ML20237D195
| ML20237D195 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 08/21/1998 |
| From: | Maynard O WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-482-98-14, WM-98-0090, WM-98-90, NUDOCS 9808250130 | |
| Download: ML20237D195 (9) | |
Text
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o W$LF CREEK NUCLEAR OPERATING CORPORATION Otto L. Maynard President and Chief Executive Officer AUG 211998 WM 98-0090 U.
S. Nuclear Regulatory Commiss, ion ATTN:
Document Control Desk Mail Station F1-137 Washington, D. C.
20555
References:
Letter dated July 23, 1998, from W.
D.
- Johnson, NRC, to O. L. Maynard, WCNOC
Subject:
Docket No. 50 482:
Response to Notice of Violation 50-482/9814-01.
Gentlemen:
This letter transmits Wolf Creek Nuclear Operating Corporation's (WCNOC) response to Notice of Violation 50-482/9814-01.
Violation 9814-01 identified that technicians had incorrectly placed and stored a door and its frame in the Control Room equipment cabinet room.
The distance from the door frame to the adjacent Train A protection system logic cabinets was less than that required by WCNOC Administrative Procedure AP 21J-001, Revision 2, " Control of Temporary Equipment."
WCNOC's response to this violation is provided in Attachment I.
WCNOC has also elected to respond to other information contained in the report.
These responses are provided in Attachment II.
Attachment III provides a list of commitments contained in this response.
If you have any questions regarding this respon.e, please contact me at ( 316') 364-8831, extension 4000, or Mr.
Michael J. Angus, at extension 4077.
Very truly yours,
.b [0k i
O L. Maynard
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OLM/rlr i
u Attachments cc:
W.
D.
Johnson (NRC), w/a E. W.
Merschoff (NRC), w/a B. A. Smalldridge (NRC), w/a K. M. Thoinas (NRC), w/a
/ (f. \\
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9808260130 980821 l
PDR ADOCK 05000482 l
G PDR i
,1-4, 7 [4 h
(
1 P.O. Box 411/ Durhngton, KS 66839 / Phone: (316) 364-8831 An Equal Opportunny Employer MS/HC/ VET w_
Attachment I to Letter WM 98-0090 j
Page 1 of 2 ATTACHMENT I
, Violatinn 50-482/9814-01:
"During an NRC inspection conducted on May 31 through July 11, 1998, one violation of NRC requirements was identified.
In accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions,"
NUREG-1600, the violation is listed below:
Technical Specification 6.8.1.a, requires, in pait, 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 2, recommends, in part, that procedures be established for general plant operations.
Paragraph 6.9 of Procedure AP 21J-001, " Control of Temporary Equipment,"
Revision 2, states that unstable equipment shall be restrained in a suitable location to prevent toppling or shall be no closer than 1 foot plus the height of the equipment from the nearest safety-related equipment.
(
Contrary to the above, on June 4, 1998, technicians placed a heavy door and frame in the control room equipment cabinet room adjacent to the Train A protection system logic cabinets.
The distance from the door and frame to the protection system cabinets was less than the height of the door plus 1 foot."
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Description of Event l
As indicated in the Notice of Violation, the storage of the door frame did l
not comply with the requirements of procedure AP 21J-001,
" Control of I
Temporary Equipment."
The height of the frame and its distance from the wall resulted in 4.5 inches of " free space."
This distance is less than the 1
12 inches required by AP 21J-001.
Although storage of the frame did not comply with AP 21J-001, there was no danger to safety-related plant equipment, and no safety significance associh ed with this issue.
AP 21J-001 is written to include a safety factor of 12 inches added to the height of temporarily stored equipment that is not secured.
The frame in this event was not stored croperly with the plus 12 inches not having been maintained for unstable equipment.
- However, the door and frame would not have come in contact with any safety related equipment had it topplad or slid down the wall onto the floor.
l Reason for Violation:
The root cause of this event is considered to be personnel error due to l
tunnel vision on the part of maintenance craft personnel.
Craft personnel l
made decisions and took action without properly assessing the entire l
situation.
They attempted to store the door and frame in a safe configuration, but failed to ensure compliance with AP 21J-001.
