ML20202E917
| ML20202E917 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 12/11/1997 |
| From: | Houck H AFFILIATION NOT ASSIGNED |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20202E915 | List: |
| References | |
| FOIA-97-480 NUDOCS 9802190088 | |
| Download: ML20202E917 (2) | |
Text
. -.
........o 6,..
- 4.,
h 9.i.*
i'
-1 LAW OFFsCMB OF j
rusmani, onAwAvon a smarra, r.A.
ese sAmmas Awarum NATsOm Townputts loss 6iWin,1 termsA, mANees eseconeees cansmas a, re.nsa.an.
=== w..a==w i,.
v= =ee. *ssa
===.
a==ev=n-a =
%m.
fina==w 11,1997
/GWPA REQUEST
.mtio; 97-4fC -.
. to Rc:'&
) 3 -It. - 9 L -
". den Oih f& cl MM C1w' no Unhed Seems Nuclear Regulatory Comunisalon ATTN: Fmedem ofInfonast'on Act ofBoer RegionIV ome.
511 Ryan Plean Dr Suhe 400 ArlingtonTX 760118064 Re:
Freedom ofInformation Act Request Our File No. 2217.0 Facility:
Wolf Creek Generadng stadon License No:
NPF 42 Licensee:
Wolf Creek Nuclear operadon Corporation Docket No:
50-482
Dear Sir / Madam:
De purpose of this letter is to request fkom your agency's Freedom ofInfonnation Act Officer a copy of all documents in its possession, custody, and control of the Nuclear Regulatory Commission (NRC) that fall into any of the following categories:
1.
NRC Inspeedon Report or Notice of Violation sogarding compliance or fallas of complisace with any wage and hour or over time rules, reguladons, or statutes.
2.
All conospondaaaa with or 60m the Wolf Creek facility, any subsidiary corporations or its agents regarding compliance or failure of compliance with any exempt personnel over-time use, violations of any wage and hour statutes, rules, or regulations, or over time problems concoming non-exempt personnel.
3.
All representations, certifications, or opinions in coru,ection with compliance or noncompliance with over time personnel use.
4.
Any information concoming Fair Labor Standards Act exempt employees being requested to record only forty (40) hours of work per week.
9 2190088 990212 FOIA
_..,,K97-400 PDR u
...a.
,... a,~.
. u a.,
2--
o l
I De United seiles Nuoleer Regulatory Commission Freedom oflaibunadan Act Omoor I
Pogs 2 Doesunbar 11,1997 5.
Any information conoeming on call or beeper duty time in violation of over-time futuirements.
6.
NRC Inspection Raport 504g2/94-12.
7.
NRCInspection Raport 504g2/9710.
I'm requesting theos documsats pusuant to the Freedom ofInfonnation Act,5 U.S.C. I 552 g agg. and its regulations issued thereunder. I would like the information as soon as possible. If you have any questions or nood any additional intbrmation, please do not hesitate to contact me airectly.
I understand that this request requires payment of a reasonable search fee and an appropriate charge per page for photocopying. I will expect billing at the tirre of delivery of the copies.
I appssoises your prompt steention to this maner.
[
Harold A.Houck FISIER, CAVANAUGH & SMITH, P.A.
HAlbn
f/
'g NUCLEAR RE2ULATORY COMMISSION
_)
CE lON IV c
7 g
$*1 RYAN PLAZA DRIVE.SulTE 400 ARLINGTON, TEXAE 760114064 October 28, 1994 Docket:
50-482 License:
NPF-42 Wolf Creek Nuclear Operating Ccrporation ATTN: Neil S. Carns, President and Chief Executive Officer P.b. Box 4fl Burlington,- Kansas 65839
SUBJECT:
NRC INSPECTION REPORT 50-482/94-10 This refers to the inspection conducted by Mr. J. F. Ringwald of this office on-August 14 through September 24, 1994. The inspection included a review of activities authorized for your Wolf Creek Generating Station facility. At the conclusion of'the inspection, the findings were discussed with those members of your staff identified in the enclosed report.
Areas examined during the inspection are identified in the report.
Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observation of l
activities in progress. The purpose of the inspection was to determine whether activities authorized by the license were conducted safely and in accordance with NRC requirements.
l j
Based on the results of this inspection, one unresolved item was identified as discussed in Section-2.2, 2.3, and 2.4.
This unresolved item involves further NRC-review of licensee corrective actions and further review of licenrae performance related to procedural adherence and control room personnel control and cognizance of activities which have the potential to impact plant conditions.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enclosures will be placed in the NRC Public Document Room.
The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No. 96.511.
f v (
b
% =e w
n
e Wolf Creek Nuclear Operating Corporation Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely,
/s/
A. Bill Beach, Director Division of Reactor Projects
Enclosures:
1.
Appendix A - Notice of Violation 2.
Appendix B - NRC Inspection Report 50-482/94-10 cc w/ enclosures:
Wolf Creek Nuclear Operating Corp.
ATTN:
Vice President Plant Operations P.O. Box 411 Burlington, Kansas 66839 Shaw, Pittman, Potts & Trowbridge ATTN: Jay Silberg, Esq.
2300 N Street, NW Washington, D.C.
20037 U.S. Nuclear Regulatory Commission ATTN:
Regional Administrator, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Wolf Creek Nuclear Operating Corp.
ATTN: Manager Regulatory Services P.O. Box 411 Burlington, Kansas 66839 Missouri Public Service Commission ATTN: Assistant Manager Energy Department P.O. Box 360 Jefferson City, Missouri 65102 Kansas Corporation Commission ATTN:
Chief Engineer Utilities Division 1500 SW Arrowhead Rd.
Topeka, Kansas 66604-4027
L.:
1.~.
i
^
- t
-Wolf Creek Nuclear Operating - Corporation Office of the Gevernor State of Kansas Topeka, Kansas -66612
- Attorney General Judicial Center 301 S.W. 10th 2nd Floor:
-Topeka, Kansas 66612-1597 County. Clerk-
- Coffey County Courthouse-Burlington, Kansas 66839-1798 Kansas Department of Health and Environment Bureau of Air & Radiation ATTN:- Public Health Physicist Division of Environment Forbes Field Building 283
. Topeka, Kansas 66620 I
W
0 APPENDIX U.S. NUCLEAR REGULATORY C0HNISSION REGION IV NRC Inspection Report:
50-482/94-10 Operating License: NPF-42 Docket: 50-482 Licensee: Wolf Creek Nuclear Operating Corporation P. O. Box 411 Burlington, Kansas 66839 Facility Name: Wolf Creek Generating Station Inspection At: Coffey County, Burlington, Kansas Inspection Conducted: August 14 through September 24, 1994 Inspector:
J. F. Ringwald, Senior Resident inspector
/s/
10/28/94 Approved:
D. D. Chamberlain, Acting Chief, Date l
Project Branch B, Division of l
Reactor Projects Inspection Summar_y Areas Inspected: Routine, unannounced inspection, including plant status, operational safety verification, maintenance observations, survaillance observations, onsite engineering, plant support act.ivities, preparation for refueling, and onsite review of a licensee event report (LER).
Results:
Plant Operations Operations performance was generally good with two noteworthy exceptions. The first example occurred when operators failed to maintain awareness of the residual heat removal (RHR) system lineup and inadvertently pumped most of the pressurizer inventory to the refueling water storage tank (RWST), partially depressurizing the reactor coolant system (RCS). The second example occurred when operators failed to restore the correct radiation monitor, and concurrent instrumentation and control (I&C) testing caused an inadvertent engineered safety features (ESF) actuation (Section 2.2).
The RCS inventory loss event was particularly noteworthy because it occurred approximately 1 day following the reactor shutdown for refueling and could have led to a challenge to RHR.
V'!!!P 70:3C
/ f PP
. While these examples represent operator errors, it is important to note that work scheduling also had a role in the RCS inventory loss event as discussed under maintenance results.
Further, the second event occurred during a period of very high operations activity requiring operators to be particularly vigilant.
In addition, the inspector identified two apparent examples involving the failure of supervising operators to follow administrative procedure requirements regarding procedure use and adherence (Section 2.3 and 2.4). An unresolved item was-identified related to the above noted activities.
pending further NRC review of licensee corrective actions and further review of licensee performance related to procedural adherence and control room personnel control and cognizance of activities which have the potential to impact plant conditions.
Operations continued to maintain generally high standards of control room professionalism and shift turnovers (Section 2.1).
The inspector identified one noncited violation when operators failed to follow an alarm response procedure (Section 2.3). Operators responded properly to source rr,e nuclear instrument failures (Section 2.5).
Operators failed to maintain aW copriate control of the pressurizer relief tank (PRT) drain valve as it was operated by electricians, resulting in overflowing the containment normal sump, Maintenance Maintenance performance was generally good, with several. examples of good maintenance practices noted (Sections 3.1, 3.2, 3.3, 3.4, 3.5, t.nd 4).
Poor scheduling of a packing leak repair on a motor-operated valve contributed to the RCS inventory loss event (Section 2.3).
The removal of a temperature switch for calibration without any documentation of lifted leads or the switch removal suggests that this level of reliance on skill of the craft provides few barriers to problems such as personnel error. Despite technicians' poor radiation worker practice, their recognition of the poor radiation worker practice and recognition of inadequate work instructions represents good questioning by the worker and a refusal to proceed in the face of uncertainty.
The inspector's identification of weak worker safety practices underscores the nesd for greater worker familiarity and compliance with safety rules (Sections 3.5 and 4.2).
Enaineerina Engineering performance and support to operations were generally good.
The engineering evaluation of the recycle hold up tank (RHUT) and engineering evaluations of Technical Specifications (TS) operability demonstrated strong engineering support to operations (Section 5).
Plant Support Plant support performance was generall.y good.
No evidence of the previously identified declining performance in the security area was noted during this inspection period.
Radiation work permits (RWPs) effectively controlled work l
. in the restricted area (Section 6.1).
A chemistry procedural deficiency resulted in an otherwise properly performed gaseous radwaste release, causing a process radiation monitor alarm (Section 6.2).
A supervisory error resulted in the necessity for administrative authorization for contract health physics (HP) technicians to work overtime in excess of administrative limits specified by TS.
The licensee's response to this issue resulted in improved documentation whenever work in excess of administrative overtime limits is needed.
Management Overview Several observations of good performance indicated that management action has improved or maintained good performance in several areas. Control room standards of professionalism remained high. An I&C technician recognized personal and work instruction errors and refused to proceed in the face of uncertainty.
