ML20195D824

Responds to NRC Re Violations Noted in Insp Rept 50-482/98-12.Corrective Actions:Upon Issuance of PIR 98-1008 Shift Supervisor Requested Operability Evaluation Per AP 28-1008

ML20195D824
Person / Time
Site:	Wolf Creek
Issue date:	11/13/1998
From:	Maynard O WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-482-98-12, WM-98-0118, WM-98-118, NUDOCS 9811180175
Download: ML20195D824 (12)

Text

Otto L Maynard W$LF CREEK NUCLEAR OPERATING CORPORATION President and Chief Executive Officer NOV 131998 WM 98-0118 U. S. Nuclear Regulatory Commission

' ATTN . Document Control Desk Mail Station P1-137 Washington, D. C. 20555

Reference:

Letter dated September 29, 1998, from William D.

Johnson, USNRC, to O. L. Maynard, WCNOC

Subject:

Docket No. 50-482: Response to Notice of Violation 50-482/9812-01 (EA 98-274) and 9812-02 Gentlemen:

This letter transmits Wolf Creek ' Nuclear Operating Corporation's (WCNOC) response to Notice of Violations 50-482/9812-01 and -02. Violation 9812-01 identified a failure to perform a written evaluation in accordance with 10 CFR 50.59 that provided the bases for the determination that procedure changes did or did not involve an unreviewed safety question. Violation 9812-02 required response to the first example only, which involved a failure to follow procedures in _ that a calculation was not updated with a design change as required by procedure. On October 22, 1998, Tony Harris, WCNOC Licensing, requested an extension of'the required September 29, 1998, due date from September 29, 1998 to November 13, 1998. This request was approved by Tom Stekta, USNRC.

WCNOC's response to these violations and discussions related to other

-information contained in Inspection Report 98-12 are provided in Attachment I.

Attachment II provides a list of commitments contained in this letter.

WCNOC is denying that a violation occurred in the first example of violation 9812-02; therefore, a copy of this letter is being provided to the Director, Office of Enforcement. If you have any questions regarding this response, please contact me at (316) 364-4000, or Mr. Michael J. Angus at (316) 364-4077.

Very truly yours, I/j

/,

j WA (Afl/

Otto L/ 14aynard '

OLM/r1r Attachments cc: W. D. Johnson (NRC), w/a J. Lieberman (NRC), w/a E. W. Merschoff (NRC), w/a B. A. Smalldridge (NRC), w/a K. M. ~ Thomas (NRC), w/a 9811100175 981113 ""

PDR ADOCK 05000482 G PDR1 A *""" P.O. Box 411/ Burhngton, KS 66839 / Phone: (316) 364-8831 An Equal Opportunny Ernployer M/F/HC/ VET

Attachment I to WM 98-0118 Paga 1 of 10 Response to Violation 50-482/9812-01 (EA 90-274)

((olation 50-402/9812-01:

A. 1,0 CFR 50.59(a) (1) states, in part, that a holder of a license aithorizing operation of a production or utilization facility may make changes in the facility as described in the safety analysis report without prior Commission approval unless the proposed change involves an unreviewed safety question.

10 CFR 50.59(a) (2) states, in part, that changes shall be deemed to involve an unreviewed safety geestion (i) if the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously analyzed in the safety analysis report may be increased; (ii) if the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report may be created; or (iii) if the margin of safety as defined in the basis for any technical specification is reduced.

10 CFR ' 50. 5 9 (b) (1) states, in part, that the licensee shall maintain records'of changes in the facility made pursuant to this section, and that these records must include a written safety evaluation that provides the bases for the determination that the change does not involve an unreviewed safety question.

