Text

Ack Receipt of 961206 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-482/96-18
	ML20132H191
Person / Time
Site:	Wolf Creek
Issue date:	12/24/1996
From:	Dyer J; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Carns N; WOLF CREEK NUCLEAR OPERATING CORP.
References
	NUDOCS 9612300009
	Download: ML20132H191 (4)
	v • d • e

..

+

t UNIT E D ST ATES

p**MGut,$

/ t NUCLEAR REGULATORY COMMISSION

$. % .S

REcioNav

' %k'v

t

- .,*[#'

611 RV AN PLAZA DRIVE, SulTE 400

AR UNGToN, TEXAS 760118064

DEC 241996

Neil S. Carns, President and

Chief Executive Officer

Wolf Creek Nuclear Operating Corporation

P.O. Box 411

Burlington, Kansas 66839

SUBJECT: NRC INSPECTION REPORT 50-482/9618

Dear Mr. Carns:

Thank you for your letter of December 6,1996,in response to our letter and Notice

of Violation dated November 7,1996. We have reviewed your reply and find it responsive

to the concerns raised in our Notice of Violation. We will review the implementation of

your corrective actions during a future inspection to determine that full compliance has

been achieved and will be maintained.

Sincerely,

l

P

. Dyer, Director

h J.Division of Reactor Projects

Docket No.: 50-482 !

License No.: NPF-42

cc w/ enclosure:

Vice President Plant Operations !

Wolf Creek Nuclear Operating Corp.

P.O. Box 411 :

Burlington, Kansas 66839 l

l

Jay Silberg, Esq.

Shaw, Pittman, Potts & Trowbridge

2300 N Street, NW l

Washington, D.C. 20037 l

'

I

9612300009 961224

PDR ALDCK 05000482

G PDR

.

I

Wolf Creek Nuclear -2-

Operating Corporation

Supervisor Licensing

Wolf Creek Nuclear Operating Corp.

P.O. Box 411

Burlington, Kansas 66839

Supervisor Regulatory Compliance

Wolf Creek Nuclear Operating Corp. ,

P.O. Box 411 '

Burlington, Kansas 66839

Chief Engineer

Utilities Division

Kansas Corporation Commission

1500 SW Arrowhead Rd.

Topeka, Kansas 66604-4027

Office of the Governor

State of Kansas )

Topeka, Kansas 66612

l

Attorney General I

Judicial Center l

301 S.W.10th

2nd Floor

Topeka, Kansas 66612-1597

County Clerk

Cof fey County Courthouse

Burlington, Kansas 66839-1798

Public Health Physicist

Division of Environment

Kansas Department of Health

and Environment

Bureau of Air & Radiation

Forbes Field Building 283

Topeka, Kansas 66620

Mr. Frank Moussa

Division of Emergency Preparedness

2800 SW Topeka Blvd

Topeka, Kansas 66611-1287

- _ _ . _ _ _ _ . _ . _ _ _ _ . _ _ _ . _ . . . _ _ _ . _ _ _ . _ . _ . . _ . . . _ _ _ _ _ _ . _ _ . _ _ - . _ _ .

.l

,

\

l

lt

. ,

) Wolf Creek Nuclear -3-

DEC 241996

f Operating Corporation

. ,

j bec to DMB (IE01)

l bec distrib. by RIV:

} L. J. Callan Resident inspector

j DRP Director SRI (Callaway, RIV)

Branch Chief (DRP/B) DRS/PSB

Project Engineer (DRP/B) MIS System

Branch Chief (DRP/TSS) RI V File

Leah Tremper (OC/LFDCB, MS: TWFN 9E10)

300007

DOCUMENT NAME: R:\_WC\WC618AK.JFR

To receive copy of document, indicate in ty: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy

l

RIV:DRP/B C:DRP/B , ,

D:DRPg

DNGraves:dk WDJohnsdp JEDy # 3

12/tc/96 F 12/j;O96 I 12/20/96

OFFICIAL RECORD COPY

I

l

r

.'

l-

Wolf Creek Nuclear -3

Operating Corporat,on i

DEC 241996

bec to DMB (IE01)

bcc distrib. by RIV:

L. J. Callan 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

Leah Tremper (OC/LFDCB, MS: TWFN 9E10)

DOCUMENT NAME: R:\_WC\WC618AK.JFR

To receive copy of document, indicate in tp: "C" = Copy without enclosures *E" = Copy with enclosures "N" = No copy

RIV:DRP/B C:DRP/B ,

D:DRPg

DNGraves;dL WDJohnsop JEDy # M

12/tc/96 F 12/,9096 f 12/20/96

OFFICIAL RECORD COPY

-_ _ .-. .