Engineering support of operations remained good.
Licensee response to issues represented good sensitivity to problem areas and generally good corrective actions.
Observations of poor performance indicated that management actions have not been consistently effective at improving performance. Operator lack of cognizance of activities having the potential to affect plant conditions l
resulted in a rapid loss of RCS inventory. A second example of operator lack j
of cognizance resulted in an inadvertent ESF actuation.
The scheduling of work having the potential to affect the only operating RHR train at a time when it was not necessary caused additional burden on the operators and I
contributed to this event. Operators failure to follow their alarm response procedure, poor radiation worker practices, and workers' failure to follow safety rules are examples where management's expectations were not met.
Operator loss of control of plant components operated by nonoperations workers, HP supervisory errors leading to the necessity to administratively authorize 23 contract HP technicians working overtime in excess of administra:ive limits, and a deficient chemistry procedure suggest inadequate management involvement in these activities.
Summary of Inspection Findinas:
Unresolved item 482/9410-01 was identified (Sections 2.2, 2.3, and 2.4)./
Inspection Followup Item 482/9410-02 was identified (Section 5.3).-
LER 482/94-007 was closed (Section 8)./
Attachments:
Persons Contacted and Exit Meeting Acronyms
)
. DETAILS 1 PLANT STATUS (71707)
The plant operated at essentially 100 percent power until August 25, 1994, when power was reduced to 93 percent power for main turbine control valve testing.
The licensee held power at 93 percent until September 6, 1994, when operators began the end of cycle coastdown.
The inspector reviewed the coastdown plan, which appeared to be appropriate, and noted that operators followed it. Operators began reducing power in preparations for shutdown and the seventh refueling outage on September 13, 1994. Operators shut down the plant on September 16, 1994.
At the end of this inspection period, the plant was in Mode 6 with the reactor head removed.
2 OPERATIONAL SAFETY VERIFICATION (71707,93702)
The inspector performed this inspection to ensure that the licensee operated the facility safely and in conformance with license and regulatory requirements and that the licensee's management control systems effectively discharged the licensee's responsibilities for safe operation.
l The methods used to perform this inspection included direct observation of activities and equipment, observation of control room operations, tours of the facility, interviews and discussions with licensee personnel, independent verification of safety system status and TS limiting conditions for operation, verification of corrective actions, and review of facility records.
2.1 Control Room Observations Routine observations of control room personnel were conducted during normal and backshift working hours.
Control room operators exhibited good use of annunciator response procedures, except as discussed in Paragraph 2.3, and good communications techniques between operators.
The operators were alert and limited distractions in the at-the-controls area.
Shift supervisors and supervising operators properly entered and exited limiting conditions for operation. The inspector found licensed operators knowledgeable of each illuminated annunciator.
The inspector observed numerous control room shift turnovers and noted that they were thorough. The offgoing shift notified the oncoming shift of problems, emergent work, and changes in system lineups that occurred during the previous shift. Control board walkdowns, log reviews, and verbal discussions between the operators were thorough.
Abnormal conditions were highlighted and discussed to the satisfaction of both the offgoing and oncoming crew members.
When questioned by the inspector, the oncoming operators were aware of operational occurrences from the previous shift.
l
_a
-b-2.2-Inadvertent ESF Actuation On September 6, 1994, at 3:30 p.m., operators were instructed to restore Radiation Monitor GG RE-27, fuel building exhaust monitor, to service following a filter change.. Operators mistakenly restored Monitor GT RE-22, containment purge exhaust radiation monitor, which had been in bypass for I&C surveillance testing.
At 4:05 p.m., operators received ESF actuation of the control room ventilation isolati9n actt. tion system and containment purge isolation actuation system.
The licen ee initiated Performance Improvement Request (PIR) 94-1468.
The licensee's subsequent investigation revealed that
-the actuation occurred as a result of scheduled and approved I&C technician testing of Monitor GT-RE-22.
The inspector concluded that operators failed to maintain cognizance of I&C surveillance testing and, as a result, restored the incorrect radiation
-monitor, thus allowing the testing to generate the inadvertent ESF actuation.
This appears to ' represent an example of control room personnel not maintaining control of activities which have the potential to impact plant conditions as was the case in the drain down event discussed in Section 2.4.
This matter will remain unresolved pending further NRC review of licensee corrective actions and further assessment of licensee performance related to this event and the drain down event. This will be Unresolved Item 482/9410-01.
2.3 Alarm Response Procedure Not followed On September 8, 1994, the inspector observed that operators had not followed all the required steps of Procedure ALR 00-0618, " Process Rad Hi," Revision 9.
Step 6 of the procedure required operators to direct chemistry to sample, perform dose calculations, refer to the offsite dose calculation manual, and
)
go to 0FN SP-010, " Accidental Radioactive Release," Step 1.
When Radiation I
Process Monitor GH-RE233, gaseous process monitor, alarmed, operators directed chemistry to sample; chemistry stated that sampling was not necessary and the operators agreed.
Since the cause of the alarm was the securing of fans in the radwaste building that caused noble gasses to accumulate near the radiation monitor, the reason chemistry gave for not sampling was valid.
This was, however, not consistent with the procedure requirement, and operators did not follow the administrative procedures to permit them to not follow this procedure as written.
The licensee responded by counselling the shift supervisor and supervising operator regarding the requirements for following procedures and discussing management expectations for following procedures at the next shift supervisor / supervising operator meeting. Operations will also review Procedure ALR 00-061B to determine if it is applicable to all ccaditions that might generate the alarm.
This matter will remain unresolved pending further NRC review of licensee corrective actions and further review of licensee performance related to procedural adherence. This will be reviewed along with the issues discussed in Sections 2.2 and 2.4.
This will be part of Unresolved Item 482/9410-01.
j
6_
2.4-Inadvertent Transfer of Water From the RCS to the RWST On September 17, 1994, with the plant in Mode 4 at approximately 290 F cold leg temperature and 345 psig, operators opened Valve EJ HV8716A, RHR A to safety injection system hot leg recirculation Loops 2 and 3 isolation, with Valve BN V8717, RHR pump to RWST, open causing the RHR Train A pump to transfer approximately 9,200 gallons of water from the RCS to the RWST.
This drained the pressurizer from an almost solid condition to nearly empty, depressurized the RCS to approximately 250 psig, and caused approximately 600 gallons of water to overflow out of the top of the RWST to the liquid radwaste system. Operators responded immediately by isolating letdown, maximizing charging, stopping the two running reactor coolant pumps (RCPs),
and shutting Valve EJ HV8716A.
Operators were filling the pressurizer to establish a solid condition and adjusting RHR Train B boron concentration so it could be declared operable as an additional RCS loop as required by TS 3.4.1.3.
Yo accomplish this, operators were establishing a recirculation lineup for the Train B RHR system with the RHR pump taking a suction on the RWST and discharging through Valve EJ HV8716B and Valve BN V8717 back to the RWST.
Prior to the lineup of RHR Train B, electricians had performed Valve Operation Test and Evaluation System (VOTES) testing on Valve EJ HV8716A. The shift supervisor and supervising operator had previously discussed the necessary conditions for safe V0TES testing on Valve EJ HV8716A and determined that as long as Valves EJ HV8716B and BN V8717 remained shut, Valve EJ HV8716A could be opened l
safely. No caution tags or other preventive measures were taken to ensure that these two valves remained shut during the repeated stroking of Valve EJ HV8716A. During the V0TES testing, a packing leak was noted and mechanics tightened the packing on Valve EJ HV8716A to stop the leak.
Electricians then requested a followup VOTES test to ensure that the packing adjustment did not increase valve stem friction excessively. After operators opened Valve BN V8717, as part of the RHR B recirculation lineup, electricians requested operators to open Valve EJ HV8716A again as part of the VOTES testing. The reactor operator asked and received permission from the supervising operator to open Valve EJ HV8716A and created the unintended flow path. Several annunciators alerted operators to the major transient and operators responded by verifying that letdown was isolated, stopped the running RCPs and stopped the transient by shutting Valve EJ HV8716A approximately 1 minute after it began.
The licensee noted later that the V0iES testing of Valve EJ HV8716A was not scheduled to be performed during that shift and was investigating the reasons for the performance of unscheduled work.
During the event followup, the inspector noted that, after the packing adjustment, part of the valve retest involved the performance of Procedure STS EJ-202, "RHR System Inservice Valve Test," Revision 3.
The inspector's review of this completed procedure revealed that the performer marked Step 5.3 of the procedure "N/A" meaning that the Step was not applicable.
Step 5.3 required the plant to be in Mode 5 or 6 during the performance of this test.
Procedure AP 15C-002, " Procedure Use and l
l
~7-Adherence," Revision 0, step 6.7.5.2, allows omission of step or section if
" Omission of the Step or section does not violate the precautions and limitations stated in the procedure." The precaution and limitation listed in step 2.2.2.5 stated that "RHR valve testing per this surveillance shall be performed in Mode 5 or Mode 6."
In addition, Step 6.3.10 of Procedure AP 15C-002, requires procedure performers to modify existing procedures or develop new ones prior to continuing work whenever a procedure is incorrect or is found to be inadequate for the situation.
The licensee responded by issJing PIR 94-1644. As part of the corrective actions, operations developed a briefing on procedural compliance and the use of N/A as described in Procedure AP 15C-002. This briefing was promptly given to all operating crews, and the licensee planned to give this briefing to all operations personnel involved in the use of procedures.
The licensee also initiated PIR 94-1537 and formed an Incident Investigation Team.(IIT) to review the event. The Vice President Plant Operations stopped all outage work until the plant was stable and management could ensure that outage activities would not impact stable plant operations.
The licensee's investigation revealed that similar events had occurred at Callaway and Wolf Creek in 1983 prior to initial criticality for both units. The only record of the Wolf Creek event was control room log entries.
In addition, as a result of another similar event at Braidwood on March 18, 1990, the licensee had l
added a placard to Control Board RL017 to mimic the location of Valve BN V8717.
After reviewing plant activities, the inspector concluded that the V0TES testing on Valve EJ HV8716A did not need to occur at the time it was performed. The inspector further concluded that, when the decision was made to perform V0TES testing on a component with the potential to affect the only available safety train, the licensee failed to take adequate measures to prevent this testing from impacting that saf'ety train.
This matter will remain unresolved pending further NRC review of licensee corrective actions and further review of licensee performance related to procedural adherence and control room personnel control and cognizance of activities which have the potential to impact plant conditions. The event discussed in Section 2.2 will be included in this review along with the issue discussed in Section 2.3 related to following an alarm response procedure.
