ML20216D055
| ML20216D055 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 05/12/1998 |
| From: | Johnson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Maynard O WOLF CREEK NUCLEAR OPERATING CORP. |
| References | |
| 50-482-98-04, 50-482-98-4, NUDOCS 9805200026 | |
| Download: ML20216D055 (4) | |
See also: IR 05000483/1998004
Text
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ARLINGTON, TE XAS 76011-8064
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MAY I 21998
Otto L. Maynard, President and
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Chief Executive Officer
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Wolf Creek Nuclear Operating Corporation
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P.O. Box 411
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Burlington, Kansas 66839
SUBJECT: NRC INSPECTION REPORT 50-482/98-04 AND NOTICE OF VIOLATION
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Thank you for your letter of April 28,1998, in response to our letter and Notice of
1
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Violation concerning: (1) the operators failure to log entry into a Technical Specification Action
Statement for shutdown rod insertion; (2) failure to perform surveillance testing on auxiliary
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feedwater pumps and emergency diesel generators on a staggered test basis; and (3) a quality
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control inspectors failure to follow radiation protection requirements regarding hot spots and
performing work without appropriate health physics coverage. We have reviewed your reply and
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find it responsive to the concerns raised in our Notice of Violation. We will review the
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implementation of your corrective actions during a future inspection to determine that full
compliance has been achieved and will be maintained.
Sincerely,
W. D. ohnson, Chief
Project Branch B
Division of Reactor Projects
Docket No.:
50-482
License No.: NPF-42
cc:
Chief Operating Officer
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Wolf Creek Nuclear Operating Corp.
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P.O. Box 411
Burlington, Kansas 66839
9005200026 980512
ADOCK 05000482
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Wolf Creek Nuclear Operating Corporation
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Jay Silberg, Esq.
Shaw, Pittman, Potts & Trowbridge
2300 N Str!iet, (!W
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Washington, D.C. 20037
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Supervisor Licensing
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Wolf Creek Nuclear Operating Corp.
P.O. Box 411
Burlington, Kansas 66839
Chief Engineer
Utilities Division
Kansas Corporation Commission
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1500 SW Arrowhead Rd.
Topeka, Kansas 66604-4027
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Office of the Governor
State of Kansas
Topeka, Kansas 66612
Attorney General
Judicial Center
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301 S.W.10th
2nd Floor
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Topeka, Kansas 66612-1597
County Clerk
Coffey County Courthouse
Burlington, Kansas 66839-1798
Vick L. Cooper, Chief
Radiation Control Program
Kansas Departmect of Health
and Environment
Bureau of Air and Radiation
Forbes Field Building 283
Topeka, Kansas 66620
Mr. Frank Moussa
Division of Emergency Preparedness
2800 SW Topeka Blvd
Topeka, Kansas 66611-1287
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Wolf Creek Nuclear Operating Corporation
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MAY I 21998
bec to DCD (iE01)
bec distrib. by RIV:
Regional Administrator
Resident Inspector
DRP Director
SRI (Callaway, RIV)
Branch Chief (DRP/B)
DRS-PSB
Project Engineer (DRP/B)
MIS System
Branch Chief (DRP/TSS)
RIV File
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DOCUMENT NAME:' R:\\_WC\\WC804AK.JFR
To receive copy of document, indicate in#x: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy
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Wolf Creek Nuclear Operating Corporation
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bec distrib. by RIV:
Regional Administrator
Resident inspector
DRP Director
SRI (Callaway, RIV)
Branch Chief (DRP/B)
DRS-PSB
Project Engineer (DRP/B)
MIS System
Branch Chief (DRP/TSS)
RIV File
,
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DOCUMENT NAME: R:\\_WC\\WC804AK.JFR
To re eive copy of document, indicate inAox:"C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy
.
RIV:PE:DRP/B
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WQLF CREEK
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NUCLEAR OPERATING CORPORATION
Otto L Maynard
President and Chief Executive Officer
April 28, 1998
U. S. Nuclear Regulatory Commission
ATTN:
Document Control Desk
Mail Station Pl-137
D.
C.
20555
Reference:
Letter dated April 1,
1998, from T.
P.
Gwynn,
URC, to 0.
L. Maynard, WCNOC
Subject:
Docket No. 50-482:
Reply to Notice of Violations
50-482/9804-01, 50-482/9804-03, and 50-482/9804-07
.
Gentlemen:
This letter transmits Wolf Creek Nuclear Operating Corporation's (WCNOC) reply
to Notice of Violations 50-482/9804-01, 50-482/9804-03, and 50-482/9804-0/.
