ML20199J043
| ML20199J043 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 01/30/1998 |
| From: | Maynard O WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-482-97-22, WM-98-0012, WM-98-12, NUDOCS 9802050204 | |
| Download: ML20199J043 (10) | |
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W@ NUCLEAR OPERATING CO LF CREEK Otto L Ma tistd r
Prescent and CNe vecutive Offcer January 30, 1998 WM 98-0012 U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Mail Station Pl-137 Washingtors, D. C.
20555 References Letter dated December 29, 1997, from W. D. Johnson, NRC, to O. L. Maynard, WCNOC
Subject:
Docket No. 50-402:
Response to Notice of Violations 50-482/9722-01, and 9722-02.
l Gentlement This letter transmits Wolf Creek Nuclear Operating Corporation's (WCNOC) response to Notice of Violations 50-482/9722-01 and 9721-02.
The required due date for this response is January 30, 1998, per the telephone discussion of January 28, 1998, between Bill Johnson, USNRC, and Michael Angus, WONOC.
Violation 9722-01 identified that the person procedurally required to be stationed at the containment personnel haten, with sole purpose to close the hatch, was assigned additional duties.
Additionally, Control Room personnel were not able to contact the person when requested by NRC Inspectors.
Violation 9722-02 addresses a failure of personnel during the post-trip review to identify an error in a 10 CFR 50.72 report.
WCNOC's response to these violations is provided in Attachment I.
WCNOC has also elected to respond, in Attachment II, to other information contained in the report.
If you have any questions regarding this response, please contact me at (316) 364-8831, extension 4000, or Mr. Michael J.
Angus at extension 407'.
Very truly yours.g/
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$DR Otto L. Maynard.
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Attachments ec:
W. D. Johnson (NRC), w/a_
,f'kiin,kpig'l{I'ij bff7f l __
4 E. W.
Merschoff (NRC), w/a j(
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F. Ringwald (NRC), w/a 1;
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- V-K. M. T., mas (NRC), w/a PO, Dox 411 ! Burhngton, kS 66839, Phone (3.6) 364-8831 A1 Eoaat Opportun ty E mployo, M F 'HC VET I
At t a chtnent t to WM 98-0012 Page 1 of 5 ATTAC}DIENT I Violation 50-402/9722-01:
" Technical Specification 6.8.1.a requires, in part, that writtea procedures be established, inr!emented, and maintained coverinq the applicable procedures recommended in Appendix A ot Regulatory Guido 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Revision 2, February 1970, Section 2, recommends, in part, that procedure. be established for general plant operations.
General Operating Procedure GEN 00-008,
" Reduced Inventory -Operations,"
hevision 5, Se : tion b.16.2, requires that personnel be statior.ed at affected containment hatches whose sole purpose is to close the hatch prior to the onset of core boiling in the event that decay heat removal is lost, and that a means oi communication be established between the control room and the stationed personnel.
Contrary to the above, on November 13,. :s 97, the laspectors noted that the containment coordinator had beer, assigned the duty of closing the containment hatch while retaining the balance of the containment coordinator cuties, and personnel were not able to contact the containment coordinator when requested by the inspectors."
Description of Violation On November 13, 1997, _ olf L' reek Generating Station (UCGS) was in a reduced W
inventory operational condition with both containment persc'inet hatches open.
Procedure GEN 00-008, Revision 5,
" Reduced Inventory Operations," step 5.16.2.2 statta:
"If a containment penetration, perscrinel hatch, or equipment hatch will be open during reduced inventory conditions, then perform the following:
1)
Ensure that all obstructions to the affected penetration or hatches can be removed within 30 minutes; 2)
Station personnel at the affected penetration or hatches whose solo purpose is to close it off prior to the onset of core boiling in the event that decay heat.c.noval la lost; and, 3) Establish a means of communication betwee.3 the Control Roem and the stationed personnel."
Prior to entry into Reduced Inventory Conditions the Control Room crew contacted the Containment Coordinatec and verified an individual was availabl(
to close the containment personnel batch.
The Containment Coordinator accepted responsibility to close the containtient personnel hatch.
- Hewever, the Contr31 Room c:ew did not adequately verify or communicate that a specific person was required to be stationed at the affocted hatch, whose sole purpose was to close the hatch.
