ML20246M123
| ML20246M123 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 05/10/1989 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| References | |
| NUDOCS 8905190049 | |
| Download: ML20246M123 (2) | |
See also: IR 05000482/1989007
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MAY l 01989 -
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In Reply Refer To:
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. Docket:
STN 50-482/89-07
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Wolf Creek Nuclear Operating Corporation
- ATTN: Bart D. Withers
President and Chief Executive Officer
P.O. Box 411
Burlington, Kansas 66839
Gentlemen:
Thank you for your letter of April 13, 1989, in response to our letter and the.
- attached Notice of Violation dated March 15, 1989. As a result of our review
and the telephone conversation with Mr. Otto Maynard and other members of
your staff on April 26, and May 4,1989, we understand that you have revised
your position concerning the reason for Violation 482/8907-01'and that now you
agree that the temporary modification did impact the continuous alarm system
associated with the battery.
We request that you provide the following additional information:
1.
Instructions, guidance, and/or training that will be provided to
individuals that prepare and review safety evaluations and report
responses to assure that they understand the revised procedure
(ADM 01-022) and other measures you have taken to prevent recurrence
of this type of issue.
2.
The results of the reevaluation of the Nuclear Safety Evaluation
(S.E. No. 89-SE-921) considering the effects of the decreased voltage
of the battery bank with a cell jumpered as it is being discharged
under design accident conditions.
Please provide the supplemental information within 30 days of the date of this
, letter.
Sincerely,
Original Signed By
L J. CaUan
L. J. Callan, Director
Division of Reactor Projects
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Wolf Creek Nuclear Operating
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Wolf Creek Nuclear Operating Corporation
ATTN: Otto Maynard, Manager
-.- .of Licensing
P.O. Box 411
Burlington, Kansas 66839
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Wolf Creek Nuclear Operating Corporation
ATTN: Gary Boyer, Plant Manager
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P.O. Box-411
Burlington, Kansas 66839
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Kansas Corporation Comission
ATTN: . Robert D. Elliott, Chief Engineer
Fourth-Floor Docking State Office Building.
Topeka, Kansas 66612-1571
Kansas Radiation Control Program Director
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bec to DMB (IE01)
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'R. D. Martin, RA
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R. DeFayette, RIII
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SRI..Callaway, RIII-
MIS System
RSTS Operator
Project Engineer (DRP/D)
Lisa Shea, RM/ALF
J. E. Gagliardo
D. V. Pickett, NRR Project Manager (MS:
13-D-18)
D. R. Hunter
G. Sanborn
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W$LF CREEK
NUCLEAR OPERATING CORPORATION
Bart D. Withers
President and
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Chief Executive Omcor
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April 13, 19
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NM 89-0107
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U. S. Nuclear Regulatory Cmmission
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ATIN: Document Control Desk
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Mail Station Pl-137
Washington, D. C. 20555
Reference: letter dated March 15, 1989 from L. J. Callan, NRC,
to B. D. Withers, NCIOC
Subject:
Docket No. 50-482: Response to Violation 482/8907-01
and 02
G3ntimen:
Attached is a detailed response to violations 482/8907-01 and 02 which were
docunented in the Reference.
Violation 482/8907-01 involved the failure to
provide a written safety evaluation for a temmmry modification and
violation 482/8907-02 involved the failure of the ' Plant Safety Review
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Comittee (PSRC) to meet to review the safety evaluations for two temmm_ry
modifications prior to implsentation.
If you have any questions concerning this natter,
please contact ne or
Mr. O. L. Maynard of my staff.
Very truly yours,
,
Bart D. Withers
President and
Chief Executive Officer
BDN/jad
Attaciment
cc:
B. L. Bartlett (NRC), w/a
D. D. Chamberlain (NRC), w/a
R. D. Martin (NRC), w/a
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D. V. Pickett (NRC), w/a
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PO. Box 411/ Burhngton. KS 66839 / Phone: (316) 364-8831
An Equal Opportunity Empivyer M F/HC/ VET
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Attachment to NM 89-0107
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Page 1 of 3
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Violation (482/8907-01): Failure to Provide a Written Safety Evaluaticn
For a Teporary Modification
Findina:
Paragraph (b)(1) of 10 CER 50.59, requires that the licensee shall maintain
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records of changes in the facility made pursuant to 10 CPR 50.59.
The
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records nust incitrie a written safety evaluation which provides the basis
for the determination that the change does not involve an unreviewed safety
question.