This will be part of Unresolved Item 482/9410-01.
2.5 Source Range Instrumentation Noise On September 16, 1994, the licensee declared Source Range Nuclear Instrument Channel 31 inoperable due to high noise.
Operators completed the actions required by TS 3.3.1, Action Sa, On September 17, 1994, the licensee declared Source Range Nuclear Instrument Channel 31 inoperable due to high noise.
Operators completed the actions required by TS 3.3.1, Action 5b, which included opening the reactor trip breakers.
8-When the reactor trip breakers opened, the P-4 contact in coincidence with-low Tave initiated an automatic feedwater isolation signal 'which closed the feedwater isolation, feedwater regulating, and feedwater bypass valves.
Operators reported this ESF actuation within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> per 10 CFR_50.72, and initiated PIR 94-1548.
After evaluating the immediate ramifications of this event and the event described in paragraph 2.4, the_ licensee determined that operators had stabilized the plant, carefully proceeded with establishing RHR Train B as an operable RCS loop as required by TS, verified that the shutdown margin was indeed positive due to the high RCS boron concentration, then proceeded with the cool down and outage activities.
The licensee has-noted enough problems with source range nuclear instrumentation noise that they scheduled replacement of both detectors very early in the work schedule for the 1994 refueling outage. The licensee replaced both detectors on September 20, 1994. The inspector concluded that the licensee's actions immediately following the event and the long-term corrective actions were appropriate.
2.6 Inadvertent Excessive Heatup Rate of the Pressurizer On September 17, 1994, as the licensee recovered from.the event described in L
paragraph 2.4, operators exceeded their pressurizer administrative heatup rate L
limit. Operators energized the pressurizer heaters with the pressurizer.
l nearly full in an attempt to reestablish a bubble so one RCP could be
(
restarted. The operators knew that, without forced circulation of the RCS, there wr sid be uneven heating.
Licensee management had established a conservative administrative pressurizer heatup rate limit of 75*F per hour to minimize thermal stresses on the pressurizer and to provide operators with some maroin to the 100*F in any hour period TS limit. As soon as operators determined that the pressurizer heatup rate was high, they secured the pressurizer heaters.
This action limited the heatup rate to 94.6*F per hour.
The licensee initiated PIR 94-1533 to evaluate the event and provided recoanendations to prevent recurrence.
2.7 Inadvertent Oraindown of the PRT Overflowed the Containment Normal Sumo On September 19, 1994, electricians asked operators for permission to " stroke" Valve BB HV8037A, PRT to containment normal sump isolation. Operators believed this request to mean that electricians would open then immediately close the valve. The electricians opened the valve and left it open until operators received a containment normal sump high level alarm.
By the time operators contacted the electricians and directed them to close the valve, the containment normal sump overfloved.
The licensee initiated PIR 94-1545. The inspector concluded that operators failed to maintain appropriate control of plant equipment manipulated by nonoperations personnel.
._.9
9
_g.
2.8 Conclusions Two examples of a-self-revealing violation occurred when operators failed to mainta?n cognizance of plant. activities. Two examples of a second violation occurred when operators failed to follow plant procedures.
Licensee actions in response to failed source range instruments were appropriate.
Management's establishment of administrative operating limits more restrictive than TS was conservative and appropriate. A significant operational challenge resulted in the operating strategy being ineffective in controlling. pressurizer heatup rate to within this administrative limit. Operators failure to maintain control of the position of the PRT drain valve resulted. in an inadvertent overflow of the containment normal sump.
3 MAINTENANCE OBSERVATIONS (62703)
During this inspection period, the inspector observed and reviewed the selected maintenance and activities listed below to verify that personnel complied with regulatory requirements and licensee procedures that i
included:
receiving permission to start; requiring quality control department
-involvement, proper use of safety tags, proper equipment alignment.and use of jumpers, appropriate radiation worker practices, use of calibrated tools and test equipment; documenting the work performed; and ensuring proper
,postmaintenance testing.
The inspector witnessed portions of the maintenance activities discussed below.
I L
3.1 Control Switch Calibration On September 8, 1994,-the inspector observed I&C technicians perform portions of Procedure STN IC-252A, " Calibration of RHR Pump A Mini Flow Valve Control Switch,"-Revision 2.
The technicians worked well together, used calibrated test equipment, and had a current copy of the procedure with them in the
-field. During the calibration setup, the technicians installed two small reservoirs on both sides of the instrument to provide a volume of water on either side of the bellows.
Personnel had marked the reservoirs with a yellow and magenta posting which stated that the reservoir had internal contamination. HP personnel had not set up a contaminated area and did not provide job coverage. One technician used rubber gloves and a plastic squeeze-bottle with a small piece of tubing out the top to fill the reservoirs with demineralized water.
The technician inserted the tube into the chamber, filled the reservoir, then removed it but did not handle it as potentially contaminated. The inspector questioned this after the lid and tube were removed from the bottle and placed on a multimeter.
The technicians acknowledged that-they had not utilized good radiation worker practices.
The inspector noted that the technicians frisked their hands and the tube and found them to not' be contaminated. -The inspector concluded that this represented weak radiation worker practices.
Later it..he calibration, the procedure required the technicians to remove wires from Terminals 1, 2, 3, and 4 of a barrier terminal block.
After removing the first wire, the technician noted that the terminal block was not
-.. numbered. While that particular step could have been completed, in that the step required the removal of four of four wires, the technicians still stopped and contacted their supervision prior to continuing the calibration. The inspector concluded that this represented a good questioning attitude and a refusal on the part of the technicians to proceed in the face of uncertainty.
3.2 RCS Wide Range Pressure Indicator Replacement On August 31, 1994, the inspector observed I&C technicians perform a portion of the replacement of Indicator BB-PI-406, "RCS Wide Range Press Channel No. 4."
The inspector noted that the technicians used effective work practices, had permission to perform this work, and followed the procedure.
The inspector noted that the retest section of the work request (WR) had not been filled out.
The technicians explained that this would be filled out by the work group supervisor after they completed the indicator replacement. The inspector asked if there was any possibility for the WR to be closed out without a complete retest. The technicians stated that they did not consider this to be a possibility because they routinely discuss retests after the initial portion of the work is complete, The inspector concluded that the work was performed well.
3.3 Spent Fuel Pool Cleanup Pump Isolation Valve Seat Replacement On September 14, 1994, the inspector observed mechanics perform portions of the valve seat replacement for Valve EC V0038, Fuel Pool Cleanup Pump 2A discharge isolation valve, using WR 02554-94.
The mechanics lapped the valve and performed a blue check on the valve disk to confirm good sealing on valve closure.
The inspector noted that the mechanics failed to initial the block indicating completion of Step 7.01 of the WR and Steps 7.1.1 and 7.1.2 of the work signoff sheets. The WR supplemental work instructions stated that the work steps could be worked out of order as long as workers did not change the intent of the work.
Step 7.01 pertained to an inspection of the body-to-bonnet sealing surfaces.
The assistant superintendent of mechanical maintenance stated that this inspection was intentionally delayed until just prior to reassembling the valve so that mechanics could ensure that the sealing surfaces were in good condition upon reassembly. This practice also ensured that workers would notice and repair any incidental damage to the sealing surfaces which may have occurred while the valve was disassembled.
Steps 7.1.1 and 7.1.2 pertained to the use of exclusion dams. The supplemental work instructions stated that optional or contingent work steps that were not performed were to be marked NA. The assistant superintendent of mechanical maintenance stated that he left it up to the workers to decide whether exclusion dams were needed or not.
The inspector reviewed the completed WR and noted that all steps were signed off appropriately.
The inspector concluded that the reasons for not signing these steps in order were reasonable; however, the workers questioned did not know the reasons. The licensee indicated that they would address this issue with the workers involved to establish appropriate corrective actions.
e 3.4 Mechanical Snubber Replacement-On September 23, 1994, the inspector observed mechanics replace Snubber BB11R004232. When_the_ inspector arrived, one mechanic and one quality control inspector were out on scaffolding discussing the replacement of the snubber. The mechanic was wearing a safety harness which did not appear to be tied off.
The quality control inspector was not wearing a harness.
The inspector questioned where the harness tie off point was and the mechanic responded by immediately tying off. The inspector questioned whether the quality control-inspector was also required to be tied off.
The quality control inspector responded by stating-"I didn't expect to be there that
-long.".The inspector questioned licensee management regarding the tie-offs 1
and management promptly responded by stating that both individuals should have been-tied off, and that the response -from the quality control inspector was -
inappropriate. The licensee counselled both individuals and had the quality control inspector brief all quality control inspectors on lessons learned and safe-scaffold work practices. This briefing by the quality control inspector occurred on September 25, 1994, during a turnover meeting.
The inspector also observed the mechanic care'ully set up a plastic bag underneath the snubber to catch the fasteners and washers while removing the snubber. The mechanic stated that this was-to protect workers who might be underneath the work area.- A few minutes later, the mechanic permitted a hammer to-fall approximately 15 feet to the floor.
The inspector concluded that the maintenance work was performed appropriately and-that the licensee's actions in response to weak personnel safety practices were appropriate.-
3.5 dousekecoina and Material Condition Issues Throughout this report period, the inspector observed numerous examples of minor.hou:ekeeping and material condition problems. These included mis-ing fasteners in safety and nonsafety-related equipment, overgreasing of fan bearings, and clear plastic found on the spent fuel pool building operating floor. This issue was previously discussed in NRC Inspection Report:50-482/94-08, paragraph 3.5.
While none of the examples directly impaired safety-related equipment, some had the potential to degrade plant equipment. The licensee responded by correcting each identified problem and by revising the guidance to electricians for greasing the fan bearings.
3.6 Conclusions The maintenance work observed was performed well.
Licensee responses to the inspector's observation of weak safety practices were appropriate. The inspector observed weak radiation worker practices that were_ also recognized by the worker after the potential existed for personal contamination. Workers recognized inadequate work instructions, stopped the work, and obtained clarification, rather than proceeding in the face of uncertainty. The reasons J
O
. for performing work steps out of sequence was not well known by some workers during valve repair work.
4 $URVEILLANCE OBSERVATIONS (61726)
The inspector reviewed this area to ascertain whether the licensee conducted surveillance of safety significant systems and components in accordance with TS and approved procedures.
The inspector verified that personnel knew the purpose and scope of the test, used calibrated test equipment, used appropriate self-checking, used good repeat back techniques, and communicated clearly.
