IR 05000482/1997014: Difference between revisions

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{{Adams
{{Adams
| number = ML20217F197
| number = ML20198Q295
| issue date = 10/02/1997
| issue date = 11/06/1997
| title = Insp Rept 50-482/97-14 on 970810-0920.Violations Noted. Major Areas Inspected:Operations,Maint,Engineering & Plant Support
| title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-482/97-14 .Finds Reply Responsive to Concerns Raised in Nov. Will Review C/As During Future Insp
| author name =  
| author name = Johnson W
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| addressee name =  
| addressee name = Maynard O
| addressee affiliation =  
| addressee affiliation = WOLF CREEK NUCLEAR OPERATING CORP.
| docket = 05000482
| docket = 05000482
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-482-97-14, NUDOCS 9710070390
| document report number = 50-482-97-14, NUDOCS 9711120166
| package number = ML20217F190
| title reference date = 10-31-1997
| document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| page count = 19
| page count = 4
}}
}}


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ENCLOSURE 2 :
'4  AR LINoToN.TExA8 760114064 9 ' " * * ,v 140V - 61997 Otto L. Maynard, President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411
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U.S. NUCLEAR REGULATORY COMMISSION
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      ' REGION IV l
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Docket No.:  50-482 License No.:  NPF-42 -
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Report No.: 50-482/97 14 a-j-  Licensee:  Wolf Creek Nuclear Operating Corporation Facility:  Wolf Creek Generating Station    ,
Burlington, Kansas 60839 SUBJECT: NRC INSPECTION REPORT 50 482/97 14
;  Location:  1550 Oxen Lane,-NE 3~    Burlington, Kansas t
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Datesi  August '10 to' September 20,1997    !
f--  Inspectora:  J. F. Ringwala, Senior Resident inspector
!-    B.- A. Smalldridge, Resident inspector.
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I  Approved By:-  iWi D.' Johnt.on,' Chief, Reactor Projects Branch B i-i          !
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. ATTACHMENT: Supplementai information:
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==Dear Mr. Maynard:==
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Thank you for your letter of October 31,1997,in response to our letter and Notice of Violation dated October 2,1997. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the impicmontation of your
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: corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.
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Sincerely, w
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a    .D.Joh n, lef Project Branch B Division of Reactor Projects Docket No.: 50 482 License No.: NPF-42 cc:
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Chief Operating Officer Wolf Creek Nuclear Operating Corp.    /
P.O. Box 411      If 4 Burlington, Kansas G6839      I Jay Silberg, Esq.


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Shaw, Pittman, Potts & Trowbridge 2300 N Street, NW Washington, D.C. 20037 E


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Wolf Creek Nuclear    2 Operating Corporation
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; Supervisor Licensing Wolf Creek Nuclear Operating Corp.


EXECUTIVE SUMMARY Wolf Creek Generating Station NRC Inspection Report 50-482/97-14 l
P.O. Box 411 j Burlington, Kanses 66839 Chief Engineer
l Operat i ons
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The absence of management expectations and insufficient operator familiarity with the status of the auxiliary steam system prior to system startup resulted in an inadvertent steam release from the auxiliary steam system during system startup (Section 01.1).


* Operators responded promptly and appropriately to an inadvertent transfer of water from the volume control tank during a resin transfer (Section 01.2).
Utilities Division
; Kansas Corporation Commission i
1500 SW Arrowhead Rd.


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; Topeka, Kansas 66604-4027 i
Operators developed a good practice of using a stopwatch as a physical reminder to prompt them to remain focused on a positive reactivity addition evolution (Section 01.3).
;. Office of the Governor i
 
.9 tate of Kansas Topeka, Kansas 66612
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The shift supervisor made an appropriate decision to deny permission for plant personnel to be0i n radiography when evaluations to address the effect of the l   radiation on equipment had not been performed (Section 01.4).
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Attorney General Judicial Center l 301 S.W.10th 2nd Floor Topeka, Kansas 66012 1697 County Clerk Coffey County. Courthouse Burlington, Kansas 66839 1798 Vick L. Cooper, Chief Radiation Control Program Kansas Department of Health and Environment Bureau of Air and Radiation Forbes Field Building 283 Topeka, Kansas 66620 Mr. Frank Moussa Division of Emergency Preparedness 2800 SW Topeka Blvd Topeka, Kansas 66611 1287


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L  Wolf Creek Nuclear-  3-Operating Corporation     NOV - 61997 bec to DCD (IE01).
The licensee acted in a responsible manner after discovering that required surveillar'ces had not been performed on eight relay contacts as part of their review of testing in ri.iponse to NRC Generic Letter 96-01 (Section 01.5).


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bec distrib. by RIV:
The licensee implemented Technical Specification Amendment 108 in a manner that confused shift supervisors as they attempted to interpret Limiting Condition for Operation 3.6.3, following two valve failures (Section 03.1).
Regional Administrator  Resident inspector DRP Director  SRI (Callaway, RIV)
Branch Chief (DRP/B)  DRS PSB Project Engineer (DRP/B)  MIS System Branch Chief (DRP/TSS)  RIV File
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DOCUMENT NAME: R:\_WC\WC714AK.JFR
  - To receive copy of document, indicate in boa: "C" = Copy without enclosures "E" = Copy wth enclosures "N" = No copy RIV:PE:DPR/B  C:DRP/B DNGraves;dfp  WDJohnson[p(p
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11/b /97  11/ (f/97 ]
OFFICIAL RECORD COPY
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The Nuclear Safety Review Committee conducted an effective, candid, probing, and critical meeting. This demonstrated considerable improvement in the effectiveness of the committee in reinforcing nuclear safety values (Section 07.1).
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Wolf Creek Nuclear   -3-Operating Corporation    NOV - 61997


Maintenan::e
i M91EMil80M)
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j  bec distrib. by RIV:
The inspectors concluded that the good practice of posting protected train signs on personnel entrances to operable train equipment during train outages was not being consistently applied (Section M1.3).
1  Regionel Administrator  Resident inspector 3  DRP Director  SRI (Callaway, RIV)
i. Branch Chief (DRP/B)  DRS PSB Project Engineer (DRP/B)  MIS System Branch Chief (DRP/TSS)  RIV File
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DOCUMENT NAME: R:\_WC\WC714AK.JFR To receive copy of document. Indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:PE:DPR/B  C:DRP/B ,
DNGraves;dfy  WDJohnsorit$
11/b /97 - -' 11/ (f/97 J OFFIC:AL RECORD COPY t:nc53
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The inspector identified a minor typographical error in a work package that demonstrated insufficient attention to detail in the work package planning, review, and field use (Section M1.4).
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W@ NUCLEAR  LF CREEK      OPERATING Clay C Warren Chef Operstify Officer
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1    WO 97-0120 i  '
        , O hJ j'__    October 31, 1997 U. S. '' clear Regulatory Commission l  ATTN: Document Control Desk
:  Mail St.ation F1-137 Washington, D. C. 20555 Reference:  Letter dated October 2, 1997, from T. P. Gwynn, NRC, to 0. L. Maynard, WCNOC l  Subject:  Docket No. 50-482:  Response to Notice of Violations j      50-482/9714-01, 9714-03, and 9714-05
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!  Gentlemen i
j  This atter transmits Wolf Creek Nuclear Operating Corporation's          (WCNOC)
,  response to Notice of Violations 50-482/9714-01, 9714-03, and 9714-05.         Notice i
of Violation 9714-01 cites inef fective maintenance of a procedure to support l  implemertation of Technical Speification Amendment 108.        Notice of Violation l  9714-03 cites an exampie of a radiation worker failing to have the correct
;  dosimetry required by the Radiation Work Permit.      Notice of Violation 9714-05 j  addresses a failure to perform surveys of radiation levels in unrestricted and
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controlled areas.


