ML20199E885
| ML20199E885 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 01/26/1998 |
| From: | Johnson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Maynard O WOLF CREEK NUCLEAR OPERATING CORP. |
| References | |
| 50-482-97-19, NUDOCS 9802020269 | |
| Download: ML20199E885 (4) | |
See also: IR 05000482/1997019
Text
. . . . . _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
g-' 4
t 0"4 UNITE 3 STATES
g
+
9'g NUCLEAR REGULATORY COMMISSION
-g E REGION IV
% / 611 RYAN PLAZA DRIVE, SulTE 400
"'+9*****
- JAN 2 6 1998
Otto L. Maynard, President and
Chief Executive Officer
- Wolf Creek Nuclear Operating Corporation
P.O. Box 411
Burlington, Kansas 66839
SUBJECT: NRC INSPECTION REPORT 50-482/97-19
Dear Mr. Maynard:
2
Thank you for your letter of December 23,1997, in response to our letter and Notice of
Violation dated November 25,1998. We have reviewed your reply and find it responsive to the
concerns raised in our Notice of Violation. We will review the implementation of your corrective
actions during a future inspection to determine that full compliance has been achieved and will-
be maintained.
Sincerely,
W
W. D. Johnson, Chief .
Project Branch B
Division of Reactor Projects
'
Docket No.: 50-482 /
License No.: NPF-42
cc:
Chief Operating Officer
Wolf Creek Nuclear Operating Corp.
P.O. Box 411
Burlington, Kansas 66839
Jay Silberg, Esq.
Shaw, Pittman, Potts & Trowbridge
2300 N Street, NW
Washington, D.C. 20037
~
9802020269 990126 i . '*
,
,
1
PDR ADOCK 05000482 -
I
'
G PDR
_ _ _ _ _ _ _ _ _ _ _ _ _
. _ __ ___ _ _ _ ________
.
.. .
,. . . ,
Wolf' Creek Nuclear Operating Corporation -2-
l
Supervisor Licensing _ _
Wolf Creek Nuclesr Operating Corp.
P.O. Box 411
Burlington, Kansas 66839
. Chief Engineer
-
Utilities Division -
Kansas Corporation Commission
157 SW Arrowhead Rd.
. Topeka, Kansas 66604-4027
- Office of the Govemor
State of Kansas.
Topeka, Kansas 66612
Attomey General
Judicial Center
301 S.W.10th
_
2nd Floor
Topeka, Kansas 66612-1597
County Clerk -
Coffey County Courthouse
Burlington, Kansas 66839-1798
Vick L. Cooper, Chief
Radiation Control Program
Kansas Department of Health :
and Environment -
Bureau of Air and Radiation
- Forbes Field Building 283
-Topeka, Kansas 66620
Mr. Frank Moussa
Division of Emergency Preparedness --
4 2800 SW Topeka Blvd
Topeka, Kansas 66611-1287
.
_ _ - - - . _ _ _ . - - - _ . _ . _ _ - - - _ - - . . _ _ . _ _ _ _ - . - _ .
,. -. .
.
K
.: .
- Wolf Creek Nuclear Operating Corporation 3-
JAN 2 61998
bec to DCD (IE01)
bec distrib. by RIV: - _
Regional A&inistrator - Resident inspector
-
. Branch Chief (DRP/B) ..
DRS-PSB
- Project Enginect (DRP/B)i MIS System
Branch Chief (DRP/TSS) RIV File
_
--
L
i
.
--.
,
4
1
DOCUMENT NAME: R:\_WC\WC719AK.JFR
' To receive copy of trxxa, indicate in box % = Copy without enclosures "E" = Copy with enclosures "N" = No copy
RIV:C:DRP/BG
WDJohnsory6f
1/2(o/98 ~
OFFICIAL RECORD COPY
_
. - - - -
, , .4
Wolf Creek Nuclear Operating Corporation --3
JM 2 6 1998 -
,-
E!d
bec dittrib; by RIV:
Regional Administrator Resident inspector
DRP Director SRI (Callaway, R!V)
Branch Chief (DRP/B) DRS-PSB
Project Engineer (DRP/B)- MIS System
Branch Chief (DRP/TSS) RIV File .