Personnel i
were more focused on the door and frame sliding down the wall, and did not l
give sufficient consideration to the potential of *'.e frame toppling over.
Corrective Steps Taken and Results Achieved:
l Upon identification of the concern, WCNOC personnel placed the door and l
frame in a condition that was in compliance with Procedure AP 21J-001 on l
June 4, 1998.
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' Attachment-I to Letter WM 98-0090 Page 2 of 2
+
ATTACIDENT I i
.The Superintendent of Mechanical Maintenance addressed this error with
- supervision and craft personnel involved.
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As a further enhancement, on August 11, 1998, the WCNOC Human Performance i
group. distributed a " Human Performance Lessons Learned Report" site-wide l
discussing this violation.
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Copies of Performance Improvement Request (PIR) 98-1616 were given to the i
responsible management of Operations, Chemistry / Health Physics, Maintenance, and Engineering work groups for distribution.
Discussion of this PIR is
-intended to heigh'.+n workers' awareness of storage requirements for
' temporary equipment.
Corrective Steps To Be Taken:
PIR 98-1929 has been initiated by WCNOC Maintenance to provide review, assessment, and evaluation of the definition and control of " stable" versus
" unstable" equipment, the approval processes for storage areas, and the j
storage time limits for temporary equipment.
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'Date When Full Compliance Will Be Achieved:
Full compliance wasfachieved on June 4, 1998, when storage of the door frame was brought back into compliance with procedure AP 21J-001 requirements.
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Attachment II to Letter WM 98-0090 Page~1.of 5 Attachment II This attachment provides. ' WCNOC's comments and observations relative to the
' -content of,NRC Inspection Report 50-482/98-14.
Moisture' Intrusion The Executive Summary of Inspection Report 98-14 stated:
" Operators inade reasonable preparations for anticipated severe weather, but discovered during the st orm that other actions,.such as closure of the turbine building. roll-up doors, would have provided improved protection of plant structures and equipment."-
WCNOC Response:
It is not-a normal practice to close these doors when storms are expected, as they are only partially open.
There is no vital equipment exposed to the
- elements when these doors are only partially open and the amant of water
. ingress is minimal.
Water entering through these roll-up doors falls on the concrete floor, flows to the drains, and. subsequently drains to the lake.
Although the. storm that WCGS experienced on June 29, 1998, was extreme in intensity, the station did not experience a significant threat.. The roll-up doors.in the' Turbine Building were not closed during the height of the storm due to the short warning time before the storm hit, and personnel safety concerns once the ' storm was in progress.
Wolf Creek does not believe that closure of the turbine. building roll-up doors would have 'provided improved protection of plant structures and equipment.
Component Cooling Water Surge Tank Level Indication Corrective Actions The Executive Summary.of Inspection Report 98-14 stated:
" Corrective ' actions from a 1997 component cooling water surge tank level
-indication transient were not adequate to prevent ' recurrence.
Engineering's response. to collect additional data appeared to be useful in developing.
additional corrective actions that may successfully prevent further recurrence."
WCNOC Response:
The original corrective actions for the concern that was identified in 1997 included replacing the transmitter, collecting and performing an analysis of the sample line contents, 'and the creation of ~a' 36 month preventive maintenance task to drain and refill the sample lines.
These. corrective 3
. actions were " s ucces s ful, with the exception 'of the selection of a 36 month i
time interval between flushing -(draining and filling) the sample lines.
At i
the time of the original problem in 1997, the system had functioned for 12 i
years without exhibiting a problem with build-up of corrosion products.
Under those. conditions a'
36 month interval between flushes was considered reasonable.
WCNOC has reexamined the basis of this decision and has elected to flush the lines at six month intervals.
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A Attachment II to Letter WM 98-0090 Page 2 of 5 4
Attachment II I
Closure of Violation 50-482/9804-07 Radiation Work Permit (RWP)
Noncompliance L
This violation involved an incident where a Quality Control inspector failed to meet the requirements of his RWP.
Page 10 of the inspection report,Section IV, " Plant Support" states:
"The ' inspector verified the corrective actions described in the licensee's response letter, dated April 28, 1998, to be reae.onable but not complete because the response did not address all the correr.tive actions prompted by this event.
Radiation protection supervision initiated Performance Improvement Request 98-0452 to address s eve'. al radiation protection programmatic issues that were raised by this issue.
