ML20246M123

Ack Receipt of 890413 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-482/89-07. Understands That Position Revised Re Reason for Violation Concerning Impact of Temporary Mod on Continous Alarm Sys

ML20246M123
Person / Time
Site:	Wolf Creek
Issue date:	05/10/1989
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Withers B WOLF CREEK NUCLEAR OPERATING CORP.
References
NUDOCS 8905190049
Download: ML20246M123 (2)

See also: IR 05000482/1989007

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MAY l 01989 -

u In Reply Refer To:

. 3 . Docket

STN 50-482/89-07

Wolf Creek Nuclear Operating Corporation

- ATTN: Bart D. Withers

President and Chief Executive Officer

P.O. Box 411

Burlington, Kansas 66839

Gentlemen:

Thank you for your letter of April 13, 1989, in response to our letter and the.

- attached Notice of Violation dated March 15, 1989. As a result of our review

and the telephone conversation with Mr. Otto Maynard and other members of

your staff on April 26, and May 4,1989, we understand that you have revised

your position concerning the reason for Violation 482/8907-01'and that now you

agree that the temporary modification did impact the continuous alarm system

associated with the battery.

We request that you provide the following additional information:

1. Instructions, guidance, and/or training that will be provided to

individuals that prepare and review safety evaluations and report

responses to assure that they understand the revised procedure

(ADM 01-022) and other measures you have taken to prevent recurrence

of this type of issue.

2. The results of the reevaluation of the Nuclear Safety Evaluation

(S.E. No. 89-SE-921) considering the effects of the decreased voltage

of the battery bank with a cell jumpered as it is being discharged

under design accident conditions.

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Please provide the supplemental information within 30 days of the date of this

letter.

Sincerely,

Original Signed By

L J. CaUan

L. J. Callan, Director

Division of Reactor Projects

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Wolf Creek Nuclear Operating -2-

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, Wolf Creek Nuclear Operating Corporation

ATTN: Otto Maynard, Manager

-.- .of Licensing

P.O. Box 411

Burlington, Kansas 66839

f Wolf Creek Nuclear Operating Corporation

ATTN

Gary Boyer, Plant Manager

..- P.O. Box-411

Burlington, Kansas 66839 '

Kansas Corporation Comission

ATTN: . Robert D. Elliott, Chief Engineer

Fourth-Floor Docking State Office Building.

Topeka, Kansas 66612-1571

Kansas Radiation Control Program Director

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bec to DMB (IE01)

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'R. D. Martin, RA

_SectionChief(DRP/D) DRP

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R. DeFayette, RIII

RIV File SRI..Callaway, RIII-

MIS System RSTS Operator

Project Engineer (DRP/D) Lisa Shea, RM/ALF

DRS J. E. Gagliardo

D. V. Pickett, NRR Project Manager (MS: 13-D-18)

D. R. Hunter G. Sanborn

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W$LF CREEK NUCLEAR OPERATING CORPORATION

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Bart D. Withers

President and "

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Chief Executive Omcor

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April 13, 19  :-+ . 'h,

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NM 89-0107 g g gggg

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U. S. Nuclear Regulatory Cmmission

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ATIN: Document Control Desk ' ~

Mail Station Pl-137 L ~ ~

Washington, D. C. 20555

Reference: letter dated March 15, 1989 from L. J. Callan, NRC,

to B. D. Withers, NCIOC

Subject: Docket No. 50-482: Response to Violation 482/8907-01

and 02

G3ntimen:

Attached is a detailed response to violations 482/8907-01 and 02 which were

docunented in the Reference. Violation 482/8907-01 involved the failure to

provide a written safety evaluation for a temmmry modification and

violation 482/8907-02 involved the failure of the ' Plant Safety Review

9 Comittee (PSRC) to meet to review the safety evaluations for two temmm_ry

modifications prior to implsentation.

If you have any questions concerning this natter, please contact ne or

Mr. O. L. Maynard of my staff.

Very truly yours, ,

Bart D. Withers

President and

Chief Executive Officer

BDN/jad

Attaciment

cc: B. L. Bartlett (NRC), w/a

D. D. Chamberlain (NRC), w/a

R. D. Martin (NRC), w/a  ;

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D. V. Pickett (NRC), w/a -

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

An Equal Opportunity Empivyer M F/HC/ VET

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Attachment to NM 89-0107

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Page 1 of 3

Violation (482/8907-01): Failure to Provide a Written Safety Evaluaticn

For a Teporary Modification

Findina:

Paragraph (b)(1) of 10 CER 50.59, requires that the licensee shall maintain ,

records of changes in the facility made pursuant to 10 CPR 50.59. The l

records nust incitrie a written safety evaluation which provides the basis

for the determination that the change does not involve an unreviewed safety

question.

Contrary to the above, on Nov m ber 11, 1988, the licensee installed a

tanmrary jumper across Cell 10 of Station Battery NK12 and no written

safety evaluation was provided. The battery cell was jtuuruul at the ti2ne

of the inspection. The tanmrary jumper resulted in a change which reduced.

the tested battery capacity and inpacted the continuous alarm system '

associated with the battery, which is described in Section 8.3.2.2 of the

USAR.