,
5
{}2OON
DOCUMENT NAME: R:\_WC\WC719AK.JFR
To receive copy of qecument. Indic:.te in box:"C" = Copy without enclosures "E" * Copy with r nclosures "N" = No copy
RIV:C:DRP/BG ,
WDJohnsory6f
1/2(o/98
OFFICIAL RECORD COPY
I
M -
.
.
.
!
,
n
. LF
W@) NUCLEAR OPERATING CO CREEK ~
a !
Otto L Mayr.ard l
Prescent and Chef Executive Offrer -
December 23, 1997
U. S. Nuclear Regulatory Commission
ATTN Documer.t Control Desk
Mail Station 01-137
Washington, D. C. 20555
Reference: Letter dated November 25, 1997, from W. D. Johnson,
!J RC , to O. L. Maynard, WCt100
Subject: Docket No. 50-482: Response to Notice of Violations
50-402/9719-01, 9719-02, 9719-03, 9719-04, and 9719-05
Gentlement
This letter transmits Wolf Creek Nuclear Operating Corporation's (WCNOC)
response to Notice of Violations 50-482/9719-01, 9719-02, 9719-03, 9719-04,
and 9719-05. Notice of Violation 9719-01 cites use of an operator aid without -
the docunented approval of the Shift Supervisoc. Notice of Violation 9719-02
cites examples of offectiveness follow-ups for corrective action documents not
being performed as required by procedure. Notice of Violation 9719-03 cites
an example of a maintenance worker working outside cf procedural guicance
which resulted la an inadvertent opening of an atmospheric relief valve.
Notice of Violation 9719-04 addresses a failure to reinstall an equipment
hatch cover following the replacement of the associated filter cartridge,
Notice of Violation 9719-05 cites four examples of personnel failing to adhere
to radiation protection procedures.
WCNOC's response to these violations is provided in the attachment. If you
have any questions regarding this response, please contact me at (316) 364-
8831, extension 4000, or Mr. Michael J. Angus at extension 4077
Very truly yours,
. $olL
Otto L. Maynard
OLM/jad
Attachment
cc: W. D. Johnson (NRC), w/a
E. W. Merschoff (NRC), w/a
J. F. Ringwald (NRC), w/a
K. M. Thomas (NRC), w/a
PO Box 411/ Burkngton. KS 66839 Phone'(316) 364-8831
An Eoual Opportumtv Employer M F HC VET
<IBW6dMd /qF _ _ _ _ _ _ _ _ _ _
[
I* , Attachmont to WM 97-0151
'
Page 1 of 9
.
Violation 50-402/9719-01:
" Criterion V of Appendix D to 10 CFR 50 requires, in part, that activities
affecting quality shall be prescribed by documented i'ntructions, procedures,
and drawings appropriate to the circumstances, and shall be acccmplished in
accordance with these instructions, procedures, or drawings.
Pr ocedure AP 21D-003, " Control of Information Taggiag," Revision 1 Step 6.6.10
requires operatcr aids to be approved and documented by the Shift Supervisor.
Cont rary to the above, f rom October 8, to October 22, 1997, operators used
markings on Drawing EID-0003 as an operator aid without documented approval of
the shift supstvisor.
This is a Severity Level IV violation (Supplement 1) (50-482/9719-01)."
Reason for Violation
Engineering Information Drawing (EID)-0003, " Refuel Level Indication," was
referred to by Control Room operators between Octcber 8, and October 25, 1997.
The inspector noted that EID-0003 listed the levels in percent while the wide
range cold pressurizer level was calibrated in inches. In order to provide a
correlation between the two, a c1 :ulation was performed and EID-0003 was
marked-up with handwritten notes. EID-0003 and the hardwritten notes should
have been controlled as either an operator aid, or the notes should have been
incorporated as a revision to the drawing.
The reason for the violation is failure to follow procedures which resulted in
use of information which had not been verified and validated. AP 21D-003,
" Control of Information Tagging" das not followed when the hand written notes
were added to the drawing, and therefore not verified, validated and approved
for usage.
Corrective Steps Taken and Results Achioved:
On November 3, 1997, Revision 1 to EID-0003 wts issued. This revision removed
all Callaway site specific inf ormation and verified the tygon tubing water
<
level (feet).
Corrective Steps That Will Be Takent
The contributing cause and generic implications related to - this event are
being evaluated by PIR 97-0945 which was w-itten in association with Self
Assessment 97-017, " Evaluation of Desktops or other Informal Instructions,"
which looks at the generic implication of site wide uncontrolled nocuments.