Contrary to the above, on several occasions without prior

ommis sion approval and without performing written safety evaluations, the licensee made changes to the facility as described in the Updated Safety Analysis Report, that involved an l unreviewed safety question. Specifically, on April 22, 1992, j November 11,- 1993, and December 1, 1995, the licensee added i operator actions to Emergency Management Guideline ES-12, l

" Transfer to Cold Leg Recirculation," a procedure described in the '

Updated Safety Analysis Report, without performing written safety evaluations that provided the bases for the determination that the changes did not involve an unreviewed safety question. These changes constituted an unreviewed safety question in that they increased the probability that operators would not be able to complete the switchover of emergency core cooling system pump suction from the refueling water storage tank to the containment sump before depletion of the refueling water storage tank. This increased the probability of a malfunction of the emergency core cooling system pumps (equipment important to safety).

This is a Severity Level IV violation (Supplement I) (50-482/9912-01).

Description of Events:

Updated Safety Analysis Report (USAR) Section 6.3.2.2 entitled, " Transfer lllowance - RHR, Charging, SI," discusses that, during a large break loss of

c. 'ola at accident (LOCA) with the single failure of valve 8812A or 8812B to close on demand, switch-over of the Emergency Core Cooling System (ECCS) from injection mode to recirculation mode can be accomplished before the " transfer allowance" of 90,660 gallons is removed fr om the Reactor Water Storage Tank (RWST). Analysis has shown that, beginning with the Residual Heat Removal (RHR) automatic switch-over at low-low-1, this volume could be removed from the RWST in approximately eight minutes. However, simulator runs have shown that the associated steps in emergency procedure Emergency Management Guideline (EMG) ES-12, " Transfer to Cold Leg Recirculation," (currently l

__________q l

.. l Attachment'I to'WM 98-0118

. :Page:2 of 10 Revision 9) require . approximately ten minutes for completion. Therefore, the

' statement in USAR~ Section 6.3.2.2 regarding switch-over before use of the "transf'er ' allowance" of 90,660 gallons is not consistent.with procedure EMG ES-12. This same statement also appeared ' in the original Final Safety Analysis Report - (FSAR) .

EMG ES-12 contains eleven detailed actions that must be accomplished to complete ECCS switch-over. The initial steps in ES-12 are for Component Cooling Water (CCW) alignment to the RHR heat-exchanger. This is not included in the list of actions in USAR Table 6.3-12. The times assumed in USAR Table 6.3-12 are significantly. different from the actual times required for the actions of ES-12 to be performed.

,\"

'EMG ES-12 has been revised nine times since 1984. The major changes are itemized below:

. Revision Date Changes 2 12/20/88' ' Note added prior to Step 1 that FR should not be implemented: prior to completion of Steps 1 through 5 (RWST switch-over).

3 04/22/92 Note added before Step 6; to be completed prior to RWST empty (6%).

11/11/93 Step 1;JWording changed from " verify" to " establish" 4

CCW flow to RHR heat exchangers.

Step'2; Isolate CCW from spent fuel pool heat exchangers.

Step 3; Verifies switch-over is required.

Order of various steps changed to accommodate above-changes.

1 Steps added to check if Spray Addition Tank should be isolated, to' verify flow paths, SI pump injection and

. core cooling..

7 12/01/95 Added List of Commitments, including USAR Table 6.3-8.

After these revisions were'made, the action time results from operating crew training on EMG ES-12 were not compared to the associated times assumed in

- USAR Tables ' 6. 3-11 and 6.3-12. The regulatory screenings performed for each

' EMG ES-12: procedure revision failed to identify that the.resulting changes in execution time ifor EMG ES-12 could result in conflict with USAR Section 6.3.2.2 and Tables 6.3-11'and 6.3-12.

WCNOC agrees that for Revisions 3, 4 and 7, of EMG ES-12, Unreviewed-Safety Question Determinations- (USQDs) should have been performed to provide the

t.  ; documentation that an unreviewed safety question (USQ) did not exist. In failing to perform the USQDs, it was not discovered that an USQ was created.

These changes potentially increased the probability of a malfunction of the ECCS and Containment Spray pumps in that, should the swapover not occur on

. time, .Cperator response would be required to shut off the pumps and then turn the Containment Spray pumps back on to control Containment pressure.