4.1 Pressurizer Pressure Analoo Channel Operational Test On August 18, 1994, the inspector observed portions of Procedure STS 10-5028,
" Channel Calibration of 7300 Process Pressurizer Instrumentation,"
Revision 11. The technicians were knowledgeable, used good communication techniques, and properly calibrated test equipment.
The inspector noted that the procedure had been verified to be the latest ravision. The inspector verified that this test satisfied the surveillance requirements of TS 4.3.1.1 (Table 4.3-1; 9,10), 4.3.2.1 (Table 4.3-2; 1.d, II.a), 4.3.3.5.1 (Table 4.3-6; 7), and 4.4.4.1 for pressurizer rack mounted instruments only.
The inspector concluded that the test was performed properly.
4.2 Main Steam Safety-Valve (MSSV) Setpoint Testina l
On September 14, 1994, the inspector observed portions of Procedure STS MT-008, "MSSV Settings," Revision 6.
This test measured the i
MSSV lift setpoint using the Furmanite Trevitest method. The test performers used calibrated test equipment.
Licensee personnel escorted and provided technical oversight of the Furnanite personnel who actually performed the test. The application of hydraulic force to the Trevitest lift rig was performed in a manner which produced a clear valve lift. This resulted in a clear, peak force trace that the test performers read directly as the peak force. The test performer was, therefore, not required to perform any subjective interpretation of the test force trace. Two independent individuals calculated the lift pressure and their results were compared before the results were logged as the test result. The inspector verified that this test satisfied the surveillance requirements of TS 4.0.5 and 4.7.1.1.
The inspector concluded that the test was controlled well and accurately measured the valve setpoints.
The inspector noted that test performers and mechanics did not reconnect the safety chain on a ladder near the MSSVs as they walked between the mezzanine level and main upper operating level of Area 5 in the auxiliary building.
The inspector questioned whether licensee policy required this chain to be reconnected after each individual traversed the ladder, The mechanics and their supervision stated that they were not required to reattach the chain if they were working between the two areas, but they were required to reconnect it before they left the area. After verifying this understanding with safety l
g 7:- _
services ;they11 earned that';this. understanding was incorrect and that the safety, chain was required to be reconnected after each individual traversed-the' ladder. -The inspector concluded that the mec h nics did not have a tcomplete and-accurate understanding of personnel 'ifety; requirements.
4.3 -Conclusion-
-Observed surveillance testing was well controlled and-satisfied TS surveillance requirements.
5 10NSITE ENGINEERING (37551)
- The inspector reviewed and evaluated-engineering performance related to Jselected plant-problems. The-inspector. evaluated licensee activities related to.. identifying potential design and-operability concerns.
5.1 - RHUT Overflow On August 26, 1994, RHUT B-overflowed to the clean radwaste ' sump as operators
_ pumped water from the s)ent fuel transfer canal to RHUT B.- The level-l-
transmitter indicated t1at the-RHUT was only 71 percent full as the-tank L
overflowed. As a result of a hardware problem, the sump overflowed and the L
high. level annunciator failed to annunciate. Water spilled onto the radwaste-L building floor and into the-dirty radwaste sump via floor drains. Operators werel alerted to the problem when '
dirty radwaste sump:high level annunciator? alarmed'. Operators rt onded by stopping the transfer of water, cleaning up the ' water on the-radwaste building floor, and initiating a WR to repair the annunciator.- Management initiated-an IIT to evaluate the. level (discrepancy. -
e The inspector reviewed the licensee's final IIT report.
The IIT determined
-that a_large; amount of air was trapped-between the recently installed replacement bladder and the liquid volume-in the tank. This air pressed the bladder up against the top of the tank, then compressed the air while water
- overflowed to the clean radwaste sump.
The IIT evaluated operator-and other licensee personnel; actions,: vendor and industry experience, generic l transportability,: system design, and administrative controls.. The IIT drew-dehnitive conclusions and made practical-recommendations which would address the issue.-
- The; inspector concluded that the licensee's actions in response to the event
.were: appropriate. The inspector further concluded that the IIT performed a
-. thorough evaluation of the problem, analyzed the problem effectively, and
- provided good recommendations to prevent recurrence.
5.2 Engineerina Evaluations of:TS Operability On-two occasions the shift supervisor requested engineering assistance to support ~ operability determinations. On August 30, 1994, the licensee found Asiatic clams in. essential service water supply lines to le auxiliary L
o
. feedwater system and also found a small leak from the back of the Containment Spray Pump B room cooler.
The shift supervisor requested engineering to-perform Procedure KGP-1215, " Evaluation of Nonconforming Conditions of Installed Plant Equipment," Revision 2, evaluations of these two conditions.
The licensee concluded that both conditions were minor and did not affect the operability of the associated systems. The inspector reviewed these two evaluations and found them to be adequate and consistent with both the licensee procedure and NRC guidance in Generic letter 91-18, "Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded-and Nonconforming Conditions and on Operability."
5.3 Enaineerina Evaluation of Temporary Conditions on Plant Structures.
Systems and Components The licensee initiated a new program for reducing the scope of engineering evaluations required for temporary conditions such as scaffolding, shielding, freeze seals, etc. By using a probabilistic risk assessment methodology, using time as an input variable, and administratively limiting the length of time these temporary conditions will be present, the licensee plans to l
. eliminate the need for detailed seismic evaluations of the impact of these conditions on safety-related plant structures, systems, and components. The inspector learned that a similar approach was taken at the LaSalle facility, l
and that the Office of Nuclear Reactor Regulation is reviewing this approach under Technical Assignment Control 89067, "LaSalle One:
Reduced Seismic Criteria at Ceco Facilities."
The inspector asked the licensee if this approach will be used for operability determinations or TS interpretations.
The licensee responded by stating that this approach will be limited to reviewing the need for seismic evaluations and will not be used for operability determinations or TS interpretations. The inspector's review of
-this new program will be completed after the Nuclear Reactor Regulation review of Technical Assignment Control 89067 is complete. This will be tracked as Inspection Followup Item 482/9410-02.
5.4 Conclusions Licensee evaluations 'of the RHUT overflow was thorough and provided good recommendations.. Engineering assistance with operability determinations was timely and-appropriate. The licensee decision to not use their new engineering methodology for seismic evaluations as the basis for TS interpretations or operability determinations was appropriate.
6 PLANT SUPPORT ACTIVITIES (71750) 6.1 RWPs The inspector evaluated radiation worker personnel activities related to the following RWPs:
o
t O
94 0007 Routine I&C access for calibrations of components-(radiological controlled. area excluding containment) 94 0091 MMA to disassemble / rework various. leaking EC system components located on 2000 foot fuel building.
Includes valve seat replacement on.EC V0038, reworking of PE C01A/B and all other associated support work.
The inspector concluded that these RWPs were appropriate for the planned work-and were_followed by the associated radiation workers.
6.2 Excessive Gaseous Radwaste Release Rate On September 1,- 1994, while initiating a gaseous radwaste' release, Process.
Radiation Monitor GH RE-10B alarmed at'the alert level. Operators followed Gas Release Permit 940123 which permitted a release rate of up to 7-standard cubic feet per minute (SCFM). Operators used a release rate of 6.2 SCFM when the monitor alarmed. Operators reduced the release rate to 3.0 SCFM and then to 1.5 SCFM before the alarm cleared. The licensee initiated PIR 94-1460.
-The PIR evaluation stated that chemistry technicians calibrated gas effluent l
monitors with Xe-133, which has a lower average beta energy than the typical fission product gasses. -The majority of the gaseous activity from gas tank releases is due to Kr-85, which has a higher average beta energy and, thus, causes's higher reaction on the process radiation monitor. The licensee determined that no release-rate limits were exceeded. The licensee revised Procedure CHM 03-153, "Use of EMS for Gas Decay Tank Releases.. Revision 17, to include a method of more accurately predicting the monitor response. The inspector agreed with the-licensee's conclusion.that the procedure was deficient and concluded that the licensee's corrective actions were appropriate.
6.3 Documentation of HP Overtime Use On September 20, 1994, the call superintendent authorized 23 contract-HP technicians to exceed the overtime limits specified in Administrative Procedure ADM 01-023, " Guidelines for WCGS Staff Working Hours," Revision 8.
Th s administrative procedure implements the requirements of TS 6.2.2.f and requires that the guidance in Generic Letter 82-12 be implemented. The shift supervisor made a log entry to document this approval and attached a memorandum that discussed an error which created the need for the high level of overtime and listed the individual's names, the number of hours in excess of 72=in 7 days, and the date this would occur. Neither the memorandum nor the shift supervisor's log entry documented an evaluation of the potential impact of these individuals working this level of overtime. The inspector questioned the licensee regarding this evaluation. The licensee stated that both the call superintendent and the shift supervisor verified that this evaluation was performed. The licensee determined that Administrative Procedure ADM 01-023 could be improved and revised the procedure to I
I
.,~...
l0 -
incorporate a form which will be used for all future approvals of overtime in excess of the limits in the procedure.
6.4 Conclusions RWPs were used properly. A self-revealing chemistry procedure deficiency -
resulted in a gaseous radwaste release which caused the process radiation monitor to alarm at the alert level. HP supervisory errors resulted in the need to-authorize contract HP technicians working overtime exceeding administrative limits as required.by TS, and the licensee initiated a revision to improve the procedure for future approvals of overtime in excess of administrative limits.
7 PREPARATION FOR REFUEL.ING (60705)
The inspector reviewed various aspects the licensee's preparation for refueling.
In particular, the inspector reviewed the procedures directly related to major outage activities; the planning, scheduling, and outage risk assessment activities; and the reactor engineering coastdown plan.
The~ inspector reviewed the following proce'dures:
ADM 04-020, Chemistry Surveillance Program FHP 01-001, New Fuel Receipt FHP 04-001, Spent Fuel' Inspection FHP 02-001, Refueling Procedure FHP 02-011, Fuel Shuffle and Position Verification FHP 02-012, Control' Rod Shaft Unlatching / Latch FHP 02-013, Upper Internals-Removal and Installation FHP 03-001, Refueling Machine Operating Instructions FHP-03-003, Spent Fuel Assembly Handling Tool Ops FHP 03-006, Fuel Transfer System Operating Instructions FHP 03-007, Spent Fuel Pool Bridge Crane Op Instruction GEN 00-006, Hot Standby to Cold Shutdown QAP 16.2, Stop Work STS CR-002, Shift Logs for Modes 4, 5, and 6 STS RE-004, Shutdown Margin Determination SYS EJ-120, Startup Residual Heat Removal-Train These procedures provided the licensee with adequate detail and appeared to be
-appropriate to control the plant. The inspector reviewed the licensee's planning,-scheduling,- and outage risk assessment activities.