The expected completion date is January 15, 1999.
The Superintendent Operations Support will meet with each operating crew and
review AP 21D-003, " Control of Information Tagging" in conjunction with
Performance Improvement Request (PIR) 97-3442, associated with this violation,
to ensure they understand the appropriate use of documents. This action will
be completed by February 2, 1998.
Each Operations Shift Supervisor and the Superintendents of Operations and
Operations Support will meet with their direct reports and ensure all
uncontrollad documents that could be used to make decisions in operating the
plant are removed from the Operations office spaces and the Control Room.
These uncontrolled documents are then to be either destroyeo or subritted for
processing to become controlled documents. The expected completion date fnr
these meetings is February 2, 1998.
1
]
-
. . .
. - - _ _ _ _ - _ __
._ . . _ - --
.
. Attachment to WM 97-0151
Pega 2 of 9
.
Date When Full Compliance Will Be Achievedt
WC110C is currently in full compliance. Compliance was achieved on October 2$,
1997 wnen EID-0003 was removed from the Control Room,
e
%
e
. _ _
f
b
.
.
.
_ _ _ . _ _ _ . _ _ _ _ _ _ _ _ . _ _
_ . . .
.
.
. Attachment to WM 97-0151
Page 3 of 9
.
Violation 50-492/9719-02:
Criterion V of Appendix B to 10 CFR Fart 50 requires, in part, that activities
affecting quality shall be prescribed by documented instructions, procedures,
and drawings -appropriate to the circumstances and shall be accomplished in
accordance with these instructions, procedures, or drawings,
l
l
Administrative Procedure AP 28A-001, " Performance Improvement Request."
Revision B, Step 6.1 1.1, requires that an effectiveness followup review be
performed for all Significance Level I and II performance improvement
requests.
Contrary to the above, on October 22, 1997, effectiveness followup reviews
were not performed for Performance Improvement Requests 96-2906 and -2989.
Both were Significance Level II performance improvement requests.
This is a Severity Lovel IV violation (Supplement 1)(50-482/9719-02).
Reason for the Violation
Additional reviews by WCNOC personnel identified 35 Performance Improvement
Requests (PIbs) past their effectiveness follow-up review due dates. Twenty-
seven of these were significant PIRs which are required to have an
effectiveness follow-up review. Eight of the PIRs were non-significant which
are not required to have an effectiveness follow-up review. Eight different
groups had effectiveness follow-up reviews past due.
The reason for the violation is that during initial development of the PIR
program, mechanisms were not designed to provide management all of the tools
to effectively monitor effectiveness follow-up reviews. Specifically, though
the requirement was in place to perform effectiveness follow-up reviews,
guidance for reporting and trending and the responsibility for performing
these actions were not established.
Contributing cause
The controls to execute a computer search for effectiveness followup review
dates were not user friendly and were different from the usual search
techniques.
Corrective Steps Taken and Results Achieved
Responsible managers were contacted to advise them of the concern and request
they review their PIRs or re-schedule them to an appropriate time. Immediate
actions included the Operations department complet ing six effectivenens
follow-ups and the Maintenance department re-scheduling four follow-ups and
deleting one follow-up date that was assigned to a non-significant PIR. By
October 29, 1997, all the overdue effectiveness follow-up reviews had been
completed or re-scheduled.
Sn October 26, 1997, the PIR data base was modified to make the search for
effectiveness follow-up review dates more user friendly. PIR Logkeepers were
then interviewed and on-the-job training performed to ensure they know how to
search for effectiveness follow-up review due dates and have adequate
knowledge to find PIR due dates.
The Licensing and Corrective Action group began monitoring effectiveness
follow-up review due dates on October 29, 1997 A 30-day "look ahead" report
is now provided to managers to advise them of effectiveness follow-up reviews
coming due. This corrective action was implemented on Decerber 19, 1997.
.. .. . . .
.
.. .. .
. .
_
_
.
'
. Attachment to wt4 97-01$1
Page 4 of 9
Corrective Steps That Will Be Taken
The p'ogram for monitoring effectiveness follow-up reviews will be modified to
ass 19a PIR Coordinators the responsibility to monitor effectiveness follow-up
review due d a'.e s . Procedure AP 28A-001, " Performance Improvement Request,"
will be rev; sed by December 31, 1997, to clearly state the PIR Coordinator
responsibility for this rnonitoring function.
