ML20151K534
| ML20151K534 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 04/14/1988 |
| From: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| WM-88-0098, WM-88-98, NUDOCS 8804210337 | |
| Download: ML20151K534 (28) | |
Text
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LF CREEK W@NUCLEAH OPERATING C l
Bart D. W4hers Premdent and cr=# Ex.cuw. ome.t i
April 14, 1988 i
WH 88-0098 James Lieberman, Director Office of Enforcement U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D. C. 20555
Reference:
Letter dated March 17, 1988 from R. D. Hartin, NRC, to B. D. Withers, WCNOC l
Subject:
Docket No. 50-482: Answer to Notien of l
Violation (87-31)
Dear Mr. Lieberman:
This letter provides Wolf Creek Nuclear Operating Corporation's (WCNOC) response to the Notice of Violation and Proposed Imposition of Civil Penalty transmitted in the Reference.
The Notice of Violation identified procedural deficiencies and procedural noncompliances relative to activities being performed while Wolf Creek Generating Station (WCGS) was shut down for Refuel
- 2.
These procedural deficiencies and noncompliances, when considered in the aggregate, were placed in the Severity Level III category.
In addition, the Proposed Imposition of Civil Penalty increased the base amount because of the number of examples and perceived lack of prompt corrective actions.
Wolf Creek Nuclear Operating Corporation recognizes that a number of problems occurred during the 1987 Refueling Outage and that there were violations of our programs.
- However, the escalation of the base civil penalty is considered to be inappropriate in this case based upon the following.
1.
Contrary to statements made in the reference. WCNOC did take prompt corrective actions prior to the October 21, 1987 meeting in the Region IV office in that on October 16, 1987 a self-initiated work stoppage was imposed on outage related work and several actions were immediately initiated to evaluate and correct the problems that had occurred.
2.
WCNOC believes it is inappropriate to use the number of violations as a reason to increase the amount of the base civil penalty since the number of examples of violuions of our programs was used to escalate the Severity Level classification to a Severity Level III.
L 8804210337 880414 i
PDR ADOCK 05000482 O
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g PO Box 411/ Buriingtor. KS 66839 / Phone- (316) 364-6831 An Equad orporwaty Empoyer M F NGYET A
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WM 88-0098-Page 2 of 2 Apr1114, 1988 3.
The plant was in a cold shutdown condition for refueling and none of the events posed a threat to the health and safety of the public.
In addition, essentially all of the problems were self 4
identified and reported as required.
WCNOC hopes that as a result of your consideration of these facts, set forth in more detail in Attachment A to this letter, you will mitigate the civil penalty proposed on March 17, 1988.
Pursuant to 10 CFR 2.205, Wolf-Creek L
formally requests such mitigation.
Also provided as Attachment B to this letter is WCNOC's response to the Notice of Violation, as required by 10 CFR 2.201.
WCNOC appreciates your consideration of these matters and would be pleased to discuss them in more detail with you and your scaff.
Very truly yours, 1&
Bart D. Withers President and BDW/jad Chief Executive Officer Attachments cci B. L. Bartlett (NRC), w/a R. D. Martin (NRC), w/a P. W. O'Connor (NRC), 2 w/a
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.c STATE OF KANSAS
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) SS COUNTY OP COPPEY
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Bart D. Withers, of lawful age, being first duly sworn upon oath says that he is President and Chief Executive Officer of Wolf Creek Nuolear Operating Corporations that he has read the foregoing document and knows the content thereof that he has executed that same for and on behalf of said Corporation with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.
By "1A Bart D. Withers President and Chief Executive Officer SUBSCRIBED and sworn to before me this /Y day of /p d, 1988.
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ATTACHMENT A to WH 88-0098 REQUEST FOR HITIGATION OF PROPOSED CIVIL PENALTY (EA 87-213) 1 April 14, 1908
Attachm:nt A to WM 88-0098 Page 1 of 3 April 14, 1988 REQUEST FOR MITIGATION OF PROPOSED CIVIL PENALTY On March 17,
- 1988, the Regional Administrator of Region IV proposed the assecsment of a civil penalty in the amount of $100,000 for violations which involved procedural control weaknesses.
The NRC Notice of Violation and Proposed Imposition of Civil Penalty further stated that the weaknesses indicate that licensee management failed to provide an appropriate level of management oversight of safety-related activities.
The violations were categorized in the aggregate as a Severity Level III violation.
Although the base civil penalty for a Severity Level III violation is $50,000, the NRC increased the base amount by 100% making the proposed civil penalty
$100.000 because
- ...of the number of examples of failures to adhere to and have adequate procedures and because of the licensee's failure to take prompt corrective actions once problems were identified, in that little, if
- any, corrective actions were taken prior to the October 21, 1987 meeting in the Region IV office.' Wolf Creek Nuclear Operating Corporation (WCNOC) contends that this rationale for increasing the amount is inappropriate in that.
1) the number of violations was considered in aggregate to increase the level to a Severity Level III and it is therefore inappropriate to use the number of examples again to increase the base amount, and 2) the record clearly shows that prompt corrective actions were taken at WCNOC's oen initiative prior to October 21, 1987.
Pursuant to 10 CFR 2.205(b) and Appendix C to 10 CFR 2 WCNOC hereby requests mitigation of the proposed civil penalty.
The following j
information is provided in support of this request.
' NUMBER OF EXAMPLES' l
The NRC stated that the base civil penalty had been increased 100 percent in part
...because of the number of examples of failures to adhere to and have adequato procedures...'.
WCNOC believes that it is inappropriate to increase the base amount due to the number of events.
The Notice of Violation and Proposed Imposition of Civil Penalty stated that the violations were
... categorized in the aggregate as a Security Level III problem.'
Therefore, the number of events had already been considered in the determination of the Severity Level III classification.
WCH0C believes it is inappropriate to then use the
' aggregate
- again as a reason for increasing the base amount since it has already been used to increase the Severity Level.
This reamoning penalizes WCNOC twice for the same item of concern.
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Attechm^nt A to WM 88-0098 Page 2 of 3 April 14, 1988
' FAILURE TO TAKE CORRECTIVE ACTIONS PRIOR TO OCTOBER 21, 1987' The NRC stated that the base civil penalty had been increased 100 percent in part
...because of the licensee's failure to take prompt ccrrective actions once problems were identified, in that little, if any, corrective actions were taken prior to the October 21, 1987 meeting in the Region IV office'.
