ML20248E688
| ML20248E688 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 05/29/1998 |
| From: | Maynard O WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-482-98-07, 50-482-98-7, WO-98-0048, WO-98-48, NUDOCS 9806030411 | |
| Download: ML20248E688 (5) | |
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W$LF CREEK NUCLEAR OPERATING CORPORATION Otto L Maynard Prudent and Chief Executive Officer MAY 2 91998 WO 98-0048 i
U. S.
Nuclear Regulatory Commission ATTN:
Document Control Desk Mail Station P1-137 Washington, D. C.
20555
Reference:
Letter dated April 30, 1998, from Blaine Murray, NRC, to O.
L. Maynard, WCNOC
Subject:
Docket No. 50-482:
Response to Inspection Followup Item 50-482/9807-01.
Gentlemen:
This letter transmits Wolf Creek Nuclear Operating Corporation's (WCMOC) response to Inspection Followup Item (I FI) 50-482/9807-01.
IFI 9807-01 identified a performance weakness involving one crew that failed to properly assess plant conditions to permit classification of a general emergency.
This occurred during the use of the simulator for the emergency preparedness inspection. WCNOC's response to this IFI is provided in Attachment I.
Attachment I also contains WCNOC's response to four additional items discussed in the inspection report:
- 1) Three self-contained breathing atparatus (SCBA) cylinders had low air pressure, 2) A Shift Supervisor did not know the spare air cylinder storage locations, 3) Silver-zeolite cartridges were found with no shelf-life expiration date, and 4) WCNOC does not perform SCBA fit testing.
If you have any questions regarding this response, please contact me at (316) 364-8831, extension 4000, or Mr. Michael J. Angus at extention 4077 Very truly yours,
.b M
Grto L. Maynard OLM/rir Attachment f
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W.
D.
Johnson (NRC), w/a E.
W.
Merschoff (NRC), w/a
/jJ J.
F. Ringwald (NRC), w/a K. M. Thomas (NRC), w/a
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9906030411 900529 j
PDR ADOCK 05000482 0
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PO. Box 411/ Burhngton, KS 66839 / Phone:(316) 364-8831 An Equal Opporttray Employer M/F/HCNET
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Attachment I to WO 98-0048 Ppge 1 of 4 Response to Inspection Report 98-07 Performance Weakness / Inspector Followup Item 9807-01 The cover letter on Inspection Report 98-07 identifies the following excerpt as a " performance weakness," and on page 7 of the Enclosure to the Inspection Peport, the excerpt is identified as an inspection followup item:
"Because this [ operating) crew did not declare a general emergency, key elements of the emergency plan associated with the general emergency (notification of offsite agencies and protective action recommendations) were not demonstrated.
10 CFR Part 50, Appendix E.IV.F.2.g, requires that deficiencies or weaknesses identified during drills or exercises shall be corrected.
The review of measures to be taken by the licensee was identified as an inspection followup item (I FI 50-482/9807-01)."
The inspection report states on page 8 that the second crew declared the general emergency but exceeded the goal of 15 minutes to assess the plant condition to make the declaration.
The declaration took 18 minutes, three minutes longer than the goal provided in NRC Emergency Preparedness Position No.
2.
The inspectors acknowledged that the 3 extra minutes delay would not have significantly affected the protective action recommendation process, and that had the performance of the first crew not beca considered, this issue would likely have only been a discussion item with the licensee.
However, the inspectors considered that the delay was the result of the second crew having trouble assessing plant conditions.
The inspectors pointed out that there may have been a common factor associated with assessing plant conditions for both crews.
Response to IFI 9807-01 WCNOC recognizes that during the Emergency Preparedness inspection of March 30 through April 2,
- 1998, the NRC observed that one crew had difficulty determining the presence of a 2000 scfm leak in the Containment boundary.
The Containment pressure dropped approximately three psig while Containment temperature continued to increase.
The crew considered the pressure trend to be due to the cooling effect of the Containment coolers.
This resulted in the crew not declaring a general emergency classification for the scenario.
Incediately af ter the completion of the scenario, the crew critique discussed the Containment pressure response and cooler operation.
The crew then recognized that the only way the Containment coolers can decrease pressure is to decrease temperature.
The inspectors observed two crews perform the scenario on the simulator.
The first operating crew observed by the inspectors misdiagnosed the Containment leak.
The second crew correctly assessed plant conditions, but took 18 minutes to declare the general emergency.
Inspection Report 98-07 states that there may have been a common factor associated with assecsing plant conditions based on the second crew taking 18 minutes to declare a general emergency.
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l WCNOC does not believe that there is a common factor between the performance of the first and second crew.
The same training scenario was used on nine operating crews during requalification cycle 98-3.
Similar to the second crew, the other crews performing the same scenario correctly assessed plant conditions, correctly characterized all applicable Emergency Action Levels, and met WCNOC's expectations for timeliness.
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I Attachment I to WO 98-0048 P, age 2 of 4 WCNOC considers the failure to identify the Containment conditions to be a training issue for the crew involved.