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WCNOC's response to these violations is provided in the attachment.          If you have any questions regarding thir response, please contact me at ;316) 364-
The inspector concluded that a surveillance test on the emergency diesel generator load sequencer met the Technical Specification requirement. The inspector further concluded that the technicians demonstrated inadequate attention to detailin not
!  8831, extent.ien 4000, or Mr. Richard D. Flannigan at extension 4500, i
j          Very truly y    rs,
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b i          C1  C. Warren j  CCW/jad Attachment


l  cc; W, D. Johnson (NPC), w/a
!  E. W. Merschoff (NRC), w/a J. F. Ringwald (NRC), w/a
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h. M. Thomas (NRC), w/a
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identifying that the observed voltage polarity differed from that specified in the procedure and that procedure preparation was weak in that the voltage polarity could have been easily researched and was not (Section M1.5).
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P.O. Box 411/ Burlington, KS 66839 / Phone- (316) 3644831
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An Equal opportunity Employer M F HC. VET
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Enaineerina
At t echnont to WO 97-0120
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The inspectors concluded that the control room ventilation system was operable and that the material condition and associated documentation were adequate. The minor discrepancies noted demonstrated that the control room ventilation system received less attention than other safety systems the inspectors have reviewe (Section E2.1).
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Violation 50-482/9714-01:
  " Technical Specification 6.8.1.a requires, in part, that written
,  procederes be established, implemented, and maintained covering the I
applicable procedures recommended in Appendix A of Regulatory Guide I  1.33, Revision 2, February 1978.


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Regulatory Guida 1.33, Revision 2, February 1978, Section 3.f.,
The licensee responded promptly and appropriately to an increasing vibration trend on Centrifugal Charging Pump B (Section E2.2).
recommends, in part, that procedures be established for the operation of containment.


Plant Sunoort
Surveillance Procedure STS GP-007, "CTMT Penetration Isolation Verification," has been established in accordance with these requirements.
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The licensee failed to perform an evaluation of radiauon levels in the unrestricted aiea adjacent to the restricted area south of the radwaste building before moving a spent resin liner or to perform surveys in the same area during movement of the liner. The licensee attempted to restrict personnel access to the unrestricted area by assigning personnel inside the restricted area fence to control personnel access outside the fence (Section R1.1).


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Contrary to the above, on August 20, 1997, Procedure STS GP-007, "CTMT Fenatration Isolation Verification," was not effectively maintained in that the licensee implemented Technical Specification Amondment 108, which relocated a list of containment isolation valves from Technical Specification 3.6.3 to Procedure STS GP-007, without providing adequate guidance for how this procedure would subsequently be used to identify containment isolation valves covered by Technical Specification Limiting Condition for Operation 3.6.3."
The licensee identified that a radiation worker had entered the radiologically controlled area without the dosimetry required by the radiation work permit (Section R4.2).


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Reason for Violation:
The implementation of Technical Specification (T/S) Amendment 108 on August 19, 1997, resulted in the inability of the Control Room personnel to properly implement Technical Specification (T/S) 3.6.3).


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On August 28, 1997, Control Room personnel became concerned with the operability of valve BM HV-36 during the performance of procedure STS IC-616B, "SLV RLT TST K616 Safety Injection." This valve was identified in the Equipment out of Service Log as a T/S 4.0.5 failure. The Shift Supervisor (SS) reviewed the applicable system drawings, T/S Amendment 108, and the physical location of the valve (the first valve inside containment) and conservatively determined that valve BM HV-36 was a containment isolation valve. The SS instructed the valve be closed and tagged with Clearance Order 97-1047-BM until additional reviews could be completed on day shift.
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Report Detajls Summary of Plant Status The plant operated at essentially 100 percent power throughout the inspection period, l. Operations 01 Conduct of Operations 01.1 Auxiliary Steam System Startuo Inspection Scone (717071 The inspector reviewed the circumstances associated with the problem that the
. licensee encountered while starting up the auxiliary steam system, Observations and Findinas On August 14,1997, while warming up the auxiliary steam system, control room operators received reports that steam was emanating from several places in the radwaste building, auxiliary building, and condensate storage tank valve pit. After shutting down the auxiliary steam system, operators discovered open Procedure SYS FB-321 " Auxiliary Steam System Shutdown," Revision 8, in the open procedure book. Steps in this open procedure clearly indicated that operators had opened the steam drain valves and removed the drain caps for system draining, and these system openings were to be capped and closed prior to system restoratio The operator performing the system warmup had reviewed a closed copy of
, Procedure SYS FB-321, but had failed to check the open procedure book and,
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therefore, was unaware of the systern configuratio The licensee initiated Performance improvement Request (PIR) 97-2477 to address this concern. During the evaluation of this PIR, the licensee learned that they had no specific procedural guidance that required operators to review the open procedure book prior to initiating a procedure. The operations manager stated that this requirement would be added to licensee procedures. The inspector noted that NRC Inspection Report 50-482/96 09, Section 4.1, described a violation associated with another procedural coordination error where operators were not aware of the status of another open procedure when performing a surveillance piocedure that resulted in an overspeed trip of the auxiliary feedwater turbine, Conclusions The absence of management expectations and insufficient operator familiarity with the status of the auxiliary steam system prior to system startup resulted in an inadvertent steam release from the auxiliary steam system during system startu __ _ _ _ _ __ . _ _ _ ___ _ _
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    -2-s 01.2 Inadvertent Volume Control Tank Water loss Durina a Resin Transfer Inspection Scope (71707)
Day shift personnel subsequently reviewed Updated Safety Analysis Report Figure 6.2.4-1, and determined that valve BM HV-36 was not a containment isolation valve. Day shif t personnel then removed Clearance order 97-1047-BM.
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The inspector reviewed the circumstances associated with the inadvertent transfer of water from the volume control tank during a resin transfer evolutio Observations and Findinas i On August 14,1997, the primary reactor operator noted the volume control tank a levellowering during a resin transfer evolution. An immediate investigation revealed that Valve BG V8524A, chemical and volume control system mixed bed i Demineralizer A inlet, indicated closed, but in fact it was approximately one turn


open when the resin transfer evolution began. The auxiliary building nuclear station
Due to Control Room personnel questicns and concerns with compliance to T/S 3.6.3, Operations management decided that STS GP-007, "CTMT Fenetration Isolation Verification," was the governing procedure for iraplementation of T/S Amencment 108. This decision process occurred af ter T/S Amendment 108 was released for implementation.
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operator closed Valve BG V8524A, which stabilized the volume control tank level.


l Approximately 50 gallons of water was transferred out of the volume control tank.
The cause of this event is inadequate change management cf program implementation. Evaluation of this event disclosed examples of ineffective planning, communication, ownership, and implementation.


Prior to the evolution, an operator had performed a valve lineup which included I closing Valve BG V8524A. The valve appeared to be closed, but remained approxin'.ately one turn open. The cause of the improperly closed valve appeared to be a mechanical misadjustment of the valve actuatcr. The licensee initiated Level 11 PIR 97 2506 to determine the root cause and address corrective actions, Conclusions Operators responded promptly and appropriately to an inadvertent transfer of water
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. from the volume control tank during a resin transfe .3 Operator Practice to Manaae Reactivity
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! Insoection Scope (71707)
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The inspector observed operator activities during a reactivity manipulation, Observations and Findinas in August 1997, the inspector noted that an operator held a stopwatch while monitoring control panel indications. The inspector asked the operator what activity the stopwatch was timing. The operator replied that the operators on that crew decided to use a stopwatch as a means to prompt them to remain focused on the reactivity addition during reactor coolant system dilutions they performed using the boron thermal regeneration system demineralizer. The practice included their j personal expectation that they hold the stopwatch in their hand until they isolated the dilution flowpath, thus stopping the positive reactivity addition. The operators


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Attachman? 'o WO 97-0320
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Corrective Steps Taken and Results Achievedt Procedure STS GP-007, "CTMT Penetration Isolation Verification," was revised October 4, 1997, to clearly specif y which valves are cont a i nt.,ent isolation valves. Operations management has provided guidance to operating crews concerning the effects of Amendment IJB on cor.tainment ieolation valves.
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; said that they developed this idea after receiving training on industry reactivity mismanagement events and hearing their management's expectations regarding reactivity management.
l Corrective Steps That Will Be Takent Licensing will coordinate treetings to discuss the current license amendment )
requests which have been submitted, but not approved, as well as license amendment requests currently in process. These meetings will assure that apptcpriate ownership of each amendment and that implementation activities have been considered prior to receipt and implementation of the amendments.