Two-test runs of this procedure were made on the Wolf Creek simulator in April 1998. -In one run the time required for the operators to complete the required sta,s in EMG ES-12 was.nine minutes; in the second run, the time was eleven m .utes. Once the discrepancy in the USAR - time . requirement and the actual

. performance was discovered, PIR 98-1008 was initiated and an operability evaluation performed.- As noted in the Inspection Report, the operability evaluation was found to-be acceptable by the inspection team.

E

, y - -

- ~~._ - - - . - -. - - ~ ~ - - - . - . - . - -

s

' Attachment I to'WM 98-0110-Page 3-of.10 l

l-T Although the changes represented an USQ, the specific concerns are of minimal safety significance. The fold-out page of EMG ES-12 includes mitigating <

a'ctions,, should the RWST level reach 6% prior to completing the switch-over, I that. will -prevent any. damage to the ECCS or containment spray pumps. In I

. addition, the RHR pumps, which automatically switch-over to recirculation from the ~ containment recirculation sump when the RWST Lo-Lo-1 level setpoint "is reached, will provide sufficient flow to the core for the post-LOCA transient conditions.. One RHR pump will - provide sufficient long-term cooling without the high. head and intermediate head ECCS pumps available for the large break LOCA, when these times are critical.

The containment ' integrity analysis relles on the containment spray to help mitigate the peak pressure and temperature consequences. The limiting i l

pressure and temperature conditions occur earlyuin the transient following-a .

large. break lLOCA. Near the.' time of switch-over,: the. pressure and temperature

have decreased .to much lower values, and the containment spray. pumps can be L

. shut off for a significant period'of time beginning at the time of switch-over  ;

l Lwithout' compromising' pressure and temperature limits. 'A gradual heat up and

- pressurization of- containment' will occur. if the sprays are terminated at the l time : of switch-over; however, the'~ peak or limiting conditions would not be  !

approached for an extended period'of time.

'As mentioned-in Inspection Report 98-12 (on'page 3 of the report details),--PIR 97-3403- initially identified the concern of potentially injecting cold CCW flow into an already hot heat exchanger, due to delays . in aligning the CCW system. The immediate safety consequences of the potential for voiding on the secondary side of.the'RHR' heat exchanger were evaluated in . conjunction with

' the '; operability assessment of PIR 97-3483. The conclusion reached in the operability assessment for PIR 97-3483, that there is reasonable assurance the i

heat. exchanger will befable to perform its intended function, remains valid, i

.Although the initial evaluation for PIR 97-3483 was narrow in scope (i.e., did '

.not' address.the increase in operator response time),' the initial operability

.. and reportability determinations performed for PIR 97-3483 were correct and i

the actual safety significance minimal.

Reason for Violation:

The regulatory screenings for EMG ES-12 failed to identify that the resulting changes in< execution time for EMG ES-12 could result in conflict with USAR iSection 6.3.2.2 and Tables 6. 3-11 and 6. 3-12. ,This failure occurred because the change ~ process did not contain specific guidance to ensure that assumed safety significant . operator response times in the USAR remain consistent with the actual' performance of the operators.

Immediate Corrective Steps'Taken:

Upon issuance'of PIR-98-1008, the Shift Supervisor requested an operability evaluation pursuant to AP 28-001, " Evaluation of Nonconforming Condition of

-Installed Plant Equipment." The evaluation addressed the consequences of the RWST ' reaching the empty level prior to completing ECCS switch-over. The evaluation 1 concluded that current plant procedures (EMGs) would direct the operators.to shutdown the high head and intermediate head ECCS and containment

< spray pumps, .and thereby, prevent damage to these pumps.

= Corrective Actions to Prevent Recurrence WCNOC developed a.' list of safety significant and time critical operator action assumptions _that were included in our USAR and our safety' analysis.