Licensing and Correction Action will develop performance indicators for
tracking corrective action effectiveness follow-up reviewa. These performance
indicators will be developed by February 2, 1998.
PIR Coordinators will be trained by - December 31, 1997, to use the search
functions in the PIR data base to find effectiveness follow-up review due
dates.
Date When Full Compliance Will Be Achieved:
Full compliance was achieved on October 29, 1997, when the overdue
effectiveness follow-up reviews were either performed or rescheduled.
. . .
_ _ _ _ - _ _ _
. . . . . . .
. Attachment t o WM 97-0151
Page 5 of 9
Violatien 50-482/9719-03:
" Technical Specification 6.B.l.a requires, in part, that written procedures be
established, implemented, and maintained covering the applicable procedures
reconcended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. .
Regulatory Guide 1.33, Revision 2, February 1978, Section 3.f., recommends, in
part, that procedures be established for surveillance tests.
Surveillance Procedure STS MT-008, " Main Steam Safety Valves Settings,"
Revision 8, Section 4.3, ree" ires the test performer to not operate the root
valves indicated on Attacb"* a
Contrary to the above, on S 9 ;q? 5e 30 ,1997, the test performers closed then
opened Valve AB V0028, the inst rt.ae nt root valve indicated on Attachment C of
Procedure STS MT-000, causing an inadvertent opening of Valve AB PV0003,
atmospheric relief valve for Steam Liae C.
This is a Severity Level IV violation (Supplement 1) (50-482/9719-03)."
Reason for Violatient
.
The reason for this violation is personnel error in that Maintenance personnel
failed to comply with procedural requirements. The procedure, STS MT-000, did
not contain step for operating val ~e ABV0028, a root valve. It contained a
caution note telling the worker not to operate the valve.
Contributing '.o the event were two additional causes:
1. There was inadequate communication between personnel involved in the work
activities. There were missed opportunities to provide more specific
direction, to confirm what was misunderstood or to call " time-out".
2. The pre-joo briefing was 2ncomplete in that there was a failure to cover
- specific responsibilities, procedural precautions, and procedure use
requirements. The failure to cover these items in the pre-job briefing was
a missed opportunity to make sure everyone understood their roles and
responsibilities.
Corrective Steps Taken and Resulta Achieved:
The Manager Maintenance met with Mechanical Maintenance personnel, first line
Maintenance supervisors, and contractors on September 30, and October 1-2,
1997, to reinforce the limits and expectations for maintenance personnel
operating plant equipment. Additionally, the expectation that the Control
Room be contacted immediately upon recognizing a component or system
manipulation error was reinforced.
Training for all Mechanical Maintenance personnel, reaffirming the
requirements of procedure AP 15C-002, " Procedure Use and Adherence," was
completed on October 2, 1997 The training also included instructions for use
of three-way communication and the expected elements of pre-job briefings.
Fact .inding discussions and job counseling were done with those personnel
- involved. These actions were completed on October 7, 1997.
s Procedure STS MT-008 was revised en October 9, 1997, to correct valve
misnomers, add caution notes and incorporate other human factor improvements.
" Communication for Error Preventien" training was given to Maintenance craft
persennel. This training was completed on December 22, 1997.
_ _ _ _ _ _ _ -___ ___-__-_ -____ __ _ _ - - _ _ _ _ - -__ --_-_ -_ - _ _ _ _ _ _ _ _-___ _ _-__ - _ - _ -
.
t
. Attachment to WM 97-0151
Fage 6 of 9
,
Corrective Steps that will be Takent
The lessons learned from this event will be shared with the other maintenance
groups through review of Performance Improvement Request (PIR) 97-2959 during
group safety meetings. This corrective action will be ecmpleted by February
27, 1998.
Date When Full Compliance Will P.s Achievedt
WCtmC is currently-in full compliance. Compliance was achieved on September
30, 1997, when ABV00;d was opened.
L
.
, Attachment to WM 97-0151
Page 7 of 9
.
Violation 50-402/9719-04:
" Technical Specification 6.6.1.a requires, in part, that written procedures be
established, implemented, and maintained covering the applicable procedures
recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide-1.33 Revision 2, February 1970, Section 3.f., recommends, in
part, that procedures be established for replacement of important filters."