~

'

.

s

J , -

LF CREEK

W@)NUCLEAROPERATING UEC l 0 CO

,

i

% .4

Neil S. " Buzz" Cams I

'

Chairman, President and

Chief Executrve Omcer December 6, 1996 i

WM 96-0137

l

U. S. Nuclear Regulatory Commission I

ATTN: Document Control Desk

Mail Station P1-137

Washington, D. C. 20555

Reference: Letter dated September 23, 1996, from

J. E. Dyer, NRC, to N. S. Carns, WCNOC

Subject: Docket No. 50-482: Response to Notice of

Violations 50-482/9618-02, -03, -04, and -07

Gentlemen:

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

response to Notice of Violations 50-482/9618-02, -03, -04, and -07. Violation

9618-02 concerns the failure to correctly remove power from a safety injection

pump discharge valve. Violation 9618-03 concerns the failure to maintain

containment integrity during core alterations. Violation 9618-04 concerns the

incorrect performance of a portion of the surveillance requirements specified

by Technical Specification 4.8.1.1.2.g (6) (c) , while at power. Violation 9618-

07 concerns the failure to perform required post modification testing.

WCNOC's responses to these violations are in the attachment. If you have any

questions regarding this response, please contact me at (316) 364-8831,

extension 4100, or Mr. Terry S. Morrill at extension 8707.

Very truly yours,

'

. gv-

Neil S. Carns

NSC/jad

Attachment

ec: L. J. Callan (NRC), w/a

W. D. Johnson (NRC) , w/a

J. F. Ringwald (NRC) , w/a

J. C. Stone (NRC), w/a g3Q

PO. Box 411 / Burhngton, KS 66839 / Phone: (316) 364-8831

y f, , / . _vm /

-

An Egwal Opportunity Employer M F HC, VET

-

f U[ ( i 4. c% Y' $ff

. _.._ _. ._....__ _ _ _ _ . - . . . _ _ _ . . . - . . _ _ _ _ _ _ . _ . _ . _ . _ . _ __.___m__.__-

< -

3

4

J

'

j Attachment to WM 96-0137

1 Paga 1 of 7

5

1

4 Recly to Notice of Violations 50-482/9618 -02. -03, -04, and -07

1

4

l Violation 50-482/9618-02: The failure to correctly remove power from a

, safety injection pump discharge valve.

,

.

l "A. Technical Specification 3.5.4 requires that all safety injection

j pumps be inoperable during Modes 5 and 6 with the reactor vessel

head on. The pumps are to be made inoperable by securing the

'

motor circuit breaker in the open position. The inoperable pump

may be energized for testing or for filling accumulators provided

'

the discharge at the pump has been isolated from the reactor

l coolant system by a closed isolation valve with power removed from

the valve operator or by a manual isolation valve secured in the

,

closed position.

1

4 i

i

Contrary to the above, on March 23, 1996, with the plant was in '

, Mode 5, operators discovered that Safety Injection Pump Discharge

! Valves EM HV-8802A and -8021A handswitches were tagged *Do Not

l Operate" closed, but still had power available to them. The pump

j motor circuit breaker was racked. closed so that safety Injection

Pump A could be started." '

0

W saion of Violation

l

'

1

Wolf Creek Nuclear Operating Corporation (WCNOC) acknowledges and agrees that

j a violation of Technical Specification 3.5.4 occurred in March 1996, when

i operators failed to remove power - from Safety Injection Pump Discharge Valves

3

EM HV-8802A and -8821A. This event was self discovered and reported to the

j NRC in Licensee Event Report (LER) 96-004-00 (WCNOC Letter Number WM 96-0054,

, issued on April 19, 1996).

i

l Reason for Violation:

1

Root Cause and Contributing Factors:

! See LER 96-004-00.

l

j Corrective stens Taken and Results Achieved ]

l

l In addition to the corrective actions documented in LER 96-004-00, the

! following actions have been implemented:

I

i

1. The ' er t director involved with the clearance order was counseled. l

l

4 2. Tht: shift supervisor that authorized the change to the clearance order was

counseled.

