ML20214E472
| ML20214E472 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 01/17/1986 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20214E466 | List: |
| References | |
| EA-85-127, KMLNRC-86-010, KMLNRC-86-10, NUDOCS 8603260212 | |
| Download: ML20214E472 (10) | |
Text
.
KANSAS GAS AND ELECTRIC COMPANY TH: ELECTAC COMAANY January 17, 1986 4LENN L NOESTER vtE PRESIDENT - NUCLEAF 3R@10M3 3 Mr. R. D. Martin I
Regional Administrator
/
U.S. Nuclear Regulatory Commission M22 ji k
Region IV
]h 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 D
KMLNRC 86-010 Re:
Docket No. STN 50-482 Subj : Response to Notice of Violation 50-482/85-35 (Enforcement Action 85-127)
Dear Mr. Martin:
This letter is written in response to your letter of December 18,
- 1985, which transmitted Notice of Violation 50-482/85-35 (Enforcement Action 85-127).
As requested, the violations A'through E identified in the Notice of Violation are being addressed in four parts.
(a) The reason for the violation if admitted; (b) The corrective steps which have been taken and the results achieved; (c) Corrective steps which will be taken to avoid further violations; and (d) The date when full compliance will be achieved.
1.
Violation A (Inspection Report Item 50-482/8535-01): Violation of Technical Specifications - Centrifugal Charging Pump Inoperable Finding:
Technical Specification 3.5.2 requires that "two independent emergency core cooling systems (ECCSs) subsystems shall be operable with each subsystem comprised of:
(a) One operable centrifugal charging pump, (b) One operable safety injection pump, (c) One operable RHR heat exchanger, (d) One operable RHR pump, and (e) An operable flow path capable..."
8603260212 860311 1 ( -009 h PDR ADOCK 05000482 O
P1'R 201 N. Market - Wictuta, Kansas - Mail Address: RO. Box 208 I Wichita, Kansas 67201 - Telephone: Area Code (316) 261-6451
.l:
Mr. R. D. Martin KMLNRC 86-010 Page 2 January 17, 1986 The action statement for Technical Specification 3.5.2 states: "with one' ECCS subsystem inoperable, restore the inoperable subsystem to operable status within-72 hours or be in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in hot shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />."
Contrary to the above, on August 31,
- 1985, it was determined that centrifugal charging pump A had been inoperable for 97 hours0.00112 days <br />0.0269 hours <br />1.603836e-4 weeks <br />3.69085e-5 months <br /> without the required action statement being implemented.
Reason For Violation If Admitted:
On August 27, at approximately 2112 CDT, Cent-ifugal Charging Pump (CCP) "A" was taken out of service for maintenance.
Maintenance activities were completed on August 30,
- 1985, and following completion of surveillance test STS BG-100A,
" Centrifugal Charging System 'A' Train Inservice Pump Test", the CCP was declared operable at 2030 CDT on August 30, 1985. At that time, CCP "A" had been out of service for less than the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed by Technical Specifications.
On August 31, at approximately 2200 CDT, during routine operator inspections of the status of safety systems, it was discovered that manual valve BG-8485A, the CCP "A" discharge isolation valve, was closed rather than in its rcquired open position.
This condition resulted in the CCP being inoperable.
It was subsequently determined that a. personnel error had occurred during the performance of surveillance test STS BG-100A.
The operator performing the surveillance test misinterpreted a caution s tatement in the test procedure regarding the position of valve BG-8485A in various plant modes, resulting in the valve being left in
~
the closed (incorrect) position.
As a consequence of this error, Centrifugal Charging Pump "A" had remained out of service from August 27, 1985, until August 31, 1985, exceeding the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed by Technical Specifications.
jorrective Steps Which have Been Tak9.n And Results Achieved:
Valve BG-8485A was opened immediately upon discovery that it was not in the proper position, returning CCP "A" to operable status.
A temporary change was made to STS BG-100A and its companion procedure, 'STS BG-100B, to clearly state the required position for the centrifugal chatging pump discharge valves.
Mr..R. D. Martin KMLNRC-010 Page 3 January 17, 1986 A ' review of operations surveillance test procedures has been conducted to identify any other notes or caution statements which may be ambiguous or misleading.
Temporary changes have been prepared which correct ambiguous statements that were identified.
This event was the subject of Licensee Event Report (LER) 85-063-
- 00..