Additionally, the Control Room crew failed to ensure that a means of communication between the Control Room end the stationed indj ;idual was estauij shed.
At the time of this event, two Containment Coordinators were on duty.
One was in the Containment Building and would ho e been able to respond and close the hatch within the required time frame.
The second was in an administrative support building and also would have been able to respond and close the hatch within t'le required time frame.
Both were aware of their responsibility to close the hatch if required.
When the Control Room crew attempted to centact the Containment Coordirator, they were unable to reach him.
It was Inter determined that the on-duty
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Attachment I to 9 98-0012 Page 2 of $
2ontaintrent Coordinatot was in the Containr ent Building at the toa] crib.
'I he Control Foom crew was unsuccessful in contacting the Containment Coordinator hy tphone ' because che Coordinator's phone batteries were disebarged.
Atterpts to contact the Containment Coordinator by the plat paging system w"re unsuccessful because of the general noise levelo in and around the tool ettb.
They were successful in contacting the second Containrunt Coordinator who was in one of the seppotting office buildings within the protected area.
The second Containment Coordinator knew his responsibilities and the irnportance of closing the containment personnel hatch within thirty minutes.
This individual was able to walk irom his location to the '.on t a irmen t personnel hat':h.in apptoximately ten minutes.
If an actuel Containment evac.ntion had been required, then the control noom usage of the Containment Evacuation Alarm would have realted in the Containment Coordint. tor calling the Control Room by the Gaitronics system or by a land phone.
This would have allowed sufficient time for the Containment Coordinator to close the door.
Safety Significance:
During the timeframe of reduced. inventory operation, plant condit to.is and decay heat removal capability remainsd stable.
Time to core boil was calculated at 77 minutes, which pro *1ded additional margin to achieve containment closure beyond the required 20 minutes.
Additionally, personnel were availablo and able to respond to closa containment within the 30 minute requirement.
Therefore, there is no safety enneern associated with this iLsue.
Reason for Violation:
Floot Cause:
The Control Roon Crew failed to implement step 5.16.2.2 of procedure GEN 00-008, Revision 5,
" Reduced Inventory Operations." In addition, the Containment Coordinator incorrectly interp-eted that " stationed" and " stationed at" had the same meaning.
He accepted the responsibility for assuring the personnel hatch would be closed, if required, even though his additional dutjes prevented him from being stationed at the hatch, and f rom devoting sole dny to the closing of the hatch.
The Control Room crew also failed to verify an adequate means of communication was available.
Contributing Factor _s The established procedures, GEN 00-008 and AP 21D-004, Revision 0, "Contral Of Containment Penetrations During Shutdown Operations," were not adequate.
Incongruent wording within the procedures contributed to the Control Room Crew failing to adequately implement Step 5.16.2.2 of GEN 00-008.
Corrective Steps Taken and Results Achieved:
A dedicated individual was assigned to the Containment Personnel Hatch in accordance with the requirements set forth in Step b.16.2.2 of GEN 00-008.
Petsonnel responsible for implementing GEN 00-008 and AP 210-004 were cour.s el ed.
Procedures GEN 00-008 and AP 21D-004 were revised to clarify containment closure requirementa dvring reduced inventory operationel conditions.
Attachment I to JH 98-0012 Page 3 of 5 Corrective Steps To Be Takent All corr 6ctive actions have been completed.
Date When hall Compliance Will Be Achievedt
- .ull comp 11ance was achieved at 0915 on November 13, 1997, when an individual having the means tu contact, and be contacted by, the Control Room was stationed at the containment personnel hatch.
This person had specifi: and exclusive arsignment to close the hatch if required, l
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1 Attachment I to W!4 90-0012 Page 4 of 5 i
Violation 50-482/9722-02:
"Criter16n V of Appendix B to 10 CfR Part 50 requires, in part, that activities af fecting quality shall be prescribed by doeur.;ented instructions, procedures, and drawings appropriate to the circumstances, and shall be accomplished in accordance with these instructions, procedures, or drawings.
Procedurs AP 20-002, " Post-Trip keview," Revisicn 0, Section 6.6.?,
requi.res the shift supervisor or appointed senior reactor operator to ensure that the event is properly evaluated and analyzed.
