ML20216A893

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-482/97-12 Issued on 980129.Implementation of Corrective Actions Will Be Reviewed During Future Inspections

ML20216A893
Person / Time
Site:	Wolf Creek
Issue date:	03/10/1998
From:	Johnson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Maynard O WOLF CREEK NUCLEAR OPERATING CORP.
References
50-482-97-23, NUDOCS 9803120361
Download: ML20216A893 (4)

See also: IR 05000482/1997012

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pS"2 UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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,4 611 RYAN PLAZA DmVE, SUITE 400

k+9 +0,, AR LINGTON, T EXAS 76011-8064

MAR 101995 ,

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Otto L. Maynard, President and

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Chief Executive Officer '

Wolf Creek Nuclear Operating Corporation

P.O. Box 411 ,

Burlington, Kansas 66839

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SUBJECT: NRC INSPECTION REPORT 50-482/97-23 I

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Dear Mr. Maynard: I

Thank you for your letter of February 27,1998, in response to our letter and Notice of

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huion dated Jant ary 29,1998. We have reviewed your reply and find it responsive to the

concems laised in our Notice of Violation. We will review the implementation of your corrective

actions during a future inspection to determine that fuli compliance has been achieved and will

be maintained.

Sincerely,

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W. D. Johnson, Chief  !

Project Branch B

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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

Buriirigton, Kansas 66839

Jay Silberg, Esq.

Snaw, Pittman, Potts & Trowbridge

2300 N Streat, NW

Washington, D.C. 20037

9803120361 900310

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Nolf Creek Nuclear Operating Corporation -2-

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Supervisor Licensing

. Wolf Creek Nuclear Operating Corp. j

P.O. Box 411 j

Burlington, Kansas 66839

Chief Engineer

Utilities Division -

Kansas Corporation Commission

'1500 SW Arrowhead Rd.

Topeka, Kansas 66604-4027 -

Oflice of the Governor

State of Kansas

. Topeka, Kansas 66612

Attorney General

Judicial Center-

' 301 S.W.10th

2nd Floor ,

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Topeka, Kansas 66612-1597

County Clerk l

Coffey County Courthouse i

Burlington, Kansas 66839-1798  ;

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Vick L. Cooper, Chief

. Radiation Control Program

Kansas Depsttment of Health

and Environment i

Bureau of Air and Radiation I

Forbes Field Building 283 l

Topeka, Kansas 66620 1

Mr. Frank Moussa l

Division of Emergency Preparedness )

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2800 SW Topeka Blvd

Topeka, Kansas 66611-1287

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Wolf Creek Nuclear Operating Corporation -3- J

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DRP Director SRI (Callaway, RIV)

Branch Chief (DRP/B) DRS-PSB

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Branch Chief (DPP/TSS) RIV File

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DOCUMENT NAME: R:\_WC\WC723AK.JFR ,

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W$LF CREEK NUCLEAR OPERATING CORPORATION

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Gary D. Boyer ~

CNef Admirustrative Ofreer

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Febrdary 27, 1998 l

Co 98-0015

U. S. Nuclear Regulatory Commission

ATTN: Document Control Desk

Mail Station 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 Violations

50-482/9723-01, and 50-482/9723-02

Gentlemen:

This letter transmits Wolf Creek Nuclear Operating Corporation's (WCNOC) reply ,

to Notice of Violations 50-482/9723-01 and 50-482/9723-02. .  !

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Notice ot Violation 50-482/9723-01 identified that WCNOC personnel performed

procedure steps out of sequence while changing the charging pump line up.

Notice of Violation 50-482/9723-02 identified the failure of WCNOC personnel

o follow procedural guidance. WCNOC's response to these violations 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 follow-up to the inspector observation during the PSRC review of the

Unreviewed Safety Question Determination evaluation regarding the use of

contact lenses while using respiratory protection devices, the PSRC assistant

chairman and the PSRC chairman met separately with the inspector. The PSRC

chairman agreed that accurate decision making by the PORC 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 to facilitate gaining the necessary information for

decision making; 1) presenters to the PSRC would be verbally given the

expectation that information pertinent to the decision should be provided in

the presentation and 2) PSRC memoers would direct lines of questioning to the

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presenter focused at assuring information necessary for decision making was

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clearly understood. This discussion and the conclusions were subsequently

documented in the PSRC minutes and discussed with the inspector.