In all other cases, .e w have verified that the operator action time is conservative

=with respect to these assumptions. The operator actions list and response i,

w r,e,.>y .,

y .y -,.yy---p.--,,._,e -- 4 4

s i

l lA .

'Attachmsnt I'to WM' 98-0118 I

l2 l l'

• Page 4,of,'10: l l

r time assumptions were iincorporated into the' Engineering Information System jEIS) database.. i

1. I

! .,  ; Operator Action' Response' Time Validation l

=The .ist of operator, actions was derived from approximately 35 scenarios. The majority of these. actions will be incorporated into the Systematic Approach'to.

Training.(SAT) two year: plan and,.thereby; routinely validated in.the future.

(  : The SAT 'will' " ensure ~ that each f of these operator action evolutions and the

- assumed.l response time are, verified every two ' years during. the . operator

requalificationfcycle.

For ~ 'the ! operator Eaction ? assumptions which- cannot be reasonably ' validated

~

. . :through the SAT (approximately 10 items), a plan - will be - developed to ensure ,

~ "'

routine 1 verification that these evolutions can be performed by plant operators i within' the assumed' response. time. Generally, .these fare ~ longer term actions I Lwhich can not'be reasonably modeled in the' plant' simulator. The plan will be-developed.by July 31'01999.

j g Regulatory Screening Process.

' ~

Alth.dugh .several'.' screening evaluat4ons f (prior. _to 1994)i did' not . ' identify ' the

need to perform a USOD,lno changes-to the current regulatory screening process are' necessary. The current screening process .and the environment for performing.. evaluations are much more rigorous'than the pre-1994 process. 'This- l

' conclusion is further supported 'by. the Auxiliary Feedwate'r System- Functional  ;

Assessment wherwin ~many screening evaluations were . reviewed and ' no errors

_ where: identified. 'Similar results wereLseen from the Essential Service Water

System -functional ascessment. Based on this .information no changes _ are l necessary to the. screening process. '

Corrective Actions Required for Compliance

m. .

RWST Switch-over-Resolution (Actions necessary,to resolve:the. operator response time USO will be completed' -j prior-to'the end of Refuel Outage X. ' Included in.the actions necessary_to resolve.this. issue-is a Design Change.Puckage (DCP) to automate CCW alignment

-during-switch-over from ECCS injection to recirculation mode.

1 Date When Full Compliance Will Be Achieved:

Fd11 compliance will be achieved no later'than the end of Refuel Outage X, once the' discrepancy' between .the' USAR response times and the actual response times

.that resulted'in-an unreviewed safety question has been resolved.

s t

j t

, _ i

,v 4

L t

s L-L

, e - .. _ . . .

1h -

Attachment I to WM 98-0118 Page 5 of 10 Response to Violation 9812-02 B'. l'0 CFR Part 50, Appendix B, Criterion V states, in part, that activities affecting quality shall be prescribed by procedures appropriate to the circumstances and snall be accomplished in accordance with these procedures. Procedures shall be accompanied by appropriate acceptance criteria for determining a>

that important activities have been satisfactorily accomplished.

Procedure AP 05-001, " Change Package Planning and Implementation," Revision 2, Section 6.2.3, required that all programs requiring revision, .such as calculations, be identified.

Contrary to the above, the following examples of a failure to follow procedures and an example of inadequate procedures were identified:

1. In March '1998, activities were not. accomplished in accordance with Procedure AP 05-001. Revisions to Calculation NK-E-003, " Class 1E 125 V DC Battery Short Circuit Study," ' Revision 0,. to reflect the new fault contribution from the equipment being installed were not identified by Design Change Package 05846, " Battery Replacement," . Revisions 0 through 11, and Design Change Package 05248, "NK System Swing Battery Charger Installation," Pevisions 0 through 9.