, Conclusions
This is an interim measure to ensure amendments are properly implemented which will be effective until the procedure revision described below is completed.
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Operators developed a good practice of using a stopwatch as a physical reminder to prompt them to remain focused on a positive reactivity addition evolutio .4 Conservative Shift Suoervisor Decision Makina insoection Scope (71707)
Tha inspector observed the shift supervisor's activities related to a request for radiography, Observations and Findinas


On August 26,1997, a radiographer asked the shift supervisor for permission to ,
In addition, Procedure AP 268-001, " Revisions to the Operating License and/or Technical Specifications," will be revised to ensure tha following actions occur 1. 1.mendment ownership is established 2. Pre-submittal meetings are held to dis, cuss amendment implementation 3. Ownership is established for implementation activities 4. Post amendment receipt meetings are conducted to review pre-submittal decisions and ensure Wolf Creek is prepared to implement the amendment.
conduct radiography in the south electrical penetration room. The shift supervisor asked if transmitters in the room had been evaluated for the anticipated radiation levels during the radiography. Since these evaluations had not been performed, the shift supervisor denied the request to begin radiography until the evaluations were complete, Conclusions


The shift supervisor made an appropriate decision to deny permission for plant personnel to begin radiography when evaluations to address the effect of the radiation on equipment had not been performe .5 Response to a Missed Surveillance Insoection Scoce (71707)
This revision will be completed by January 31, 1996.
-TM inspector reviewed the licensee's actions following the discovery of three missed surveillance requirements during their review of testing in response to NRC Generic Letter 96-0 Observations and Findinas On September 4,1997, as a result of their NRC Generic Letter 96-01 review, licensee personnel determined that portions of the surveillance testing required by Technical Specification 4.8.1.1.2.g had not been performed on eight contacts. The licensee initiated a request for a Notification of Enforcement Discretion and prepared


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Date When Full Compliance Will Be Achievedt WC110C is currently in full compliance, i
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,  test procedures to accomplish the required testing. The licensee requested enforcement discretion because Technical Specification 4.8.1.1.2.g required that
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Attachmont to WO 97-0120
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i violation 50-482/9714-03:
  "10 CFR 20.1302(a) requires, in part, that the licer.see reake or cause to be made, surveys of radiation levels in unrestricted and controlled areas to demonstrate compliance with the dose limits for individu*l members of the public in paragraph 20.1301.


this testing be performed during shutdow On September 5,1997,'during a conference call with NRC personnel, the NRC j  Office of Nuclear Reactor Regulation granted a verbal Notice of Enforcement i  Discretion which was subsequently documented in Notice of Enforcement Discretion 97 06-013. The licensee completed all required testing on September 6, i  1997.' The licensee planned to submit a licensee event report to report the missed
Contrary to the above, on Septenber 16, 1997, the licensee moved a spent resin liner without first performing a survey of the radiation levels in the unrestricted area adjacent to the restricted area south of the radwaste building. A subsequent evaluatian estimated the dose rate in the unrestricted area well in excess of the limit of 10 CFR 20.1301."
!'  surveillance. The circumstances associated with the missed surveillance will be
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reviewed during the review of the licensee event repor Conclusions
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;  The licensee acted in a responsible manner after discovering that required i  survaillances had not been performed on eight relay contacts as part of their review l
of testing in response to NRC Generic Letter 96-01. Operations Procedures and Documentation
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03.1 Technical Soecification Amendment lmolementation
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j . Insoection Scoce (71707)
i  The inspector reviewed the licensee's implementation of Technical Specification l  Amendment 108.


I        i Observations and Findinas
Reason for Violation Wolf Creek Nuclear Operating Corporation (WCNOC) acknowledges and agrees that a violation of 10 CFR 20.1301 and 10 CFR 20.1302 occurred. However, a subsequent evaluation has shown that the dose rates identified in 10 CFR 20.1301 were not exceeded at the unrestricted area boundary. This clarification is necessary because a clear unoerstanding of the location of the unrestricte. **usdary and the radiologic.nl controlled area (RCA) boundary was not ade qua t el., communicated to the inspector. NRC Inspection Report 97-14 and Notice of Violatien 9714-03 reflect this misunderstanding. 1:ealth Physics personnel comtrunicated clarifying informaticn to the NRC Senior Resident Intpector on October 8, 1997 This event involved the transfer of a High Integrity Container (HIC) from a process shield to a shielded tranrport cask on September 16, 1997. During the transfer process the HIC was remcVed from one shielded area and transferred to another shielded area. It was * luring this evolution that the radiation levels increased in the RCA because the HIC was not shielded during the transfer process.
!  On August 21~ and 28,1997, the shift supervisors logged that, following two valve failures, they were not certain what specific actions were required by Technical
, Specification Limiting Condition for Operation 3.6,3. This condition occurred because the table listing the applicable valves had been removed from the Technical Specification during the implementation of Technical Specification Amendment 108.


l  The amendment specifically required the licensee to relocate the valve list into
For this evolution one Health Physics empivyee was placed at the southeast and southwest corners of the RCA to monitor the radiological conditions and halt any traffic along the access road adjacent to the south side of the Radwaste Building during the HIC movement evolution. Each Health Physics employee carried a survey meter and was qualified to operate the survey meter.
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  . administratively controlled licensee procedures.- The licensee did not create u new
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procedure for this list, instead, the licensee relied on Surveillance
. Procedure STS GP-007, "CTMT (Containment) Penetration Isolation Verification,"
l-  Revision 19, which contained a superset of the list that had been in the Technical
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Specifications. While the inspector concurred that it was appropriate for the licensee to consider the existing.superset list as the relocated table, it was inappropriate for management not to provide adequate guidance to operators on
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how to interpret Technical Specification 3.6.3 after implementing Amendment 108.


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However, since they were not Health Physics Technicians, they could use the
, survey meters for personal anformation only and were not allowed to parforra surveys. The radiation levels observed where the personnel were stationed was 1.5 mrem /hr. This was below the 2 mrem /hr. limit specified by 10 CFR 20.1301 and 20.1302. The Hcalth Dhysics employees halted one Security officer on foot, two Security of ficers cn bicycles and one truck during the approximately fif teen minute ew olutiers.


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10 CFR 20.1301 specifies that, "The total effective dose equivalent to 5 individual members of the public from the licensed operation does not exceed
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< 0.1 rem in a year," and "The cose in any unrestricted area from external sources does not exceed 0.002 rem in any one hour." Compliance with the dose limits are specified by 10 CFR 20.1302(a) as, "The 'icensee shall make or cause to be made, as appropriate, surveys of radiation levels to unrestricted and controlled areas...to demonstrate compliance with the dose limits for individual members of the public in 20.1301."


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  . The failure of the licensee's procedures to contain adequate guidance for operators to properly implement Technical Specification 3.6.3 af ter implementing Amendment 108 is a violation of Technical Specification 6.8.1.a.


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  (50-482/9714-01).


