ML20244C744
| ML20244C744 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 04/13/1989 |
| From: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| WM-89-0107, WM-89-107, NUDOCS 8904200395 | |
| Download: ML20244C744 (4) | |
Text
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.g W6LF CREEK NUCLEAR OPERATING CORPORATION 9 art D. Withers President and Chief ExecutiveOfficer April 13, 1989 NM 89-0107 U. S. Nuclear Regulatory Cmmission ATIN: Document Control Desk I
Mail Station F1-137 Washington, D. C. 20555-Referencet letter dated March 15, 1989 finn L. J. Callan, NRC, to B. D. Withers, NCNOC
Subject:
Docket No. 50-482: Response to Violation 482/8907-01 and 02 Gentlenen:
Attachet. is a detailed response to violations 482/8907-01 and 02 which were documented in the Reference.
Violation 482/8907-01 involved the failure to provide a written safety evaluation for a tenporary modification and vin 3ation 482/8907-02 involved the failure of the Plant _ Safety Review Comtittee (PSRC) to meet to review the safety evaluations for two tmmmy modifications prior to implementation.
1 If you have any questions concerning this matter, please contact ne or Mr. O. L. Maynard of my staff.,
very truly yours, Dart D. Withers President and Chief Executive Officer f
EW/jad i
Attachment B. L. Bartlett (NRC), w/a cc:
D. D. Chamberlain (NRC), w/a L
R. D. Martin (NRC), w/a D. V. Pickett -(NRC), w/a 8904200395 890413 l
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PDR ADOCK 05000482 Q
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P.O. Box 411 / Burlington, KS 66839 / Phone: (316) 364-8831 l
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I An Equa! Opportunity Empbyer MT/HC/ VET l1
i Attachnent to NM 89-0107 Page 1 of 3 violation (482/8907-01): Failure to Provide a Written Safety Evaluation For a Temporary Modification Findinc:
Paragraph (b)(1) of 10 CFR 50.59,.@s that the license shall maintain records of changes in the facility made pursuant to 10 CFR 50.59.
'Ihe records nust include a written safety evaluation which provides the basis for the detennination that the change does not involve an unreviewed safety question.
Contrary to the above, on November 11, 1988, the licensee installed a temrary jumper across Cell 10 of Station Battery NK12 and no written safety evaluation was provided.
The battery cell was jumpered at the time of the inspection.
The tmmrary jumper resulted in a change which reduced the tested Mttery capacity and inpacted the continuous alarm systen associated with the Mttery, which is described in Section 8.3.2.2 of the USAR.
Reason Far Violation:
The mason for the violation was a difference of opinion between NCNOC personnel and the NRC inspector on what constitutes a change in the facility as described in the Updated Safety Analysis Report (USAR).
During the 10 CFR 50.59 screening review performed by Results Engineering personnel, it was determined "that the temmnj modification which installed a temporary jumper across Cell 10 of Station Battery NK12 did not result in
- t. change to the facility or procedures as described in the Updated Safety Analysis Report (USAR).
This determination was based on the USAR not explicitly describing the number of cells in the battery, even though, USAR Figure 8.3-6 identifies Mttery NK12 as having a battery capacity of 900 Amp-Hrs.
Additionally, the tanporary modification did not impact the continuous alarm systen associated with the battery.
Therefore, the screening review resulted in an interpretation that a written safety evaluation was not required for this temmry modification.
Corrective Steps Which Have Been Taken And Results Achieved A written safety evaluation (89-SE-021) was performed on the temporary modification with no unreviewed safety question being identified.
The safety evaluation has been reviewed by the Plant Safety Review Carmittee.
Corrective Steps Which Will Be Taken To Avoid Further Violations:
A revision to Procedure ADM 01-022,
" Authorization of Changes, Tests, and Experiments (10 CFR 50.59)" was implemented to clarify when a written safety evaluation should be initiated when the USAR description is general in nature and the change can not be easily determined to affect the 10 CFR 50.59 Section (a)(1) criteria.
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f-5ttachment to W 89-0107 L
l' age 2 of 3 Other WOC procMures will be reviewed and revised as app.vgiate to incorporate the above conservative approach.
Date When Full Cmpliance Wil) Be Achieved:
The review and revision, as appuplate, of proceduras will be cmpleted on or before Septmber 15, 1989.
Violation (482/8907-02): Failure of the Plant Safety Review Ccmnittee (PSRC) to Meet to Review the Safety Evaluations For Two Tmporary Modifications Prior to Implementation Finiing:
Technical Specification 6.5.1 requires that a quorum of PSRC Kuui;m.B shall meet as convenal by the PSRC Chairman to advise the plant manager on all 1
matters related to nuclear safety.
Technical Specification 6.5.1.6.d requires that the PSRC shall be responsible for the review of all safety evaluations perfnr mi under the provision of Section 50.59(a)(1) of 10 CFR 50, for changes to the facility.
Contrary to the above, the licensee made two changes to the facility, 1
mnporary Modification (DO) 86-65-GK (86-SE-87) installed on June 20, 1986,
' and Tto 87-006-BB (87-SE-003) installed on November 01, 1987, without the benefit of a meeting by a quorum of PSRC members convened by the PSRC chairman.
Rather, the review of the two dos and associated safety evaluations was conducted utilizirg a " serial review" sheet (walk around and telephone calls) by mer.hars of the PSRC, and the PSRC chairman prior to the installation of the E.
Reason For Violation:
The Plant Safety Review Ccmnittee has previously performed reviews of the itms required by Technical Specification 6.5.1.7(a) utilizing a quorum of the members, through a " serial review",
either by walk around or via telephone.
It was believed that this method of review, and approval or disapproval, mat the regulatory requirements and intent of the 'Lbchnical Specifications.
Technical Specification 6.5.1.7(a) states:
"The PSRC challs Reconnend in writing to the Plant Manager approval or disapproval of it ms considered under specification 6.5.1.6(a) through d and m above,".
Re-evaluation of this criteria has identified that a serial review may not now neet the intent of this Technical Specification.
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-Attachnent'to NM 89-0107--
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' Corrective Steps Which Have Been Taken And Results Achieved:
As'a result'of the re-evaluation of the Technical Specifications,.the serial review process perfonned by the PSRC has been elbninated. -
Administrative procedua AEM 01-002, Revision 20, '" Plant Safety Review l
Cmmittee",. has been revised to state; "A.:aseting does not-require the-l physical presence of the quorum at one location.
It nay.be performed by a
- Conference Call anong a qucrum." Additionally, the procedure now states;
" Safety Evaluations should not normally be Conference Call Reviewed. During nonnal working hours the PSRC should cmvene in a special meeting to review' as : a ccanittee a Safety Evaluaticn.. Ccnference Call Reviews peu.fouimmi outside of nonnal' working' hours should include, when available, a quorum of
- related technical expertise, i e.,. Manager NPE Wolf Creek for temp mods;,and the Cognizant Manager. Additionally, the SE should be subsequently reviewed at the next regularly scheduled PSRC meeting by the cmmittee."
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Corrective Steps Which Will Be Taken To Avoid Further Violations:-
Ihe abovo. corrective steps will provide for the aan.vg late review by the PSRC and will avoid further violations.
lq Date When Full Cmoliance Will Be Achieved:
l Full cmpliance has been achieved.
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