ML20217N980

Responds to NRC Re Violations Noted in Insp Rept 50-482/98-04.Corrective Actions:Revised Surveillance Test Procedure STS SF-001 to Provide Enhanced Guidance on Applicability of TS 3.1.3.5 & 3.1.3.6

ML20217N980
Person / Time
Site:	Wolf Creek
Issue date:	04/28/1998
From:	Maynard O WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-482-98-04, 50-482-98-4, ET-98-0025, ET-98-25, NUDOCS 9805060015
Download: ML20217N980 (6)

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e W4PLF CREEK NUCLEAR OPERATING CORPORATION Otto L Maynard President and CNef Executive Officer April 28, 1998 WM 98-0025 U. S. Nuclear Regulatory Commission ATid: Document Control Desk Mail Station Pl-137 Washington, D. C. 20555

Reference:

Letter dated April 1, 1998, from T. P. Gwynn, URC, to O. L. Maynard, WCNOC

Subject:

Docket No. 50-482: Reply to Notice of Violations 50-482/9804-01, 50-482/9804-03, and 50-482/9804-07 Gentlemen:

This letter transmits Wolf Creek Muclear Operating Corporation's (WCNOC) reply to Notice of Violations 50-482/9804-01, 50-482/9804-03, and 50-482/9804-0/.

Notice of Violation 50-482/9804-01 identified that WCNOC Operations personnel performed a technical s;>eci ficat ion surveillance on the centrol rod shatdown banks that required entry into the Limiting Condition for Operaticn (LCO) for the specification, but the procecure did not indicate entry into the LCO was required and the Operators did not log the entry into the control room log.

Notice of Violation 50-482/9804>u3 identified ineffective correct ive actions on an LER concerning surveillance testing on a staggered test basis. The inspection report indicated that no response is regaired for this violation.

Notice of Violation 50-482/9804-07 identified weaknesses in the radiation protection program and in individual radiation worker performance that resulted in two examples of noncompliance with radiation work permit requirements. WCNOC's response to these violations is provided in the Attachment.

If you have any questions concerning this matter, please contact me at (316) 364-8831, extension 4000, or Mr. Michael J. Angus, at extension 4077.

Very truly ycgrs,

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fj)Yl Y Otto L. Maynard OLM/rlr Attachment cc: W. D. Johnson (NRC), w/a E. W. Merschoff (NRC), w/a J. F. Ringwald (NRC), w/a K. M. Thomas (NRC), w/a 9805060015 980428 /

PDR ADOCK 05000482 -

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. e v# PO. Box 411/ Burlington. KS 66839 / Phone: (316) 364-8831 An Equal Opportundy Employer M F'HC VET

f Kttachment to WM 98-0025

• Page 1 of 5 Response to Notice of Violations I l

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i violation 50-482/9804-01

" Technical Specification 6.8.la requires, in part, that written procedures be established, implemented, and maintained covering the applicable procedures j recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.  !

Regulatory Guide 1.33, Revision 2, February 1978, Section 2, recommends, in part, that procedures be established for general plant operations.

Technical Specification 3.1.3.5 states that, 'All shutdown rods shall be j limited in physical insertion as specified in the Core Operating Limits Report' in Modes 1 and 2. The core operating limits report limits shutdown j rod insertion to no less than 222 steps. The action statement associated with i Technical Specification 3.1.3.5 limits the number of shutdown rods inserted l beyond the insertion limit to a maximum of one rod, except for surveillance l testing pursuant to Technical Specification 4.1.3.1.2. The action statement I requires that rods be restored to within the rod insertion limit within 1 l hour.

Procedure AP 21-001, ' Operations Watch Standing Practices,' Revision 8,

, requires that all entries into short-term limiting conditions for operation be l logged in and out of the control room log.

Contrary to the above, on February 18, 1998, operators failed to log entry into the action statement for Technical Specification 3.1.3.5 for shutdown rods inserted beyond the rod insertion limits. l This is a Severity Level IV violation (Supplement I)(50-482/9804-01)."

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! Description of Violation:

l WCNOC Control Room personnel failed to acknowledge entry into the Action Statements for Technical Specifications 3.1.3.5, SHUTDOWN ROD INSERTION LIMIT, and 3.1.3.6, CONTROL ROD INSERTION LIMITS, when performing testing in accordance with Technical Specification Surveillance Requirement 4.1.3.1.2.

The failure to log the entrance into the Technical Specification Action l Statements 3.1.3.5 and 3.1.3.6, represented no safety significance. This is based on the information contained within the Action Statements for Technical i

Specifications 3.1.3.5 and 3.1.3.6. Specifically, the Action Statements for l Technical Specifications 3.1.3.5 and 3.1.3.6 exempts the operators from having to take any actions as long as surveillance testing pursuant to Technical Specification 4.1.3.1.2 is being performed.

Reason for Violation:

This violation was determined to be the result of a failure to develop adequate procedural guidance within surveillance test procedure STS SF-001,

" Control And Shetdown Rod Operability Verification." Specifically, this procedure did not alert the implementers that the associated testing activity would result in an entry into the action statements for Technical Specifi catj ons 3.1.3.5 and 3.1.3.6. The wording of Technical Specifications 3.1.3.5 and 3.1.3.6 are unique in nature. No other WCNOC technical specification contains an exception statement within an action statement. '" h e failure to adequately develop STS S F-001 is an isolated case and does not i

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Nttachment to WM 98-0025

, Page 2 of 5 Response to Notice of Violations represent a generic concern. A contributing factor was determined to be the failure of the Control Room Personnel to identify the applicability of i Technical Specifications 3.1.3.5 and 3.1.3.6 and to log entry into these action statements.

i Corrective Steps Taken and Results Achieved: 1 STS SE-001 was revised to provide enhanced guidance on the applicability of Technical Specifications 3.1.3.5 and 3.1.3.6. This activity was completed on March 31, 1998.