These issues included the
- applicability of dose gradients to hot spots'in lower dose areas, the lack of a-procedural requirement for workers to inform radiation protection
- technicians prior to beginning work in the radiologically controlled area, and the actual meaning of intermittent radiation protection job coverage.
Corrective actions included revising procedures to clarify dose gradient dosimetry issues, procedurally ' requiring radworkers to inform radiation protection technicians prior to entering the radiologically controlled area, and creating a start of job reference card to help radworkers ensure that
- radiation protection procedural requirements will be met prior to starting
- work, No similar problems were identified."
1 WCNOC's Response:
I This violation stated:
"... Radiation Work' Permit 98009, Revision 0, required intermittent health physics coverage and required the worker to avoid all posted hot spot locations.
Contrary to the above, on February 18, 1998, 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 was provided during this 3-hour period."
Our response to this violation stated:
"The QC inspector failed to meet the expectations of RWP 98-009, specifically, Special Instruction 3, which states:
' Avoid all hot spot locations.'
The QC inspector did not adequately review the survey map prior to entering the area and was unaware of the radiological conditions in the work area.
As a result, the QC inspector performed work in close proximity to a posted hot spot area and, due to not checking in with the HP Shift Tech, intermittent HP coverage was not provided.
When the QC inspector noted the posted hot spots on the piping he, lid not challenge the ALARA aspects of the situation by asking Health Physics to evaluate the working conditions.
Therefore, both aspects of this violation were the result of inadequate work practices on the part of.the QC inspector."
Wolf Creek believes that this issue was caused solely by a failure on the part of the Quality Control Inspector to meet procedure guidance expectations of a Radiation Worher at the Wolf Creek Generating Station. We do not believe that the actions on the part of this individual are indicative of a generic concern with' Radiation Worker compliance with RWP requirements. Rather, this violation was due to an individual's failure to meet management expectations and
' procedural requirements.
Therefore, corrective actions in our response focused on those actions germane to this violation (disciplinary action for l
the involved individual).
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Attachment II to Letter WM 98-0090 Page 3 of 5 Attachment II The issues discussed in Inspection Report 98-14 (the applicability of dose
' gradients to hot spots in lower dose areas, the lack of a procedural requirement for workers to inform radiation protection technicians prior to beginning work in the radiologically controlled area, and the actual meaning of intermittent radiation protection job coverage), while considered important issues to address at Wolf Creek, are not necessary to prevent recurrence of this personnel error violation, and therefore were not included in our response.
Possible Loss of Independence Page eight, Paragraph two, of the 98-14 Inspection Report stated:
"In subsequent discussions with the electrical maintenance department and the electrical quality control group supervisor, the inspector learned that the installing technician and the quality control technician discussed diode bias orientation and jointly looked at prints during the course of the work.
This may have caused a loss of independence which contributed to both technicians failing to ensure that the diodes were installed as directed."
WCNOC Response:
WCNOC's investigations identified two root causes for this event:
The craft person fell into an incorrect mindset during the job that led to his error, and The Quality Control (QC) Inspector, never having been trained on how diodes can be installed, was given a short brief on what he was to be looking for by another inspector who was familiar with this job.
In this brief there was miscommunication and misinterpretation based on the information provided.
Several contributing factors were also identified.
These issues have been addressed in PIR 98-1732.
WCNOC's investigation of this event did not identify a loss of independence on the part of the QC Inspector.
Cart Storage in Control Room Inspection Report 98-14 paragraph M4.lb stated:
"On June 29, 1998, the inspector observed that two portable Instrumentation and Control 7300 Rack Testing Cabinets located along the northwest wall in the control room equipment cabinet room also appeared non-compliant with the unstable equipment storage criteria contained in paragraph 6.9 of Procedure AP 21 J-001.
The testing cabinets, which were 70 inches tall and moonted on casters, were located a distance of approximately three feet from cabinets which contained control room annunciator circuitry.
While not directly safety
- related, the annunciation circuitry contained in the cabinets provides indication to control room operators of trouble with safety-related equipment and circuitry.
The inspector informed the shift supervisor who took action to remove the portable testing cabinets from the control room.