1

3. The individuals responsible for implementing the corrective actions were

4

counseled.

4 l

l

l

.

.v. , ,.. n -

- - . . . _ - .

.'

'

Attachm3nt to WM 96-0137

/ Page 2 of.7

The corrective actions as documented in LER 96-004-00 and the additional

corrective actions documented above, are considered adequate for compliance

with the requirements of the technical specifications. The paragraphs below

describe additional measures being undertaken to enhance the root ,

cause/ corrective action process. )

Corrective Stoos That will Be Taken And Their Excocted Cosapletion Dates:

I

Discussions, to review the root cause determination process, will be held with 1

Operations department supervision. These discussions will focus on lessons I

learned and procedural requirements associated with the root cause l

determination and appropriate corrective actions. This action will be )

completed by December 31, 1996. I

Performance Improvement Request (PIR) 96-2592 was issued to address the

mismatches between the root causes and corrective actions documented in LERs

96-004-00 and 96-005-00. This PIR will be placed in Operations required

reading to familiarize the staff with the errors made and the lessons learned.

The corrective action program is being modified to include the following:

1. The formation of a formal corrective action review board. This board chair

will be assigned by the Chief Operating Officer. This board will review

root cause determination and corrective action plan for all significant

PIRs. This action was implemented on November 30, 1996.

2. Organizational changes will be implemented such that each group within the

Plant Operations Organization will have personnel whose primary

responsibility will be to support the corrective action process. This

action will be completed by January 31, 1997.

3. Additional training will be conducted for all managers (one day) and

individuals responsible for implementing ~ the corrective action program

(three days). This action will be completed by January 31, 1997.

Safety Sianificance:

During the time frame that the Technical Specification for cold over-pressure

protection was not being met, administrative controls remained in place to

protect the vessel from over-pressurization. The discharge valves EM HV-8802A

and EM HV-8821A were tagged closed, and no additional volume could have been

added to the vessel. Even if the SI pumps were inadvertently started, the

closed discharge valves would have prevented volume addition to the vessel.

Therefore, the safety significance of this event is low.

,

- _ ~ . . . . - - . _ - _ - - _ _

. . .- - . . _ . - _ . _ _

. .

'

Attachm2nt 'o WM 9F-0137

,~/. Pcga 3 of 7

Violation 50-482/9618-03: The failure to maintain containment integrity

during core alterations.

"B. Technical Specification 3.9.4 requires that each penetration

,

providing . direct access from the containment atmosphere to the

l outside atmosphere be closed by an isolation valve, blind flange,

'

manual valve, or be capable of being closed by an operable

automatic containment isolation valve. This Technical

[ Specification is applicable during core alterations or movement of

irradiated fuel within containment.

i

Contrary to the above, on March 14, 1996, the licensee found that

"

operators had directed the opening of Containment Isolation Valve

, BM-V046 to allow draining of Steam Generator B and C. Core

j alterations were in progress at the time the valves were open."

!

W saion of violation:

WCNOC acknowledges and agrees that a violation of Technical Specification 3.9.4 occurred in March 1996, when operators had incorrectly directed the

opening e'. a containment isolation valve (resulting in a loss of containment

integrity) during core alterations. This event was discovered and reported to

the NRC in LER 96-005-00 (WCNOC Letter Number WO 96-0096, issued on June 19, ,

1996).

'

Reason for Violation

Root Cause and Contributing Factors:

In addition to the root cause and contributing factor, as documented in LER

96-005-00, the following contributing factor has been identified:

1

System Operating Procedure SYS BM-201, " Steam Generator Draining," failed to !

clearly establish initial conditions necessary to allow the draining of the

steam generators. Because this contributing factor was not identified the

responsible personnel failed to perform a review to determine if other similar

procedures failed to establish adequate initial conditions prior to

performance of required actions.