As a good practice, management expectations on 1) reviewing all applicable technical specifications before the performance of an activity, 2) literal compliance to all applicable specifications, and 3) compliance with all established (both programmatic and technical) requirements were reinforced with Control Room personnel. This activity was completed on March 10, 1998, during the Shift Supervisor's Meeting.

Corrective Steps To Be Taken:

Operations' Management will issue an essential reading assignment to .11 licensed individuals to ensure the events surrounding this issue, the associated corrective actions, and management's expectations associated with logging Technical Specification action statements entered due to surveillance testing, are clearly understood. Further, this reading assignment will stress the importance of reviewing surveillance procedures for applicability of other Technical Specifications during the performance of the surveillance. The projected completion date of this activity is May 31, 1998.

Date When Full Compliance Wi]1 Be Achieved:

Full compliance was achieved on March 20, 1998, when Cont r s . Room Personnel appropriately logged into the Control Room Log entry into and exit from Technical Specifications 3.1.3.5 and 3.1.3.6 during the next scheduled performance of STS SE-001 (a monthly surveillance).

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Attachment tc WM 98-0025

. Page 3 of 5 Response to Notice of Violations violation 50-482/9804-03 "rechnical Specifications 4.7.1.2.1.a and 4.8.1.1.2 require surveillance tests on the auxiliary feedwater pumps and emergency diesel generators be performed on a staggered test basis.

Contrary to the above, between August 1994 and May 1990, the licensee failed to perform surveillance testing on the auxiliary feedwater pumps and emergency j diesel generators on a staggered test basis.

This is a Severity Level IV violation (Supplement I)(50-482/9804 03)."

WCNCC Response Inspection Report 50-482/98-04 states that Licensee Event Reports 50-482/96-  !

009-00 and 50-482/96-009-01 adequately addressed the corrective actions taken and planned to correct the violation and prevent recurrence and the date when full compliance wa< achieved. The inspection report also indicates that no additional response is required for this violation unless the referenced licensee event reports do not accurately reflect WCNOC's corrective actions for, or position on, this issue. WCNOC has determined that the referenced )

licensee event reports accurately describe our corrective actions and position j on this issue and that no additional response is required. 1 i

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1 Attachment to WM 98-0025 l

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Response to Notice of Violations j violation 50-482/9804-07 ,

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" Technical Specification 6.11 requires, in part, that radiation protection l technicians and workers adhere to procedures for personnel radiation protection consistent with the requirements of 10 CFR Part 20.

Administrative Procedure AP 25B-100, Radiation Worker Guidelines, Revision 5, l Section 6.3.6, requires individuals to comply with radiation work permit requirements.

Radiation Work Permit 98009, Revision 0, required intermittent health physics coverage and required the radiation worker to avoid all posted hot spot locations.

Contrary to the above, on February 18, 1998, l

a. A quality control inspector worked within 18 inches of two posted l hot spots for approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, and i

b. No health physics coverage of the work was provided during this 3- ,

hour period.  !

This is a Severity Level IV violation (Supplement IV) (50-482/9804-07) ."

Description of Violation:

A Quality Control (QC) inspector involved with work in Containment Spray Room "A" was working near a posted hot spot, not utilizing As Low As Reasonably Achievable (ALARA) principles. Investigation identified that the QC inspector

.did not check in with the Health Physics (HP) Shift Technician for a briefing of radiological conditions. The individual was not aware of the dose rates in the area and did not check the survey map at the entrance to the "A" Containment Spray Room. Radiation Work Permit (RWP) 980009, under Special Instructions 3, states: " Avoid all posted hot spot locations." The worker was not aware of the hot spots.

Therefore, the individual did not meet the Radiation Worker expectation of knowing the expected dose rates and contamination levels encountered. The individual did not conform to AP 25B-100, " Radiation Worker Guidelines," steps 5.3 and 6.1.9.

Reason for Violation:

The QC inspector failed to meet the expectations of RWP 98-0009, specifically Special Instruction 3, which states: " Avoid all posted hot spot locations."

The QC inspector did not adequately review the survey map prior to entering the area and was unaware of the radiological conditions in the work area. As a result, the QC inspector performed work in close proximity to a posted hot spot area and, due to not checking in with the HP Shift Tech, intermittent HP l coverage was not provided. When the QC inspector noted the posted hot spots on the piping he did not challenge the ALARA aspects of the situation by asking Health Physics to evaluate the working conditions. Therefore, both aspects of this violation were the result of inadequate work practices on the part of the QC inspector.

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, Attachment to WM 98-0025

• • Page 5 of 5 Response to Notice of Violations Corrective Steps Taken and Results Achieved:

The' QC inspector's RCA access was revoked on February 19, 1998, pending completion of the investigation. On March 19, 1998, the QC inspector was disciplined in accordance with WCNOC policy. This issue was reviewed with the QC inspector and the Supervisor QC by the Manager Chemistry / Radiation Protection. . Based on this discussion, the QC inspector's RCA access was re-established on March 20,,1998.

.The importance of proper Radiation Worker Practices was re-emphasized to QC personnel during a group meeting on February 20, 1998.

. Corrective Steps To Be Taken:

No additional corrective actions are required.

Date When Full Compliance Will Be Achieved:

Full compliance was achieved on February 18, 1998, once the QC inspector left the work area of concern and was no . longer in violation of the RWP requirements.

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