The inspector also noted that the procedure did not address how long an item classified as temporary equipment could be stored outside of a designated storage area.
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two instrumentation and control testing carts had been stored in the control room at that location for several years.
The shift supervisor initiated Performance Improvement Request 98-1896 to identify the procedural inadequacy."
Attachment II to Letter WM 98-0090 Page 4 of 5 Attachment II WCNOC Response:
PIR 98-1896 documents that the Westinghouse 7300 Process Test Cabinets referenced above, and located in the Control Room, are in compliance with the procedure; however, PIR 98-1929 has been initiated to review the Inspectors concerns with respect to adequacy of procedure AP 21J-001.
Closure of Violation 50-482/9819-03 Inspection Report 98-14, Page 8,
Paragraph M8.1,
"(Closed) Violation 50-482/9719-03" stated:
" Inadvertent atmospheric relief valve actuation.
The inspector verified the corrective actions described in the licensee's response letter, dated December 23, 1997, to be reasonable but not complete in that the letter identified a contributing c :.s e, but described no corresponding corrective actions.
One contributing cause was that there were missed opportunities to provide more specific direction, to confirm what was misunderstood, or to call " time-out."
A quality evaluations individual identified the error prior to the inadvertent atmospheric relief valve actuation, but raised the question with the planner rather than questioning the worker or calling " time-out."
The inspector discussed this matter with the acting performance improvement and assessment manager who indicated that this issue has been discussed in detail with the quality evaluator.
In addition, the expectation for any person in performance improvement and assessment to call " time-out" when they identify an error or problem in the field has been reinforced with everyone in the group."
WCNOC Response:
Investigations associated with PIR 97-2959 reviewed whether the Quality Evaluations auditor could have prevented the inadvertent atmospheric relief valve actuation.
This review concluded that, at no time during this brief incident did the auditor have an opportunity to intercede to keep the worker from turning the incorrect valve.
Because the Quality Evaluation auditor's involvement was not pertinent to the root cause and corrctive actions, the information noted by the Resident Inspector in his closure of this violation, was not included in the response to Notice of Violation 9719-03.
Meteorological Tower Inspection Report 98-14, Page five, " Observations and Findings" stated:
"The inspector also noted numerous instances where the meteorological tower was inoperable and that many of these occurrences coincided with severe weather at the plant site.
During discussions with the engineer assigned to review Performance Improvement Request 98-1919, the engineer said that the review would include an historical review of the meteorological tower's instrumentation performance compared with the Updated Safety Analysis Report description, leading to an evaluation of whether the meteorological tower design is adequate to fulfill the Updated Safety Analysis Report description.
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Attachment II to Letter WM 98-0090
- Page 5 of 5 Attachment II
, CNOC's Response:
W WCNOC needs to clarify our intended actions.
The review of PIR 98-1919 will include a historical review of the meteorological tower's wind speed instrumentation performance, compared with the Updated Safety Analysis Report description, leading to an evaluation of whether the meteorological tower wind speed design is adequate to fulfill the Updated Safety Analysis Report description.
This clarification was discussed with the Resident Inspectors and was also noted at the Inspection exit meeting, l
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Attachment III to Letter WM 98-0090 Page 1 of 1 Attachment III LIST OF COMMITMENTS The following table identifies those actions committed to by Wolf Creek Nuclear Operating Corporation (WCNOC) in this document.
Any other statements in this submittal are provided for information purposes and are not considered to be commitments.
Please direct questions regarding these commitments to Mr.
Michael J.
Angus, Manager Licensing and Corrective Action at Wolf Creek Generating Station, (316) 364-8831, extension 4077 COMMITMENTS PIR 98-1929 has been initiated by WCNOC Maintenance to provide review, assessment, and evaluation of the definition and control of
" stable" versus " unstable" equipment, the approval processes for storage areas, and the storage time limits for temporary equipment.
PIR 98-1929 has been initiated to review the Inspectors concerns with
)
respect to adequacy of procedure AP 21J-001.
The review of PIR 98-1919 will include a historical review of the meteorological tower's wind speed instrumentation performance, compared with the Updated Safety Analysis Report description, leading to an evaluation of whether the meteorological tower wind speed design is adequate to fulfill the Updated Safety Analysis Report description.
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