The shift supervisor's log dated August 21,1997, documented considerable
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research performed in at'empting to identify whether Valve AB LV0009 was a l-  containment isolation valve. The log entry also noted that additional work would be performed the next day aid that a PIR may need to be written to address the concern.- Since the shif t supervision did not initiate a PIR, the rigor provided by the
Attachment to WO 97-0120
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licensee's formal review process was not brought to bear on this issue. The .
Procedure AP 25A-001, " Radiation Protection Manual," step 4.34, defines the restricted area as bounded by the Security fence (protected area boundary).
inspector determined that this was a contributing factor to the ineffective immediate corrective actions, Conclusions The licensee implemented Technical Specification Amendment 108 in a manner that confused shift supervisors as they attempted to interpret Limiting Condition for Operation 3.6.3 following two valve failure Quality Assurance in Operations 07.1 Nuclear Safety Review Committee Meetino Insoection Scope (71707)
The inspector observed a portion of the regularly scheduled Nuclear Safety Review-Committee meeting, Observations and Findinos On August 19,1997, the Nuclear Safety Review Committee held a regular meeting to review recent plant issues and events. A poster listing Nuclear Safety Review -
Corm..ittee challenges hung on the wallin the room, and a list of Nuclear Safety Review Committee ground rules appeared on the back of each member's nhme sig ' These served to reinforce expectations for members and plant staff personnel. The committee received presentations from various managers consistent with the committee charter. These presentations not only provided the members with first
  . hand information of the areas reviewed, but also provided the managers with the nuclear safety values of the committee as they asked questions to probe the various aspects of the issue SevernI new members of the committee asked very insightful questions and were-not reluctant to probe the potentially negative aspects of issues. Other members of the committee adopted this practice as well, and the meeting as a whole was conducted in a manner that was considerably more probing than the inspector had
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The calculation for the RCA boundary dose rate previously provided to the resident inspector was understood by the NRC Resident Inspector as the unrestricted area boundary dose rate. A new calculation was performed using the protected area fence as the unrestricted area boundary and the result was 1.5 mrem /hr or 0.38 mrem for the 15 minute evolution. The nuw calculations demonstrate the unrestricted area boundary was maintained below the limits specified by 10 CFR 20.1301 and 1302, however, there were no surveys to demonstrate compliance as required by 10 CFR 20.1302(a) .
_ . .
AP 25A-200, " Access to Locked High or Very High Radiation Areas," step 4.3 defines a transient locked high radiation area as transfer of items that are
.
> 1 rem /hr at 12". These areas will not be posted during transfer as long as 3 Health Physics Technician is in direct surveillance of the areat step 6.6 discusses transient or temporary locked high radiation areas not controlled by red flashing lights or keys. These areas shall have continuous direct surveillance to prevent unauthorized entry. The cause of this event is lack of procedural guidance to perform surveys in the unrestricted areas for the purpose of monitoring ionizing radiation in excess of 10 CFR 20 limits.
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    -6-
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previously observed. The nature of the questions resulted in the committeo clearly communicating that they expected each manager to present information in a manner that focused on nuclear safety values, Conclusions The Nuclear Safety Review Committee conducted an effective, candid, probing, and critical meeting. This demonstrated considerable improvement in the effectiveness of the committee in reinforcing nuclear safety value II. Maintenance M1 Conduct of Maintenance M 1.1 General Comments on Maintenance Activities Inspection Scope (62707)
The inspectors observed all or portions of the following work activitie FHP 01-001 Revision 22 New fuel receipt RNM C-1301 Revision 4 NB0215, miscellaneous relay test 101437 Revision 5 Molded case breaker replacement on NG04DAF 116110 Revision 1 NG0407 breaker test 116330 Revision 1 Seal weld nondestructive testing on Valve JEV0086 122200 Revision 1 NB0205 breaker test Observations and Findinas Except as noted in Sections M1.3 and M1.4, the inspectors found no concerns with the maintenance observe Conclusions Except as noted in Sections M1.3 and M1.4, the inspectors concluded that the maintenance activities were being performed as require l


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Corrective Steps Taken and Results Achieved Performance Improvement Request (PIR) 97-2839 was initiated to address this issue. Corrective Actions initiated to address PIR 97-2839 include the performance of a review of 10 CFR 20 and a comparison to existing procedures to determine any additional areas of missed guidance. This review was completed on October 14, 1997 No areas of missed guidance were found.
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    = M1.2 Q3nstal Comments on Surveillance Activities _ - Inspection Scope (617261
    - The inspectors observed i.?! or portions of the following surveillance activitie STS IC 530D, Revision 13 - Channel calibration wide range temperature -
and wide range pressure instrumentation STS NF-001 A, Revision 0  MDAFW A start inhibit circuit test LSELS Relay K1102  * Observations and Findinas Except as noted in Section M1.5, the inspectors found no concerns with the surveillances observed.= Conclusions Except as noted in Section M1.5, the inspectors concluded that the surveillance activities were being performed as require M1.3 Use of Protected Train Postinas B
'--- Insoection Scoce (62707)    ,
The inspector observed the licensee's practice of using protected train signs during
    : train outages, Observations and R. .nas
    - On August 28,1997, during Train B outages for essential service water, auxiliary
    :
feedwater, and emergency diesel generator, the i_nspector noted that the licensee instituted the good practice of posting a sign at the entrance to the Train A components. These postings stated that these components were protected, and plant personnel were not to perform _any maintenance and were not to go near these components because of the opposite train outage The inspector also noted that the licensee had not posted a similar sign around -
Essential Switchgear NB01, despite the fact that significant work occurred on Essential Switchgear NB02.' When the inspector. questioned the central work -l authority about the absence of these signs, the response was that the posting of these signs was a good practice, but was not required by procedures. -When the-I i
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As an interim measure, until procedure RPP 02-210, " Radiation Survey Methods,"
_,
is revised, Health Physics personnel will conduct the following activities when moving HICs
8-
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Access to effected areas within the restricted area will be controlled and surveys will be performed.
inspector noted the amount of work occurring on Essential Switchgear NB02, the central work authority responded by directing perscnnel to post protected train signs around Essential Switchgear NB0 During subsequent discussions with the plant manager, the inspector learned that the plant manager had directed integrated plant scheduling personnel to revise appropriate procedures to add the requirement for this good practice into licensee-
  -procedures. -The plant manager _ said that the omission of a protected train sign on Essential Switchgear NB01 did not meet management expectations, and the planned
  - procedure revision would help ensure that the expected postings occur in the future, Conclusions
  - The 8,spector concluded that the good practice of posting protected train signs on personnel entrances to operable train equipment during train outages was not being consistently applie 'M1.4- Inspection Procedure Revision Error in a Work Packaae Insoggtion Scoce (62707)-
The inspector reviewed four packages during the inspection of safety related maintenance, Observations and F ndinos On August 28,1997, Work Package 16330, Task 1, Step 5.7,6, directed the quality control inspector to examine a weld using Procedure OCP.20 501, " Liquid Penetrant Examination,''. Revision 1. The inspector questioned the quality control
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{' in_spector who acknowledged the work package task error. The latest revision to?
l  Procedure QCP 20 501 was Revision 0, and the technician referred to this latest-
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revision during the weld examination.


I-  The inspector noted that t_he weld data sheet referred to the proper revision of '
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  * Surveys of the unrestricted area will be performed and access will be restricted to those areas when radiation levels exceed 10 CFR 20 limits.
Procedure OCP 20 501 and that the quality control inspector demonstrated
: appropriate f amiliarity with the procedure ar.d the inspection activity.