The inspector
. concluded that the licensee was prepared for the outage and was appropriately concerned with conditions which could jeopardize plant safety. The inspector reviewed the coastdown plan, found that it p'rovided adequate guidance and was consistent with TS requirements, and noted that operators followed it.
The inspector noted that the licensee tuthorized removal of many of ' he t
equipment hatch missile shield bolts on September 13, 1994, 3 days prior to
',- 1 shutting down the unit for refueling.
The inspector questioned this action in light of the need for the missile shield to be in place as part of containment integrity. The licensee asserted that there was not a single credible missile which they could envision which had the potential to move the door and damage the hatch. - After the inspector questioned the removal of the bolts, the
-- Ticensee stated that they would review the missile shield bc1 ting requirement
- and determine the minimum number of bolts needed for the shield to meet the safety requirement. The licensee also stated that they would review other work performed prior to shutdown-and determine if any work was performed in Mode I which would have been more appropriately performed after shutdown.
The inspector concluded that the missile shield bolt removal was a minor example of work which could have been more appropriately. performed after 1
shutdown. The ~ inspector finally concluded that the licensee was appropriately prepared for refueling when they shut down for the seventh refueling outage.-
8 ONSITE REVIEW 0F AN LER (92700)
(Closed) LER 482/94-007:
Failure to Perform Emeraency Diesel Generator Fast Load Test This LER involved the failure of operations to perform the fast load surveillance of-Emergency Diesel Generator A as required by TS 4.8.1.1.2.f.
The licensee determined that the root cause of the event was a cognitive personnel error on the part of the operator preparing the surveillance-test l-procedure for use.
Contributing causes included the operator's choice of
-shift turnover time to prepare the procedure for use, and unclear delineation of the requirements of TS 4.8.1.1.2.f in the procedure.- The licensee revised
- the procedure to clearly delineate the TS requirements, initiated PIR 94-1281, and placed the completed PlR evaluation in the operations-required reading program. This event was discovered by licensee initiated Self-Assessment SELf94-031, "WC;3 Surveillance Testing." The inspector considered it appropriate and proactive for the licensee to have initiated the self-assessment which identified this event.
The inspector further concluded that the licensee's corractive actions appeared appropriate to prevent recurrence.
ATTACHMENT l'
~1 PERSONS CONTACTED'
.G. D. Boyer, Manager.-Training T. W. Coates, Supervisor, Instrumentation and Control Support
'C. E. DeLong, Supervisor, Quality Control Inspections C. W. Fowler, Manager, Maintenance and Modifications R. B..Flannigan, Manager, Regulatory Services M. A _Gayoso, Chief Businest, Officer R. C. Hagan, Vice President Nuclear Assurance K. M. Harvey, Manager, Document Services R. Johannes, Chief Administrative Officer W._M. Lindsay, Manager, Performance Assessment R. L.-Logsdon, Superintendent,-Chemistry O. L.- Maynard, Vice President Plant Operations
- B. T. McKinney, Manager, Operations L. L. Parmenter, Operations
-J. M. Pippin, Manager, Outage F. T. Rhodes, Vice President Engineering l
A. S. Serhal, Supervisor, Plant Safety Assessment R. L. Sims, Supervisor, Operations Support
- J. D. Stamm, Manager, System Engineering S. G.-Wideman, Supervisor, Licensing The above licensee personnel attended the exit meeting.
In addition to the personnel: listed above, the inspectors contacted other personnel during this inspection period.
2 EXIT MEETING-An exit meeting was_ conducted on September 23, 1994. During this meeting, the inspectors reviewed the scope and findings of the report.
The licensee did not identify:as proprietary any information-provided to, or reviewed by,.the inspectors.
~
- -_- J
3 ACRONYMS
'ESF engineered safety ' features HP _
health physics I&C_
instrumentation and control-IIT Incident Investigation Team LER licensee event' report MSSV.
. main steam safety valve PIR performance improvement request PRT pressurizer relief tank RCP reactor coolant pump RCS reactor coolant system RHR:
residual heat removal-RHUT recycle hoid up tank-RWP radiation work permit RWST refueling water storage tank SCFM standard cubic feet per minute TS Technical Specification V0TES.
-Valve Operation Testing Evaluation System WR work request l
h:j/,y,( y F '
hLEAR REGULATORY COMMISSION I
a
$j-
- - t i*
teDog sv t
611 cVAN PLAZA DAIVE, SUITE 400 4.3
['
Anuworow.tE xAs nott oou i.
m Docket: 50-482 1.icense: NPF Wolf: Creek-Nuclear Operating Corporation ATTN:' Neil S. Carns, President and Chief Executive Officer P.O. Box 411 Burlington, Kansas 66839
]
SUBJECT:
NRC. INSPECTION REPORT 50-482/94-12 (NOTICE OF VIOLATION)
This refers to the inspection conducted by Mr. J. F. Ringwald and l
Hs. J. L. Dixon-Herrity of this office on September 25 through November 5, l
- 1994, The inspection included a review of activities authorized for your Wolf Creek Generating Station facility.
At the conclusion of the inspection, the findings were discussed with those members of your staff identified in the l
enclosed report.
Areas examined during the inspection are identified in the report.
Within
-these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observation of activities-in progress. The purpose of the inspection was to determine-whether activities authorized by the license were conducted safely and in accordance with NRC requirements.
Based on the results of this inspection, certain licensed activities appeared to be in violation of NRC requirements, as specified in the enclosed Notice of Violation (Notice). Although some of the specific examples of the viniations are relatively minor in nature, all examples are included because they appear to' involve inattention to detail and_the failure to follow procedures which indicates a potential that' management expectations in-this area have not been well communicated or understood.
We are particularly concerned with work scheduling early in the-' refueling outage which led to problems such as the technician's error during maintenance on your only available train of control room ventilation that challenged the operability of the system.
This is similar to your decision to proceed with
--testing of Valve EJ HV8716A-as described in paragraph 2.4 of NRC Inspection Report 50-482/94-10 and inadvertently transferring approximately-9200 gallons of p'rimary coolant to the refueling water storage tank.
Your scheduling-of maintenance that had the potential to jeopardize your only available safety-system train in each case did not appear to be necessary. We recognize that you made changes in your work scheduling prior to taking your Train B components out of service and this appears to have prevented recurrence of these types of problems.
I R 4'< 2 % r r u ym
)
'\\c s
o.
A Wolf Creek Nuclear Opehating *
-Corporation
-You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response.
In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
-In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enclosures will be placed in the NRC Public Document Room.
The responses directed by this letter and the enclosed Notice are-not subject to the clearance-procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No. 96.511.
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
l Sincerely, l-
/
q f
a a
A. Bill Beach, Director Division of _ Reactor Projects
Enclosures:
1.
Appendix A - Notice of Violation 2.
Appendix B - NRC Inspection Report 50-482/94-12 cc w/ enclosures:
Wolf Creek Nuclear Operating Corp.
ATTN:
Vice President Plant Operations P.O. Box 411 Burlington, Kansas 66839 Shaw,_Pittman, Potts & Trowbridge ATTN: Jay Silberg, Esq.
2300 N Street, NW
. Washington, D.C.
20037 U.S. Nuclear Regulatory Commission ATIN:
Regional Administrator, Region 111 799 Roosevelt Road-Glen Ellyn, Illinois 60137
U
'I-LWo1f Creek Nuclear Operating-Corporation Wolf Creek Nuclear Operating Corp.
ATTN: Manager Regulatory Services P.O. Box 411 Burlington, Kansas.66839 Missouri Public Service Commission ATTN: Assistant Manager Energy Department P.O. Box 360 Jefferson City, Missouri 65102 Kansas Corporation Commission
-ATTN: Chief Engineer Utilities Division 1500 SW-Arrowhead Rd, Topeka, Kansas. 66604-4027 Office of the Governor State of Kansas l
-Topeka, Kansas 66612
~ Attorney General
' Judicial Center
.301 S.W. 10th 2nd Floor
' Topeka, Kansas 66612-159,7
. County Clerk Coffey County Courthouse Burlington, Kansas -66839-1798 Kansas Department of Health and Environment
' Bureau of Air-& Radiation ATTN:
Public Health Phys.icist Division of Environment Forbes Field Building 283
-Topeka, Kansas 66620-a
4 L
APPENDIX A o
NOTICE OF VIOLATION Wolf Creek Nuclear Operating Corporation Docket:
50-482 Wolf Creek Generating Station-License: NPF-42 During an NRC inspection conducted on September 25 through November 5,1994, three violations of NRC requirements were identified. -In accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C, the violations are listed below:
A.
Technical Specification 6.8.1.a-states, in part, that written procedures shall be established and implemented covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2.
(1)
Regulatory Guide 1.33, Appendix A, Section 7.a requires procedures covering the liquid radioactive waste system.
Procedure SYS HE-201, " Boron Recycle Holdup Tank Operations,"
Revision 9, Step 4.4.1, requires that the operator perform Section 4.2 for proper system alignment for recycling and sampling l
to transfer water from the Recycle Holdup Tank B to the spent fuel l
pool.
Contrary to the above, on September 30, 1994, an operator failed to perform Section 4.2 of Procedure SYS HE-201, and thereby incorrectly transferred unsampled Recycle Holdup Tank A to the spent fuel pool instead of Tank B as planned.
(2)
Regulatory. Guide 1.33, Appendix A, Section 1.c, requires administrative procedures covering equipment control.
Administrative Procedure ADM 02-102, " Control of Locked Component Status," Revision 28, Step 4.12, requires that all valves required to be locked be rechecked prior to entry into Mode 4.
Contrary to the above, on October ~ 26, 1994, Valve BB V0149 was found inadequately locked such that it could be repositioned without removing the locking device.
(3)
Regulatory Guide 1.33, Appendix A, Section 10, requires procedures covering chemical and radiochemical control.
Chemistry Procedure CHM 02-050, " Determination of Boron (Titration Method),"
Revision 6, Step 9.2.15, requires that two st. oops of mannitol and five drops of phenolphthalein be added to the sample container in preparation for the titration.
Contrary to the above, on October 30, 1994, a chemistry technician added three partial scoops of mannitol and an indeterminate amount of phenolphth'alein to the sample container.