2. On January 9, 1998, the inspectors determined that the acceptance criteria for station battery Surveillance Test Procedures STS-MT-021, " Service. Test for 125vdc Class lE Batteries," Revision 11, STS-MT-022, " Service Test for 125vdc Discharge Battery Test," Revision 10, were not appropriate for determining that activities were accomplished in tnat the procedure acceptance criteria did not assure that battery discharge current was consistent with the load profile, that the battery final terminal voltage; was greater than the minimum allowable design value, and that a constant discharge rate was maintained during testing.

This is a Severity Level IV violation (Supplement I) (50-482/9812-02).

Note: Inspection Report 98-12 did not require a response to 9812-02 example 2.

Basis for Denial WCNOC contends that no procedure violation occurred in either part of Example 1 of'this violation. Example 1 of Violation 9812-02, cites two violations of procedure AP 05-001, " Change Package Planning and Implementation." Page 7 of the Inspection Report details states that Section 6.2.3 of AP 05-001, requires all programs requiring revision such as calculations be identified. The violation contends that due.to this step, Calculation NK-E-003 should have been listed as an affected document for both of the Design Change Packages (DCPs).

This procedure does not require engineers to identify "affected" documents.

Step 6.2.3 of AP 05-001, states,. "When completing the Change Package Review Forms, Organizations shall identify all programs, procedures and training "roquiring" revision as a result of the Change Package in the appropriate

Attachment I'to WM 98-0118

', Page 4 of 10 I 1

section of form APF 05-005-04." Engineering's responsibility regarding this statemept is to identify the groups or departments which may have procedures, programs, etc.,. impacted by the change. There are no requirements in AP 05-001 applying.to calculations. Step 6.2.3 does not mention calculations and is directed at groups or departments external to Design Engineering to review the change package and initiate- any required changes to their programs, L procedures, etc.

In relation to other more relevant procedural guidance, WCNOC has two procedures which require identifying "affected" documents in change packages:

Procedure AP 05-005, " Design Implementation and Configuration Control of Modifications," and Procedure AP 05-002, " Dispositions and Change Packages."  ;

1 Engineering's calculations are also reviewed in accordance with Procedure AP  ;05-002, which defines an "affected document" as a document which requires '

revision to reflect the modification ~ but is not required to implement or i support the modification. WCNOC does not " require" an engineer- to update '

calculations when the change that is being considered is bounded by the  ;

related assumptions in that calculaticr..  ;

Procedure AP 05-005, Step 6.2.6.4 requires that, "The Configuration Status Accounting Record System-(CSARS) list of affected component and documents must

'be kept current to avoid interfering with other ' designs under development." ,

The procedure goes on to state that, "Affected documents include, but are not i limited to Engineering drawings, procedures, specifications, calculations, i etc., that have been affected by the change."

In the two examples cited, WCNOC correctly implemented the above procedural  !

requirements in that neither DCP required the revision of NK-E-003. Further !

details are provided below for each instance cited in Example 1 of this j violation. J Example la: DCP 05846, "NK Battery Replacement"

.DCP 05846 Revision 0 replaced the existing Class lE GNB rectangular cell- l batteries with AT&T round cell batteries. The Ampere-hour (Ah) ratings of the AT&T batteries were less than those of the GNB batteries (1600 vs. 1650 Ah for batteries NK11 and NK14, 864 vs. 900 Ah for batteries NK12 and NK13).

Since the Ah ratings of the AT&T batteries were less than those for the GNB batteries, the engineer responsible for preparation of DCP 05846 knew that the calculated currents in NK-E-003 were greater than the currents that the AT&T batteries could produce. Therefore, NK-E-003 was conservative. On this

. basis, calculation NK-E-003 did not need to be revised and therefore was not listed as an affected document in the DCP.