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R S ~0Y%

P O Box 411/ Burkngton, KS 66839 / Phone- (316) 364 8831 i

l An Equal Ooportunity Ernployer DNF/HCNET

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Letter'CO 98-0015

Page 2 of 2 ,

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If'you have any questions regarding.this response, please contact me at (316)

l' 364-8831; extension 4450, or Mr. Michael J. Angus'at extension 4077.

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.Very truly yours,

.GDB/jad

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Attachment <

L- cc W. D. Johnson (NRC), w/a

l .E. W. Merschoff (NRC), w/a ,

J. F. Ringwald.(NRC), w/a

K. M.-Thomas-(NRC), w/a

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Attachment I-to'CO 98-0015'

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7 Attachment

violation 50-462/9723-01-

" Technical Specification 6.8.?.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.

p Regulatory Guide 1.33, Revision 2, February 1978, Section 1.d, recommends, in

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part, that procedures be established for procedure adherence.

Procedure AP 15C-002, ' Procedure Use and Adherence,' Revision 8, Section

6.2.3, requires that each step be completed or properly N/A'd (not applicable]'

before proceeding to the next step.

Contrary to the above, on January 15, 1998, a reactor operator performing.

Procedure SYS BG-201, ' Shifting Charging Pumps,' Revision 31, directed a

nuclear station operator to perform Steps 6.1.7 through 6.1.10, then proceeded

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to complete Steps 6.1.11 - through 6.1.17 without superrn ary approval before

- receiving notification from the nuclear station operate: that Steps 6.1. 7 -

l -through 6.1~.10 were complete."

Dpacription'of Violation:

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

BG-201, '" Shifting Charging Pumps," before previous procedural steps 'were "

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. comp 10ted by a nuclear ~ station operator at a remote location (i. e., the steps

were performed concurrently instead of the prescribed sequence) . Performing

steps out of sequence is allowed with Shift Supervisor or Supervising Operator l

! concurrence if there is no adverse ef fect . on the system.. In this case, the ]

l Reactor Operator did'not'have autnorization from the Supcrvising Operator nor 1

i the Shift Supervisor to complete steps for swapping from the Normal Charging

l Pump. to Centrifugal Charging ~ Pump "A" before discharge pressure gauge

l isolation valves were manipulated. Although the evolution did not adversely .

impact public health and safety, this practice is in violation of Procedure AP 3

15C-002, " Procedure Use and Adherence," Revision 8, step 6.2.3, and is not in

accordance with Operations management expectations.

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l Reason for Violation: l

The root cause of this event is determined to be misjudgment on the part of

=the Reactor' Operator involved, due to habit intrusion. It became an accel ed

practice, and therefore a habit, to perform steps concurrently in the fi , d

i while Reactor Operators performed steps in-the Control Room.

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j. A centributing factor to this event is inconsistency in Operations procederes

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' regarding when steps can be performed concu: rently.

-Corrective Steps Taken and Results Achieved:

Performance Improvement Request (PIR) 98-0198 was written to determine root

cause and corrective action for this event.

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The- Reactor Operator has been counseled by the Supervising Operator in )

accordance with the Management Action Response Checklist (MARC) process for j

failing to obtain concurrence from the Shift Supervisor or the Supervising 1

Operator prior te performing steps out of sequence,

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[ Attachment 11 to CO 98-0015

Page 2 of 5

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i Attachament

This; event, and the expectation to comply with procedure requirements, was

Jiscussed at a ~ Shift Supervisor / Supervising Operator meeting conducted

February 24,'1998. The Information discussed at this meeting was trarsmitted

to those individuals who were unable to attend.

Corrective Stepe To Be 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 conditions under which steps may be performed out of sequence or

concurrently will be evaluated by Operations and a . single method, adopted for

all' operating procedures, if feasible. If it is determined that a' single ,

method cannot be adopted for all procedures, then one method will be adopted  !

for normal operating procedures. The existing guidance for emergency and off-  !

normal procedures will not be changed. This evaluation will be complete by

April 3, 1998.

AP 15C-002 will be revised. outlining the conditions and requiremer.cs for

performing stops out of 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. 1

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The Superintendent Operations or the Superintendent Operations Support will

discuss this event with each operating crew. Emphasis will be placed on ,

ensuring compliance with a l l, procedures and Wolf Creek Nuclear Operating l'

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 wtated back on-shift. 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

simulator scenarios. The data collected from these evaluations will be fed  ;

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back , to Operations management during end-of-cycle meetirtgs 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.

l Date When Full Compliance Will Be Achieved:

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Full compliance was achieved on January 15, 1998, immediately following

completion of surveillance test STS BG 100A, " Centrifugal Charging System 'A'

Train Inservice Pump Test, " which was the oterall controlling procedure for

'this activity.