This reason for increasing the base amount is partially based on inaccurate information.
WCNOC did take prompt corrective actions prior to October 21,
- 1987, and WCNOC believes the record clearly supports this position.
WCNOC management placed a self-imposed work stoppage on all outage related activities that could be stopped without leaving the plant in an unsafe condition. This self-initiated work stoppage was due to concern on the part of WCNOC management because there had been four incidents within a short period of time.
The details of the actions taken were discussed verbally with the Resident Inspector and Region IV management on October 16, 1987 and was subsequently documented in a letter to the Region IV Administrator on October 20, 1987.
The October 20, 1987 letter stated that on October 16,
- 1987, WCNOC management had decided
...to stop outage related activities to allow time for a management review and evaluation...'.
The letter provided a description of the four events leading to the self-initiated work stoppage and described the actions being taken as part of the review and evaluation of the outage work activities.
In the October 21, 1987 meeting, WCNOC management personnel described the four events in more detail and discussed the specific corrective actions that had been taken and the status of actions that were still in process.
Following the meeting, Region IV personnel provided input to Senior WCNOC management relative to the actions taken and the actions being taken by WCNOC and made no substantial recommendations for changes to the outage resumption plan developed by WCNOC.
WCNOC believes that the self-initiated work stoppage on October 16, 1987 represents substantial action on the part of WCNOC and the actions taken prior to October 21, 1987 were prompt and appropriate for the circumstances.
The purpose of the October 21,
.1987 meeting in the Region IV office was to discuss the events that had occurred and the corrective actions WCHOC was taking. At the time of the meeting, WCNOC had not resumed the safety related work activities.
WCHOC believes that the NRC Staff had concurred with the actions documented in the October 20, 1987 letter and subsequently discussed with the Staff on October 21, 1987.
- Since, in the Notice of Violation and Proposed Imposition of Civil Penalty, the NRC did not identify fault with the specific actions discussed above and since the NRC concurred with the resumption of safety-related work activities. WCNOC believes that the NRC did not adequately coneider the actions taken prior to October 21, 1987 and the actions were appropriate for the circumstances at that time.
Therefore, the increase in the base civil penalty of 100 percent based on a lack of prompt action is not warranted.
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i Attachm:nt A to WH 88-0098 I
Page 3 of 3 April 14,-1988 1
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i CONCLUSION i
WCNOC believss that it is important to note that the incidents all occurred while the plant was in a cold shutdown. status and none of the incidents I
posed a threat to the health and safety of the public.
In addition.
[
essentially all of the problems were self identified, the corrective actions taken. by WCNCC were self-initiated and WCNOC kept the NRC well informed of j
all actions being taken.
Based upon the above discussions, WCNOC believes that it was inappropriate to use the number of events as justification for a Security Level III classification and as justification for increasing the amount of the base i
civil penalty. In addition, WCNOC believes the statement relative the lack of corrective actions prior to October 21, 1987 is.not supported by the record and therefore is inappropriats justification for increasing the base amount.
t Therefore.
WCNOC respectfully requests that the NRC mitigate the proposed civil penalty back to the base amount of $50,000.
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to kH 88-0098 RESPONSE TO NOTICE OF VIOLATION l
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April 14, 1988 l
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9 Attachment B to WM 88 0098 Page 1 of 20 April 14, 1988 RESPONSE TO NOTICE OF VIOLATION (50-482/87-31)
I.
INTRODUCTION On March 17,
- 1988, the Regional Administrator of Region IV issued a Notice of Violation for procedural noncompliances and inadequate procedures relative to work activities during Refuel II.
Wolf Creek Nuclear Operating Corporation (WCNOC) recognizes that a number of problems occurred during this outage and that there were violations of our programs.
In Section III of this Attachment, WCNOC has addressed each of the specific items identified in the Notice of Violetion.
Although a specific response has been provided for each of the findings. WCNOC believes it is important to also address the generic aspects of the problems and to provide a discussion of the more generic corrective actions taken. Therefore,Section II contains generic discussion the changes and enhancements made at WCNOC to strengthen a
its overall Management effectiveness.
II.
ENHANCEMENTS TO HANAGEMENT EFFECTIVENESS After reviewing the number and types of problems encountered during the 1987 Refueling outage, it became apparent that changes were needed to increase management and supervisory oversight of all work activities.
Although corrective actions were taken to resolve each of the specific problems WCNOC recognized the need to make some broader changes in order to preclude a similar situation in the future.
Therefore, WCNOC has instituted several changes to enhance the overall management control and effectiveness.
In order to more clearly control day to day work activities during outages, the Outage Manager will report to the Plant Manager rather than the Vice-President Nuclear Operations.
The Outage Manager's function and authority will be clearly reflected in Administrative Procedures.
The Outage Hansger will have a support steff consisting of Scheduling personnel and two Senior Technical personnel.
As an improvement to the Maintenance Organization, Maintenance will be combined with Facilities and Modifications to form an organization titled Maintenance and Modifications.
This organizational change combines all maintenance activities under a ringle administrator and creates a large skilled labor pool to be used on any maintenance or new modification task.
As a part of the organizational enhancements in the Maintenance and Modifications area, a comprehensive review was made of job assignment and job responsibility.
As a result of this effort, a significant movement of I
individuals within Maintenance took place to more properly slign talent and i
ability with job assignment.
These changes were not disciplinary in nature, but instead were improvements in alignment of individuals and jobs to insure problems such as those in the report are prevented.
In context with this
- change, significant management attention has been focused on assuring that unnecessary levels of supervision have been eliminated and establishing more direct management control in all work activities within Haintenance and Modifications.
Attechment B to WM 88-0098 Page 2 of 20 April 14, 1988 In addition to these organizational enhancements, WCNOC Hanagement formally restated to all personnel the importance of strict adherence to written procedures during the performance of work activities, testing, equipment
- repair, and plant modifications.
This is being reinforced by mandatory pre-work briefings.
Daily management meetings have been established to ensure direct management control and supervision of all ongoing work activities.
To enhance communications and provide more management involvement in day-to-day activities, the daily planning meeting has been restructured to focus more on problems and corrective actions than on work status. The meeting is attended primarily by management personnel to provide the necessary level of authority to resolve problems and take necessary corrective actions.