This LER was placed in Operations required reading to ensure operator awareness of the ambiguous statement in the procedure.
A management review of this event determined that an additional factor contributed to this event. Administrative procedures require a post test review of the completed surveillance procedure by the Shift Supervisor. In this case, the detailed post test review could have identified the error in performance of the test, but did not.
.To help prevent a recurrence of this type event, the Shift Supervisors were trained in post test review requirements and implementation responsibilities.
Corrective Steps Which Will Be Taken To Avoid Further Violations:
The temporary procedure changes will be incorporated into permanent procedure revisions.
Date When Full Compliance Will Be Achieved:
Full compliance will be achieved by March 1, 1986.
2.
Violation B (Inspection Report Item 50-482/8535-02):
Failure To Observe Protective Clothing Requirements Of A Radiation Work Permit Finding:
Critericn V states:
" Activities affecting quality shall be prescribed by documented inst ructions,
procedures, or drawings
.and shall be accomplished in accordance with these instructions, procedures, or drawings.
Administrative Procedure ADM 03-101, Revision 4,
" Radiation Work Permit Program," has been established in accordance with 10 CFR Part 50, Appendix B, Criterion V and Section 3.5 states, in part, "Each individual using a radiation work permit (RWP) is responsible to comply with thiit procedure and applicable instructions from the health physics group."
N
4 l'
E Mr. R. D. Martin KMLNRC 86-010 Page 4 January 17, 1986 h
. Contrary to the above, on August 30, 1985, a radiation worker was observed entering a radiologically controlled work area without
' donning the protective clothing (cotton liners, rubber gloves.
plastic shoe covers, and rubber shoe covers) delineated in RWP 850143, which had been established for the controlled area by the
-health physics group.
Reason For The Violation If Admitted:
A Station Operator was preoccupied with the task he was assigned to do.
When he crossed the step-off pad, he failed to recognize it as a sign that he das entering a radiological area requiring cdditional protective clothing.
Corrective Steps Which Have Been Taken and Results Achieved:
This event was documented in accordance with procedure ADM 03-006
" Notice of Radiological Work ' Practice Violation".
Thc Station Operator was counseled on the importance of complying with radiological work procedures.
The Radiation Worker Training program was reviewed to ensure that it provides adequate training on the postings of radiologically controlled work areas and the requirements for entering them.
The administrative procedures governing radiological work practices were reviewed to ensure they contained adequate methods and controls to ensure the preecribed clothing is worn.
No required changes were identified.
. Corrective Steps Which Will Be Taken To Avoid Further Violations:
Investigations into this event led to a conclusion that this was an isolated event.
Strict adherence to the administrative procedure governing radiation work practices are adequate to avoid further violations.
Date When Full Compliance Will Be Achieved:
Full compliance has bean achieved.
3.
Violation C (Inspection Report Item 50-482/8535-03):
Violation of Contsinment Fire Detection Technical Specifications Instrumentation Out Of Service Technical Specifier. tion 3.3.3.8, requires that the fire detection instrumentation fot Fire Detection Zone 201 be operable.
4
- ;;j -
Mr. R. D. Martin f
KMLNRC 86-010 Page 5 January 17, 1986 The action statement for Technical Specification 3.3.3.8 requires that when the fire detection instrument for Fire Detection Zone 201 (located inside containmeat) is inoperable, a fire watch patrol must be established to inspect Fire Zone 201 at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or the containment air temperature must be monitored at least once per hour at the locatio.is listed in Technical Specificaiton 4.6.1.5.
Contrary to the above, on August 13, 1985, with the fire detection instrument for Fire Zone 201 inoperable, containment air temperature was not monitored at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> between the hours of 0700 and 1459, nor was a fire watch patrol established to monitor Fire Zone 201.
Reason For Violation If Admitted:
The Containment zone 201 fire detector, a heat-type fire detector, had been inoperable since approximatley 2019 CDT on August 9, 1985.
The required Containment temperature readings, performed in accordance with Technical Specifications 3.3.3.8, had been recorded hourly since that time until approximatley 0600 CDT on August 13, 1985. Beyond that time, the hourly readings were not recorded until this oversight was discovered at approximately 1500 CDT on August 13, 1985. Hourly readings were resumed immediately upon discovery.
The cause of this event was a procedural personnel error by a licensed Control Room operator coming on shift who failed to adequately review Control Room logs as required by administrative procedures.