This review is to include a determination of whether all major safety-related and other important equipment involved in the trip operated as anticirited or expected.
Contrary to the above, on November 29, 1997, the appolated senior reactor operator signed the post trip review package recommending restart, yet failed to identify the error in the initial 10 CFR 50.72 report, which wes part of the post trip data package.
The initial report identified the cause of the start of both motor-driven auxiliary feedwater pumps as a low steam generator level below 23.5 percent, yet the steam generator levels did not approach or decline below the low level setpoint."
Description of Violation An Intermediate Range trip occurred at WCGS on NovembLr 29, 1997 Following the trip, the Shift Superviser (SS) prepared the Duergency lloti fication Sys*em (ENS) worksheet to report the trip to the llRO Cperations Conter.
Based on similarities to past situativns, the SS incorrectly reported that th cause of the auxiliary feedwater activation was due to steam generator Lo-Lo level.
The actual cause of the actuation was due to a trip of both Main Feed Pumps on high discharge pressure, which aut oma ti call y starts both motor dri ven auxiliary feedwater pumps.
This incorrect information, included on the NRt notificatior. form, was also included in the Post-Trip Review package.
The night shift Outage rentrol Center (OCC) Operations Representative assumed responsibility as appointed Senior Reactor Operator (SRO) of the Post-Trip Review package.
The OCC Operations Representative reviewed the post trip package to determine the ciuse of the trip, and to identify any potential restart issues.
The ENS form was included as part of the package, but not speci fi cally reviewed for accuracy.
The OCC Operations Representative signed the Post-Trip Review at 2033 on November 29, 1997.
After the Foot-Trip Review was signed, the NRC Senior Resident inspector reviewed it L.nd identified the incorrect information on the ENS form.
The inspector brought the error to the attention of the R'C Operations Representative.
Safety Significance:
The mis-identification of the cause for the auxiliary feedwater pump start did not impact'tne evaluation of equipment response following the plant transient.
As such there was no impact on plant or public safety, and this issue is not considered safety significant.
Reason for Violation Root Cause The root cause lor this incident was that the SS made a decision or judgment based on sinul aritie s to past situations without adequately evaluating the p
Attachment I to WM 98-0012 Page $ of $
current situation.
As a result, the SS failed to record and report accurate information in the notification to the NhO per 10 CPR 50.72.
s Contribut ing Fact ors The SS did not maintain an adequate mental focus on the particular situation or details involved with the performance of the task.
Insttention to detail on the part of the appointed SRC when reviewing supporting documentation for the Post-Trip kevat package resulted in the SP's error not tming recognized in the Post-Trip Package re"lew.
Correctivu Steps Taken and Resu!te Achieved:
A f ollow-up 10 CFP, $0.72 report was made to the NRC Operations Center on Novemoor 29,
- 1997, providing the correct information for safoguards equipment that started automat;ually as t renult of the plant trip.
The Foet Trip Review package was reviewed again for accuracy by the originally arp,inted SRO, and by an additional SRO.
The enmpleted review was then approved by the Plant haf ety Review Committee, and permission to restart the reactor was granted.
The SS received job counse.ing from the Operatior.s Superintendent for the error in recording and toporting to the NRC.
- The apoointed SRO sho reviewed the incorrect Post Trip Review report received job counseA;ng from the Plant Manarjet.
Corrective Stora To Be Takent Initial 1.icense Operator Training Program lessoa plans related to Post Trip Reviews tvill be revised to includc a discussion of this event.
This concerc will be addressed daring the next Shift Supervisors' meeting.
1 Data khen Full coupliatice Will Be Achieved Fu; compliance was ac:aeved on November 29,
- 1997, when the correct information was documented and provided to the NRC in the follow-up not if ication t oport.
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Attachment II to WM 98-0012 Page 1 of 4 Attachment II This attachment provides WCNOC's comments and observations relative to the content of NRC Inspection Report 50-4B2/97-22.
Hid-loop Bafety Margin Concerns In the Executive Summary a nc' Section Ol.3b the Inspectors identificd four conditions concerning preparation for mid-loop operations.
In Section 01.3c the Inspectors concluded that preparations for mid-loop operation had weaknesses in several areas that collectively reduced the safety margin.