The meeting is normally attended by one or more of the Corporate Officers to provide senior management support.
The above organizational modifications and programmatic enhancements will serve to strengthen the performance of WCNOC and subsequently WCGS.
These actions should minimize the potential for operational or management weaknesses during future outages at VCGS.
The individual examples identified in this section are fully discussed in other sections of this response to NRC Inspection Report 87032.
III. SPECIFIC RESPONSES This section provides specific responses to each of the alleged violations and associated finding.
For each violation, the response is organised in the following manner:
Violation - The violation is reprinted for convenience and given the letter that corresponds to the letter used in the Notice of Violation.
Finding - The specific finding is reprinted for convenience and given the number that corresponds to the number used in the Notice of Violation.
Response - Admission Or Denial Of The Alleged Violation The Reasons For The Violation If Admitted The Corrective Steps That Have Been Taken And The Results Achieved The Corrective Steps That Will Be Taken To Avoid Further Violations The Date When Full Compliance Will Be Achieved The complete response is provided for each Finding before proceeding with the next Finding.
A.
Failure to Follow Procedures 10 CFR Part 50 Appendix B,
Criterion V,
- requires, in part, that activities affecting quality be prescribed by documented instructions, procedures, or drawings.
The activities shall be accomplished in accordance with these instructions, procedures, or drawings.
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Attachment B to WM 88-0098 Page 3 of 20 April 14, 1988 1
Findina:
1.
Procedure MPE E 009Q-01, Revision 0,
'13.8KV and 4.16KV Switchgear Inspection and Testing' establishes the requirements for accomplishing maintenance work in the NBC2 switchgear when terminals in the NB02 switchgear are energized, i
Step 6.1 of Procedure MPE E 009Q-91, Revision 0, states, ' Check the electrical drawings and identify any area (s) which will have high voltage potential present even when the bus is grounded. List the areas on the-Attachment
'A' sign-off sheet.'
'i Step 6.3.9.5 of Procedure MPE E 009Q-01, Revision 0 stetes, a
' clean the insulator and high voltage connection in each tubs.
check the insulators for cracks and the rossettes for damaged r
fingers.'
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l Step 6.4.3 of Procedure MPE E 009Q-01, Revision 0 states,
'Using the high voltage gloves and tester, chock the stationary disconnects for high voltage potential.
If no potential is j
found, check that the high voltage connections are discharged.'
t
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Contrary to the above, on October 14, 1987 Procedure MPE E i
009Q-01 was not followed in thats (1) Cubicle NB0209 feeder from Cubicle XNB02 was not identified as an area that had a high voltage entential present and therefore was not listed in Attachment
'A' sign off sheet as required by Step 6.1 of Procedure MPE E 009Q-01, Revision 0 (2)
Step 6.3,9.5 of the Procedure MPE E 009Q-01, Revision 0 had been signed off for cleaning the insulators and checking the insulators for cracks and the rosettes for damaged fingers as completed: however, had the insulator been actually j
- cleaned, the person performing this step would have encountered it 1
energiaed and would have been unable to perform the required i
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- cleaning, and (3) the electrician failed to check the stationary l
)
disconnects for high voltage potential to ensure that the high i
voltage connections were discharged as required by Step 6.4.3 of Procedure MPE E 009Q-01, Revision O.
i Admission or Denial of The Alleged Violation:
On October 14,
- 1987, Procedure MPE E 009Q-01, Revision 0 Step 6.1 was not followed when Cubicle NB0209 was not listed on Attachment j
A sign-off sheet.
Step 6.3.9.5 of the procedure requiring cleaning the insulators and checking the insulators for cracks and h
j the rosettes for damaged fingers, had been signed off although l
the step had not been completed.
Step 6.4.3 of the procedure, l
which requires the electrician performing the procedure to check the stationary disconnects for high voltage potential, also had not been l
completed.
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The Reasons For The Violation. If Admitted a
i The maintenance personnel performing Procedure MPL E 009Q-01, l
l Revision 0,
on October 14, 1987, had become lax in their i
j approach to the work activities being performed.
This failure to l
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I Attachment B to WH 88-0098 Page 4 of 20 April 14, 1988 l
follow the procedure led to the electrocution on October 14, 1987, of one of the personnel performing the work activities.
Step 6.4.3 of the procedure is a precautionary step, which was to be accomplished prior to performing any cleaning or inspection activities in the potential transformer cabinet. Had this step been performed, it would have prevented the electrocution from occurring.
The Corrective Steps That Have Been Tsken And The Results Achieved:
The work was stopped on the switchgear at the time of the electrocution and was not allowed to restart until an assessment of the accident and its primary cause could be evalnated and corr The cal Safety Committee mat the following day with the appt te personnel, thoroughly disenssed the accident, and began theit investigation.
Plant management decided that the inmediate corrective action which must be taken before work could be resumed, was to make step 6.4.3 a mandatory sign-off step. Th?
Jocedure was revised to incorporate this step as a mandatory Un-ff with a double verification signature also added.
The Corrective Steps Thal Vill Be Taken To Avoid Further Violations Wolf Creek management temporarily suspended the Refuel II Outage because of the electrocution, coupled with three other incidents.
As an interim
- measure, the Vice-President Nuclear Operations distributed a memo station-wide mandating that thorough pre. job i
briefings shall occur on all work activities, in or out of an outage.
The pre-job briefing vill be as short or as long as the job complexities require, and will include as a minimum safety precautions fcr the job including the clearance order will be discussed:
the actual procedures or work instructions to be used will be reviewed a general discussion of the job complexities and potential problems will be made and the pre-job briefing will repeat prior to each shift starting work in the field if a job is an on-going one.
In addition, the Vice President Nuclear Operations met with all VCNOC field working groups (Operations.
Electrical Maintenance, Mechanical Maintenance, instrument & Control, Health Physics, Chemistry, etc.) to insure all WCNOC workers understood the seriousness of procedure compliance and individual responsibility at Wolf Creek.
These meetings reinforced the management coemitment to doing the job right and in accordance with the administration rules.
In addition, the Plant Manager mandated that meetings be held with all work groups to discuss the events, causes, and corrective ictions.
During the group meetings, key program elements such as careful planning of the work, taking the time to do the work right, and paying attention to detail were discussed with the groups extensissly.