Reason For Violation:

The reason for the violation was a difference of opinion between WCtOC

personnel and the NRC inspector on what constitutes a change in the facility

as described in the Updated Safety Analysis Report (USAR).

j During the 10 CFR 50.59 scmening review perfonned by Results Engineering

personnel, it was determinai"that the tanmmry modification which installed

a t m porary jumper across Cell 10 of Station Battery NK12 did not result in ,

a change to the facility or procedures as described in the Updated Safety l

Analysis Report (USAR). This determination was based on the USAR not

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explicitly describing the number of cells in the battery, even though, USAR

Figure 8.3-6 identifies battery NK12 as having a battery capacity of 900

Amp-Hrs. Mditionally, the temporary modification did not impact the

continuous alann systan associated with the battery. Therefore, the I

screening review resulted in an interpretation that a written safety

evaluation was not required for this tunmrary modification.

Corrective Steps Which Have Been Taken And Results Achieved

A written safety evaluation (89-SE-021) was performed on the temporary

modification with no unreviewed safety question being identified. The

safety evaluation has been reviewed by the Plant Safety Review Ccumittee.

, Corrective Steps Which Will Be Taken To Avoid Further Violations:

A revision to Procedure ADM 01-022, " Authorization of Changes, Tests, and

Experiments (10 CFR 50.59)" was implemented to clarify when a written safety

evaluation should be initiated when the USAR description is general in

nature and the change can not be easily detennined to affect the 10 CFR

50.59 Section (a)(i) criteria.

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At'tachnent to NM 89-0107

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Other NCNOC p uceslures will be reviewed and revised as agu.vgiate to j

incw.au. ate the ab:me conservative approach.

Date When Full Catoliance Will Be Achieved:

The review and revision, asaa u.vplate, . of Mcanes will be coupleted on

or before Septaber 15, 1989.

Violation (482/8907-02): Failure of the Plant Safety Review CL2mtittee

(PSRC) to Meet to Review the Safety Evaluaticms

For 'IWo Tatoorary Modifications Prior to

Inolementaticn

Findina:

Technical Specification 6.5.1 requires that a quorum of PSRC Inmi;ers shall

meet as convened by the PSRC Chaire n to advise the plant snager on all

m tters related to. nuclear safety. Technical Specification 6.5.1.6.d

requires that the PSRC shall be responsible for the review of all safety

evaluations performed under the provision of Section 50.59(a)(1) of 10 CFR

50, for changes to the facility.

Contrary to the above, the licensee mde two changes to the facility,

'Ibuporary Modification (TO) 86-65-GK (86-SE-87) installed on June 20, 1986,

9 and 90 87-006-BB (87-SE-003) installed on Novenber 01, 1987, without the

benefit of a meeting by a quorum of PSRC rmW convened by the PSRC

chainnan. Rather, the review of the two nos and associated safety

evaluations was conducted utilizing a " serial review" sheet (walk around and

telephone calls) by nanbers of the PSRC, and the PSRC chairmn prior to the

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installation of the 2 0.

Reason For Violation:

The Plant Safety Review Ccumittee has previously perfoured reviews of the

itens required by Technical Specification 6.5.1.7(a) utilizing a quorum of

the md;ces , through a " serial review", either by walk around or via i

telephone. It was believed that this method of review, and approval or I

disapproval, met the regulatory requirements and intent of the Technical j

Specifications.

'Dachnical Specification 6.5.1.7(a) states: "The PSRC shall: Reccmtend in

writing to the Plant Manager approval or disapproval of iters considered  !

under specification 6.5.1.6(a) through d and m above,". Re-evaluation of

this criteria has identified that a serial review my not now meet the

intent of this 'Itchnical Specification.

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AktbchmenttoWM 89-0'107

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Corrective Steps Which Have Been Taken And Results Achieved:

As a result of the re-evaluation of the Technical Specifications, the serial

ruview process performed by the PSRC has been eliminated.

Administrative procedure ADM 01-002, Revision 20, " Plant Safety Review

Cm mittee", has been revised to state; "A meeting does not require the

physical presence of the quorum at one location. It may be performed by a

Conference Call among.a quorum." Additionally, the procedure now states;

" Safety Evaluations should not normally be Conference Call Reviewed. During

normal working hours the PSRC should ccnvene in a special meeting to. review

as a cm mittee a safety Evaluation. Conference Call Reviews performed

outside of nonnal working hours, should include, when available, a quorum of

related technical expertise, i.e., Manager NPE Wolf Creek for temp mods; and

the Cognizant Manager. Additionally, the SE should be subsequently reviewed

at the next regularly scheduled PSRC meeting by the conmittee."

Corrective Steps Which Will Be Taken To Avoid Further Violations:

The above corrective steps will provide for the appropriate review by the

PSRC and will avoid further violations;

Date When Full Canpliance Will Be Achieved:

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Full compliance has been achieved.

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