ML20203J451

Responds to NRC Ltr Re Violations Noted in Insp Rept 50-482/97-23.Corrective Actions:Reactor Operator Counseled IAW Mgt Action Response Checklist Process for Failing to Obtain Concurrence from Shift Supervisor

ML20203J451
Person / Time
Site:	Wolf Creek
Issue date:	02/27/1998
From:	Boyer G WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-482-97-23, CO-98-0015, CO-98-15, NUDOCS 9803040137
Download: ML20203J451 (7)

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W$LF CREEK NUCLEAR OPERATING CORF' ORATION Gary D. Boyer Chief Administrative Officer February 27, 1998 CO 98-0015 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk ,

Mail Stacion Pl-137 Washington, D. C. 20555

Reference:

Letter dated January 29, 1998, from W. D. Johnson, NRC, to O. L. Maynard, WCNOC

Subject:

Docket No. 50-482: Reply to Notice of Violatior.s 53-482/9723-01, and 50-482/9723-02 Gertlemen:

This letter t ransmits Wolf Creek Nuclear Operating Corporation' (WCNOC) reply to Mot 20e sf Violations 50-482/9723-0 and 50-482/9723-02.

Fotice ot Violation 50-482/9723-01 ideritified that WCNOC personnel per formed procedure steps out of sequence while changing =

charging pump line up.

Notice of Violation 50-482/9723-02 identified t dlure of MCNOC personnel to tollow procedural guidance. WCNOC's response to these violationr is provided in the Attachment.

In the Executive Summary and Section 06.lb, of Inspection Report 50-482/97-23 the Inspectors identified a situation where the Plant Safety Review Committee (PSRC) considered an Unreviewed Safety Question Determination without pertinent information, which was omitted by the issue presenter.

In fol_ov-up to the inspector observation during the PSRC review of the Unreviewed Safety Question Determination . evaluation regardino the use of contact-lenset, while using respiratory protection devices, the PSRC assistant cha.rman and the PSRC chairman met separately with the inspector. The PSRC chairman agread that accurate cecision making by the PSRC requires an adequate understanding of the parameters of the decision. At the following PSRC meeting, a separate item was placed on the agenda to discuss this issue and to explore reasonable methods for assurance that the PSRC obtained sufficient information in support of decisions. At the conclusion of the discussion, the PSRC adopted two methods tc facilitate gaining the necessari information for decision making; 11 p esenters to the PSRC would be verbally given the expectation that information pertinent to the decision should be prcvided in the presentation and 2) PSBC members would direct lines of questioning to the

[ presenter focused at assuring information necesc>a ry for decision making was  ;

clearly understood. This discussion and the conclusions were subsequently documented in the PSRC minutes and discussed with the inspector. #

9803040137 980227 PDR ADOCK 05000482 -

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] ,, } } } P.O. Box 411/ Burlington, KS 66839 / Phone: (316) 364-8831 An Equal Opportunity Employer MF/HC/ VET  !, , ,q ,a1 ,I I

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l Letter CO 98-0015 Page 2 of 2 l

If you have any questions regarding this response, please contact me at (316) i 364-d831, extension 4450, or Mr. Michael J. Angus at extension 4077 Very truly yours, I ary D Boyer i

GDB/jad Attachment cc: W. D. Johnson (NRC), w/a E. W. Merschoff (NRC), w/a

.~. E' . Ringwald (NRC), w/a l K. M. Thomas (NRC), w/a l

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1 1 Attachment I to'CO!98-0015 ,

.Page 1 of $-

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-Attachment Violation 50-482/9723-01

" Technical Specificat!.on.6.8.la~ requires, in part, that written procedures be I

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 1978, Section 1.d. recommends, in part, that procedures be establfshed for procedure adh3rence.

-Procedure AP _ 15C-002, ' Procedure _Use and Adherence,' Revision 8, Section 6.2.3,-requires that each step Le completed or properly N/A'd (not applicable) before proceeding to the ncxt step.

Contrary to the above,_on January 15, 1998, a reactor operator performing Procedure SYS 3G-201, ' Shifting Charging Pumps,' Revision 31, directed a

- nuclear station operator to perform Steps _6.1.7 through 6.1.3 0, then proceed 3d

.-to complete Steps 6.1.11 through 6.1.17 without supervisory approval before

-reesiving notification from - the nuclear station operator .nat Steps 6.1.7 through 6.1.10 were complete." ,

Description of Violation:

On January 15, 1998,. a Reactor Operator proceeded with steps in Procedure :SYS

-BG-201,. " Shifting ;narging Pumps," before previous procedural steps were completed by a nuclear station operator at a remote location (i. e., the steps were performed conmrrently instead of the prescribed - sequence) . Performing i

steps out of sequence is allowed with Shift Supervisor or Supervising Operator-concurrence _11: there is no- adverse effect on the system. In this_ case,-the Re actor _Operttor _ did not have authorization f rom the Supervising . Cperator nor _.

the Shift-Supervisor.to complete steps for swapping from the Normal. Charging i Pump to Centrifugal' Charging Pump "A" before- discharge pressure gauge isolation valves were manipulated. Although-the evolution did not adversely

impact public health and safety, this-practice is in violation of-Procedure AP- l 15C-002, " Procedure Use and Adherence," Revision 8, step 6.2.3, and is not in accordance with Operations management expectations.