Corrective Stecs Taken and Results Achieved i

l

In addition to the corrective actions documented in LER 96-005-00, the I

following corrective actions have been implemented:

A review was conducted of similar procedures and two additional procedures

needed revision. They are:

1

1. SYS EF-420, " Draining ESW Trains"

2. SYS EG-401, " Component Cooling Water System Drain Procedure" i

The procedures will be revised by December 31, 1996.

The errors associated with the initial root cause evaluation were discussed

during a group meeting with the Operations' Support Staff.

Attachm:nt to WM 96-01'J7

/ Pega 4 of 7

Safety sianificanen

The water drainett from Steam Generators B and C was non-radioactive, secondary

system water. Valve BM-V046 was open for one hour and twenty-four minutes.

During that time, the flow of water varied and, toward the end of the event,

flow reduced to a trickle. Dee to the piping configuration and atmospheric

conditions in bots buildings, loop seals formed during the draining process

and no direct air to air access occurred. Additionally, no fuel handling

accident occurred during this time, and no increase of radioactivity was noted ,

by the containment radiation monitors. The health and safety of the public j

and plant safety were assured during this event. I

l

j

4

1

l

I

l

y'

Attcchm:nt to WM 96-0137

l Paga 5 of 7

Violation 50-482/9618-04: The incorrect performance of a portion of the

surveillance requirements specified by Technical

Specification 4. 8.1.1.2.g (6) (c) , while at power.

C. Technical Specification 4 . 8 .1.1. 2 . g . ( 6 ) . ( c ) requires testing

during shutdown to verify that all automatic diesel generator

trips except those that remain during emergency operation be

automatically bypassed upon loss of voltage on the emergen#: / bus

concurrent with a safety injection actuation signal, once 1er 18

months.

Contrary to the above, on July 23, 1996, while the plant was at

approximately 100 percent power, technicians performed Work

, Packages 114086 and 114087, which accomplished a portion of the ,

surveillance required by Technical Specification i

4. 8.1.1. 2.g . (6 ) (c) . " l

Admission of violation

l

WCNOC acknowledges and agrees that a violation of Technical Specification j

3.8.1.1 occurred on July 23, 1996, when technicians performed Work Packages l

'

114086 and 114087, in an attempt to meet the testing requirements of Technical

Specification 4. 8.1.1.2.g (6) (c) . This evt.nt was self discovered and reported

to the NRC in LER 96-007-00.

Reason for Violation:

Root Causes:

The root causes of this event were determined to be:

1. Inadequate pre-job briefing: During the pre-test review and discussion

between the shift supervisor and system engineering, the technical

speciff<: tion requirement that this testing be performed *during shutdown"

-

was not considered. The decision, that the work package testing was

equivalent to Surveillance Procedure STS KJ-001A, ' Integrated D/G and

Safeguards Actuation Test-Train A," which can only be performed when

shutdown, was incorrect.

1. Tne failure to establish adequate administrative controls: AP 29B-003,

" Surveillance Testing," allows credit for meeting surveillance requirements

by alternate means. Section 6.2.3 of this procedure provides guidance for

situations where " tests / events" may be approved as satisfying technical

specifications. These guidelines require the designation of a * Test

Performer" who is responsible for reviewing the test / event for credit.

This review, as described in the procedure, only requires the Test

Performer to compare the test / event to the plant procedure incorporating

the same requirements. In this case, the work package test was c.ampared to

only a single section, Attachment M - Step Mll, of STS KJ-001, and found to

e meet the requirements for that step of the procedure. This comparison was

used as the basis for taking credit for meeting the technical specification

surveillance requirement. The procedure did not require review of the

applicable technical specification requirements.

. . . . . - - . - - . - - - .- . . , - . . - - - - + - - . _ - . - . . - . - . . .

.- !

, Attachm:nt to WM 96-0137

f Pega 6 of 7 i

<

'

3. An inappropriate organizational culture Following recognition that the

<

technical specifications required the testing to be performed "during l

shutdown,"- WCNOC personnel justified . the acceptability of this testing i

,

based. on compliance with the perceived intent of the technical ;

i specifications. The basis clearly acknowledged that the testing did not *

'

achieve verbatim compliance with technical specifications. ,

"

!