c, Conclusions -
* RWP 970019 pre-jeb checklist has been revised to caution individuals to survey unrestricted areas if dose rates are exceeded at the RCA boundary.
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The inspector identified a minor typographical error in a work package th;'.
demonstrated insufficient attention to detailin the werk package planning,- review, l  : and field us *
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Corrective Steps That Will Be Takent Procedure RPP 02-210, will be revised to incorporate guidance on surveys of unrestricted areas.
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9, M1.5 - Surveillance Procedure Specification Error inspection Scope (6172.DJ The inspector reviewed two paaages ot.4og the inspection of surveillance testin Observations and Findinas On September 6,1997, Surveillance Procedure STS NF-001 A, "MDAFP (Motor Driven Auxiliary Feedwater Pump) "A" Start inhibit Circuit Test, LSELS (Load Shed and Emergency Load Sequencing) Relay K11C?," Revision 0, Step 9.9, directed instrumentation and controls technicians to verify the presence of approximately 67 VDC with their digital voltmeter positiva lead connected to TB2 Terminal 10 and the negative lead connected to cabinet ground. The technicians read -64.5 VDC, and initialed the procedure, indicating that this met the procedural requiremen The inspector questioned whether the negative polarity reading actually met the test requirement. The system electrical engineers reviewed the system prints and later demonstrated that, with the meter connected as the procedure specified, a negative voltage was proper, Conclusions The inspector concluded that the surveillance test met the Technical Specification requirement, The inspector futher concluded that the technicians demonstrated inadequate attention to detailin not identifying that the observed voltage polarity differed from that specified in the procedure and that procedure preparation was weak in that the voltage polarity could have been easily researched, but was no . Enaineerin_g E1 Conduct of Engineering E . Control Room Door Leaktichtness inspection Scope (37551)
The inspector reviewed the circumstances associated with the discovery of damage to the control room door seal and the licensee's response, Observations and Findinas On August 5,1997, at 5:40 p.m., the shif t supervisor logged entry into Technical Specification 3.0.3 due to the discovery of damage to the control room door sea The shift supervisor began the power reduction requ; red by the Technical Specifications and determined that the maintenance ectivity to replace the seal was
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Date When Full Compliance Will Be Achieved-WCNOC is currently in full compliance. The procedure revision for these changes will be complete by January 30, 1998.
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:o e-10- emergent work. At 6:10 p.m. maintenance personnel completed the repairs to the control room door, and at 9:09 p.m. engineering personnel completed Surveillance Procedure STS PE-004 to demonstrate that the control room bounda y could maintain the required prescur On September 9,1997, the licensee retracted their notification for entry into Technical Specification 3.0.3, based on testing that demonstrated that the control room envelope could maintain the required pressure even if they completely !
removed the seal that was damage The inspector noted that Updated Safety Analysis Report (USAR) Section 6.4. stated that the control room doors were designed to maintain their specified leaktightness of 0.1 cfm leakage per linear foot of sealing surface at a positive control room pressure of 1/4-inch water gauge. Engineering Specification 16577-A 075A, Section 5.7, specified the airtightness criterion of the control room door, but stated that this could be demonstrated through succersful completion of the control room positive pressure test outlined in Engineering Specification 10466 M 61 The inspector asked the licensee how they demonstrated that the control room door ,
complied with the leaktightness criterion specified in the USAR. The licensee-initiated PIR 97 2620 to address this issue. At the end of the inspection period, this PIR remained open. This issue will remain unresolved pending additional inspection and will be tracked as an unresolved item (50-482/9714-02).  , Conclusions    ,
  'The inspector identified an unresolved item associated with questions regarding -
how the control. room door met the leaktightness criteria specified in the USAR, E2 Engineering Support of Facilities and Equipment E Control Room Ventilation System Walkdown inspection Scooe (71707)
  -The inspectors performed a detailed walkdown of the control room ventilation system, Observations and Findinas During this inspection period, the inspectors performed a detailed walkdown of the control room ventilation system. During the walkdown, the inspectors noted a number of issues that sugges'ed that the cornrol room ventilation system has not received as much attention as other safety systems.


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Violation 50-492/9714-05:     ,
     - 11-While performing the component verification and component position verification, the inspectors identified one drawing error. On Drawing M 12GK01, Revision 6, the inspectors noted that one drain valve for Control Room Filtration System Filter
  * Technical Specification 6.11 requires, in part, that radiation workere adhere to procedures for personnel radiation protection consistent with the requirements of 10 CrR Part 20.
. Adsorber Unit FGKO1 A, Valve GK V0065, the charcoal filter drain valve, had been mislabeled GK V0086. In addition, Checklist Procedure CKL GK-131, " Control Building HVAC Electrical Checklist," Revision 15, incorrectly described Breaker NG01CR119. Operations persennel submitted Defect Deficiency
- Report 97-1784 to correct Checklist Procedure CKL GK-13 The inspectors noted corrosion on the tubing leading to Valve GK V0775, access control f an coil unit chilled water supply line drain valve, and Valve GK VO776, access control fan coit unit chilled water supply line vent valve. These valves were somewhat inaccessible and the copper tubing supporting these valves vibrated -
noticeably. The inspectors also noted minor packing leaks on several other valves,  !
Checklist Procedure CKL GK-121, " Control Building HVAC Valve Checklist,"
Revision 13, required that operators check filter adsorbt unit transmitter high and
    .
-low side isolation valves, but did not require them to verify that the equalization valves were shut. Engineering personnel explained that this stemmed from the common practice of labeling only the isolation valves or root valves, and not including any other instrumentation valves on system drawings While the inspectors did not identify any instances where the equalization valves were mispositioned, the practice of not checking them shut could result in them being left ope Conclusions The inspectors concluded that the control room ventilation system was operable and that the material condition and associated documentation were adequate The minor discrepancies noted demonstrated that the control room ventilation system received less attention than other safety systems the inspectors have reviewe E2,2 Centrifuaal Charaino Pumo Shaf t Vibration Insoection Scope (37551)
The inspector reviewed the licensee's response to increasing vibratior of Centrifugal Charging Pump Observations and Findinas in August 1997, the licensee noted increased vibration on the shaft of Centrifugal
" Charging Pump B. The system engineer noted that this vibration was similar to that seen on similar pumps at other nuclear power plants. Lngineering personnel placed-this pump on an increased monitoring frequency as required by the Section XI of the American Society of Mecnanical Engineers Boiler and Pressure Vessel Code and
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Administrative Procedure AP 25B-100, ' Radiation Worker Guidelines,'
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Revision 4, Section 6. 3. 6, states that ' Individuals shall comply with the RWP [ Radiation Work Permit) requirement.'
    -12-applicable Addenda for inservice inspection. Maintenance personnel began the planning and preparation for replacement of the pump rotating assembly. After additional evaluation and management review, the licensee decided to add replacement of the pump rotating assembly to the scope of Refueling Outage Conclusiong
Contrary to the above, on August 28, 1997, a worker entered the radiologically controlled area without the electronic dosimetry required by Radiation Work Permit 970009."
- The licensee responded promptly and appropriately to an increasing vibration trend on Centrifugal Charging Pump IV. Plant Support R1 Radiological Protection and Chemistry Controls    .
R1.1 ' S2ent Resin Liner Transfer Inspection Scope (71750)
The inspectors reviewed the licensee's radiological controls while moving a spent resin liner from a shielded storage trea to a shipping cas Observations and Findinas On September 16,1997, the licensee moved a spent resin liner from the square process shield to a shipping cask in the truck bay of the radwaste building. The inspectors observed the radiation monitoring techniques and radiological controls used during the transfer by health physics psrsonnel. Radiation level monitoring in the high radiation area was effective and personnel exposure to radiation was -
minimized through the effective use of shielding and remote radiation monitoring technique Within the restricted area, the technicians restricted personnel access to the truck bay. The technicians locked the door to the truck bay from the radwaste building and assigned a technician to prevent personnel from approaching the truck ba .The technicians stationed two additional personnel outside the truck bay to monitor the dose rate and prevent personnel access to the truck bay from outside the building. The technicians also directed the personnel inside the restricted area boundary fence to prevent personnel access into the unrestricted area adjacent to the radiologically controlled area boundary fence along the south side of the radwaste buildin During discussions with the licensee after completion of the spent resin liner a  transfer, the licensee stated that, while they had not performed an evaluation of the radiation levels in the unrestricted area at the radiologically controlled area boundary
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to the south of the radwaste building before conducting the evolution, they recognized the potential for the dose rate at the unrestricted area boundary to l
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Reason for Violation l
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On August 28, 1997, an individual arrived at Access Control to enter the RCA for a tour of the pump and tank rooms on the 1974' elevation of the Auxiliary Building. Upon arrival, he found the area around the book containing copies of the Radiaticn Work Permits (RWP) to be congested, j After signing into the Radiological Controlled Are.n (RCA) through the Automated Radiological Access Control System the individual was able to access the RWP book and review RWP 970009. Upon completion of the review, the individual performed a cursory check for proper t'Osimetry. The individual procteded towards the RCA boundary. During this time the individual was engaged la an on and off conversation, which distracted the individual from the sign-in process. After accessing the pump and tank rooms, the individual was in transit to the "B" Centrifugal Charging Pump room, the individual noticed that the electronic dosimeter (PD-1) was not in place. The individual immediately exited the a.rea, along with another raclation worker whv had been with the individual, and notified the Health Physics Shift Technician. The PC-1 was located in the rack of the computer station where the individual had signed into the RCA. Based on the other radiation worker's PD-1, who had been with the individual the entire time, the individual was assigned a dose of zero mrem. The cause of this event was the inattention to detail caubed by distractions during the RCA sign-in process. A contributing factor was the lack of a strong continuing training program for all radiation workers, Corrective Steps Taker. and Results Achieved:
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* The worker notified the Health Physics Shift Technician immediateJ y upon discovering the dosimetry discrepancies. This resulted in a potential reduction of exposure, and allowed Health Physics personnel to evaluate and perform corrective action in a more timel) menner.
    -13-exceed 2 mrem per hour. Subsequent to the evolution, at the inspector's request, the licensee estimated the dose rate at the restricted area boundary fence during the evolution to be approximately 13 mrem per hour for a duration of 15 minutes. The f ailure of the ficansee to perform surveys for the spent resin liner movement evolution is a violation of 10 CFR 20.1302 (50-482/9714-03),
c. Conclusions The licensee f ailed to perform an evaluation of radiation levels in the unrestricted area adjacent to the restricted area south of the radwaste building before rnoving a spent resin liner or to perform surveys in the same area during movement of the liner. The licensee attempted to restrict personnel access to the unrestricted area by assigning personnel inside the restricted area fence to control personnel access outside the fenc R4 Staff Knowledge and Performance R4.1 Spent Fuel Pool Transfer Canal Postina a, inspection Scope (71750)
The inspector reviewed the posting of the spent fuel transfer canal during spent fuel transfer equipment modificetion, b. Observations and Findinas During spent fuel transfer canal fuel equipment modification work, the inspector reviewed the radiological posting of the spent fuel pool transfer canal. At the north end of the contaminated area by the door _into the fuel building from the auxiliary building, the inspector noted a section of the boundary where the west boundary shifted approximately 5 feet west. Radiological protection technicians posted the first contaminated area sign approximately 10 feet south of the point where the west bnundary shif ted further wes With this posting configuration, as personnel entered the fuel building from the auxiliary building, they could walk up to the west boundary north of the point where the boundary shifted and not see any radiological posting sign. In addition, the entire boundary consisted of vertically supported yellow sheeting taped with red adhesive tape. The technicians used no yellow and magenta rope, ribbon, or tape to mark the boundary as a barrier for the purpose of radiological protectio The inspector questioned whether the posting met the requirements of the licensee's radiological protection plan. At the end of the inspection period, the inspector's review of this posting was not complete. The adequacy of the posting will be reviewed during a future inspection and will be tracked as an unresolved item 150 482/9714-04).