(4)
Regulatory Guide 1.33, Appendix A, item 1.d, requires administrative procedures to address procedure adherence.
Procedure AP 15C-002, " Procedure Use and Adherence," Revision 0,
$ !?$6?jfG -
ifygd 9
6 1
6
- 2-Section 6.3.4, requires that the intent and direction provided in the procedures be followed during the course of activities. of Procedure KGP-1210, " Performance-Improvement Requests," Revision 10, identifies the failure of a safety-related piece of equipment to perform its intended safety function on demand or as expected as-significant.
Procedure KGP-1201,
" Corrective Action," Revision 1, requires that a Performance improvement Request (PIR) be initiated to determine the cause and-corrective actions to prevent recurrence for significant hardware
- failures, intrary to the above, on October 16, 1994, Essential. Service water Self-Cleaning Strainer A, a safety-related component, failed to operate when the driver motor thermal over1 cads tripped on actuation and a PIR was not initiated.
This is a Severity level IV violation (Supplement 1) (482/9412-01),
l 8.
Technical Specification 6.7.2.f. requires that the amount of overtime l
worked by unit staff members performing safety-related functions shall l
be limited in accordance with the NRC Policy Statement on work hours (Generic Letter No. 82-12).
Generic Letter No. 82-12 states that.
individuals should not be permitted to work more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in 7 days.
Contrary to the above, on October 13, and October. 19, 1994, operators worked in excess of.the Technical Specifications guidelines without l
authorization in that a refueling SRO worked 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in excess of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.in 7 days and a licensed operator performing valve lineups in containment exceeded 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period.
This is a Severity level.IV violation (Supplement VII) (482/9412-02).
C.
Technical Specification 6.11 states that procedures for personnel radiation protection shall be prepared consis,'ent with the requirements of 10 CFR Part 20 and shall be approved, maintained, and adhered to for all operations involving personnel ra61ation exposures.
(1)
Radiation Protection Procedure RPP 02-105, "RWP 1 Radiation Work Permit)," Revision 6, Step 5.3.1, states that u.a protective equipment specified on the radiation work permit is to be per Procedure RPP 03-505, " Selection of Protective Clothing,"
Revision 1.
Procedure RPP 03-505 requires protective clothing to be selected based on the known or expected contamination levels in the work area.
Radiation Work Permit 942100, Revision 0, requires a full set of protective clothing for access to contaminated areas.
__ _ j
0 3
O Contrary to the above, on September 28, 1994, a licensee employee removed contaminated packing from a valve in a known contaminated system without wearing a full set of protective clothing.
(2)
Procedure RPP 02-105, "RWP," Revision 6, Step 9.3.1, states that the protective equipment specified on the RWP is a minimum requirement, which all personnel accessing the RWP must comply with.
Radiation Work Permit 940005, Revision 0, requires a full set of protective clothing for contaminated access.
Contrary to the above, on October 6, 1994, a licensee employee accessed a contaminatad area in cectrifugal charging pump room B without a full set of protective ciothing in that the coveralls were not zipped up prior to entry.
(3)
Procedere AP 25B-100 " Radiation Worker Guidelines," Revision 0, Step 6.6.3, requires radiation workers to perform a hands, feet, and face frisk after exiting a contaminated area.
Contrary to the above, on October 30, 1994, a chemistry technician failed to frisk after exiting a contaminated area.
This is a Severity Level IV violation (Supplement IV) (482/9412-03).
Pursuant to the provisions of 10 CFR 2.201, Wolf Creek Nuclear Operating l
Corporation is hereby required to submit a written statement or e.mlanatior. to l
the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, l
Washington, D.C. 20555 with a copy to the Regional Administrator, Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011, and a copy to the NRC Resident Inspecto at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation:
(1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved, if an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued to show cause why the license should not be modified, suspended. or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
Dated at Arlington, Texas this /5T day of /WetAL/) 1994
APPEN0!X $
U.S. NUCLEAR REGULATORY COMMISSION REGION IV NRC Inspection Report:
50-482/94-12 Operating 8.icense:
NPF-42 Docket:
50-482 Licensee: Wolf Creek Nuclear Operating Corporation P. O. Box 411 Burlington, Kansas 66839 facility Name: Wolf Creek Generating Station Inspection At:
Coffey County, Burlington, Kansas l
Inspection Conducted:
September 25 through November 5, 1994 inspectors:
J. F. Ringwald, Senior Resident inspector i
J. L. Dixon-Herrity, Resident insps.ctor Other Personnel:
M. A. Shuaibi, Intern f 2"/" N Approved:
I
~'
D. D. (Chamberlain, At.ing Chief, Date Project Branch B. Division of Reactor Projects inspection Summary Areas inspected:
Routine, unannounced inspection including plant status, operational safety verification, maintenance observations, surveillance observations, plant support activities, cxcolex surveillance, refueling activities,.'estart from refueling, foreigr t Jtirial exclusion controls, and licensee event report (LER) reviews - onsiu.
Results:
Plant Operations Operations performance declined somewhat during this report period.
Operators allowed a surveillance to be performed on Control Room Pressurization System Train B while Control Room Pressurization. System Train A was out of service for maintenance.
An error on the part of maintenance during this surveillance caused the heaters to be inoperable for a period of time during which the i
na b
.g.
ability of tha system to perform its safety function in a humid environment came into question (Section 4.1). A concern about working on the only available train of safety-related equipment had been expressed with the licensee during the last report period. This was driven by an event where L
. maintenance on the residual heat removal system resulted in draining the
-pressurizer to thu refueling-water storage tank.
The failure on the part of operators to follow procedures allowed the contents of an unsampled recycle hold up tank (RHUT) to be transferred to the spent fuel pool-(SFP) (Section 2.2)1 two operators to exceed Technical SpeciMcations (15) overtime limits (Section 2.5)1 and a locked valve to be improperly secured (Section 2.6). Operators' failure to maintain cognizance of.their actions and to use self-checking techniques resulted in the
. inadvertent deenergization of a safety-related direct current (DC) bus (Section 2.3), and the inoperability of both trains of containment atmosphere radiation w nitoring (Section 2.4).
The failure of operations to properly review a work request, and of maintenance and engineering to adequately communicate expectations with operations resulted in operators declaring Centrifugal Charging Pump (CCP) A operable before the expected postmaintenance testing was performed (Section 3.2).
Maintenance j
Most maintenance observed was well controlled and performed, but there were several exceptions.
The failure to self-check allowed a technician to install j
a probe incorrectly which would have prevented the safety-related heaters on the Control Room Pressurization System Train B from energizing if called to do so-(Section 4.1).
This failure and an incident involving confusien as to whether as-left data should be reverified indicated that maintenance supervision and craft were not familiar with the maintenance department procedures (nction 4.2).
Contractors brought onsite to augment the maintenance staff during the outage did not follow licensee procedures or instructions:in some instances (Section 3.3).
P1 ant Suooort Performance in the area of plant support was adequate.
Although good health physics-(HP) practices were noted in general, two examples of failure to follow the dress out requirements on radiation work permits (RWPs) indicated a need for improvement (Sections 6.1 and 6.3).
The licensee identified a continuing problem with following procedures in the area of material control (Section 10.1). Chemistry personnel also failed to follow procedures while determining the boric acid contents of a primary sample (Section 6.4), by failing to frisk when exiting a contaminated area in the lab (Section 6.5),
and.in requesting that operations isolate the incorrect valves to change a
' filter (Section 2.4).
Engineerinq f
3 Engineering performance and support to operations were generally good.
This 4.
tas evident in the initial troubleshooting effort for the SFP cooling pump bearing failure (Section-5.1), reactor physics testing (Section 9.1), and preparation for and followup analysis of the noise event (Section 5.4).
However, engineering failed to consider the broader implications of the i
problem with the SFP cooling pump and to invoke the corrective action program in response to a repeat failure of the Train A essential service water (E5W) i strainer, a safety-related piece of equipment (Section 7.1).
Management Overview Observations-of poor performance indicated that management actions have not been consistently effective at improving performance.
Operations' continued lack of cognizance of activities having the potential to affect plant conditions was reflected in allowing a surveillance to be performed on one train of the control room pressurization system while the other train was out of service, unintentionally taking both trains of containment radiation monitors out of service, and unintentionally deenergizing a safety-related DC bus.
The corrective actions taken by management when this concern was brought to their attention were immediate and appropriate. During f.he second part of the recent refueling outage, more time was spent on reviewing work and no work was scheduled on the operable train.
These actions prevented further similar cishaps during the outage.
A need for management to stress its expectations with regards to procedure adherence was identified due to the identification of a number of procedure violations.
Examples of these included the failure to follow RWPs, adherence to overtime limits, and the control of. contractors activities.
Several performance improvement requests (PIRs) from the previous year dealing with the control of materials in and around the exclusion area arcund the SFP indicated that a p Nblem existed with maintaining controls over foreign
-taterial exclusion.
The corrective actions in response to the problem failed to prevent similar problems during the outage. Managements responded to instances of failure to follow procedures by stressing the need to follow procedures and by increased emphasis toward handling problems associated with failures to follow procedures.-
Supervision and the generai professionalism in the control room and during tests observed during the oula93 were found to be good.. Management decisions to place holds on restart untit engineering completed their reports on the noise event and the emergency diesel generator (EDG) transformer fire were considered conservative and appropriate.
Summary of Inspection findinos:
o
- Violation 482/9412-01 was apened (Sections 2.2, 2.6, 6.4, and 7.1)f o
Violation 482/9412-02 was noened (Section 2.5)(
o Violation 482/9412-03 was opened (Sec.tions 6.1, 6.3, and 6.5)r LER 482/94-009'wa$ closed (Section 11). <
o
. + -
---~me.
v--,
4 e / LER 482/94-012 was closed (Section 11)r o
Attachments:
e' Persons Contacted and Exit Meeting Acronyms-l l
=
e i
l DETAILS 1 PLANT STATUS (71707)
At the beginning.of this inspection period, the plant was in Mode 6 at the beginning of the seventh refueling outage.
Operators restarted the reactor on October 30, 1994, and placed the unit online on November 3, 1994. At the end of the inspection period, operators were increasing power from 75 percent.
2 OPERATIONAL SAFETY VERIFICATION (71707,93702)
The inspettors performed this inspection to ensure that the licensee operated the facility safely and in conformance with license and regulatory requirements. The methods used to perform this inspection included direct observation of activities and equipment, observation of control room operations, tours of the facility, interviews and discussions with licensee personnel, independent verification of safety system status and TS limiting conditions for operation, verification of corrective actions, and review of facility records.