2 Corrective Actions Taken And Results Achieved: ,

, i

1. On November 6, 1996, the Chief Operating Officer issued Letter WO 96-0146,

l " Compliance With Requirements." This letter clearly communicated, to all i'

personnel, the requirement regarding literal compliance with Title 10 of

the Code Of Federal Regulations, technical specifications and the Updated )

,

Safety Analysis Report. 1

i

1 Corrective Stoos That Will Be Taken And The Date when Full Compliance Will Be

3 Achieved:

) 1. The process of taking credit for meeting surveillance requirements by

alternate means, as detailed in AP 29B-003 will be evaluated and revised to

j limit the use of " credit sheets." The use of work package tasks, or other

i documents not subject to the review and approval requirements for

i Surveillance procedures, will be prohibited. A detailed review of

4

applicable Technical Specification requirements will be required as part of

the " credit" process.

i

,

2. Applicable operations procedures will be reviewed and revised as necessary

j to require that any testing to satisfy surveillance requirements on

4

inservice equipment be performed in accordance with an approved procedure. l

(Similar to controls currently in place for maintenance on inservice d

j equipment - reference AP 16-001, " Control of Maintenance," section 6.6.2-4,

and AP 16C-003, " Work Package Task Planning," section 6.2.3.1).

!

3. LER 96-007 will be revised to address that the testing performed on July

'

i 23, 1996, which was a corrective action for the failure to perform this

surveillance during refueling outage VIII, did not fulfill the requirement

to perform the test "during shutdown," but did demonstrate operability of

j the emergency diesel oenerator volts / hertz relays. l

The above discussed actions will be completed by January 31, 1997.

i

'

safety sienificance: l

) The failure to perform the post modification operability testing did not :

. result in any adverse consequences to the plant. No systems were rendered

i inoperable, and no equipment was damaged. The relays were individually tested

l upon completion of the modification installation process to assure their

functionality. The post-modification testing performed on July 23, 1996,

demonstrated the relays were correctly installed and were operable. Based on

the results of the testing WCNOC is confident that if a condition had occurred

f between the time of installation and the time of testing, the relays would

have been bypassed and the EDGs would have started and functioned as required.

a

1

4

__

_

_ . - - . . - . _ _ _ - ~ . - _ . - - . . - _ . - . . _ ~ - . - . . - _ . - ~ - - ~ - - - _

_ .

- - . . ,

l,

Attachmsnt to LH 96-0137

p Paga 7 of 7

Violation 50-482/9618-07: The failure to perform required post f

modification testing.

i ]

i

"D. Technical Specification 4. 8.1.1. 2.g . (6 ) . (c) requires testing I

during shutdown to verify . that all automatic diesel generator

trips except those that remain during emergency operation be l

automatically bypassed upon loss of voltage on the emergency bus. j

concurrent with a safety injection actuation signal, once per 18 !

months. j

!

Contrary to the above, on July 23, 1996, the licensee found that j

the required testing had not been performed for the volts per i

L hertz relays which had been installed in the two emergency diesel

generator control circuits during Refueling Outage VIII in ,

February 1996."

W ssion of Violation:

WCNOC acknowledges and agrees that a violation of Technical Specification 4.8.1.1.2.g. (g) . (c) . occurred during Refueling Outage VIII, when WCNOC failed

to perform the require post modification testing on the volts / hertz relays

prior to returning to power. This event was self discovered and reported to

i the NRC in LER 96-007-00 (WCNOC. Letter Number WO 96-0118, issued on August 22, 1

l 1996).

l l

l EggmRD for Violation (Root Cause) and Corrective Steps Taken and Results

!

L Aeved

, LER 96-007-00 describes the root cause and corrective steps taken and results

!

achieved.

Safety Sicrnificance :

1

t The failure to perform the post modification operability testing did not

result in any adverse consequences to the plant. No systems were rendered

inoperable, and no equipment was damaged. The relays were individually tested

l

upon completion of the modification installation process to assure their

l functionality. The post-modification testing performed on July 23, 1996,

demonstrated the relays were correctly installed and were operable. Based on !

the results of the testing WCNOC is confident that if a condition had occurred f

l

between the time of installation and the time of testing, the relays would

have been bypassed and the EDGs would have started and functioned as required.

l

1

!

l

!

i

_. , _ - -

, , , . _ - _ ,. ._. , , . - _xr

ML20132H191

Text

Navigation menu

Search