Example lb: DCP 05248, "NK System, Swing Battery Charger Installation"

.DCP 05248, Revision 0 was released on December 12, 1995. The objective of DCP 05248 was the installation of a second spare 125 volt Class 1E battery charger in addition to existing spare charger (NK25). This DCP required procurement

.and installation of associated AC and DC transfer switches. The 125 VDC output from each spare charger is connected to the NK system buses via the DC transfer switches. These switches must be rated to withstand maximum predicted fault currents, as determined in NK-E-003. The switches have a 35,000 : Amp withstand current rating at 125 VDC. NK-E-003 Revision 0 shows

. maximum fault current.to be less than 16,000 amps. The engineer responsible for preparation of DCP 05248 determined that the modification did not affect t

the calculations in NK-E-003 and therefore, did not list it as an affected document.

_ _ . _r _, . .. _ . . . .m._ , .=m .. . . _ . .. . - _ . . . ,m

!- s - , - 1 .

,, iAttachmint'.I to WM 99-0118'

-*L Paga 7Lof~10 1 As .: described '. hbove, in each ' example, the engineers questioned . the safety

- implications . J of each DCP :and ' concluded that the calculation bounded the

cbnditi'on. ' Had the lDCPs ' changed the assumptions . such that they- no - longer

-enveloped 4 the change, or- changed the = conclusions in NK-E-003 it would have )

been listed as an effected document. Therefore,.WCNOC does not believe that a. 'j

--violation. ..of - procedures . occurred with respect ' .to 'either part of Violation l 9812-02,. Example 1, 3 3 i ~

,,(

4 l

)

s i ,

4 Y

4

(.'y f

w

, .. . __ _ _ _ _ _ _ . _ .. _ _ _ _ - , __ ~

4 Attachment I to WM 98-0118 Pagc-~8 of 10 Additional Information 1

D m

Minimi ing Emergency Core Cooling System Leakage During Emergency Operations L

'Page 4 of the Inspection Report Details co'ntains a discussion about minimizing Emergency Core Cocling System 1(ECCS) leakage during emergency c. stations. The inspection report states that the team observed no sense of urgency on the part of the licensee to identify and expedite the repair of ECCS leaks. l Although ~ WCNOC has been monitoring ECCS ~ leakage ~ through boron crystallization foi many years. An aggressive, focused program for identifying, inspecting, trending ECCS leakage was initiated in spring 1998. The WCNOC Maintenance 5 artment assigned a fo rsl person to perform a drip bag inspection at least every other week.

Part of this inspection in'ludes c verification of component number, location-e.g., building and elevation, date of drip bag installation, active -leaks,' statu: of any current work request to ' repair this leak, and integrity'of bag and rope or ribbon that are securing the drip bag are loggad.

Should the inspection identify any new -leaks or increasing leakage from identified leaks . Health Physics is notified and a work request is written.

Depending ~on'the job' scope, the Fix It Now (FIN) team may be assigned and if possible fix the leak immediately. If not, a sub-work order is written and prioritized based on significance and.then scheduled into the next available train window as.part of our thirteen week rolling schedule. The WCNOC work ,

j control process considers the maintenance rule, allowed

~

outage times, availebility of equipment and other work to be performed when prioritizing and

. scheduling items.

1

)

To provide further guidance,- Maintenance has developed procedure AI 12-001,- )

" Control of Drip Bags." The ' scope of the procedure includes installing, j

, monitoring,- and removing drip bags, and establishment of routine surveillances

~

to verify the integrity of installed drip bags. j

~

1. In addition to the inspection  !

activities,; maintenance' compiles a monthly report on the status of drip bags in l the plant and maintains. a . performance indicator which is reviewed by management. Our goal is=to have 19. drip bags by the . end of 1998. There are currently 20 drip bags.in use at the plant.  !

Operations. personnel quantify total ECCS leakage, in accordance with Procedure AP 25C-001, "WCGS Leak Reduction of Primary Coolant Sources Outside of

.Containmen ." In accordance'with this procedure, total laakage is required to i be less than i gpm. If the total leakage is greater than 1 gpm, the corrective-work to reduce the leakage is treated as emergent work until the total rate leak is; reduced to less than 1 gpm. The 1 gpm leakage limit is within the  !