WCNOC does not. agree that the three minutes used beyond the NRC's Emergency Preparedness Position No. 2 goal of 15 minutes is indicative of a weakness in assessing plant conditions and should not be associated with the first crew that misdiagnosed plant conditions.
As stated at the exit meeting, WCNOC's position is that although timeliness is important, a correct and accurate declaration is paramount during emergency conditions.
The second crew met these expectations and appropriately diagnosed the event in a timely manner.
Corrective Actions In response to the one crew that misdiagnosed the Containment leak, WCNOC has added training on parameters and trends that should be used to determine if a breach of Containment exists to requalification cycle 98-4.
Requalification cycle 98-4 will be completed by July 1, 1998.
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Attachment I to WO 98-0048 P, age 3 of 4 Additional Information Low Pressure in SCBA Air Cylinders During the inspection, one Self Contained Breathing Apparatus (SCBA) cylinder in the Control Room Emergency Planning storage area was found to be below the acceptable pressure range.
In accordance with AI 10-001,
" Fire Brigade Monthly Inventory," these cylinders are checked on a monthly basis.
The cylinder in question was last checked on March 3, 1998, and was found to be within the acceptable range.
On March 30, 1998, the cylinder was found to be out of range.
Investigation determined that the valve was fully closed.
The cylinder was replaced with a fully charged cylinder, and the pressure gauge monitored for five days at the low pressure and no further decrease in pressure occurred.
The cylinder was then recharged to full operating pressure.
It was noted that the pressure dropped in approximately three days to an unacceptable level as found on March 30, 1998.
This indicated that a high pressure leak in the valve was present.
The valve was dismantled and inspected.
A sealing o-ring was found to have a small tear on the seating side.
The o-ring was replaced, and the cylinder was charged to full operational pressure.
The cylinder now appears to be holding the required amount of air.
This cylinder has been in use for one and half years and had shown no previous air loss.
Two additional fire brigade cylinders were identified as indicating questionable pressures.
The two cylinders, located in the fire brigade storage area, were known to be approaching the lower acceptance level and were being monitored.
They were scheduled to be replaced or refilled on March 31, 1998.
When these two cylinders were replaced, the pressure indicator was found to be in the middle of the gauge between 3000 and 4000 psi, which is the normal change-out range.
The cylinders were refilled and no leaks were identified.
The cylinders have since maintained their pressure.
The SCBA vender was contacted for assistance, but could not identify any additional causes for the pressure decreases in the cylinders.
The fire brigade SCBAs were purchased three years ago and the Emergency Planning SCBA was purchased one and one half years ago.
This was the first time that pressure problems have occurred.
The maintenance record program and Performance Improvement Request (PIR) program will track any deviations in air cylinder pressures for potential continuing trends.
Location of Replacement Air Cylinders The inspectors noted a concern with a Shift Supervisor's familiarity with spare air cylinder locations.
An e-mail was sent to each Shift Supervisor on April 3,
1998, explaining the location of spare air cylinders.
In addition, the SCBA lesson plan for fire brigade and non-fire brigade use was reviewed and updated identifying the storage areas of spare air cylinders.
Silver Zeolite Cartridge Storage l
Inspection activities indicated that the shelf life of the sealed silver zeolite and charcoal cartridges used in Emergency Planning may have expired.
WCNOC personnel further investigated this issue, and produced a letter dated November 2,
1988, from the vendor stating that the cartridges purchased by WCNOC
"...have indefinite shelf life."
Based on information from the inspector, WCNOC learned that the vendor now indicates that these cartridges have.a ten year shelf life limitation, as stated in a letter included with each new purchase of the silver zeolite cartridges.
Because WCNOC had not i
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Atta chsnent I to WO 98-0048 Ppge*4 of 4 made a recent purchase, personnel were unaware of this ten year storage expl. ration.
A review of WCNOC's stock revealed that a number of cartridges had exceeded the ten year shelf life.
This difference in storage conditions was resolved to the inspector's satisfaction through communication with the i
vendor.
1 The entire stock oi silver zeolite cartridges was examined.
Replacement cartridges were ordered from the vendor, then properly distributed.
During the shipping interim, a contingency plan for distribution of remaining silver zeolite cartridges throughout the ERO facilities was developed and l
communicated with the site Health Physics group. WCNOC personnel inspected l
Emergency Planning storage cabinets for other materials which might need expiration dates; no new items were identified.
In addition, WCNOC sent a message to alert the rest of the industry of the shelf life expiration information on silver zeolite cartridges.
SCBA Fit Testing The inspection report discusses that WCNOC does not currently perform fit testing for SCBAs.
Many guidelines exist for the use and testing of SCBAs.
WCNOC follows the OSHA requirements.
The current OSHA requirements do not include fit testing of SCBAs.
At the time of the inspection, WCNOC was in compliance with the current OSHA regulations for a Respiratory Protection Program (29 CFR 1910.134).
Prior to the NRC inspection, WCNOC was aware of the impending changes to the OSHA regulations.
The required revisions will be processed and the date to be in compliance with the new OSHA standard of October 5,
1998, will be met.
Necessary fit testing equipment has been purchased in preparation for meeting these new requirements.
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