The group discussions concentrated on the individual's i
., S Attschment B to WM 88-0098 Page 5 of 20 April 14, 1988 responsibility to work safely, understand and comply with the work hour limitations, pay attention-to detail, perform comprehensive pre-job briefings, maintain proper supervision on the job, and ensure
' hat all people understand the.importance of strict compliance with procedures.
As a permanent corrective action,
. Procedure, ADM 08-201, j
' Control of Maintenance and Modifications",
which definec.the policies and practices by which the plant controls maintenance and modification activities.- was revised to incorporate the requirements as outlined above.
An engineering evaluation request has been submitted to evaluate the possibility of placing disconnects 'between the secondary windings E
and the potential transformers on.the Engineered Safety Features bus feeders as an additional permanent corrective measure.
The Date When Full Compliance Will Be Achieved:
Full compliance has been achieved.
Finding:
2.
Procedure 10-3, Revision 2,
' Sluicing Media from Duratek EVR System' describes the methods to sluice resin from the Duratek system to a disposal container.
l Contrary to the
- above, on October 10,
- 1987, two contract workers failed to follow the methods described in Procedure 103, Revision 2, when they physically "opened" a clogged pipe resulting in the contamination of the individuals themselves and the surrounding area.
Admission Or Denial Of The Alleged Violations On October 10,
- 1987, two contract workers physically breached a pressurized system containing contaminated material in an attempt to clear a clogged pipe.
This activity was not included in the apprcved procedure being performed.
Prior to brecching the system, adequate precautions were not taken to ensure that the system was depressurized.
This resulted in the contamination of the two i
contract workers and the surrounding area when the system was opened while pressurized.
The Reasons For The Violation. If Admitted:
The two contract workers performing Procedure 10-3, Revision 2, on October 10, 1987, were not adequately supervised by station personnel.
Inadequate supervision led to the two contract workers performing activities outside the approved procedure.
Attachmsnt B to WM 88-0098 Page 6 of 20 April 14, 1988 The Corrective Steps That Have Been Taken And The Results Achieved:
Following the contamination of ~the two contract workers and the surrounding
- area, Health Physics personnel performed dose calculations and whole body counts of the two contract workers.
Decontamination and cleanup activities of the surrounding area were also initiated.
Immediately following this event, management personnel stopped all radwaste operations being performed by the contract company, and
-initiated an internal investigation into the event.
At site management'a request, the contract company placed senior supervisory personnel on-site to work with the contract workers.
A meeting was held with site management and the contract company management to discuss the operations of the contract company and the attitudes of their personnel.
The Corrective Steps That Will Be Taken To Avoid Further Violations:
The Operations Coordinator issued a memo to operations personnel stipulating that site operations personnel have
_ authority and responsibility for contract radvaste procescing activities being performed on site.
In addition, cne applicable contract company's procedures have been revised to contain caution statements which require that Healtn Physics personnel be contacted prior to breaching a system.
The Date When Full Compliance Will Be Achieved:
Full compliance has been achieved.
Finding:
3.
Procedure ADM 03-101, Revision 9-
"Radiation Work Permit Program',
requires that a Radiation Work Permit (RWP) be issued for all entries into the Radiological Controlled Area (RCA).
For work activities to be performed in the RCA, Radiation Work Permit (RWP) 870017 required that a continuous air sample be drawn during the work.
Contrary to the above, on October 10,
- 1987, a continuous air sample was not drawn as required by Procedure ADM 03-101, Revision 9 while work activities were being performed in the RCA, so that any potential airborne contamination that may have existed in the area would not have been detected.
Admission Or Denial Of The Alleged Violation:
On October 10, 1987 Procedure ADM 03-101, Revision 9, was not followed when a continuous air sample of the RCA was not
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-f l' Attachmint B to WM 88-0098 Page
_ 7 of 20 April 14, 1988 performed in accordance with the requirements of RWP 870017.
Therefore, any airborne contamination that may have.been present in
~
area at the time would not have been detected.
The Reasons For The Violation.~If Admitted:'
The two contract workers performing work-activities under_lRWP 870017 on October 10,
- 1987, failed to notify Health Physics (HP) personnel that the work they were performing would require a continuous air sample..The continuous air sample was. required by RWP 870017 during the performance of waste transfer activities.
The Corrective Steos That Have Been Taken And The Results Achieved:
Immediately following this event, HP personnel performed an air sample of the area which indicated that airborne radioactivity levels were below HP action levels. Management personnel stopped.all waste processing operations'being performed by the contract company and conducted an investigation into the event.
HP personnel revised RWP 87-0017 to prohibit system breaches.while performing work activities under'the RWP, and thereby elbninated the requirement for a continuous air sample.
New RWP's were written specifically for resin transfer and system breach operations.
The Corrective S.eos That Will Be Taken To Avoid Further Violations:
The General Employee -Training stresses the necessity.to follow procedures.
Emphasis has been placed : on the procedure governing RWP's, including reading, understanding, and complying with RWP requirements.
All contract personnel with access to the RCA receive training on the_ requirements, limitations, and responsibilities of performing work activities under an RWP.
In addition, the contract company's procedures were reviewed and revised to contain where appropriate,
' caution statements requiring contract personnel to contact HP prior to any1 system-breach.-
As a result of these procedure revisions, more restrictive RWP's were written for their waste processing and transfer activities.
The Date When Full Compliance Will Be Achieved:
Full compliance has been achieved.
Finding:
4.
Procedure ADM 03-202, Revision 4
' Radiological Control and Unconditional Release of Tools and Equipment',- in Step 4.1.1
- statas, "All items prior to leaving the RCA, will be surveyed for loose contamination and for fixed contamination.
' and 'will be verified to have no.
contamination.'
contrary to the above, the Licensee failed to comply. with
l Attachm2nt B to WM 88-0098 Page 8 of 20 April 14, 1988 Procedure ADM 03-202, Revision 4, on November 9,
- 1987, in that it released radioactive material to the Coffey County Landfill that was neither surveyed for loose and fixed contamination, nor was the material verified to have no contamination.
Admission Or Denial of The Alleged Violation:
On November 9,
- 1987, it was discovered that Procedure ADM 03202, Revision 4,
was not followed when radioactive ventilation ductwork was released from Wolf Creek Generating. Station (WCGS) to the Coffey County Land Fill.
Although surveys were performed on the
- ductwork, the survey results were not acted upon in accordance with the procedure. This lead to the release of the ductwork to the landfill.