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* Dose calculations were performed for the worker. No exposure resulted from the incident.


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* WCNOC is currently monitoring and challenging ' workers entering the RCA.
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b- Conclusions -
The in:pector identified an unresolved item associated with questions regarding the adequacy of radiological control posting in the fuel building.


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This is a short term action that will be implemented until further evaluation can be performed.
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  . R4.2 Radiation Work Permit'Reouirements
!  -a,- Insoection Scope (71750)
i l  The inspector reviewed the circumstances associated with a radiation worker who t  failed to comply with the requirements of the radiation work permit.


i'  . Observations and Rndinas i:
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On August 28,1997, an individual logged onto Radiation Work Permit 97009 and
   -    .-- - .
{  entered the radiologically controlled area without the electronic dosimeter required  ,
F  by the radiation work permit. The individual subsequently recognized the f.rror, i  exited the radiologically controlled area, and reported the error. The licensee
]  . initiated PIR 97 2644 to revies this issue and develop corrective action L
'
NRC inspection Reports 50-482/9710 and -11 noted violations for similar occurrences. Certain corrective actions for those violation 3 were still being
['  ' evaluated when this violation occurreo. Consequently, the licensee implemented-l additional corrective actions to address the continuing trend, 3=
"
After learning of the August 28,1997, occurrence, the new radiation protection superintendent decided to implement "Just-in-Time" traming for all radiation workers prior to Refueling Outage 9, including a practical training session involving
   - protective clothing use~and radiation worker quizzes, and the appointment of -
,  . radiation protection personnel as " Radiological Control Area Greeters," who assist
;  personnel preparing to enter the radiologically controlled area with answers to questions. -They, in turn,. quiz the radiation worker to ensure that they are knowledgeable of certain facts necessary to comply with their radiation work permit -
]
requirements, j-The failure of the radiation worker to obtain the dosimetry required by the radiation
'  work permit is a violation of Technical Specification 6.11 (50-482/9714-05). Conclusions
   .The licensee identified that a radiation worker had entered the radiologically-controlled area without the dosimetry required by the radiation work permi . _ _ _ _ - -- _
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Attachmant to Wo 97-0120
. Page 2 of 6
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* "Just-In-Time"  has been conducted training  to rei.nf orce Radiation Protection policies and supplement radiation worker training. This training included a practical f actors qualification for radiation workers to demonstrate the correct login, dre:s out, undress and RCA exit procedures.


e-15-V. Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on September 19,1997. The licensee acknowledged the findings presente The inspectors asked tha licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie s l
* The Manager Radiation Protection has given direction for Health Physics personnel to question radiation workers on expected standards.
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* The Health Physics Access Control area has been declared a "No Talk Zone"
, to minimize distraction of radiation tarkers entering the RCA. In addition
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a Security of ficer has been assigned to the Health Physics Accebs Control j to verify radiation workers entering the RCA are wearing proper dosimetry.


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Corrective Steps To Be Taken In an effort to improve human performance in the Access Control area, WCNOC Health Physics personnel will submit a proposed facility change to be evaluated using the design change process. This proposal will be submitted by January 1, 1998.
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i      ~ ATTACHMENT-EUPPLEMENTAL INFORMATION
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t
;-    PARTIAL LIST OF PERSONS CONTACTED p
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Licensee
 
G. D; Boyer, Chief Administrative Officer i  O. L. Maynard, President and Chief Executive Officer
;  8. T.- McKinney, Plant Manager      ,
;. R, Muench, Vi::e President Engineering
!  .W. B. Norton, Manager, Performance improvement and Assessment
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C. C. Warren, Chief Operating Officer
;    INSPECTION PROCEDURES USED i
j-  IP 37551  Cnsite Engineering IP 61726  - Surveillance Observations
!  IP 62707___  Maintenance Operations .
IP 71707  Plant Operations    :
p  IP 71750  Plant Support Activities i.
 
[ _
ITEMS OPENED.-CLOSED, AND DISCUSSED
 
1
!  Ooened        ,
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. 50-482/9714-01  VIO - Technical Specification Amendment implementation (Section O3.1)
50-482/9714-02  URI Control Room Door Leaktightness (Section E1.1)
50-482/9714-03  VIO Spent Resin Liner Transfer (Section R1.1)
50-482/9714-04  URI Spent Fuel Pool Trahsfer Canal Posting (Sect on R4.1)-


50-482/971_4-05-  VIO - Radiation Work Permit Requirements (Section R4.2)
Date When Pull Compliance Will Be Achieved:
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WCNOC"is currently in full compliance, c
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Revision as of 09:43, 8 December 2021

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-482/97-14 .Finds Reply Responsive to Concerns Raised in Nov. Will Review C/As During Future Insp
ML20198Q295
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 11/06/1997
From: Johnson W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Maynard O
WOLF CREEK NUCLEAR OPERATING CORP.
References
50-482-97-14, NUDOCS 9711120166
Download: ML20198Q295 (4)
v • d • e


Text

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p NUCLEAR REGULATORY COMMISSION g REGloN IV

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'4 AR LINoToN.TExA8 760114064 9 ' " * * ,v 140V - 61997 Otto L. Maynard, President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411

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Burlington, Kansas 60839 SUBJECT: NRC INSPECTION REPORT 50 482/97 14

Dear Mr. Maynard:

Thank you for your letter of October 31,1997,in response to our letter and Notice of Violation dated October 2,1997. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the impicmontation of your

corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.

Sincerely, w

a .D.Joh n, lef Project Branch B Division of Reactor Projects Docket No.: 50 482 License No.: NPF-42 cc:

Chief Operating Officer Wolf Creek Nuclear Operating Corp. /

P.O. Box 411 If 4 Burlington, Kansas G6839 I Jay Silberg, Esq.