Updated Safety Analysis Report (USAR) chapter 15 accident enalysis ECCS leakage limit of_2 gpm.

Purchase and Installation of Equipment Page b of the Inspection Report Details includes a discussion on the battery

. charger. purchase specification whereby a different specification was used to purchase two spare batteries. Specification E-051 (Q ) , (for chargers NK-21 through NK-25) specified a regulation of +/- 0.5%; whereas Specification E-051A A(0), -(for UK-26) specified a regulation of +/- 1.0%. The dif f erence was not evaluated in the design change package. Although the inspe: tion report identified this. event as a weakness .in. the design process, a review of corrective action documents has shown this to be an isolated incident and not 3 reflective of program weakness-in either the desian or the purchasing program.

The . specification will be revised .with the correct +/- 0.5% . julation requiremont by December 15, 1998.

m ___

b N

Att'schmsnt I to WM 98 i0118:

Page?9iof.10 1 Poor Ruality Calculation IPage l8i .ofL the'? Inspection _LReport -Details 1. discusses. the poor quality 'of; calculation NK-E-002r ' " Class 1E - Battery Sizing."' Further, ons Page 9 in the

_ Conclusions section,"the report notes that calculations. and other design L products i in Jthe o electrical- area iwere of' inconsistent quality. and contained

~

errors;~ .NK-F-002 = is currently under ' revision > to . correct the inconsistencies noted ; in ' thelcalculation. WCNOC had previously r. ognized thatt some of the

. electrical documentation; reviewed .were - not up to : present . day : standards. . A.

LCalculation Standards Team was initiated in May-1998. The purpose of the-t'eam Lis'Lto .establishc and maintain standards for calculational models, input assumptions,; revision. requirements, training and independent. reviews.

Safety Significance Classification Page 156 sof . : the InspectionL Report' Details includes a . discussion on' the Performance' . Improvement Request (PIR) process. of' classification. The team -

noted that there 'were no instructions or examples in the procedure for how

' ~

~ calculation errors should be assessed for significance or addressed for

' resolution. - The ' team was- concerned that '.this _could result in the misclassificatio~n of -issues and' was therefore considered ' a weakness in the

' ~ 2

~ procese, although no examples of misclassification were found.

Corrective Action. is- one of. WCNOC's top five' priorities. 1 Management's expectations regarding -usage 'of the program have been well- communicated and enforced. Personnel ~ at WCGS j comcly with Procedure AP .28A-001, -

" Performance Improvement. Request," which does ' noti limit the! type of discrepancies.that are

' included in ' the ' process.- 1 Though examples .of safety analysis and calculation-errors',' are .not provided, Engineering errors are identified- on PIRs and

. evaluated. . The' : PIR . procedure states that the init'Ator should. include the.

following information in - the description of the issue: the consequences or i-*

potentia 11 consequences, impact-~ofLability of a' system or component-to oerform s its function, generic implications, reportability concerns, work process and

activity being ' performed, .immediate actions taken to address the problem and possible 0 causes. The Central" Work Authority ~(CWA) uses the information provided to screen the.PIR. .If the CWA cannot determine significance based'on i

the 'information provided, he then _ contacts supporting organizations, such as engineering, to provide him 1more details. The CWA looks at each issue for p ,

impact on plant' systems, operability, and reportability. 3 Regarding ithe comment' that there : were no instructions or examples in the

[ . procedure for ' how calculation errors should be ' assessed for significance or

, (addressed for' resolution, Procedure AP 28A-001 contains explicit detail on the 9 evaluation ' requirements -for 'each significance level. The responsible manager tor.. designee . is required to reviewi the evaluation and corrective actions .for subject . matter suitability.. For_ ' PIRs designated a . level III for which root l

g'- cause is not required,- procedure Step'6'6.1.1 requires the evaluator to verify j that level III is the appropriate significance level and that reviewing similar '

' events may help to o identify the appropriate scope of the evaluation.

t r  : Proce' dure ' AP 28A-001, Step 6.2.3.3, states that the responsible manager may i

change , classifications from what was initially assigned in the PR review if j

- availableinformation warrants such a change. Therefore, based on knowledge of j the; issue the. manager may decide that a root cause evaluation is necessary and ~

' upgrade the PIR. level.