This resulted in overlooking the ongoing requirement for hourly Containment air temperature readings which was identified in the appropriate-logs maintained in the Control Room.
This i
oversight was recognized and corrected during routine turnover activities by the next oncoming shift.
Coprective Steps Wh'.ch Have Been Taken And Results Achieved:
Upon discovery, hourly temperature readings were commenced.
A review of administrative procedure ADM 02-010
" Shift Relief and Turnover", which specified actioas required by offgoing and oncoming personnel for shift turnovers confirmed that adequate methods and controls are specified to effect proper transfer of information between operating shift crews.
The Shift Supervisor han individually counseled the Control Loom operator concerning this personnel error and administrative procedure ADM 02-010 was assigned as required reading for all operating personnel.
This event was the subject of LER 85-070-00.
This LER was also placed in Operations required reading.
Mr. R. D. Martin KMLNRC 86-010 Page 6 January 17, 1986 Corrective Steps Which Will Be Taken To Avoid Further Violations:
The corrective actions discussed above will help avoid further violations in this area.
Date When Full Compliance Will Be Achieved:
Full compliance has been achieved.
4.
Violation D (Inspection Report Item 50-482/8535-04):
Failure To Follow Installation Criteria For Various Conduits Finding:
10 CFR Part 50, Appendix B, Criterion V, states: " Activities affecting quality shall be prescribed by documented instructions, procedures,
.or drawings and shall be accomplished in accordance with these instructions, procedures, or drawings..."
Design Drawing E-IR 8900, Revision 3, " Raceway Notes, Symbols, and Details," has been implemented in accordance with 10 CFR Part 50, Appendix B, Criterion V.
Design Drawing E-IR 8900, Revision 3, provides the methods that are acceptable-for installation of conduit at the Wolf Creek Generating Station.
Contrary to the above, on September 26,
- 1985, flexible conduit
- IU1276, running between the rigid conduit mounted on the room wall and terminal box TV-AB05 mounted on the main steam isolation valve (MSIV) AB HV-20, was tied with a plastic stay strap to an air line (approximately 3/4" diameter) going to the same valve.
- Also, flexabla conduit 1U1279, ~ going to MSIV AB HV-17, was tied with a plastic stay strap to the conduit connector (at the valve) for conduit 1U1277..
This method of installing flexible conduit is not shown in Drawing E-IR 8900 as an acceptable installation' method.
Reason For Vis7etion If Admitted:
The investigatf o into this event has failed to identify when or why the plastic stay straps were installed. This investigation included a check of Startup and Power Ascension tests, Work Requests and Temporary Modifications.
Mr. R. D. Martin KMLNRC 86-010 Page 7 January 17, 1986 Corrective Steps Which Have Been Taken And Results Achieved:
The plastic stay straps were removed.
Corrective Steps Which Will Be Taken To Avoid Further Violations:
In order to prevent recurrence, a mat.agement letter was sent to station employees, emphasizing the problem.
Date When Full Compliance Will Be Achieved:
Full compliance has been achieved.
5.
Violation E (Inspection Report Item 50-482/8535-05): Failure To Follow Housekeeping Requirements Finding:
10 CFR Part 50, Appendix B, Criterion V,
states:
" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings.
and shall be accomplished in accordance with'these instructions, procedures, or drawings.. "
1.
ADM 13-102, Revision 4, " Control of Combustible Materials," has been established in accordance with 10 CFR Part 50, Appendix B, Criterion V.
Section 5.1 of ADM 13-102 states "The person requiring the use of combustible materials in excess of the amounts specified in Table 1 of this procedure will obtain a permit for handling, use, and/or storage of those materials from the fire protection specialist or his designee.
Storage must comply with Section 3.1.2."
Table 1 to ADM 13-102 states that the maximum quantities of transient combustible solids allowed without a permit will be (at or below) 10 cubic feet tnd 100 pounds.
Contrary to the above, on September 25,
- 1985, 19 cardboard boxes, which is in excess of the amount specified in Table 1 of Section 5.1 of ADM 13-102, were observed to be unattended and stored on the north end of the auxiliary building on the 2026' level without the use of a combustible materials permit.
Mr. R. D. Martin KMLNRC 86-010 Page 8 January 17, 1986 2.
ADM 01-034, Revision 7, "Hourekeeping and Cleanliness Control,"
has been established in accordance with 10 CFR Part 50, Appendix B, Criterion V.