The Reasons For The Violation. If Admitted:
The HP Technician performing surveys on material to be released from the RCA for disposal on November 8, 1987, noted a_small amount of activity near the seams of the ductwork.
Procedure ADM 03-202, Revision 4,
which governs the release of materials from the RCA, not followed by the HP Technician who believed the radioactivity was to be the result of Tungsten-187 weld rod, and therefore released the ductwork from the RCA prior to completing the proper analysis.
The Corrective Steps That Have Been Taken And The Results Achieved:
The HP Technician who released the ductwork from the RCA was reprimanded for his failure to follow established procedures.
On November 10, 1987, HP Technicians were dispatched to the Coffey County Land Fill to retrieve the radioactive material.
The HP Technicians located and returned to WCGS approximately 60 square feet of the ductwork. Upon return to WCGS, personnel involved in the disassembly of the ductwork, inventoried the materials returned to WCGS to ensure all had been retrieved.
The personnel determined that three pieces were una: counted for, totalling approximately six square feet.
On November 11,
- 1987, the Nuclear Regulatory Commission, Coffey County officials, and the State of Kansas Department of Health and Environment (KDHE) were notified of the incident, and a press release was issued.
An attempt to locate and retrieve the remaining six square feet of ductwork from the landfill was initiated.
Two pieces believed to be part of the ductwork were located and returned to WCGS.
In response to the event, HP personnel and Region IV NRC Inspectors conducting a follow-up survey of the Coffey County Land Fill, located a plastic trash bag containing'two pieces of disposable cloth containing a small amount of radioactive material on November 16, 1987.
The disposable cloths, one approximately six inches by twelve inches and the other approximately eighteen square inches in size, were contaminited. A Wolf Creek HP room survey form
s Attachmint B to WM 88-0098 Page 9 of 20 April 14, 1988 dated October 15, 1987, was found inside the bag._ Therefore, HP personnel were able to determine the bag had been released to the landfill on or after October 15, 1987.
The bag was retrieved from the Coff9y County Land Fill and returned to WCGS.
On November 16, 1987, the NRC, Coffey County officials, and the KDHE were notified of the incident, and a press release was issued.
The Coffey County Land Fill segregated the area where the trash bag was found in cooperation with WCGS management, and further releases of trash from the RCA to the landfill were halted pending the completion of an investigation.
_On November 17, 1987, additional surveys of the landfill were initiated to determine the extent of the improper shipments.
The surface area of the landfill in use was surveyed.
This area was then graded and divided into 10 feet by 10 feet sections, l
Based on discussions with NRC personnel and State officials, a survey plan was deva 1 cped.
An area approximately 210 feet by 120 feet was segregatcd for data t'.ed surveying to a depth of 4 feet. The remaining area of the landfill, approximately 140 feet by 120 feet, was spot surveyed to a depth of 4 feet.
The surveys of the landfill were completed November 30, 1987.
The Corrective Steps That Will Be Taken To Avoid Further Violations:
All HP Technicians have been retrained on the proper use of the unconditional release procedure and the survey instruments.
It is believed that the disposable cloths were inadvertently released from the RCA due to the difficulty in detecting omall radioactivity levels in areas of the plant that are susccptible to background level changes as plant conditions change.
It is believed the surveys conducted on the plastic trash bag were completed in areas of the plant with background levels between 20 and 50 microrems per hour.
In an effort to prevent recurrence of these events, the location used for unconditional release surveys has been moved to an area with low, stable background radiation levels.
Because additional materials from WCGS were located at the landfill during the detailed surveys, interviews with appropriate HP personnel were conducted to deterudne the nature and extent of the problem.
In addition, the procedure governing the release of materials from the RCA has been reviewed for adequacy and accountability.
The procedure hac been revised and a method for double verification has been added.
The Date When Full Comoliance Will Be Achieved:
Full compliance has been achieved.
Attachm2nt B to WM 88-0098 Page 10 of 20 J
April 14, 1988 Finding:
5.
Procedure ADM 01-057, Revision 12, "Work Request' establishes the use of the Work Request to document and control work activities involving Safety Related Items, a.
Work Request (WR) 05013-86 required the documentation of the hydrostatic test manifold relief valve.
setting for the hydrostatic test of Spool Piece EF05-S050.
Contrary to the above, as. of November 13, 1987
-the hydrostatic test manifold relief valve setting for the hydrostatic test of Spool Piece EF05-S050 (pursuant to WR 05013-86) had not been documented.
b.
WR 02827-87, Step 5.0, required the quality control verification of the installation of an air dam bag downstream of I
valve EF V-058 on pipe 080-UBC-24.
Contrary to the above, as of November 2,
- 1987, the quality control verification of the installation of an air dam bag downstream of valve EF V-058 on pipe 080-UBC-24 (pursuant to WR 02827-87) had not been performed.
Admission Or Denial Of The Alleged Violations a.
Procedure ADM 01-057, Revision 12, was not followed when the hydrostatic test manifold relief valve setting for the hydrostatic test of Spool Piece EF 05-3050 was not documented.
b.
Procedure ADM 01-057, Revision 12, was not followed when the Quality Control (QC) verification of the installation of an air dam bag downstream of valve EF V-058 on pipe 080-UBC-24 was not performed.
The Reasons For The Violation. If Admitted a.
The Maintenance personnel who performed the hydrostatic tent of Spool Piece EF 05-S050, failed to document the hydrostatic test manifold relief valve setting as required by Work Request (WR) 05013-86.
The personnel performing this test did not fully understand the documentation requirements.
During the evolution of the work package for WR 05013-86, the work changed significantly from the work initially identified to the work finally performed.
Following four revisions to the work package, the fifth revision required the fabrication and installation of Spool Piece EF 05-S050.
These revisions to the work package resulted in the package containing work instructions that were no longer applicable or had been superseded.
The applicable instructions of the final reviriion were not clearly identified.
Some of the instructions
've re inadequate or poorly written.
In
- addition, inadequate
s Attachmtnt B to WM 88-0098 Page 11 of 20-April 14, 1988 references to maintenance and fabrication procedures were included in the work package, resulting in a work package that was confusing and misleading, b.
The maintenance personnel performing WR 02827-87, bypassed the j
QC verification during the installation of an air, dam bag downstream of valve EF V-058.