-Reason for Violation:

The root. cause -'of this event is determined to be misjudgment on .the ' part -of the Reactor Operator 11nvolved, due to habit intrusion. It-became an accepted practice, and therefore.a habit, to perform steps concurrently in the - field while Reactor Operators performed steps in the Control Room.

A contributing factor to_this event is inconsistency in. Operations procedures regarding when-steps _can be performed concurrently.

Corrective Steps Taken and Results-Achieved:

Performance _ Improvement Reque't . (PIR) _98-0198 -- was written to determitie root

.cause and corrective action iar this event. ,

The Reactor Operator _ has been counseled by the Supcrvising Operator in accordance with the Man,gement Action Response - Checklist (MARC) process - for failing to obtain concurrence from the Shift Supervisor or the Supervising Operator r Jr to performinq steps out of sequence.

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4 Attachment I to CO 98-0015 Page 2 o 5 r Attachment This event, and the expectation to comply with procedure requirements, was discussed at a Shift Supervisor / Supervising Operator meeting conducted February 24, 1998. The information discussed at this meeting was transmitted to those individuals who were unable to attend.

Corrective Steps To De Taken:

The Superintendent Operations will counsel the Shift Supervisor and Supervising Operator involved in accordance with the MARC process for failing to provide adequate oversight of programmatic requirements. This activity will be complete by March 20, 1998.

The conditiona acer which steps may be performed out of sequence or concurrently ai} M evaluated by Operations and a single metbo adopted for all ope ratir.. c. z t dures, if feasible. If it is determined . hat a single method cannet tv- . :-pted for all procedures, then one method <ill be adopted for normal ci m e.ing procedures. The existing guidance for emergency and off-normal nrocer :es will not be changed. This evaluation will be complete by April 3, 1998.

AP 15C-002 will be revised outlining the conditi;.s and requirements for performing steps out af sequence or concurrently. Normal operating procedures will be revised as applicable, to include the approved method adopted for performing steps out of sequence or concurrently. Revisions will be complete June 19, 1998.

The Superintendent Operations or the Superintendent Operations Support will discuss this event with each operating crew. Emphasis will be placed on ensuring compliance with all procedures and Wolf Creek Nuclear Operating Corporation (WCNOC) approved programs. These discussions will clearly state that future failures to implement WCNOC approved program requirements will be dealt with in accordance with the MARC process. For on-shift personnel, these discussions will begin on March 3, 1998, and continue until all crews have been rotated back on-shif t. These discussions will be complete by April 7, 1998.

The Operations standards will be modified to include adherence to approved WCNOC programs. This activity will be complete by March 13, 1998.

The Operations Field Supervisor will perform frequent observations of control room and field activities to observe procedural use and adherence, and to reinforce the expectation of programmatic adherence. All operating crews will be observed. This activity will be complete by May 1, 1998.

Evaluation criteria for programmatic adherence will be added to complex si.nula tor scenarios. The data collected from these evaluations will be fed back to Operations management during end-of-cycle meetings beginning with Training Cycle 98-4, which begins April 27, 1998. This feedback will be used to evaluate the progress of continuing a culture change in Operations that is related to programmatic adherence.

Date When Full Compliance Will Be Achieved:

Full compliana was achieved on January 15, 1998, immediately following completisn of surveillance test STS BG 100A, " Centrifugal Charging System 'A' Train Inservice Pump Tes t , " which was :he overall controlling procedure for this activity.

fi g Attachment I to CO 98-0015 Page 3 of 5 Attachment Violation 50-482/9723-02

" Technical Specification 6.8.la 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 1978, Section 1.d, recommends, in part, that procedures be established for procedure adherence.

Procedure STS IC-450B, ' Channel Calibration Containment Atmosphere and RCS Leak Detection Radiation Monitor GTPE31,' Revision 12, Step 8.4.1.4, requires Technicians to remove field wires from TB1-1, and Step 8.4 1.5 requires Technicians to connect the variable transformer hot lead to TB1-6 and neutral Joad to TB1-1.

Contrary to the above, on January 7, 1998, Technicians failed to comply with these procedure steps. They removed the vendor wire (instead of the field wire) from TBi-1 and reversed the variable transformer leads."

Description of Violation: 3 On January 7, 1998, three Instrument & Control (I&C) Technicians were dispatched to perform STS IC-450B, " Channel Calibration Containment Atmosphere and RCS Leak Detection Radiation Monitor GTRE31." This procedur? provides guidance for performing calibration of Containment Atmosphere and Reactor Coolant System Leak Detection Radiation Monitor GTRE0031.