The following are excerpts from ADM 01-034:
Section 6.2.3:
" Oily mops and wiping rags will be atored in noncombustible containers when not in use."
Section 6.1.4:' " Rags, paper, and other debris shall be placed in suitable waste containers.
If radiologically contaminated items are involved, the decontamination and/or disposal will be done under the direction of the health physics group."
Section 6.2.2.1:
" Combustible waste material will be disposed of at least once per working shift in noncombustible covered waste receptacles."
Section 6.2.2.8:
" Oily rags and waste, in small amounts, shall be disposed of in portable metal waste cans with.a self-closing cover."
Contrary to the above, on September 26, 1985, the following conditions were observed in the auxiliary building:
a.
A metal trash container (flapper lid type), located in Room 1509 on the 2047' level and adj acent to main steam isolation valve AB HV-20, was overflowing with combustible trash to the extent that the flapper lid was being held open by the trash and a paper towel was on the floor beside the trash container.
^ b.
In Room 1412 on the 2026" level and adjacent to main feedwater isolation valve AE FV-041, approximately 20 oil-soaked rags (approximately l' by l' in size) were lying on
'the floor.
c.
On the 1974' level adjacent to Column AJ-A6~ in the north-south corridor on the east side of the building, a trash barrel (50 gallon open top drum) was approximately one-half full of mostly combustible material.
d.
On the 2026' level adj acent to Column AJ-A13, a trash barrel (50 gallon open top drum) was approximately two-thirds full of mostly combustible material.
Mr. R. D. Martin KMLNRC 86-010 Page 9 January 17, 1986 e.
On the 2000' level adjacent to Column A13 at the south end of the north-south corridor, an unattended pile of approximately 10 rags (approximately l' by l' each) was on the floor beside an overturned maintenance cart.
f.
On the 2047' level adjacent to Column AJ-A9, a trash barrel (50 gallon open top drum) was approximately three-fourths full of mostly combustible material.
Reason For Violation If Admitted:
1.
The reason for this violation is that the sub-vendor working procedures which governed these work activities were not fully coordinated with station procedures relative to the control of combustible ' materials.
Therefore the sub-vendor was not aware of the requirement for the controls for combustible materials.
Normally material is removed from crates and boxes before being
. brought to. the work area.
- However, in this case the boxes contained safety related insulating material and the appropriate traceability identification.was marked on the outside of the cardboard box.
2.
All trash containers in the Auxiliary Building are _ radioactive waste containers and all trash is treated as radioactive waste until surveyed.
The reason that many of the trash containers did not 'have lids is that not having to handle a lid when disposing of radioactive waste reduces the likelihood of personnel contamination.
The large number of oil soaked rags in the MSIV and MFIV areas was generated _as a result of leakage of Fyrquel 220 hydraulic fluid from these valves.
Fyrquel 220 is a self extinguishing material and rags soaked with this fluid will not support combustion.
The reason that the container was overflowing is that the personnel responsible for the cleanup effort failed to provide an adequate number.of containers for the large amount of waste generated.
The reason for the pile of rags on the floor under one of the valves was an attempt to contain the leaking oil and prevent it from spreading.over the entire floor.
An inspection of the Auxiliary Building on September 30, 1985 found all trash receptacles empty.
Mr. R. D. Martin KMLNRC 86-010 Page 10 January 17, 1986 Corrective Steps Which Have Been Taken And Results Achieved:
1.
Construction management is now having a meeting once a week with the contractor craft supervisory people.
This meeting is used to go over plant procedures,
.such as housekeeping and fire protection, as well as to discuss specific problems.
2.
All trash containers in the Auxiliary Building have been provided with lids.
All trash discovered outside of closed containers was put into containers with lids.
Also, daily management meetings are held to discuss the status of current work activities and special plant problems which includes problems with housekeeping and fire protection.
_C_orrective Steps Which Will Be Taken To Avoid Further Violations:
The management meetings discussed above will continue to be an effective preventive measure to avoid further violations.
In
- addition, the 50 gallon crash containers will be replaced with containers having self closing lids.
Date When Full Compliance Will Be Achieved:
The replacement of containers will be completed by March 31, 1986.
If you have any questions concerning this matter, please contact me or Mr. O.L. Maynard of my staff.
Yours very truly, M
Glenn L. Koester Vice President -Nuclear GLK:see cc: P0'Connor (2)
JCummins JTaylor