ML20235V020

Responds to Notice of Violation (EA-88-282) & Proposed Imposition of Civil Penalty in Amount of $50,000. Util Denies Allegations Re Inoperability of Essential Svc Water Loops.Detailed Engineering Evaluation to Be Initiated

ML20235V020
Person / Time
Site:	Wolf Creek
Issue date:	03/01/1989
From:	Withers B WOLF CREEK NUCLEAR OPERATING CORP.
To:	Lieberman J NRC OFFICE OF ENFORCEMENT (OE)
References
EA-88-282, WM-89-0067, WM-89-67, NUDOCS 8903100002
Download: ML20235V020 (5)

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W$LF CREEK NUCLEAR OPERATING CORPORATION Bart D. Withers President and

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Chief Execuuve Officer March 1,1989 WM 89-0067

' James Lieberman, Director Office of Enforcement U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Subj ect : Docket No. 50-482: Reply to Notice of Violation (EA 88-282)

Dear Mr. Lieberman:

This letter provides Wolf Creek Nuclear Operating Corporation's (WCNOC)-

reply to the Notice of Violation (EA 88-282) concerning Essential Service Water (ESW) system erosion. The attached response documents the corrective actions that WCNOC has taken relative to this issue.

Although WCNOC does not want to prolong this issue through the mitigation and appeal process, there are two items that need additional discussion.

First, it is WCNOC's position that the pipe in question was never inoperable. An independent engineering stress analysis was performed subsequent to the associated enforcement conference. The results of this stress analysis demonstrated that the pipe was capable of performing its safety function under all Design Bases Events (DBE). WCNOC agrees that a mora detailed evaluation should have been performed when the eroaion was l

discovered in order to have a better basis for an operability decision, but the pipe would have maintained its pressure retaining capability under DBE conditions. Therefore, the health and safety of the public were never threatened. Second, this issue was first documented by the NRC in July, 1987 but the Notice of Violation and Proposed Imposition of Civil Penalty was not issued until February 1989. If the NRC believes that issues such as this warrant imposition of a civil penalty then the NRC should address and resolve them in a more timely manner.

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', 80 RO. Box 411/ Burlington, KS 66839 / Phone: (316) 364-8831 60l An Equal Opportunity Ernpioyer M'FHC/ VET p)l

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WM 89-0067

, Fage 2 of 2 March 1, 1989 With the exception of a License Amendment to add Engineering to the Plant Safety Review Committee, all corrective actions relative to this issue had been completed before the beginning of the inspection which resulted in this enforcement action. Enclosed is a check (#038943) in the amount of $50,000 made payable to the Treasurer of the United States.

Very truly yours, Bart D. Withers President and Chief Executive Officer BDW/j ad Attachment cc: B. L. Bartlett (NRC), w/a E. J. Holler (NRC), w/a R. D. Martin (NRC), w/a D. V. Pickett (NRC), w/a

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O f "" [4 . i Attachment'to WM 89-0067 LPage 1 'of 3'

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s REPLY TO NOTICE OF VIOLATION.

References:

il) 'ET 87-0272 dated September 10,'1987- from J. A. Bailey, .

WCNOC, to R. D. Martin and Document' Control Desk, NRC

2) ET 87-0362 dated November 30, 1987 from J. A. Bailey, WCN00,-to Document Control Desk, NRC

3) WM 88-0207 dated August 19, 1988'from B. D. Withers, WCNOC, to R. D. Martin, NRC

4) WM 88-0312 dated November 30, 1988 from B. D. Withers, .

WCNOC, to Document Control Desk, NRC Finding Wolf- Creek Technical. Specification (T.S.) 3.7.4 requires that at least two-independent Essentia1' Service Water (ESW) loops be operable in Modes.1, 2, 3, and 4. With.only one ESW loop operable, the Action requirement of T.S..

3.7.4 requires that at least two ESW loops be restored to- operable statusL within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 'or- be in at least Hot Standby (Mode 3) within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />' and Cold Shutdown' (Mode 5) within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Contrary to the above, one of. the two required ESW loops became . inoperable on February 13, 1987 due to system erosion. The licensee failed to restore the ESW loop to operable ' status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of the loop becoming inoperable in that repairs were not made until July 1, 1987 and failed to.be in Hot Standby.(Mode 3) within the next 6 months and Cold Shutdown (Mode 5):

within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

. Response-Admission or Denial of the Alleged Violation WCNOC does not- agree that one of the two ESW loops became inoperable on February 13, 1987 due to system erosion. WCNOC does agree that a more detailed engineering evaluation should have been perf ormed at that time to provide a more clear technical basis for the operability decision.

The Technical Specifications define " Operable - Operability" as follows:

Operable - Operability

.1.18 A system, subsystem, train, component or device shall be j OPERABLE or have OPERABILITY when it is capable of performing its specified function (s), and when all necessary attendant i instrumentation, controls, electrical power, cooling or seal )

water,- lubrication or other auxiliary equipment that are required j for the system, subsystem, train, component, or device to perform ll its function (s) are also capable of performing their related support function (s). J

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e. L Attach:ent to WM 09-0067 Page 2 of 3 WCNOC Subsequent to this issue being raised as an enforcement item, authorized the stress analysis of the subject ESW pipe by an independent engineering firm. The results of this stress analysis demonstrated that the pipe was capable of performing its specified functions and was operable in accordance with the above definition.

Reasons for the Vio): tion if Admitted The reason for the alleged violation (as clarified above) is failure on the part of Operations personnel to recognize that an engineering evaluation was needed to provide a basis for an operability decision when it was discovered The that the pipewall had eroded below ASME Code allowable for new pipe.

. erosion and its potential impact on operability were discussed between and Engineering, but a documented, formal evaluation was not Operations performed until after this issue was identified as an enforcement item.

Steps That Have Been Taken and the Results Achieved The eroded section of ESW pipe was discovered as a result of a self initiated erosion / corrosion program at WCNOC. The pipe in question was repaired in July 1987 and replaced with stainless steel pipe during the 1987 Fall Refueling Outage. References 1 and 2 describe the key elements of the WCNOC erosion / corrosion program and document the repair / replacement discussed above. The erosion / corrosion program is periodically modified to incorporate industry and WCNOC experience. One key item added to the program as a result of this case is a requirement less for anthan engineering 87.5% of evaluation whenever pipewall thickness is equal to or Nominal Wall Thickness.

changes have been made to improve the Several other key for Engineering / Operations interface and enhance the technical basis These operability decisions as well as other safety significant issues.

Some of the key changes changes have been documented in References 3 and 4.

involve the following:

- Restructuring of the daily planning meeting to focus more on problems

- Addition of an Engineering representative to the Plant Safety Review Committee (License Amendment awaiting NRC approval) notification

- Revision of Engineering procedures to require immediate of Control Room whenever it is identified that a nonconformance impacts the performance of a system's or componenc's intended function.

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' Attachment to WM 89-0067

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Page 3 of 3

.. Corrective Steps That Will be Taken to Avoid Further Violations The corrective, actions discussed in the previous section and in References 3 and 4 should avoid further viol 4 tons in this area. i

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Date When Full Compliance Will be Achieved

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Full compliance has been achieved. Some of 'the actions such as the erosion / corrosion program are on going efforts and changes will continue to be made as necessary in order to minimize erosion / corrosion.

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