The supervisor of the personnel involved exhibited disregard for the site policy' of strict adherence to procedure and work instructions.-
j The Corrective Steps That Have Been Taken And The Results Achieved a.
Following the discovery of this procedural violation, a review of the work package was conducted.
The work package was rewritten and reformatted to clarify the work instructions to be performed.
The spool piece was then removed and retested, and the hydrostatic test manifold relief valve setting was properly documented.
b.
Work activities on WR 02827-87 were halted and the work package was revised to incorporate the additional steps necessary to allow for the verification of the installation of the air dam.
The Corrective Steps That Will Be Taken To Avoid Further Violations:
a.
Discussions were held with the appropriate personnel to emphasize the importance of providing work instructions and work-packages that can be easily understood and followed. Additional emphasis was placed on strict procedural adherence and attention to detail.
b.
Maintenance management held a meeting with the appropriate personnel to stress the importance of following work instructions. Guidelines were given for future work activities, such as thorough pre-job briefings, additional field involvement of engineers, and careful preparation of work packages.
In addition, the Maintenance supervisor who exhibited disregard for adherence to procedures and work instructions, was terminated.
The Date When Full Compliance Will Be Achieved a.
Full compliance has been achieved.
b.
Full compliance has been achieved.
F'T' w
w-m-
AttachmInt B to WM 88-0098 Page 12 of 20 April 14, 1988 Finding:
6.
10 CFR Part 50, Appendix B, Criterion IX,
- requires, in part, that measures be established to assure that special processes, including
- welding, be controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria and other special requirements, a.
Procedure ADM 08-302, Revision 4,
"Wolf Creek Generating Station Control of Welding Filler Material".
Step 6.2.4, requires that each welder have in his possession only that type and classificaticn of weld filler material authorized on the Field Welding Material Requisition.
Contrary to the above, twice on November 5 and once on November 6,
1987, welders were issued and used material different from what was authorized on the Field Welding Material Requisition.
b.
Quality Control Procedure QCI 12.1-601 Revision 2 "Inspection of ASME/ ANSI Welds",
requires that the quality control inspector verify that the weld filler material is as specified.
Contrary to the above, on November 5,
1987, a quality control inspector mistakenly verified the wrong material as being the correct material, thereby resulting in the use of improper weld filler metal in three instances for Field Welding Material Requisitions 9443, 9446 and 9448.
c.
Procedure ADM 08-302, Revision 4, S~tep 6.2.1 requires that shielded metal arc welds be performed by welders who are qualified to perform shielded metal arc welds.
Contrary to the above, on November 12, 1987, during the performance of Plant Modification Request PMR-2116, a
welder performed a shielded metal arc weld that he was not qualified to perform.
Admission Or Denial Of The Alleged Violations a.
On November 5, 1987 and November 6, 1987, Procedure ADM 084302, Revision 4,
was not followed when welders were issued and used material different from what was authorized on the Field Welding Material Requisition (FWMR).
b.
On November 5,
- 1987, the incorrect welding filler material vas verified as correct by the QC inspector who utilized the FWMR rather than physically verifying the filler material.
Because different filler material was issued to the velders than that listed on the FWMR, this resulted in the use of improper welding metal for three FWMR's 9443, 9446, and 9448.
t
AttachmInt B to WM 88-0098 Page 13 of 20 April 14, 1988 c.
On November 12,
- 1987, Procedure ADM 08-302 Revision 4, was not followed when a welder performed a shielded metal arc weld that he was not qualified to perform during the performance of Plant Modification Request (PMR) 2116.
The Reasons For The Violation. If Admitted:
a.
On November 5, 1987 and November 6,
- 1987, two welders who requested ECoCr-A welding filler material, were issued RCoCr-A welding filler material in error.
This error was not detected by the two welders prior to using the incorrect welding filler
- material, thus violating Procedure ADM 08-302, Revision 4.
b.
Procedure QCI 12.1-601, Revision 2, did not adequately specify physical verification of welding filler material.
Therefore, on November 5,
- 1987, the QC inspector utilized the FWMR's for verification of the welding filler material.
c.
The Maintenance supervisor designee failed to verify the welder's qualifications prior to the performance of the shielded metal arc welds required for PMR 2116.
This failure to follow Procedure ADM 08-302, Revision 4,
led to the welds being performed by a welder who was not qualified-to perform these welds.
The Corrective Steps That Have Been Taken And The Results Achieved:
a.
As a result of the numerous welding problems identified, an investigation was initiated by management.
All velding work being performed by Maintenance personnel was stopped in accordance with a Work Hold Agreement.
All welding activities were turned over to the Facilities and' Modifications (F&M) welders for completion.
The welds that had been completed using the unspecified welding filler material were removed and rewelded.by F&M welders using the specified material.
l b.
The welds that had been completed using the unspecified welding filler material were removed and rewelded by F&M welders using the specified material, j
QC inspectors verified that the welding filler material consumables used in the rework were as specified on the Welding Datat Sheet (WDS) and the Welding Precedure Specification (WPS),
in accordance with the revised inspection procedure.
c.
The welds that had been completed by the unqualified welder l
were removed and revelded by a qualified welder.
The Maintenance i
supervisor designee who failed to verify the welder's qualifications, was reprimanded for his failure to follow site procedures, l
j
1 Attachmsnt B to WM 88-0098 Page 14 of 20 April 14, 1988 The Corrective Steps That Will Be Taken To Avoid Further Violations:
a.
Discussions were held with all those responsible for issuing welding filler material, to emphasize the need for attention to detail and adherence-to procedures.
As a result of the investigation into the event, it was determined necessary to provide additional technical training to those responsible for issuing velding filler materials.
b.
A discussion was held with QC welding inspectors to clarify the specific procedural requirements for_ welding filler material verification.
Procedure QCI 12.1-601 was revised.to clarify the extent of the inspection activitics that are necessary to fulfill the verification requirements. A memo was issued to QC welding inspectors to reiterate these requirements for verification, c.
Discussions were held with the Mechanical supervisors and their designees to ensure compliance with procedures governing the assignment of qualified welders. Additional technical training will be provided for the Mechanical supervisors and their designees.
The Date When Full Compliance Will Be Achieved:
a.
Full compliance will be achieved by June 15, 1988.
b.
Full compliance has been achieved.
c.
Full compliance will be achieved by June 15, 1988.