Procedure MCM M7230-01, "NSSS Filter Changeout," Revision 9, Section. 8.4,
requires maintenance personnel to reinstall the hat 9h cover over the equipment
compartment as part of the restoration.
Contrary to the above, on October 12, 1997, maintenance personnel signed for
the completion of Procedure MCM M723Q-01 fe' lowing the replacement of - the
filter cartridge without reinstalling the equipaent hatch cover. The failure
to replace the hatch cover resulted in the area near the filter to be
accessible as radiation levels increased to 3 Rem per hour 12 inches from the
filter housing after operators returned the filter to service.
This is a severity Level IV violation (Supplement 1) (50-482/9719-04)
Response to Violation
The reason for the above stated violation and the associated corrective
actions were documented in WCNOC's response to violation 97-020-01, in letter
WM 97-0133, dated December 12, 1997, which pertained to the same event,
t
-
_ _ _
--
. _ , , . .
.
. Attachment to WM 97-01$1
Page 9 of 9
.
Other actions implemented by the Health Physics organization included the
s stablishment of the RCA access control area as a "No Talking Zone" to allow (
for greater concentration, and posting of a security officer at the RCA access
door as an interim control during outage activities.
i Correctiva Steps That Will Be Takent
Performance Improvement Request (PIR) 97-2389 was initiated by Health Physics
on August 7, 1997, to identify general adverse trends regaroing violations of
the Radiation Protection Program. Short term corrective actions for this PIR
were completed as of October 2, 1997. Long term corrective actions including
evaluation of changes to radiation worker training are due to be complete by
January 30, 1998,
in an effort to improve human performance in the Access Control area, WCNOC
Health Physics personnel will submit a proposed facility change to be
evaluated using the design change process. This proposal will be submitted by
January 1, 1998.
Date When Fuli Compliance Will Be Achieved:
WCMOC is currently in full compliance. Full compliance was achieved on the
date of occurrence of each event when the individuals involved were brought
into compliance with WCNOC's radiation protection program requirements.
. _ _
..
. . .
.
'
'
. . Attachment to WM 97-0151
Fage 8 of 9
.
l Violation 50-482/9719-05:
" Technical Specification 6.11 requires, in part, ti.at radiation workers adhere
to procedures for personnel radiation protection consistent with the
requirements of 10 CFR Part 20.
Administrative Procedure AP 25A-100, " Radiation Protection Manual" Revision 2,
6ection 6.7.4, requires that access to the RCA [ radiologically controlled
areal be controlled by an approved RWP [ radiation work permit].
Contrary to the abovet
a. On October 5, 1997, a mechanic accessed the radiologically
controlled area using Radiation Work Permit 970009 and used an,
internally contaminated gauge while pe r f orraing work in the
radiologically contrc11ed area, an activity prohibited by the
radiat on work permit,
b. On October 10, 1997, a radiation worker exited the radiologically
controlled area and logged out of Radiation Work Permit 972601.
The worker subsequently reentered the radiologically controlled
area without logging onto a radiation work permit and without
obtaining any dosimetry.
c. On October 26, 1997, a radiation worker entered containment
without an alarming dosimeter as required by Radiation Work Perrit
970034
d. On October 27, 1997, a radiation worker entered the radiologically
controlled area without the thermoluminescent dosimeter required
by Radiation Work Permit 970009.
This is a Severity Level IV violation (Supplement IV) (50-482/9719-05)."
Reason for Violations
As the above examples are similar in nature and pertain to violations of. the
radiation worker practices they were researched together to determine the root
cause and appropriate corrective actions.
In the case of example b. it was concluded that the initial cause was a human
error resulting from either a short-cut being taken or failure to implement
rules learned in radiation worker training.
In the remaining examples it was determined that the radiation workers
exhibited inattention to detail that caused them to violate radiation
protection program requirements. The errors were unintentional and occurred
either due to overconiidence on the part of the employee or due to an
unplanned interruption that took the employees' attention away from the
radiation protection program requirements.
Corrective Steps Taken and Results Achieved:
Corrective actions for each example included these common actions:
- Each employee or contractor had their access to the radiologically
controlled area (RCA) revoked.
- Employee retraining or counseling was periormed which met the standards of
management.
- Job performance counseling was performed.
- Each event was discussed during group or safety meetings to ensure lessons
learned were shared.