Notice of Violation 50-482/9804-01 ider.tified that WCNOC Operations personnel
performed a technical specification surveillance on the control rod shutdown
banks that required entry into the Limiting Candition for Ogeration (LCO) for
the specification, but the procecure did not indicate entry into the LCO was
required and the Cperators did not log the entry into the control room log.
Notice of Violation 50-482/9804-03 identified ineffective corrective actions
on an LER concerning surveillance testing on a staggered test basis.
The
inspection report indicated that no response is reqaired for this violation.
Notice of Violation 50-482/9804-07 identified weaknesses in the radiation
protection program and in individual radiation worker performance that
resulted in two examples of
noncompliance with radiation work permit
requirements.
WCNOC' s response to these violations is provided in the
Attachment.
If you have any questions concerning this matter, please contact me at (316)
364-8831, extension 4000, or Mr. Michael J. Angus, at extension 4077.
Very truly yours,
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Otto L. Maynard
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Attachment
cc:
W.
D.
Johnson (NRC), w/a
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E. W.
Merschoff (NRC), w/a
J. F.
Ringwald (NRC), w/a
K.
M. Thomas (NRC), w/a
RW {$ lk
PO. Box 411/ Burhngton, KS 66839 / Phore:(316) 364 8831
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An Equat Opporturuty Emp6 oyer M F NCVET
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Attachment to WM 98-0025
Page 1 of 5
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Response to Notice of Violations
Violation 50-402/9804-01
" 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, Revi:: ion 2,
February 1978.
Revision 2,
February 1978, Section 2,
recommends, in
part, that procedures be establi.=hed for general plant operations.
Technical Specification 3.1.3.5
states that,
'All shutdown rods shall be
limited in physical insertion as specified in the Core Operating Limits
Report' in Modes 1 and 2.
The cora operating limits report limits shutdown
rod insertion to no less than 222 steps.
The action statement associated with
Technical Specification 3.1.3.5 limits the number of shutdown rods inserted
beyond the insertion limit to a maximum of one rod, except for surveillance
testing pursuant to Technical Specification 4.1.3.1.2.
The action statement
requires that rods be restored to within the rod insertion limit within 1
hour.
Procedure AP 21-001,
' Operations Watch Standing Practices,'
Revision
8,
requires that all entries into short-term limiting conditions for operation be
logged in and out of the control room log.
Contrary to the above, on February 18,
1998, operators failed to log entry
into the action statement for Technical Specification 3.1.3.5
fer shutdown
rods inserted beyond the rod insertion limits.
This is a Severity Level IV violation (Supplement I)(50-482/9804-01)."
Description of Violation:
WCNOC Control Room personnel failed to acknowledge entry into the Action
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Statements for Technical Specifications 3.1.3.5,
SHUTDOWN ROD I'ISERTION LIMIT,
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and
3.
3. 6,
CONTROL ROD INSERTION LIMITS,
when performing testing in
accordance with Technical Specification Surveillance Requirement 4.1.3.1.2.
The failure to log the entrance into the Technical Specification Action
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Statements 3.1.3.5 and 3.1.3.6,
represented no safety significance.
This is
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based on the information contained within the Action Statements for Technical
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Specifications 3.1.3.5 and
3.1.3.6.
Specifically, the Action Statements for
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Technical Specifications 3.1.3.5 and 3.1.3.6 exempts the operators from having
to take any actions as long as surveillance testing pursuant to Technical Specification 4.1.3.1.2 is being performed.
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Reason for Violation:
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This violation was determined to be the result of a failure to develop
adequate procedural guidance within surveillance test procedure STS SF-001,
" Control And Shutdown Rod Operability Verification."
Specifically, this
procedure did not alert the implementers that the associated testing activity
would
result
in
an
entry
into
the
action
statements
for
Technical Specifications 3.1.3.5 and 3.1.3.6.
The wording of Technical Specifications 3.1.3.5
and
3.1.3.6
are unique in nature.
No other WCNOC technical
specification contains an exception statement within an action statement.
The
failure to adequately develop STS SF-001 is an isolated case and does not
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Attachment to WM 98-0025
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Page 2 of 5
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Response to Notice of Violations
represent a generic concern.
A contributing factor was determined to be the
failure of the Control Room Personnel to identify the applicability of
Technical Specifications 3.1.3.5
and
3.1.3.6
and to log entry into these
action statements.
Corrective Steps Taken and Results Achieved:
STS SF-001 was refised to provide enhanced guidance on the applicability of
Technical Specifications 3.1.3.5 and 3.1.3.6.
This activity was completed on
March 31, 1998.