B.
Failure to Have Acoropriate Procedures 10 CFR Part 50, Appendix B,
Criterion V,
- requires, in part, that activities affecting quality be prescribed by documented instruction, procedures, or drawings of a type appropriate to the circumstances.
l Finding:
1.
Procedure GEN 00-007, Revision 8,
'RCS Draindown*,
used to purge
)
hydrogen from the reactor coolant system (RCS) and pressurizer, in Step 4.3.4,
- states, in part,
' Commence raising pressurizer level towards 100 percent on BB LI-462, pressurizer level cold calibration, carefully observing reactor coolant system pressure *.
1 Contrary to the
- above, on October 14,
- 1987, the licensee j
experienced an inadvertent ignition of hydrogen in the pressurizer 1
because Procedure GEN 00-007, Revision 8 was not appropriate to f
ensure that all the hydrogen was purged out of the pressurizer. The j
upper taps for the level instrumentation are approximately 3 feet below the top of the pressurizer.
Therefore, even though the instruments (BB LI-462) indicated 100 percent as required by the
Attachm:nt B to WM 88-0098 Page 15 of 20 April 14, 1988 procedure, the pressurizer still had a vapor space with enough hydrogen present to support a burn.
Admission Or Denial Of The Alleged Violation:
On October 14,
- 1987, a
utility welder struck an are which caused an inadvertent ignition of hydrogen in the pressurizer.
Procedure GEN 00-007, Revision 8,
which is used to purge hydrogen from the Raactor Coolant System (RCS), was not adequate to ensure that all of the hydrogen was purged frcm the pressurizer.
The Reasons For The Violation. If Admitted:
Although Step 4.3.4 of Procedure GEN 00-007 Revision 8, was followed by raising the pressurizer level towards 100 percent as indicated on BB LI-462, the upper taps for the level instrumentation are located approximately three feet below the top of the pressurizer.
Therefore, as much as nine percent hydrogen could remain in this space in the pressurizer, enough to support a burn, following the performance of this step of the procedure.
The work activities in progress just prior to this event included the removal of the safety valves and instrument root valves which allowed the introduction of air into the pressurizer, producing the flammable mixture.
- Thus, the utility welder supplied an ignition source for this mixture when he struck an arc.
The Corrective Steos That Have Been Taken And The Results Achieved:
1 Following this event, welding of the valves was suspended by site ranagement until an investigation and evaluation could be conducted.
Radiation surveys and flammable gas samples taken following the event indicated nornal readings.
j A walkdown of the pressurizer, piping and supports was conducted on October 24,
- 1987, by utility engineering and QC personnel.
They found no specific anomalies that could be linked to the hydrogen burn event.
The pressurizer spray nozzle was visually examined on October 19,
- 1987, by utility Quality Control personnel.
This examination found no loose parts, no evidence of cracks or loss of integrity at the welded connections.
The pressurizer immersion heaters were tested for insulation resistance and continuity on October 29, 1987.
The results were satisfactory.
The pressurizer level transmitters were checked on October 29, 1987.
Two of the three narrow range transmitters were recalibrated.
These results were consistent with previous calibrations.
One pressurizer safety valve was removed and inspected.
It was not damaged by the heat generated during the hydrogen burn.
Attachm:nt B to WM 88-0098 Page 16 of 20 m
April 14, 1988 At site management's request, analysis of the event was conducted by Westinghouse to determine if the system loadings caused by the hydrogen burn exceeded the design loading.
The analysis results, showed that the peak gas pressure and temperature were. lower than the design.
The peak thermal stress resulting-from the temperature. rise, combined with the pressure stress was well below the fatigue endurance limit. Thus, the contribution to fatigue was negligible. The resulting stresses from this event were substantially less than the American Society of Mechsnical Engineers (ASME) Code stress allowables for the pressurizer shell and nozzles.
The Corrective Steps That Will Be Taken To Avoid Further Violations:
The procedure for depressurizing and draining the pressurizer will be reviewed to determine the best method of removing the hydrogen from the pressurizer.
This procedure will be revised accoraingly and the Control Room personnel will be trained on the revisions.
The necessary permanent procedure revisions will be completed prior to the use of the procedures in the next refueling outage.
The Date When Full Compliance Will Be Achieved:
Full compliance will be achieved prior to the next refueling outage.
Finding:
2.
Procedure ADM 13-101, Revision 4,
"Control of Ignition Sources',
requires verification that the pressurizer be purged of flammable material.
Contrary to the above, on October 14,
- 1987, the licensee experienced an inadvertent ignition of hydrogen in the pressurizer because Procedure ADM 13-101, Revision 4 was not appropriate in that it failed to require that a sample be taken to confirm that the pressurizer had been purged of flammable material.
Admission Or Denial Of The Alleged Violation:
On October 14,
- 1987, a
utility welder struck an arc which caused an inadvertent ignition of hydrogen in the pressurizer.
Procedure ADM 13-101, Revision 4,
which is used to control ignition sources, was not adequate in that it failed to require that sample be taken to confirm that the pressurizer had been purged of a
flammable material.
The Reasons For The Violation, if Admitted:
The administrative procedure, ADM 13-101, Revision 4,
' Control of Ignition Source',
required a check-off indicating that closed equipment such as tanks be purged of flammable gasses.
This procedure did not specifically require a flammable gas sample be taken.
Since the pressurizer had been filled with nitrogen during the RCS draindown no flammable mixture was believed to be present.
Based on this, the Shift Supervisor told the utility welder who
+
AttachmInt B to WM 88-0098 Page 17 of 20 April 14, 1988 filled out the Ignition Source Permit for the pressurizer root valve replacement, that the pressurizer had 'been purged with nitrogen gas.
The-Corrective Steps That Have Been Taken And The Results Achieved:
Corrective steps that.have been taken and the results achieved are discussed above in item B. 1.
The Corrective Steps That Will Be Taken To Avoid Further Violations:
The procedure for control of ignition sources has been revised to require a check for combustible gasses prior to welding on closed or poorly ventilated t:nks. Persoc..el authorized tc approve Ignition Source Permits have been trained on these requirements.
The Date When Full Compliance Will Be Achiaved:
Full compliance has been achieved.
Finding:
3.
Procedure SYS NG-331, Revision 5 "Deenergization of 480 Volt (Class 1E) Bus (es)',
provides instructions necessary to deenergize the 480 Volt (Class 1E) load centers and/or transformers.