2.1 [DG Potential Transformer Fires On September 30, 1994, a fire erupted on the EDG A power potential transformer while operators were performing a maintenance run. On October ll, 1994, a similar fire erupted on EDG B during a similar maintenance run.
The fires were both extinguished promptly by individuals present in the room using a portable carbon dioxide fire extinguisher.
The events and the licensee response was reviewed and reported in NRC Inspection Report 50-482/94-13.
2.2 Unsampled RHUT Pumped to the SFP On September 30, 1994, an operator was directed to pump RHUT B to the SFP but inadvertently pumped unsampled RHUT A to the SFP as a result of not following a procedure. Operators used Procedure SYS HE-201, " Boron Recycle Holdup Tank Operations," Revision 9, to perform many different tasks associated with the boron recycle system.
Some of these tasks included transferring water from trither RHUT to any desired location including the other RHUT, the SFP, or the SFP transfer canal; recirculation of either RHUT for sampling, filtering the water in either RHUT; and flushing the transfer line.
This procedure relied heavily on procedure section sequencing to ensure that valves were properly lined up.
Prior to transferring the contents of an RHUT to the SFP, operators were required to have chemistry sample the tank, or to verify that the entire contents of the tank came from a presumed clean source.
The transfer of the water in RHUT B to the SFP, was to be performed without sampling the RHUT since operatars knew the source of the water.
Knowing this, the operator read Step 4.4.1, which stated " Ensure that the tank to be used is 'Off-Service',
recirced per Section 4.2 and sampled if necessary," and determined that this step was not required since sampling was not necessary.
Section 4.2, however, also established the lineup for the transfer and ensured that only the contents of the correct RHUT would be transferred. When the operator later
t 6-started the transfer pump, the prior valve lineup transferred the incorrect RHUT to the SFP.
This failure to follow the procedure is the first example of a violation of TS 6.8.1.a (Violation Al sed to improve the clarity of what_ the 482/9412-01).
The licensee stated that Procedure SYS HE-201_would be rey sections actually accomplish.. The licensee-also counselled the individual involved.
When the unintended transfer began, the operator monitored the applicable indications, quickly recognized the error and stopped the transfer. The..
inspector concluded that this was a good operating practice to immediately monitor the expected indication for a control action, and to stop the action when the expected indications _were not received.
2.3 failure to Review Prints Resulted in the inadvertent loss of NK02 s
On_0ctober 5, 1994, operators opened the battery disconnect to Bus NK02 inadvertently deenergizing the bus.
The TS required two DC busses at the time and the NK01 and NK03 buses remained operable. Operators took the NK22 charger out of service for preventive maintenance and supplied the NK02 bus from the NK04 bus via test connections.
These test connections were between the battery disconnects and the DC buses.
Since the NK22 battery charger was-out of service and.the NK04 bus was aligned to supply power to the NK02 bus, maintenance recommended that they be permitted to complete preventive-maintenance on the NK12 battery. After discussing this-recommendation with the electricians and with personnel from the tagging group, operators a and opened the battery disconnect to isotate the battery from the bus. greed According to the shift supervisor, operators did not consult the applicable drawings prior to opening the disconnect nor did they use any other means to verify the effect of opening the disconnect..The inspector concluded that while these actions did not render any TS required equipment inoperable, this inadvertent deenergization of a DC bus without consulting the applicable
_ prints represented a poor practice on the part of licensee personnel.
2.4 Operations and Chemistrv Miscoordination Resulted in loss of Containment Atmosphere Radiation Monitors GT RE-31 and G" RE-32 On October 13, 1994, a miscoordination between operators and a chemistry technician resulted in operators placing Radiation Monitor GT RE-31 in bypass, and shutting the isolation valves for Radiation Monitor GT RE-32.
This rendered both containment atmosphere radiation mtnitors inoperable.
-Additionally, it opened a path between the auxiliary building atmosphere and
= containment via Radiation Monitor GT RE-31 while the chemistry-. technician changed the filter.
The inspectors determined that this was not a concern becausel containment integrity was not required at the time. After placing Radiation-Monitor GT-RE-31 in bypass, the operators requested that the chemistry technician change the filters immediately.
The chemistry technician misread the procedure and requested that the operators shut the-valves that isolated Radiation Monitor GT-RE-32.
Failing to confirm the proper valves, operators shut the valves requested by the chemistry technician, rendering
.both trains of containment-atmosphere radiation monitoring inoperable. One of
r,.
7 these monitors is required by TS 3.3.3.1 to be operable during all modes. The action statement allows both to be inoperable as long as the containment purge valves are maintained closed.
The operators were in the process of closing the purge V W es to meet the action statement, when flow was restored to Radiation Moi,itor GT RE-32.
The inspector concluded that this represented inattention to detail on the part of the chemistry technician and operators, and failure of the operators to verify the valves requested prior to shutting them.
The licensee initiated PIR 94-1777 for review of this matter.
2.5 Overtime limitation Exceeded On October 13 and October 19, 1994, the licensee identified two examples where licensed operators exceeded the overtime limitations of TS 6.2.2.f, without authorization.
In the first case, management authorized a refueling senior reactor operator to exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in_7 days by no more than 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
As a result of miscommunication, the individual worked 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in excess of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in 7 days, in the second case, a licensed operator performing valve lineups in containment exceeded 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period without authorization.
The inspector concluded that these are two examples of a violation of TS 6.2.2.f (Violation B, 482/9412-02).
The licensee initiated PIR 94-1770 and 94-1842 immediately after discovering.
that the workers exceeded the overtime limitations.
After the inspector discussed this violation with the licensee, the licensee recognized that the PIR screenings failed to identify these events as potentially reportable.
Subsequent to the discussions with the inspector, the licensee initiated Reportability Evaluation Request 94-048 to evaluate these occurrences for reportability.
2.6 Inadeouately locked Valve On October 26, 1994, the inspector identified that Valve BB V0149 Reactor Coolant Pump B seal water injection line isolation, was not adequately locked.
Operators used excessive chain such that the valve could be repositioned
- without removing the locking device. The inspector concluded that this resulted in the valve not actually being locked.- Procedure ADM 02-102,
" Control of Locked Component Status," Revision 28, Step 4.12, requires that all. valves required to be locked be rechecked prior to entry into Mode d..
This is the second example of a violation of TS 6.8.1.a (Violation A,
.482/9412-01).
The licensee initiated PIR 94-1911 for review of this matter.
2.7 Conclusions A self-revealing example of a violation of TS 6.8.1 occurred when an operator failed to follow the procedure resulting in the pumping of an unsampled RHUT to the.SFP._ The inspector identified a second example of a violation of TS 6.8.1 when operators used excessive chain, and therefore, failed to properly lock Valve BB V0149.
Operators extinguished EDG potential transformer fires promptly.
The failure of licensee personnel to review the prints prior-to opening the NK12 battery disconnect resulted in operators
~
- 1.
- i i
8-inadvertently deenergizing the NK02 bus. A miscoordination between operations and chemistry resulted in the inoperability of both trains of containment t
Eatmosphere radiation monitoring.
The licensee identified two examples where t
operators worked overtime in excess of the TS 6.2.2.f overtime guidelines j
without authorization.
3 MINTEMNCE OBSERVATIONS (62703)
During this inspection period, the inspectors observed and reviewed selected maintenance activities to verify that personnel complied with regulatory i
requirements including:
receiving permission to start work; requiring quality control department involvement, proper use of safety tags, proper equ' poent
- l alignment and use of jumpers, appropriate radiation worker practices, and use r
of calibrated tools and test equipment; documenting the work performed; and requiring proper postmaintenance testing.
Inspectors also evaluated the impact of the observed work on system operability and plant safety.
Specifically, the inspectors witnessed portions of the following work requests (WRs):
i e-WR 03346-94 Removal and deletion of the electrical portion of Target Rock Valve BB HV81578 in accordance with Plant t
i Modification Report (PMR) 04934.
- WR 03930-94 Replacement of Breaker NG01BBR3 for Pressurizer Relief Isolation Valve BB HVe000A.
WR 04850-94 Postmaintenance testing of Breaker NG03C HF3 for
~
Valve EG HV15, component cooling water.(CCW) return from nuclear auxiliary component.
WR 04902-94 Postmaintenance testing of Breaker NG 03CJF3 for Valve EG HV53, CCW supply to nuclear auxiliary component.
WR 05245-94 Addition of weld metal to the socket welds of Valve BG HV8357, CCP to seal injection, to obtain a weld profile in accordance with PMR 4394.
i
~
WR 80055-94
- Replacement of Reactor Coolant Loop 1 Differential
. Pressure Flow Transmitter BB FT0414, per NRC Bulletin 90-01.
WR 05769-94 Main Steam isolation Valve AB HV0017 troubleshooting.
Suspected leaky rod end head / gland 0-ring-(pressure sealing 0-ring).
e WR 60242-93 Replacement of the turbine-driven auxiliary i
feedwater (AFW) pump's internal rotating assembly for inspection.
-y-
%--a wom-9 9 g g
w
,9y_-
-n,w-,-ym.y_q..,,
.-, +,,,
7-y--,,
o 7,,--m-g-
..y3-779-,
7-.m.
i.
1 i
WR 03774-94 Modification of the vendor portion of the injection e
cooling line on EDG B.
WR 03338-94-01 Installation of Cables llBGG52AA and llBGG52AB in CCP Room A.
Selected observations from the activities witnessed are discussed below.
3.1 Maintenance Miscoordination With Enointerina and 03erations On October 12, 1994, mechanical maintenance notified the shift supervisor that CCP A had not been properly retested following scheduled outage maintenance.
The initial maintenance on the pump did not appear to have the potential to affect the pump flow characteristics.
Subsequently, mechanics decided to remove and reinstall the original outboard thrust and journal bearing package in order to permit removal of the seal package.
Due to inadequate communications and an inadequate review of the work request, operations failed to identify the need to perform Surveillance Procedure STS BG-100A,
" Centrifugal Charging System A Train Inservice Pump Test," to meet TS 4.0.5 requirements for ASME Section XI testing prior to declaring the pump operable.
Following maintenance, operators performed a postmaintenance pump run; however, the conditions were nnt established nor data collected to determine if the pump would have' met the ASME Section XI test criteria. After notification, the shift supervisor stopped core alterations and immediately directed the performance'of Surveillance Procedure STS BG-100A, which was completed satisfactorily. Operations initiated PIR 94-1766 to track corrective actions and Reportability Evaluation Report 94-043 to determine reportability.
