ML20244B763

Responds to NRC Re Violations Noted in Insp Rept 50-482/89-08.Corrective Actions:Performed Calculation to Determine Amount of Radioactive Matl Required to Be Contained within Specified Amount of Combustible Matl

ML20244B763
Person / Time
Site:	Wolf Creek
Issue date:	05/15/1989
From:	Withers B WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20244B760	List: ML20244B759 ML20244B763
References
WM-89-0144, WM-89-144, NUDOCS 8906130271
Download: ML20244B763 (4)

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l W$LF CREEK NUCLEAR OPERATING CORPORATION Bart D Withers l President and Chief Executive Omco' May 15, 1989 L WM 89-0144 y U. S. Nuclear Regulatory Commission $I JJd ;

ATIN: Document Control Desk oi. ' . '.

Mail Station PI-13)  %

Washington, D. C. 20555 L ,. _ -'

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Reference:

Letter dated April 13, 1999 from L. J. Callan, NRC, to B. D. Withere. WCNOC Subj ect : Docket No. 50-482: Response to Violation 482/8908-01 and 02 Gentlemen:

Attached is Wolf Creek Nuclear Operating Corporation's response to violations 482/8908-01 and 02 which were documented in the Reference.

Violation 482/8908-01 involved inadequate procedures and violation 462/8908-02 involved the f ailure to train operators in plant modifications.

If you have atay questions concerning this matter, please contact me or Mr. O. L. Mayaard of my staff.

Very truly yours,

.,/

Bart D. Withers President and Chief Executive Officer BnW/jad 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 8906130271 690607

{DR ADOCK 05000482 PDC P.O. Box 411/ Durlington, KS 66839 / Phone (316) 364 8831 fhf An Eaual Oprxwtunity Empioyer M T!HC! VET

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, , Attachment to WM 89-0144 Page 1 of 3 Violation (482/8908-01): Inadequate Procedures Finding:

i Technical Specification 6.'8.1 requires that written proc-Jures shall be established, implemented, and maintained covering activity recommended in Appendix A of Reguitory Guide 1.33, Revision 2, Februcry 1978. The Regulatory Guide requires, in part, that there be procedures coveries the control of modification work for the plant fire protection program. )

Procedure KGP-1131, Revision 6, " Plant Modification Process," requires that  !

a fire hazard enalysis be conducted for modf.fications to minimize and control the release of radioactive material to the environment.

Contrary to the above, the fire hazards analyses for Plant Modification Request 2206, " Auxiliary Building Fire Detection System," did not include in its fire hazards analysis consideration of the radiation release potential f rom the combustion of large amounts of radioactive contaminated materials stored within the fire zones.

Reason For The Violation:

The reason for the violation is the lack of recognition by the Health Physics staff of the potential consequences of not limiting or accounting for the quantities of radioactive material as well as the amount of combustible radioactive contaminated material.

Corrective Steps Which Have Been Taken And Results Achieved:

$ A calculation was subsequently perforned to determine the amount of radioactive material required to be contained within the r,pecified amount of .

combustible material in Rooms 1128 and 1129 necessary to exceed the 10 CFR l Parts 20 and 100 limits if the Auxiliary Building Ventilation System filters were to become clogged with smoke. This calculation identified that the amount of radioactive material required is those areas would result in extremely high dose rates (>1000 mrem /hr) necessary to exceed 10 CFR P, arts 20 and 100 limite.

Radiation surveys were conducted in Rooms 1128 and 1129 on May 4,1989. The highest dose rate measured ir. Rooms 1128 and 1129 was 16 mrem per hour.

Corrective Steps Which Will Be Taken To Avoid Further Violations:

Radiation Survsfs are routinely performed in Rooms 1128 and 1129. A letter of instruction has been issued to Health Physico Supervisors and Technicians identifying an established limit of less than 100 mrem per hour (measured at approximately 18 inches from the source) for combustible radioactive contaminated material in Reams 1128 and 1129. This is in addition to the previcusly established limits for quantities of combustible material.

Mateiial with radiation levels in excess of this established limit is to be removed from these rooms. The 100 mrem per hour dose rate is more  ;

conservative than the dose rates determined by the calculation discussed above.

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Attachment to WM 89-0144 i

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Nuclear Plant Engineering procedure KPN-D-316 " Fire Protectior Re'esew" will j be revised to ensure that during performance of design modiff estions, the i engineering review addrerses significant increases in the amount of radioactive material that can be rel. eased in the event of a fire.

Date When Full Compliance Wil_(Be Achieved:

i Full compliance will be achieved by June 16, 1989 with the revision to I procedure KPN-Dr316. I Violation (482/8908-02): Failure to Train Operators in Plant Modifications h

I Finding The Code of Federal Regulations, 10 CFR Part 55.59, requires that licensed operators be cognizant of facility design changes.

Contrary to the above, information on a f acility change, Plant Modification Request 02427, concerning eme rgency diesel generator controls, was not provided to all licensed operators prior to returning the modified equipment to service.

Reason For The Violation:

The reason for this violation was the failure to provide immediate documented training to licensed operations personnel following a modification to the emergency diesel generator circuit breaker control circuitry; (PHR 2427).

Operations supervision issued a letter (OP 87-175) on November 25, 1987, to all licensed operators to ensure they were cognizant of the required actions necessary to reenergize a 4160 volt N3 bus, whenever normal breaker rcelosure was prevented by the seal-in circuit for the diesel generator output breaker anti pump logic This specific operator action remained valid for circuit breaker reclosure following PMR 2427 implementation which now alloys the control room operator to reclose the output breaker from the control room. Therefore it was not believed immediate training prior to system restoration was required.

Corrective Steps Whic.h Have Been Taken And Results Achieved:

Upon notification that all licensed operators required documented immediate training upon. facility design change implementation, operations essential reading 024 was issued. Operations essential reading must be ermpleted prior to a licensed operator assuming their licensed duties.

The change made as a result of PMR 2427 was placed in the requalifier. tion training program f ollowing the implementation of PMR 2427. All licensed operators have completed th!s requalification training which included the specifics on the diesel generator circuit breaker modification.

4 Attachrent tc WM 89-0144

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Corrective Steps Which Will Be Taken To Avoid further Violations:

Administrative procedure ADM 01-042, "Pl at't Modification Request  ;

laplementation", is being revised to clarify when immediate training is  :

required prior to system resi; oration. Opt:ratioyr essential reading (or 1 cther appropriate methods) will provide documented evidence that a licensed operator is cognizant of system changes prior to assuming licensed duties.

Date When Full CompliancS_ Mill Be Achieved:

Full compliance will be achieved by Jrsly 1, 1989.

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