As a good practice, management expectations on 1) reviewing all applicable
technical specifications before the performance of an activity, 2) literal
compliance to all applicable specifications, and 3) compliance with all
established (both programmatic and technical) requirements were reinforced
with Control Room persor.ael.
This activity was completed on March 10, 1998,
during the Shift Supervisor's Meeting.
Corrective Steps To Be Taken:
Operations' Management ~ will issue an essential reading assignment to all
licensed individuals to ensure the events surrounding this issue,
the
associated corrective actions, and management's expectations asrociated with
logging Technical Specification action statements entered due to surveillance
testing, are clearly understood.
Further, this reading assignment will stress
the importance of reviewing surveillance procedures for applicability of other
Technical Specifications during the performance of the surveillance.
The
projected completion date of this activity is May 31, 1998.
Date When Full Compliance Will Be Achieved:
Full compliance was achieved on March 20, 1998, when Control Room Personnel
appropriately logged into the Control Room Log entry into and exit from
Technical Specifications 3.1.3.5
and
3.1.3.6
during the next scheduled
performance of STS SF-001 (a monthly surveillance).
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Attachment to WM 98-0025
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Page 3 of 5
Response to Notice of Violations
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Violation 50-482/9804-03
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" Technical Specifications 4.7.1.2.1.a and 4.8.1.1.2 require surveillance tests
the auxiliary feedwater pumps and emergency diesel generators be performed
on
on a staggered test basis.
Contrary to the above, between August 1994 and May 1996, the licensee failed
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to perform surveillance testing on the auxiliary feedwater pumps and emergency
diesel generators on a staggered test basis.
This is a Severity Level IV violation (Supplement I)(50-482/9804-03)."
WCNOC Response
Inspection Report 50-482/98-04 states that Licensee Event Reports 50-482/96-
009-00 and 50-482/96-009-01 adequately addressed the corrective actions taken
and planned to correct the violation and prevent recurrence and the date when
full compliance was achieved.
The inspectlen report also indicates that no
additional response is required for this violation unless the referenced
licensee event reports do not accurately reflect NCNOC's corrective actions
for, or position on,
this issue.
WCNOC has determined that the referenced
licensee event reports accurately describe our corrective actions and position
on this issue and that no additional response is required.
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Attachment to WM 98-0025
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Page 4 of 5
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Response to Notice of Violations
violation 50-482/9804-07
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" Technical Sp,nfication 6.11 requires, in part, that radiation protection
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technicians
and
workers
adhere
to
procedures
for
personnel
radiation
prottetion consistent with the requirements of 10 CFR Part 20.
Administrative Procedure AP 25B-100, Radiation Worker Guidelines, Revision 5,
1
Section
6.3.6,
requires individaals to comply with radiation work permit
requirements.
)
Radiation Work Pelait 98009, Revision 0,
required intermittent health physics
coverage and required the radiation worker to avoid all posted hot spot
locations.
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Contrary to the above, on February 18, 1998,
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a.
A quality control inspector worked within 18 inches of two posted
hot spots for approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, and
b.
No health physics coverage of the work was provided during this 3-
hour period.
This is a Severity Level IV violation (Supplement IV) (50-4 82/9804-07) ."
Description of Violation:
A Quality Control (QC) inspector involved with work in Containment Spray Room
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"A"
was working near a posted hot spot, not utilizing As Low As Reasonably
Achievable (ALARA) principles.
Investigation identified that the QC inspector
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did not check in with the Health Physics (HP) Shift Technician for a briefing
of radiological conditions.
The individual was not aware of the dose rates in
the area and did not check the survey map at the entrance to the
"A"
Containment Spray Room.
Radiation Work Permit (RWP) 980009, under Special
Instructions
3,
states:
" Avoid all posted hot spot locations."
The worker
was not aware of the hot spots.
Therefore, the individual did not meet the Radiation Worker expectation of
kn' wing the expected dose rates and contamination levels encountered.
The
individual did not conform to AP 25B-100, " Radiation Worker Guidelines," steps
5.3 and 6.1.9.
Reason for Violation:
The QC inspector failed to meet the expectations of RWP 98-0009, specifically
Special Instruction 3,
which states: " Avoid all posted hot spot locations."
The QC inspet'
did not adequately review the survey map prior to entering
the area and was urs
re of the radiological condittons in the work area.
As
a result, the OC ins actor performed work in close proximity to
posted hot
spot area and, aue to not checking in with the HP Shift Tech, intermittent HP
coverage was not provided.
When the QC inspector noted the posted hot spots
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on the piping he did not challenge the ALARA aspects of the situation by
.hysics to evaluate the working conditions.
Theretore, both
asking Health
aspects of this violation were the result of inadequate work practices on the
part of the QC inspector.
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