Contrary to the above,
on Nov m ber 11,
1988, the licensee installed a
tanmrary jumper across Cell 10 of Station Battery NK12 and no written
safety evaluation was provided.
The battery cell was jtuuruul at the ti2ne
of the inspection.
The tanmrary jumper resulted in a change which reduced.
the tested battery capacity and inpacted the continuous alarm system
associated with the battery, which is described in Section 8.3.2.2 of the
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USAR.
Reason For Violation:
The reason for the violation was a difference of opinion between WCtOC
personnel and the NRC inspector on what constitutes a change in the facility
as described in the Updated Safety Analysis Report (USAR).
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During the 10 CFR 50.59 scmening review perfonned by Results Engineering
personnel, it was determinai"that the tanmmry modification which installed
a t m porary jumper across Cell 10 of Station Battery NK12 did not result in
a change to the facility or procedures as described in the Updated Safety
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Analysis Report (USAR).
This determination was based on the USAR not
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explicitly describing the number of cells in the battery, even though, USAR
Figure 8.3-6 identifies battery NK12 as having a battery capacity of 900
Amp-Hrs.
Mditionally, the temporary modification did not impact the
continuous alann systan associated with the battery.
Therefore, the
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screening review resulted in an interpretation that a written safety
evaluation was not required for this tunmrary 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 Ccumittee.
, 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 detennined to affect the 10 CFR 50.59 Section (a)(i) criteria.
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At'tachnent to NM 89-0107
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Other NCNOC p uceslures will be reviewed and revised as agu.vgiate to
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incw.au. ate the ab:me conservative approach.
Date When Full Catoliance Will Be Achieved:
The review and revision, as a u.vplate, . of Mcanes will be coupleted on
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or before Septaber 15, 1989.
Violation (482/8907-02): Failure of the Plant Safety Review CL2mtittee
(PSRC) to Meet to Review the Safety Evaluaticms
For 'IWo Tatoorary Modifications Prior to
Inolementaticn
Findina:
Technical Specification 6.5.1 requires that a quorum of PSRC Inmi;ers shall
meet as convened by the PSRC Chaire n to advise the plant snager on all
m tters 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 performed under the provision of Section 50.59(a)(1) of 10 CFR 50, for changes to the facility.
Contrary to the above, the licensee mde two changes to the facility,
'Ibuporary Modification (TO) 86-65-GK (86-SE-87) installed on June 20, 1986,
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and 90 87-006-BB (87-SE-003) installed on Novenber 01, 1987, without the
benefit of a meeting by a quorum of PSRC rmW convened by the PSRC
chainnan.
Rather, the review of the two nos and associated safety
evaluations was conducted utilizing a " serial review" sheet (walk around and
telephone calls) by nanbers of the PSRC, and the PSRC chairmn prior to the
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installation of the 2 0.
Reason For Violation:
The Plant Safety Review Ccumittee has previously perfoured reviews of the
itens required by Technical Specification 6.5.1.7(a) utilizing a quorum of
the md;ces ,
through a " serial review",
either by walk around or via
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telephone.
It was believed that this method of review,
and approval or
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disapproval,
met the regulatory requirements and intent of the Technical
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Specifications.
'Dachnical Specification 6.5.1.7(a) states:
"The PSRC shall:
Reccmtend in
writing to the Plant Manager approval or disapproval of iters considered
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under specification 6.5.1.6(a) through d and m above,".
Re-evaluation of
this criteria has identified that a serial review my not now meet the
intent of this 'Itchnical Specification.
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AktbchmenttoWM 89-0'107
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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
ruview process performed by the PSRC has been eliminated.
Administrative procedure ADM 01-002,
Revision 20,
" Plant Safety Review
Cm mittee", has been revised to state;
"A meeting does not require the
physical presence of the quorum at one location.
It may be performed by a
Conference Call among.a quorum." Additionally, the procedure now states;
" Safety Evaluations should not normally be Conference Call Reviewed. During
normal working hours the PSRC should ccnvene in a special meeting to. review
as a cm mittee a safety Evaluation.
Conference Call Reviews performed
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 conmittee."
Corrective Steps Which Will Be Taken To Avoid Further Violations:
The above corrective steps will provide for the appropriate review by the
PSRC and will avoid further violations;
Date When Full Canpliance Will Be Achieved:
Full compliance has been achieved.
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