is degraded or potentially nonconforming.
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The equipment observed was the oil system for the Terr;' Turbine.
Therefore,
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the nature and quantity of the leak with respect to the oil system was the
focus for the system engineer.
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2.
Determine the safety function (s) performed by the equipment.
The oil system supports the Terry Turbine by providing oil for Turbine
lubrication and Turbine speed control.
The Terry Turbine provides cooling
water to the Steam Generator used to cool the Reactor Coolant System.
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3.
Determine the circumstances of the potential nonconformance, including the
possible failure mechanism.
The oil leaked from two pipe fittings on the Terry Turbine Oil System at
approximately one ounce per hour while the turbine was running.
The possible
failure mechanism would have been the loss of the Terry Turbine oil pressure
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and the failure of the pump to perform its safety function.
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4.
Determine the requirement or commitment established for the equipment, and
why the requirement or commitment may not be met.
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The equipment is required to meet a mission of four hours.
The commitment may
not be met if oil pressure cannot be maintained.
5.
Determine by what means and when the potentially nonconforming equipment
was first discovered.
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Attachmtnt to WM 97-0002
Paga 4 of 6
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The leak was discovered on November 11, 1996.
The leak was not active and the
leak was discovered as a result of residual oil from a surveillance performed
on November 7,
1996.
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6.
Determine the safest plant configuration including the effect of
transitional action.
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The safest configuration was to keep the Terry Turbine on standby, ready to
perform its safety function in accordance with the Maintenance Rule, based on
the mir.or nature of the leak.
7.
Determine the basis for declaring the affected system operable, through:
A.
Analysis--Based on the location and the amount of the oil leakage
from the oil system, the system engineer determined that the Terry Turbine
would lose only an estimated four ounces in a four hour period of time, if the
oil system were pressurized.
The amount of remaining oil would enable the
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pump to perform its safety function.
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B.
Test or partial test--The Terry Turbine had passed the surveillance
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(STS AL-103,
"TDAFW Pump Inservice Pump Test") on November
6,
1996.
In
accordance with ADM 02-024, if a system or component fails while being tested,
the system is to be declared inoperable or the appropriate LCO must be
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entered. Therefore, testing had already indicated that the system was capable
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of performing its safety function.
C Operating Experience--The leak rate of one ounce per hour (which only
occurred at operating pressure) , with a mission of the Terry Turbine being
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four hours, would not have made the Terry Turbine inoperable.
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D.
Engineering Judgment--Based on the system engineer's evaluation of
the condition, the Terry Turbine was considered able to perform its safety
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function,
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conclusient
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The effect of this oil leak on the operability of this component was
adequately evaluated in accordance with procedures, and that the equipment
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would have performed its safet'i function. WCNOC concludes that there has been
no violation of Criterion V of Appendix B to 10 CFR 50.
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Attachm:nt to WM 97-0002
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Paga 5 of 6
Violation 50-482/9623-03:
The failure to adequately establish and maintain
Procedure STS FP-204 as required by the fire
protection program.
"B.
Technical Specification 6.8.1.h requires, in part, that procedures
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shall be established, implemented, and maintained covering the
fire protection program implementation,
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Procedure AP
10-100,
" Fire Protection," Revision
1,
requires
Procedure STS FP-204, " Fire Protection System Flow and Sequential
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Pump Start," Revision 10,
to perform a flow test in accordance
with Chapter
5,
Section 11 of the National Fire Protection
Association (NFPA) Fire Protection Handbook, 14th Edition.
Contrary to the above, on October
24,
1996,
fire protection
personnel failed to properly establish and maintain Procedure STS
FP-204 as evidenced by the following examples:
1)
The NFPA Fire Protection Handbook provided instructions to
take pitot tube readings in the center of the flow stream at
a distance equal to one half of the diameter of the nozzle
opening.
Procedure STS FP-204 contained no such
instructions, which resulted in different personnel using
different methods to take readings during the test.
2)
The NFPA Fire Protection Handbook also provided a caution
that pitot tube readings less than 10 psi or greater than 30
psi at any open hydrant should be avoided.
Procedure STS
FP-204 contained no such limits and readings taken on
24 October exceeded 30 psi.
While the readings were taken
on a tect header and not an open hydrant, the handbook
provided limits because of reduced accuracy at higher
pressures.
3)
Procedure AP 10-100 required Procedure STN FP-204 to perform
a flow test in accordance with the NFPA Fire Protection
Handbook, 14th edition. However, the scope statement for
Procedure STN FP-204 stated that the test was in accordance
with NFPA Standard 20 and American Nuclear Insurers
requirements."
Admission of Violatient
WCNOC acknowledges and agrees that a violation of Technical Specification
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6.8.1.h
occurred on October
24,
1996, when flow results indicated that
Procedure STN FP-204 had not been maintained in accordance with the NFPA.
Emisen for violation:
Root Cause:
The root cause of this violation is that the Fire Protection Program relied
too heavily upon " skill of the craft" which led to Procedure STN FP-204, " Fire
Protection System Flow and Sequential Pump Start Test," not providing guidance
as referenced
in
the NFPA Handbook.
10-100.
" Fire
Protection,"