~

In' addition, pursuant to AP 28A-001, Step 6.3.1, if the j

. PIR evaluator ' identifies. additional information during the scope of the i evaluation that affects:the ability of an SSC to perform its intended function,

reportability,- or' significance or ^ scope of the PIR, the evaluator shall promptly.-notify.the-Contr"1 Room.-or'the CWA, If necessary initiate a new PIR,

'and.should, discuss the information with management.

t 1

f j...L

.p -

4 Attachment I to WM 98-0118 l

.. Page 10 of 10 l 1

l l

Therefore, WCNOC believes that the information . in our procedures provides i

.adequa'et guidance, and no program weaknesa exists. '

Ncn-cited Violations The inspection report contains discrepancies in the descript~on of non-cited i violations and the total listed in the Supplemental Items section of the l report. '

Item 1 It appears that an item numbert 1 50-482/9812-12 was closed on page 4 of the Supplemental Information, wher only eleven items were opened from the inspection. It was WCNOC's und irstanding from discussions with the SSEI team, and information in the Inspect *:an Report, that'two fire protection issues were being-combined into one non-ci ed violation. Pages 65 and 68 of the Inspection Report Detail identified the NCVs both as .- 9812-11, which was consistent with earlier discussions. On Page 2 of the Supplemental Information 9812-11, an NCV j was opened listing both issues under one item; however, on the closed item l

list, the issues were separated and numbered individually. )

One of the items closed in NCV 9812-011 was LER 97-016-00,. including supplements -01 and -02. However, WCNOC received inspection' report 50-482/98-017, dated October 22, 19 f!8, in which another NCV was issued for the closure of LER 97-016-00, -01 and -02. WCNOC requests that the NCV cited in Inspection Report 50-482/98-017 be rescinded.

l This item was discussed with David Graves of the NRC Region IV staff.

' Item 2 On Page 62 of - the inspection report details, a NCV is discussed in the conclusions to.section FS, " Fire Protection Staff Training and Qualifications,"

however, in the Observations and Findings Section it is discussed as a minor violation. No NCV relating to this item was fourd on the open item list.

l i

l

Attachment II to WM 98-0118

• . 'Page 1 of 1 LIST OF COMMITMENTS he following table identifies those actions committed to by Wolf Creek Nuclear Operating Corporation (WCNOC) in this document. Any other statements in this submittal are provided for information purposes and are not considered to be commitments. Please direct questions regarding these commitments to Mr. Michael J. Angus,

- Manager Licensing and Corrective Action at Wolf Creek Generating Station,(316) 364-4077.

COMMITMENT Due Date/ Event For the operator action assumptions which cannot be 7/31/99 reasonably validated through the SAT (approximately 10 itera), a plan will be develooed to ensure routine verification that -these evolutions can be performed by plant operators within the assumed response time.

Generally, these are longer term actions which can not be reasonably nodeled in the plant simulator. The plan will be developed by July 31, 1999.

Actions necessary to resolve the operator response time End of RF 10 USQ will be completed prior to the end of Refuel 10.

Included in the actions necessary to resolve this issue is a Design Change Package (DCP) to' automate CCW alignment during switch-over from ECCS injection to recirculation mode.

Page 8 of the Inspection Report Details includes a I2/I5/98 discussion on the battery charger purchace specification whereby a different specification was used to purchase two spare batteries. The difference was not evaluated in the design change package. Although the inspection report identified this event as a weakness in the design process, a review of corrective action documents has shown this to.be an isolated incident and not reflective of program weakness in either the design or the purchasing program. The specification will be revised with the correct +/- 0.5% regulation requirement by December 15, 1998. i