WCNOC takes exception with the conclusion that these four observed conditions reduced the saf ety margin.
Pre surizer Safety Valve Flange Vent Path The first observation presented in Section Ol.3b was the questioning of the adequacy of the minimum hot leg vent path.
The Inspectors a ecifically questioned whether an adequate vent path existed with the foreign material exclusion device installed.
Sectior. 5.15 of procedu*e GEN 00-008, Revision 5,
" Reduced Inventory Operations," requires a vent path of 17.46 square inches.
One Pressurizer Safety Valve murt be removed to assure an adequate vent path.
When the safety valve was removed, a foreign material exclusion (FME) device was installed.
This device was a piece of hard plastic approximately 1/8" thick, arched and taped on the flange in a manner that provided an adequate vent path throughout mid-loop operations.
When the installation was questioned by the Inspectors, WCNOC personnel took action to immediately alleviate their concern, then evaluated the original installation for adequacy.
As stated in Inspection Report 97-22, subsequent evaluation of the FME installation deterrined that the arched plastic, as originally installed, met the minimum hot leg vent path criteria of 17.46 inches.
Therefore the FME duvice did not unduly restrict the required vent path, and did not constitute a reduction in safety margin.
Monitoring of Core Exit Thermocy ples The Inspectors observed and questioned the installation of the in-core thermocouples used to monitor in-core temperatures.
Section 5.17 of procedure GEN 00-008, Revisior.
5,
" Reduced Inventory Operations,"
requitos at least two core exit thermocouples be operable prior to draining to mid-loop.
Instrumentation and Control (IEC) technicians enabled one group of thermocouples, but did not inform the operators which thermocouples had been connected.
The operators had indication of which thermocouples were operable via the Nuclear Plant Information System (NPIS).
This system provides indication of which inputs are providing reliable data, and the Operations staff is trained on the use of the computer.
The I&C technicians alsc demonstrated to the Inspectors the ability to monitor the thermocoup's output locally using a preciolon bridge.
The Inspectors questioned the operators' relying on apparently valid data to identify an operable thermocouple channel on the core cooling monitoring panel.
WCNOC apprecistes the Inspectors pointing out this area for improvement, and, as an enhancement, the Plant Manager directed I&C personnel to provide a list of operable thermocouples to operators as a part of the formal preparations for mid-loop operation.
- However, WCNOC maintains that at no time was the Control Room staff without the
Attachment II to WM 90-0012 Page 2 of 4 ability to monitor _at least two cere exit thermocouples, as required by procedure.
Therefore, there was no reduction in sefety margin involved
,w!th t'he Inspectors' concern.
R_esidual Heat Removal _"gmp Power Dources The third condition related to power sources during mid-loop operations.
The Inspectors were conce.rned that both residual heat removal (RHR) pumps _were powered 1;m a single offsite power _ circuit, such that a single omponent faijure in the one offsite power circuit would have caused the loss =of both residual heat removal pr-t e.
At all times during mid-loop operation, Wolf Creek was in compliance with the license required power sources stated - in procedure GEN 00-008, Revision 5,
" Reduced Ittventory Operations."
GEN 00-000 requires one of the following conditions to be met to consider both trains of RHR OPERABLE:
condition I condition II Two physically independent circuits one circuit between the offdite between the offsite transmission transmission network and the onsite network and the onsite Claso IE Class lE Distribution System *,
Distribution System, AND AND One OPERABLE emergency diesel Two OPERABLE emergency diesei generator, APD generators, AND One OPERABLE Class lE 125' VDC NK01 and NK04 OPERABLE Systum associated with the operable emergency diesel-generator, AND One energized Class 4E 125 VDC System other than the one taken credit for above (This was the existing condition that was questioned by the Inspectors.)
The conditions described in GEN 00-008 are more restrictive than the--
MODE 5 and 6 requirements of Technical Specification 3.8.1.2 related to AC electrical sources.
The conditions in GEN 00-000 in some cases would be more restrictive than MODE 5 and 6 Technical Specification 3.8.2.2, related to DC electrical sources.
GEN 00-000 does not allow for - a condition less ' restrictive than the MODE 5 and 6 DC source Technicel Specification.