The Lead I&C Technician was performing St p 8.4.1.2 of Procedure STS IC-4508.

A CAUTION nott ahead of step 8.4.1.2 requires the test performer to inform the Reactor Operator that the next step may effect communications to some of the monitors on the RM-11 display. The Lead I&C Technician proceeded with the performance of step 8.4.1.2, requesting the Control Room to de-energize breakers NG02BAR130 and 116 without first making the Control Room aware of the CAUTION note. The CAUTION note was brought to the attention of the Control Room after the NRC Senior Resident Inspector, who was present during a performance of the procedure, queried the I&C Technician about performance of the CAUTION note.

Procedure STS IC-450B contains another CAUTION note before step 8.4.2.3. This note states: "Use EXTREME caution while working inside the Motor Controller Assy. Use insulated tools because 120 VAC may be present." The NRC Senior Resident Inspector observed, during the performance of STS IC-450B, that the screwdriver being used by the Technician was not insulated all the way to the tip.

Step 8.4.1.4 directed the test performer to remove the field wires from terminal TD1-1. During performance of this step, the NRC Senior Resident Inspector inquired how the Technicie.n knew that the lead being lifted was the field wire and not the vendor wire. The I&C 1echnician explained the decision process for this determination to the NRC Senior Resident Inspector. Without performing a verification, the Technician incorrectly assumed that the wire going into the conduit at the bottom of the cabinet was the field wire.

Step 8.4.1.5 directed the test performer to connect variable transformer, set for 0 VAC, to TB1-6 (HOT) and TB1-1 (Neutral). The variable transformer was connected, black test lead to TB1-1 and white test lead to TB1-6 The NRC Senior Resident Inspector questioned the I&C Technician as to whether this was the correct connection for the test lead.

i1 g Attachment I to CO 98-0015 Page 4 of 5 Attachment The 74C Technicians re-examined the test equipment connections, identified that the test ~ equipment was miswired, and performed the appropriate corrections. These corrections were to connect the white test lead to TB1-1 (Neutral) and black test lead to TB1-6 (Hot). During the process of correcting the- miswiring, _- the NRC Senior Resident Inspector noted that the Technician-touched the_uninsulated portion of the screwdriver. When AC power was applied to the variable transformer, the Grcund Far . Interrupter -(GFI),

which was supplying power to the test equipment, _ tripped, p At ' this - point in-the evolution, the I&C Technician called time out. Test equipment was removed and wires which had been remosed in step 8. 4.14 4 were

-re-terminated. The I&C Technician then determined that the wire lifted in

. vtep 8.4.1.4 was the vendor wire and not the field -ire rfter the Technician located the field cable marker. Once the job was in a safe condition, the I&C Technicians returned to the shop and notified.the Assistant Superintendent of

-I&CLof the problems that were being encountered.

Reason f'or Violation:

-This violation was caused by the involved I&C Technician failing to _ comply with.the instructions- provided by Procedure STS IC-4508. In additior, the Technician failed to perform validation or verification techniques neo ,sary to ensure _ procedural compliance.

A contributing factor - to this event was that Procedure STS IC-450B diJ not provide'a specific verification technique.

An' additions! contributing factor was that the Technician became nervous and lost focus on_the job being performed. While performing the procedure,_ the technician was responding to questions about the work activities being performed. In' addition,_ the environmental conditions of.tne area where the testing was- being- conducted were unf avorable, - in that working . space was restricted and lighting was poor. The combination of these factors increased the nervousness of the Technician; however, the Technician did not use " Time Out" techniques when faced with uncertainty.

' Corrective Steps Taken and Results Achieved:

la editorial change to Procedure STS IC-450B was implemented on January _ 7,

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1998, to clarify' location of' field wires on the terminal block and co clarify test equipment : connections.- An additional change was incorporated into STS IC-450B on February 20,'1998. This change made the CAUTION note ahead of step 8.4.1.2 a - procedure step with 'a check-off block. The procedure, after the

editorial change was implemented, was re performed with satisfactory results

-on January 7, 1998.

Performance Improvement Pequest . (PIR) 98-0057 was written to determine the root cause(s) and corrective action (s) for this event.

The topic of screwdriver insulation was -discussed at an Electrical and I&C Shop meeting on January 13th, 1998, and awareness was raised with respect to having_too.much bare metal on the screwdriver tip exposed.

The Technicians involved were counseled - and awareness levels raised with

. respect-to use of verification techniques while performing work activities.

The awareness level was raised regarding the expectation to use the " Time Out" proceLs to ensure' activities do not proceed in the face of uncertainty. The MARC process has been implemented to address performance expectations. .

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Attachment I to CO 98-0015

• Page 5 of 5 Attachment Corrective Steps To Be Taken l None. All corrective actions are complete.

Date When Full Compliance Will Be Achieved:

Full compliance was achieved on January 7, 1998, when the Technicians returned to the work area and properly performeo Procedure STS IC-450B with satisfactory results.

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