Shaw, Pittman, Potts & Trowbridge 2300 N Street, NW Washington, D.C. 20037 E

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Wolf Creek Nuclear 2 Operating Corporation

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Supervisor Licensing Wolf Creek Nuclear Operating Corp.

P.O. Box 411 j Burlington, Kanses 66839 Chief Engineer

Utilities Division

Kansas Corporation Commission i

1500 SW Arrowhead Rd.

Topeka, Kansas 66604-4027 i
. Office of the Governor i

.9 tate of Kansas Topeka, Kansas 66612

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Attorney General Judicial Center l 301 S.W.10th 2nd Floor Topeka, Kansas 66012 1697 County Clerk Coffey County. Courthouse Burlington, Kansas 66839 1798 Vick L. Cooper, Chief Radiation Control Program Kansas Department of Health and Environment Bureau of Air and Radiation Forbes Field Building 283 Topeka, Kansas 66620 Mr. Frank Moussa Division of Emergency Preparedness 2800 SW Topeka Blvd Topeka, Kansas 66611 1287

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L Wolf Creek Nuclear- 3-Operating Corporation NOV - 61997 bec to DCD (IE01).

bec distrib. by RIV:

Regional Administrator Resident inspector DRP Director SRI (Callaway, RIV)

Branch Chief (DRP/B) DRS PSB Project Engineer (DRP/B) MIS System Branch Chief (DRP/TSS) RIV File

.

DOCUMENT NAME: R:\_WC\WC714AK.JFR

- To receive copy of document, indicate in boa: "C" = Copy without enclosures "E" = Copy wth enclosures "N" = No copy RIV:PE:DPR/B C:DRP/B DNGraves;dfp WDJohnson[p(p

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11/b /97 11/ (f/97 ]

OFFICIAL RECORD COPY

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Wolf Creek Nuclear -3-Operating Corporation NOV - 61997

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1 Regionel Administrator Resident inspector 3 DRP Director SRI (Callaway, RIV)

i. Branch Chief (DRP/B) DRS PSB Project Engineer (DRP/B) MIS System Branch Chief (DRP/TSS) RIV File

- -

DOCUMENT NAME: R:\_WC\WC714AK.JFR To receive copy of document. Indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:PE:DPR/B C:DRP/B ,

DNGraves;dfy WDJohnsorit$

11/b /97 - -' 11/ (f/97 J OFFIC:AL RECORD COPY t:nc53

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W@ NUCLEAR LF CREEK OPERATING Clay C Warren Chef Operstify Officer

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1 WO 97-0120 i '

, O hJ j'__ October 31, 1997 U. S. clear Regulatory Commission l ATTN: Document Control Desk

Mail St.ation F1-137 Washington, D. C. 20555 Reference: Letter dated October 2, 1997, from T. P. Gwynn, NRC, to 0. L. Maynard, WCNOC l Subject: Docket No. 50-482: Response to Notice of Violations j 50-482/9714-01, 9714-03, and 9714-05

,

i

! Gentlemen i

j This atter transmits Wolf Creek Nuclear Operating Corporation's (WCNOC)

, response to Notice of Violations 50-482/9714-01, 9714-03, and 9714-05. Notice i

of Violation 9714-01 cites inef fective maintenance of a procedure to support l implemertation of Technical Speification Amendment 108. Notice of Violation l 9714-03 cites an exampie of a radiation worker failing to have the correct

dosimetry required by the Radiation Work Permit. Notice of Violation 9714-05 j addresses a failure to perform surveys of radiation levels in unrestricted and

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controlled areas.

WCNOC's response to these violations is provided in the attachment. If you have any questions regarding thir response, please contact me at ;316) 364-

! 8831, extent.ien 4000, or Mr. Richard D. Flannigan at extension 4500, i

j Very truly y rs,

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b i C1 C. Warren j CCW/jad Attachment

l cc; W, D. Johnson (NPC), w/a

! E. W. Merschoff (NRC), w/a J. F. Ringwald (NRC), w/a

h. M. Thomas (NRC), w/a

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! qs-o(95

P.O. Box 411/ Burlington, KS 66839 / Phone- (316) 3644831

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An Equal opportunity Employer M F HC. VET

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At t echnont to WO 97-0120

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Violation 50-482/9714-01:

" Technical Specification 6.8.1.a requires, in part, that written

, procederes be established, implemented, and maintained covering the I

applicable procedures recommended in Appendix A of Regulatory Guide I 1.33, Revision 2, February 1978.

Regulatory Guida 1.33, Revision 2, February 1978, Section 3.f.,

recommends, in part, that procedures be established for the operation of containment.

Surveillance Procedure STS GP-007, "CTMT Penetration Isolation Verification," has been established in accordance with these requirements.

Contrary to the above, on August 20, 1997, Procedure STS GP-007, "CTMT Fenatration Isolation Verification," was not effectively maintained in that the licensee implemented Technical Specification Amondment 108, which relocated a list of containment isolation valves from Technical Specification 3.6.3 to Procedure STS GP-007, without providing adequate guidance for how this procedure would subsequently be used to identify containment isolation valves covered by Technical Specification Limiting Condition for Operation 3.6.3."

Reason for Violation:

The implementation of Technical Specification (T/S) Amendment 108 on August 19, 1997, resulted in the inability of the Control Room personnel to properly implement Technical Specification (T/S) 3.6.3).

On August 28, 1997, Control Room personnel became concerned with the operability of valve BM HV-36 during the performance of procedure STS IC-616B, "SLV RLT TST K616 Safety Injection." This valve was identified in the Equipment out of Service Log as a T/S 4.0.5 failure. The Shift Supervisor (SS) reviewed the applicable system drawings, T/S Amendment 108, and the physical location of the valve (the first valve inside containment) and conservatively determined that valve BM HV-36 was a containment isolation valve. The SS instructed the valve be closed and tagged with Clearance Order 97-1047-BM until additional reviews could be completed on day shift.

Day shift personnel subsequently reviewed Updated Safety Analysis Report Figure 6.2.4-1, and determined that valve BM HV-36 was not a containment isolation valve. Day shif t personnel then removed Clearance order 97-1047-BM.

Due to Control Room personnel questicns and concerns with compliance to T/S 3.6.3, Operations management decided that STS GP-007, "CTMT Fenetration Isolation Verification," was the governing procedure for iraplementation of T/S Amencment 108. This decision process occurred af ter T/S Amendment 108 was released for implementation.

The cause of this event is inadequate change management cf program implementation. Evaluation of this event disclosed examples of ineffective planning, communication, ownership, and implementation.

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Attachman? 'o WO 97-0320

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Corrective Steps Taken and Results Achievedt Procedure STS GP-007, "CTMT Penetration Isolation Verification," was revised October 4, 1997, to clearly specif y which valves are cont a i nt.,ent isolation valves. Operations management has provided guidance to operating crews concerning the effects of Amendment IJB on cor.tainment ieolation valves.

l Corrective Steps That Will Be Takent Licensing will coordinate treetings to discuss the current license amendment )

requests which have been submitted, but not approved, as well as license amendment requests currently in process. These meetings will assure that apptcpriate ownership of each amendment and that implementation activities have been considered prior to receipt and implementation of the amendments.

This is an interim measure to ensure amendments are properly implemented which will be effective until the procedure revision described below is completed.

In addition, Procedure AP 268-001, " Revisions to the Operating License and/or Technical Specifications," will be revised to ensure tha following actions occur 1. 1.mendment ownership is established 2. Pre-submittal meetings are held to dis, cuss amendment implementation 3. Ownership is established for implementation activities 4. Post amendment receipt meetings are conducted to review pre-submittal decisions and ensure Wolf Creek is prepared to implement the amendment.

This revision will be completed by January 31, 1996.

Date When Full Compliance Will Be Achievedt WC110C is currently in full compliance, i

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Attachmont to WO 97-0120

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i violation 50-482/9714-03:

"10 CFR 20.1302(a) requires, in part, that the licer.see reake or cause to be made, surveys of radiation levels in unrestricted and controlled areas to demonstrate compliance with the dose limits for individu*l members of the public in paragraph 20.1301.