Contrary to the above, on October 15, 1987, when the 4.16 KV Bus NB02 was taken out of service for routine maintenance, the normal power supplied to the 125 V DC Buses NK02 and NK04 was deenergized and the loads were then transferred and placed upon Battery Banks NK12 and NK14, respectively. While Procedure SYS NG-331 provided instructions to deenergize the 480 Volt (Class 1E) load centers, the procedure was inadequate in that no instructions existed to guide personnel in calculating the length of time the batteries could carry the electrical loads and in determining the battery attributes which should have been periodically checked.
Admisrion or Denial Of The Alleged Violation:
Although Procedure SYS NG-331 Revision 5
did not contain instructions to guide personnel in calculating the length of time the batteries could carry the electrical loads or in determining the battery attributes to be checked periodically, this procedure was not intended to cover the type of major outage experienced on October 15, 1987.
A separate procedure is needed to establish temporary power supplies to the batteries during a major outage of a safety-related 4.16 kilovolt division.
The Reasons For The Violation. If Admitted:
The failure to have an appropriate procedure to provide temporary power supplies to batteries during extended outages was due to a failure to recognize the need for such a procedure.
Attachmint B to WM 88-0098 Page 18 of 20 April 14, 1988 This failure to have an appropriate procedure led to the loss of the safety-related 125 volt DC bus, NK04, and the safety-related 120 volt AC instrument bus, NN04, when the NB02 outage was extended beyond the estimated 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> -to allow for the investigation of a separate incident.
The Corrective Steps That Have Been Taken And The Results Achieved:
Following the loss of power to NK04 and NN04, a temporary modification was installed to supply power to the battery charger for battery NK12. An additional temporary modification was installed to supply power to the 120 volt AC instrument bus NN04.
Site management initiated an investigation into. this event.
The evaluation of the batteries as a result of this investigation found that following recharge, the batteries showed no signs of degradation, and therefore capable of performing their design function.
The Corrective Steps That Will Be Taken To Avoid Further Violations:
A procedure will be written for deenergizing a safety-related 4.16 kilovolt division and supplying temporary power to the affected batteries for major outages.
The Date When Full Compliance Will Be Achieved:
Full compliance will be achieved prior to the next refueling outage.
Finding:
4.
Procedure STS IC-725B, Revision 1,
'7300 Process and N.I.
Response Time Test (2/4 Logic) Protection Set II",
establishes the requirements for testing of response times of the Analog Channels that generate certain Reactor Trip and Enginecred Safeguard Feature functions.
Licensee Technical Specification (TS) 3.9.2
- requires, in part,
'As a minimum, two source range neutron flux monitors shall be operable.
' and 'With one of the above required monitors inoperable or not operating, immediately suspend all operations involving core alterations.
Contrary to the above, on November 7, 1987, while making core alterations, the licensee performed Procedure STS IC-725B.
Procedure STS IC-725B specified that both source ranges be deenergized: however, the TS required that both source range neutron flux monitors were to be operable.
- Thus, the procedure was not adequate to ensure TS requirements were satisfied during all modes of plant operation.
Admission Or Denial of The Alleged Violation l
Although STS IC-725B, Revision 1,
did not specify -that both source ranges be deenergized, the high voltage power supply to both l
source range neutron flux monitors was lost when the procedure 1
Y'^
s Attachmsnt B to WM 88-0098 Page 19 of 20 April 14, 1988 i
performed while core alterations were in progress on November 7, was 1987.
This situation occurred in.
violation of Technical Specification 3.9.2 which states that two source range neutron flux monitors shall be operable when the plant is in Mode 6, each with continuous visual indication in the control room and one with audible indication in the containment and control room.
The Reasons For The Violation. If Admitted:
The deficiency in Procedure STS IC-725B, Revision 1, was due to a failure to recognize that when Logic Switch
'3' on the Solid State Protection System Logic Test Panel was turned through the
'3'
- position, inadvertentif initiating a P-10 signal, it would isolate high voltage supply to the Nuclear Instrumentation System (NIS) source range detectors.
The Corrective Steps That Have Been Taken And The Results Achieved:
Immediate corrective actions were taken to cease core alterations and enter Action Statement b.
of Technical Specification 3.9.2.
The IGC group discontinued STS IC-725B.
The logic switches
'A' and "B"
on Solid State Protection System Trains
'A' and "B" Logic Test Panels were returned to the "off' position, restoring high voltage to the NIS source range detectors and restoring normal indication.
The Corrective Steoa That Will Be Taken To Avoid Further Violations:
Upon review of drawings and verification of corrective actions, a temporary procedure change, MA 87-449, was completed to add steps for lifting wires from designated terminal blocks in NIS cabinets SE054A and SE054B in order to defeat the P-10 source range interlock.
In addition, steps were included to reland the wires after completion of the test.
This change allowed completion of STS IC-725B.
For future performance of response time tests, permanent revisions to Procedures STS IC-725A, STS IC-725B, STS IC-725C and STS IC-725D will be completed.
Evaluation results have indicated that other events could also generate a P-10 signal during testing, isolating high voltage supply to the NIS source range detectors.
Therefore, a permanent revision to verify leads are lifted as required before starting tests will be issued.
Review of centrol room logs documenting the October - December, 1986 Refueling Outage indicated that a similar loss of source range indications occurred on November 22, 1986, during the performance of STS IC-725A for Protection Set I.
Because core alterations were i
complete at that time, the Technical Specification 3.9.2 Action Statements were not applicable.
The Date When Full Compliance Will Be Achieved:
)
Full compliance will be achieved prior to the next refueling outage.
s' Attachmsnt B to WM 88-0098 Page 20 of 20 April 14, 1988 IV.
CONCLUSIONS WCNOC recognizes that problems occurred during the 1987 outage that require not only corrective action for the specific events, but overall corrective action to strengthen management effectiveness as well.
In Section III of this
- response, WCNOC responded to each alleged violation individually as requested in the Notice of Violation. However, 'WCN00 would like to emphacize that these findings have not been viewed as separate or unrelated problems.
WCNOC has reviewed these items collectively and believe that the overall actions discussed in Section II will significantly enhance the overall management effectiveness and general control of work activities at Wolf Creek Generating Station.
P P
l l
i I
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