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." Attachment I to CC 98-0015

Page 3 of 5

Attachment I

violation 50-482/9723-02

l " Technical Specification 6.8.la requires, in part, that written procedures be

established, implemented, and maintained covering the applicable procedures

recommended in App 9ndix A of Regulatory Nide 1.33, Revision 2, February 1978.

Regulatory Guide 1.33, Revision 2, February 1973, Section 1.d, recommends, in

I part, that procedures be established for procedure adherence.

Procedure STS IC-450B, ' Channel Calibration Containment Atmosphere and RCS

Leak Detection Radiation-Monitor GTRE31,' 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

lead 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 TB1-1 and reversed the variable transformer leads."

Description of Violation:

On January 7, 1998, three Instrument & Control (I&C) Technicians were

dispatched to perform STS IC-4508, " Channel Calibration Containment Atmosphere

and RCS Leak Detection Radiation Monitor GTRE31." This procedure provides

guidarice for performing calibration of Containment Atmosphere and Reactor

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Coolant System Leak Detection Radiation Monitor GTRE0031.

The Lead I&C TechnicAan was performing Step 8.4.1.2 of Procedure STS IC-450B.

A CAUTION note 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

l 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 8.4.1.3. This i

note states: "Use EXIREME caution while working inside the Motor Controller

l Assy. Use insulated tools because 120 VAC nay be present." The NRC Senior

Resident Inspector observed, during "he performance of STS IC-450B, that the

screwdriver teing used by the Technician was not insulated all the way to the

tip.

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Step 8.4.1.4 directed the test performer to remove the field wires from

terminal TB1-1. During performance of this step, the NRC Senior Resident

Inspector inquired how the Technician knew that the lead being lifted was the

field wire and not the vendor wire. The I&C Technician 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 bottcm 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 connectica 'or the test lead.

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Page 4 of 5

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The I&C Technicians re-examined the test equipment connections, identified i

the.t the test equipment was miswired, end performed the appropriate l

l corrections. These corrections were to connect the white test lead to TB1-1 j

(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

l was applied to the variable transformer, the Ground Fault Interrupter (GFI),

j which was supplying power to the test equipment, tripped.

l At this point in the evolution, the I&C Technician called time out. Test

equipment was removed and wires which had been removed in step 8.4.1. 4 were

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

step 8.4.1.4. was the vendor wire and not the field wire after the Technician

i located the field cable marker. Once the job was-in a safe condition, the IsC 1

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Technicians returned to the shop and noti ed the Assistant Superintendent of j

IEC of the problems that were being encountered. 1

Reason for Violation:

This violation was caused by the involved I&C Technician failing to comply

with the instructions provided by Pr'cedure STS 10-450B. In addition, the

L Technician failed to perform validation or verification techniques necessary '

to ensure procedural compliance.

A contributing factor to this event was that Procedure STS IC-450B did not I

provide a specific verification technique.  !

An additional contributing factor was that the Technician became nervous and i

lost focus on the job being performed. While performing the procedure, the l

l technician was responding to questions about the work activities being l

l performed. In addition, the environmental conditions of the area where the

testing was being conducted were unfavorable, 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.

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Corrective Steps Tzkon and Results Achieved:

An editorial. change to Procedure STS IC-450B was implemented on January 7,

1998, to clarify location of field wires on the terminal block and to clarify

! test equipment connections. An additional change was incorporated into STS

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IC-450B on February 20, 1998. This change made the CAUTION note ahead of step

l 8. 4.1. 2 a procedure step with a check-off block. The procedure, after the

editorial change was implemented, was re-performed with .natisfactory results

on January 7, 1998.

Perf o rmance Improvement Request (PIR) 98-0057 was written to determine the i

root cause(s) and corrective action (s) for this event. I

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"

process 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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Corrective Steps To Be Taken: I

None. All corrective actions are complete.

Date When Full Compliance Will Be Achieved: '

rull compliance was achieved on January 7, 1998, when the Technicians returned 1

to the work area and properly performed Procedure STS IC-450B with

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satisfactory results.

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