ML20247C403

Responds to NRC Re Violations Noted in Insp Rept 50-482/89-08.Corrective Actions:Radiation Surveys of Rooms 1128 & 1129 Conducted on 890504.Highest Dose Measured in Rooms Was 16 Mrem/H

ML20247C403
Person / Time
Site:	Wolf Creek
Issue date:	05/19/1989
From:	Withers B WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
WM-89-0144, WM-89-144, NUDOCS 8905240454
Download: ML20247C403 (4)

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W4) LF NUCLEAR CREEKOPERATING Bart D. Withers Presidern end Cheel Executive Officer May 15, 1989 WM 89-0144 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station PI-137 Washington, D. C. 20555 Ref e rer.ce : Letter dated April 13, 1989 from L. J. Callan, NRC,

o B. D. Withers, WCNOC Subj ect : Docket No. 50-482: Response to Violation 482/0908-01 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 482/8908-02 involved the failure ta train operators in plant modifications.

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

Very truly yours, u

Bart D. Withers President and Chief Executive Officer BDW/j ad Attachment ec: B. L. Bartlett (NRC), w/a E. J. Holler (NRC), w/a p/ C R. D. Martin (NRC), w/a D. V. Pickett (NRC), w/a /jjfd I d I 89052404D4 spct,19 j?

DR ADOCK 0500

((. F L\

P.O. Box 411/ Burhngton, KS 66839 / Phone: (316) 364-8831 An Equal Opportunity Ernployer M'F/HCVET

. Attachment to WM 89-0144

- Page 1 of 3 Violation (482/8908-01): Inadequatg, Procedures Finding:

Technical Specification 6.8.1 requires that written procedures shall be established, implemented, and maintained covering activity recommended in Appendix A of Reguitory Guide 1.33, Revision 2, February 1978. The Regulatory Guide requires, in part, that there be procedures covering the control of modification work for the plant fire protection program.

Procedure KGP-1131, Revision 6, " Plant Modification Process," requires that a fire hazard analysis be conducted for modifications 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 from 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 performed to determine the amount of radioactive material required to be contained within the specified amount of combustible material in Rooms 1128 and 1129 necessary to exceed the 10 CFR 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 in those areas would result in extremely high dose rates (>1000 mrem /hr) necessary to exceed 10 CFR Parts 20 and 100 limits.

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

Corrective Steps Which Will Be Taken To Avoid Further Violations:

j Radiation Farveys are routinely performed in Rooms 1128 and 1129. A letter of instruction has been issued to Health Physics 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 Rooms 1128 and 1129. This is in addition to the previously established limits for quantities of combustible material.

Material 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.

, Attachment to WM 89-0144

., 'Page 2 of 3 Nuclear Plant Engineering procedere KPN-D-316, " Fire Protection Review" will be revised to ensure that during performance of design modifications, the-engineering review addresses significant increeses in the amount of radioactive material that can be released in the event of a fire.

Date When Full Compliance Will Be Achieved:

Full compliance will be achieved by June 16, 1989 with the revision to procedure KPN-D-316.

Violation (482/8908-02): Failure to Train Operators in Plant Modifications Finding: t 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. Flant Modification Request 02427, concerning emergency 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; (PMR 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 NB bus, whenever normal breaker reclosure was prevented by the seal-in circuit for the diesel generator output breaker anti pump logic. This specific ope t ator action remained ,

valid for circuit breaker reclosure following PMR 2427 implementation which j now allows 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 requirud.

Corrective Steps Which have Been Taken And Results Achieved: i Upon notification that all licensed operators required documented immediate j training upon facility design change implementation, operations essential reading 074 was issued. Operations essential recling must be completed prior to a licensed operator assuming their licensed duties.

The change made as a result of PMR 2427 was placed in the requalification training program following the implementation of PMR 2427. All licensed operators have completed this requalification training which included the specifics on the diesel generator circuit breaker modification.

, , Attachment to WM 89-0144

. . Page 3 of'3 Corrective Steps Which Will Ea Taken To Avoid Further Violations:

Administrative pr9cedure ADM 01-042, " Plant Modification Request Implementation", is bding revised to clarify when immediate training is required prior to system restoration. Operations esseatial reading (or other appropriate methods) will previde documented evidence that a licensed .

operator is cognizant ef' system changet prior to assuming licensed duties. l Date When Full Compliance Will Be Achieved:

Full. compliance will be achieved by July 1, 1989.

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