Contrary to the above, on Septenber 16, 1997, the licensee moved a spent resin liner without first performing a survey of the radiation levels in the unrestricted area adjacent to the restricted area south of the radwaste building. A subsequent evaluatian estimated the dose rate in the unrestricted area well in excess of the limit of 10 CFR 20.1301."

Reason for Violation Wolf Creek Nuclear Operating Corporation (WCNOC) acknowledges and agrees that a violation of 10 CFR 20.1301 and 10 CFR 20.1302 occurred. However, a subsequent evaluation has shown that the dose rates identified in 10 CFR 20.1301 were not exceeded at the unrestricted area boundary. This clarification is necessary because a clear unoerstanding of the location of the unrestricte. **usdary and the radiologic.nl controlled area (RCA) boundary was not ade qua t el., communicated to the inspector. NRC Inspection Report 97-14 and Notice of Violatien 9714-03 reflect this misunderstanding. 1:ealth Physics personnel comtrunicated clarifying informaticn to the NRC Senior Resident Intpector on October 8, 1997 This event involved the transfer of a High Integrity Container (HIC) from a process shield to a shielded tranrport cask on September 16, 1997. During the transfer process the HIC was remcVed from one shielded area and transferred to another shielded area. It was * luring this evolution that the radiation levels increased in the RCA because the HIC was not shielded during the transfer process.

For this evolution one Health Physics empivyee was placed at the southeast and southwest corners of the RCA to monitor the radiological conditions and halt any traffic along the access road adjacent to the south side of the Radwaste Building during the HIC movement evolution. Each Health Physics employee carried a survey meter and was qualified to operate the survey meter.

However, since they were not Health Physics Technicians, they could use the

, survey meters for personal anformation only and were not allowed to parforra surveys. The radiation levels observed where the personnel were stationed was 1.5 mrem /hr. This was below the 2 mrem /hr. limit specified by 10 CFR 20.1301 and 20.1302. The Hcalth Dhysics employees halted one Security officer on foot, two Security of ficers cn bicycles and one truck during the approximately fif teen minute ew olutiers.

10 CFR 20.1301 specifies that, "The total effective dose equivalent to 5 individual members of the public from the licensed operation does not exceed

< 0.1 rem in a year," and "The cose in any unrestricted area from external sources does not exceed 0.002 rem in any one hour." Compliance with the dose limits are specified by 10 CFR 20.1302(a) as, "The 'icensee shall make or cause to be made, as appropriate, surveys of radiation levels to unrestricted and controlled areas...to demonstrate compliance with the dose limits for individual members of the public in 20.1301."

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Attachment to WO 97-0120

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Procedure AP 25A-001, " Radiation Protection Manual," step 4.34, defines the restricted area as bounded by the Security fence (protected area boundary).

The calculation for the RCA boundary dose rate previously provided to the resident inspector was understood by the NRC Resident Inspector as the unrestricted area boundary dose rate. A new calculation was performed using the protected area fence as the unrestricted area boundary and the result was 1.5 mrem /hr or 0.38 mrem for the 15 minute evolution. The nuw calculations demonstrate the unrestricted area boundary was maintained below the limits specified by 10 CFR 20.1301 and 1302, however, there were no surveys to demonstrate compliance as required by 10 CFR 20.1302(a) .

AP 25A-200, " Access to Locked High or Very High Radiation Areas," step 4.3 defines a transient locked high radiation area as transfer of items that are

> 1 rem /hr at 12". These areas will not be posted during transfer as long as 3 Health Physics Technician is in direct surveillance of the areat step 6.6 discusses transient or temporary locked high radiation areas not controlled by red flashing lights or keys. These areas shall have continuous direct surveillance to prevent unauthorized entry. The cause of this event is lack of procedural guidance to perform surveys in the unrestricted areas for the purpose of monitoring ionizing radiation in excess of 10 CFR 20 limits.

Corrective Steps Taken and Results Achieved Performance Improvement Request (PIR) 97-2839 was initiated to address this issue. Corrective Actions initiated to address PIR 97-2839 include the performance of a review of 10 CFR 20 and a comparison to existing procedures to determine any additional areas of missed guidance. This review was completed on October 14, 1997 No areas of missed guidance were found.

As an interim measure, until procedure RPP 02-210, " Radiation Survey Methods,"

is revised, Health Physics personnel will conduct the following activities when moving HICs

Access to effected areas within the restricted area will be controlled and surveys will be performed.

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  • Surveys of the unrestricted area will be performed and access will be restricted to those areas when radiation levels exceed 10 CFR 20 limits.
  • RWP 970019 pre-jeb checklist has been revised to caution individuals to survey unrestricted areas if dose rates are exceeded at the RCA boundary.

Corrective Steps That Will Be Takent Procedure RPP 02-210, will be revised to incorporate guidance on surveys of unrestricted areas.

Date When Full Compliance Will Be Achieved-WCNOC is currently in full compliance. The procedure revision for these changes will be complete by January 30, 1998.

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httechmsnt to UO ')7-0120

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Violation 50-492/9714-05: ,

  • Technical Specification 6.11 requires, in part, that radiation workere adhere to procedures for personnel radiation protection consistent with the requirements of 10 CrR Part 20.

Administrative Procedure AP 25B-100, ' Radiation Worker Guidelines,'

Revision 4, Section 6. 3. 6, states that ' Individuals shall comply with the RWP [ Radiation Work Permit) requirement.'

Contrary to the above, on August 28, 1997, a worker entered the radiologically controlled area without the electronic dosimetry required by Radiation Work Permit 970009."

Reason for Violation l

On August 28, 1997, an individual arrived at Access Control to enter the RCA for a tour of the pump and tank rooms on the 1974' elevation of the Auxiliary Building. Upon arrival, he found the area around the book containing copies of the Radiaticn Work Permits (RWP) to be congested, j After signing into the Radiological Controlled Are.n (RCA) through the Automated Radiological Access Control System the individual was able to access the RWP book and review RWP 970009. Upon completion of the review, the individual performed a cursory check for proper t'Osimetry. The individual procteded towards the RCA boundary. During this time the individual was engaged la an on and off conversation, which distracted the individual from the sign-in process. After accessing the pump and tank rooms, the individual was in transit to the "B" Centrifugal Charging Pump room, the individual noticed that the electronic dosimeter (PD-1) was not in place. The individual immediately exited the a.rea, along with another raclation worker whv had been with the individual, and notified the Health Physics Shift Technician. The PC-1 was located in the rack of the computer station where the individual had signed into the RCA. Based on the other radiation worker's PD-1, who had been with the individual the entire time, the individual was assigned a dose of zero mrem. The cause of this event was the inattention to detail caubed by distractions during the RCA sign-in process. A contributing factor was the lack of a strong continuing training program for all radiation workers, Corrective Steps Taker. and Results Achieved:

  • The worker notified the Health Physics Shift Technician immediateJ y upon discovering the dosimetry discrepancies. This resulted in a potential reduction of exposure, and allowed Health Physics personnel to evaluate and perform corrective action in a more timel) menner.
  • Dose calculations were performed for the worker. No exposure resulted from the incident.
  • WCNOC is currently monitoring and challenging ' workers entering the RCA.

This is a short term action that will be implemented until further evaluation can be performed.

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Attachmant to Wo 97-0120

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  • "Just-In-Time" has been conducted training to rei.nf orce Radiation Protection policies and supplement radiation worker training. This training included a practical f actors qualification for radiation workers to demonstrate the correct login, dre:s out, undress and RCA exit procedures.
  • The Manager Radiation Protection has given direction for Health Physics personnel to question radiation workers on expected standards.
  • The Health Physics Access Control area has been declared a "No Talk Zone"

, to minimize distraction of radiation tarkers entering the RCA. In addition

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a Security of ficer has been assigned to the Health Physics Accebs Control j to verify radiation workers entering the RCA are wearing proper dosimetry.

Corrective Steps To Be Taken In an effort to improve human performance in the Access Control area, WCNOC Health Physics personnel will submit a proposed facility change to be evaluated using the design change process. This proposal will be submitted by January 1, 1998.

Date When Pull Compliance Will Be Achieved:

WCNOC"is currently in full compliance, c

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