While WCNOC noted the Inspectors' observation, and stated that the practicality of pro.viding two operable offsite power-circuits would be evaluated, at no time did WCNOC acknowledge that the condition under discussion was a reduction in safety margin.
Procedure GEN 00-000 meets or exes 9ds all Technical Specification requirements, and WCNOC was in full. compliance with GEN 00-008 during the mid-loop evolution.
Therefore this condition does not constitute a reduction ' in safety margin.
Containment Personnel Hatch Closure The fourth. condition identified in Section 01.3b was related to the
-stationing of a person at_the personnel hatch as requirtj by procedure.
GEN 00-008, Revision 5, " Reduced Inventory Operations." Section 5.16 of the procedure required Operations to station an individual at the.
Containment personnel access hatch whose.__ sole. purpose was to close - the
- hatch prior to the onset of core boiling, if decay heat removal were lost.
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At t a chmer.t II to WM 98-0012 Page 3 of 4 The Containment Coordinator was assigned and understood this
. responsibility; however, the Containment Coordinator was also assigned additional duties such that he was not always stationed at the personnel hatch.
Step 5.16 of GEN 00-008, also requires that an individual be stationed such that the personnel hatch can be closed within thirty minutes = This step is based on a commitment made in response to Generic Letter 88-17, as documented in letter ET 88-0193, and later revised by letter ET 92-0001.
Operations did not comply with the requirements of step 5.16 of GEN 00-008, and WCNOC acknowledges the validity of violation 9722 01.
- However, WCNOC does not agrae with the Inspectors' conclusion that this action constitutes a reduction in safety margin.
At the time of this event, two Containment Coordinators were on duty.
One was in the Containment Building and would have been able to respond and close the hatch within the required time frame.
The second was in an administrative support building and also would have been able to respond and close the door within the required time frame; therefore, no safety concerns existed.
As mentioned above, if an actual Containment evacuation had been required, then the Control Room usage of the Containment Evacuation Alarm would have resulted in the Containruent Coordinator calling the Control Room by the Gaitronics system or by a land phone.
This would ha*.e allowed suf ficient time for the Containment Coordinator to close the door.
Also, plant conditions were such that the personnel hatch would have been closed prior to the onset of core boiling (time to boil was 77 minutes).
Because the procedural thirty minute time limit for closing the door would have been correctly implemented, no reduction in safety margin occurred.
In summary. WCNOC does not agree with the Inspectors' conclusion that the licensee preparations for mid-loop operation had w1aknesses that collectively redaced the margin to safety for the following reasons:
- 1. An adequate vent path existed at the pressurizer safety valve flange throughout mid-loop operations.
- 2. At no time was the Contral Room staf f without the ability to monitor core exit thermocouples.
- 3. WCNOC maintains power sources in accordance with GrN 00-008 which is consistent with, or more conservative than, the Technical Specification requirements.
- 4. WCNOC maintained the ability to close the personnel hatch within the thirty minutes as required by procedure GEN 00-008.
Painting of Essential Service Wator Pump Room Section M2.lb documented that engineering personnel indicated tl.e plant painting and preservatior, performad in the auxiliary feedwater, emergency diesel, and emergenay core cooling pump rooms was also plunned for the essential service water pump rooms, and was scheduled to cecur during 1998.
While there is a
planned program of appearance enhancement, WCNOC does not acknowledge a specific commitment to paint this area in 1998, l
Attachment II to WM 98-0012 Page 4 of 4 Troublo-Shooting During Magne-Blast Breaker Failure Investigation Jhe Executive Summary, section E2.lb, and Section E2.lc identify a significant weakness with trouble-shooting activities that occurred during initial investigation of multiple failures of the "B" Residual Heat Removal Pump Breaker.
WCNOC acknowledges that weakness with trouble shooting guidance and preservation of as-found data was illuminated during the Incident Investigation Team review of the Magne-Diast breaker starting problems.
Upon identification of the concern, Performance improvement Mequest (PIR) 97-3421 was initiated to track and document corrective actions.
t WCHOC is currently evaluating industry best practicea for trouble shooting and will make appropriate trouble-shooting program improvements based on these evaluations.
A checxlist for trouble-shooting Magne-Blast breakers has been developed and validated by actual field use.
This checklist will be used for future Magne-Blast trouble-shooting activities.
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