Subsequent testing demonstrated that the pump was capable of performing its safety function.
A subsequent engineering evaluation determined that the test was not actually required by TS 4.0.5 since the original thrust and journal bearings were reinstalled.
The inspector reviewed the work request, reviewed the pump drawings, and questioned the system engineer.
The inspector determined that the removal and reinstallation of the original bearing housing could not change the axial or radial position of the pump shaft, and, therefore, could not affect the flow characteristics of the pump. While the licensee was able to demonstrate the adequacy of the retest performed, the inspector noted that the work request documented the expectation that 515 BG-100A would be run and vibration readings taken to determine whether a hot alignment would be required or not.
The licensee also needed to complete the evaluation of Reportability Evaluation Report 94-043 in order to determine the adequacy of the retest actually performed.
The inspector concluded that this miscoordination between operations and maintenance represented inattention to detail and inadequate communication between maintenance, engineering, and operations.
i L
3.2 Control of Contract Workers During the refueling outage, the licensee identified several examples of contract worker errors as discussed below.-
o On September 24, 1994,.a contract worker began disassembling a head vent h
solenoid valve during head disassembly rather than determinating the leads at a junction box. This was discovered by the licensee as the worker began to remove the solenoid valve cover. The licensee took appropriate actions to reassemble the head vent solenoid valve to maintain valve environmental qualifications, o
On September 24, 1994, workers started a fire when a contract supervisor directed contract workers to apply prop 6ne torch heat directly to a
- condensate domineralizer vessel liner contrary to the work instructions.
The instructions required that heat be applied to scrapers which were then to be used to soften and remove the liner.
Licensee employees were monitoring this work approximately once per hour.
On September 27, 1994, the licensee observed a refueling technician seated in a reclined position inside a hot particle. control zone while waiting for the completion of fuel ultrasonic testing.
'In each of these cases, the licensee took appropriate actions to correct the' inappropriate work practice and reinforce expectations with contractor management. The inspector concluded that while the occurrenc6 of these examples reflects inadequate control' of work by contractors, licensee management took strong actions with contract management to-reinforce work expectations once identified.
3.3 Conclusions The inspector identified an example of a violation of TS 6.8.1 when mechanics failed to sign off required work instructions prior to proceeding to
- subsequent _ work steps. The licensee identified a maintenance miscoordination with engineering and operations, which resulted in declaring CCP A operable without performing the required surveillance.
The remaining maintenance work observed was performed well.
Early in the refueling outage, the licensee
-identified several-examples where contract work was not well controlled.
4SURVE!LLANCE OBSERVATIONS (61726)
The inspectors sampled selected surveillance tests required by TS to verify that..the-1tcer,see performed the tests in accordance with TS, used technically adequate procedures, used appropriate-test equipment, and properly dispositioned any test results, which failed to meet the acceptance criteria.
515 BG-100B Centrifugal Charging System B Train Inservice Pump Test, Revision 14.
STS AL-211 Turbine-Driven AFW System flow Path Verification and inservice Check Valve Test, Revision 6.
STS IC-204A Analog Channel Operation Test of TAVG, di and Pressurizer Pressure, Revision 4.
STS IC-500G Channel Calibration DT/TAVG Instrumentation loop 4 Revision 10.
STN 1C-264 Calibration of Containment Differential Pressure Instrumentation, Revision 4.
TMP EN-1B ESW Train B Post-Loss of Coolant Accident flow Balance Selected observations from the review of these activities are discussed below.
4.1 Instrumentation and Control (l&C) Surveillance on the Only Available Control Room. Ventilation System On September 26, 1994, electricians and l&C technicians performed Surveillance Procedure STS GK-0018. " Control Room Emergency Vent System Train B 0)erability Test," Revision 14. During the test, the licensee discovered that the control l
room pressurization unit heaters were deenergized from 8:45 and 9:35 p.m.
The j
shift supervisor initiated PIR 94-1609 and Reportability Evaluation Report 94-040. The licensee determined that operability of the pressurization system did not require the heaters during the period when the heaters failed to energize.
The inspector reviewed the licensee's evaluation and agreed with the licensee's operability determination.
The inspector noted that this surveillance was performed when the Control Room Pressurization System Train B was the only train available, and the technician error challenged the operability of the system.
Concurrent fuel handling required operability of this system.
This is similar to the drain do'in event described in NRC Inspection Report 50-482/94-10, paragraph 2.4, wher9 maintenance on a valve associated with the only available train of 'cesidual heat removal created the conditions that permitted the event to oreur.
The inspector discussed the s.imilarity of these two events with t% Vice President Plant Operations, and expressed concern regarding the scheduling of maintenance with the potential to affect the only available safety train.
The Vice President Plant Operations stated that they had also recognized this concern and had taken additional steps to conduct reviews of planned work for the remainder of the refueling outage.
These reviews provided assurance that the licensee would not permit work to proceed where the potential existed to affect the only available safety train. The inspector ooserved that the licensee erected flagging around safety-related switchgear and other equipment to discourage workers from entering and working on required operable safety-train equipment.
In addition to the flagging, the licensee posted signs which read stop, think STAR, primary safety-train equipment, check with control.oom before performing any work activity on this equipment." During the remainder of the outage, no additional events occurred where maintenance
12-on the only available train of safety equipment challenged system operability.
The inspector concluded that this re) resented an improvement and noted that the licensee did not require this scieduling pr atice in their formal scheduling program. At the exit the licensee stated that they were considering changes to their scheduling program.
4.2 I&C Surveillance Data Collection Expectations Not Clearly Understood On October 20, 1994, the inspector observed I&C technicians perform testing of T
, delta T, and pressurizer pressure circuitry in accordance with SIS it-204A, " Analog Channel Operational Test of T..,, delta T and Pressurizer Pressure Protection Set IV," Revision 4.
The inspector also observed as technicians calibrated the over temperature delta T (OTdT) reference setpoint per STS IC-500G, " Channel Calibration DT/Tavg Instrumentation Loop 4,"
Revision 10.
The inspector arrived at the work site during shift turnover and verified that all the test equipment used for the job had current calibration due dates. Additionally, the inspector verified that the equipment was setu) in accordance with the procedures.
When the oncoming technicians arrived, tae inspector noted that the oncoming crew had received an adequate turnover.
Prior to starting work, the technicians took time to verify proper equipment setup and interconnections for the next section of the procedure.
At different points in the procedure, the technicians recalled past experiences related to those steps that they were preparing to start, from these discussions, the inspector noted that the technicians were knowledgeable of the test.
The inspector also noted good communication, good use of procedures and good cross checking practices.
While performing STS IC-204A, the technicians found one data point, the OTdi reference (setpoint) of Data Table 4 out of the acceptable tolerance range.
The technicians transitioned into STS 1C-500G and corrected the out-of-tolerance condition as directed by the procedures. When the technicians returned to the original procedure, they discussed the effect of the calibration on previously collected data and whether or not they should recheck the previously checked points to ensure that AS-LEFT values were within the acceptance criteria.
The inspector noted that the technicians appeared unc9rtain, and that after discussion, they decided to recheck the AS-LEFT values.
All newly acquired values were within the tolerance ranges.
The inspector noted that the technicians obtained values that had changed as much as 43 percent of the acceptable tolerance range.
The inspector expressed concern with the technicians' apparent uncertainty regarding whether they should recheck the AS-LEFT values after the calibration.
The inspector discussed this concern with several different members of the 1&C department.
The first-line supervisor initially indicated that the technicians had done too much by rechecking the AS-LEFT values.
The I&C department supervisor and superintendent stated that they expected the technicians to recheck all of the AS-LEFT values.
Administrative Procedure ADM 08-807, "I&C Group Surveillance Testing." Revision 10. Step 5.3.5 stated, "The AS LEFT columns of applicable data tables will be completed such that the AS LEFT condition is clearly documented, it is acceptable to note AS FOUND across the AS LEFT column if no calibration adjustments are made."
The inspector expressed concern at the
~
l '
technicsans' apparent uncertainty and the initial response of the first-line supervisor since this was not consistent with senior management's expectations and the procedural requirements.
While the technicians fulfilled procedural requirements, this did not appear to be the result of a clear understanding of the requirevnents but solely as a result of discussions held in the field.
The
[
I&C superintsndent stated that this concern would be addressed with all involved individuals to ensure that procedural--requirements would be met in the future.
[
4.3 Conclusions An !&C technician installed a test probe on the output of a signal condition unit rather than the input on the Control Room Pressurization System Train B, thus preventing the heaters from energizing.
The inspector ex>ressed concern over this, in that, the licensee scheduled this surveillance wien Train 8 was the only available train of this safety system.
I&C technicians and first-line supervision expressed confusion regarding the requirements for rechecking AS-LEFT. values following a calibration to correct an out-of-tolerance reading.
The remaining observed surveillance testing was well controlled and satisfied TS surveillance requirements.
5 ONSITE ENGINEERING (37551)
The inspectors reviewed and evaluated engineering performance related to selected plant operability and design issues as discussed below.
5.1 SFP Pump B Bearina Failur_en On October 30, 1994, SFP Cooling Pump B inboard bearing failed, rendering the only train of SFP cooling inoperable.
Twenty-two minutes later, the licensee was-able to restore SFP Train A cooling. Mechanical maintenance replaced the bearing and-restored the pump to operation.
Prior to completing a root cause of failure determination, the bearing failed again on October 5, 1994.
Mechanical maintenance repaired the pump again, and worked with engineering to complete a root cause failure determination.
By carefully measuring the oil level needed to adequately lubricate the bearing, the licensee determined that the vendor provided inaccurate instructians for setting the Trico oiler.
The vendor instructions stated that the oiler height should be 9/16 inches, while engineering determined that the proper oiler level should be 13/16 inches based on adequate oil-level in the bearing.
The inspector questioned whether any other pumps supplied by the same vendor could be similarly affected.
Engineering stated that this had not been considered.
The licensee acknowledged the inspector's concern and initiated a review for any other pumps supplied by the same vendor.
Tlie inspector concluded that while the initial troubleshooting effort appropriately found the vendor error, engineering failed to consider the broader implications of this discovery.
g
-5.2 Reactor Startus Procedural Weaknesses On October 30,:1994, the inspector observed the reactor startup using the Reactor Engineering Procedure RXE 01-002, " Reload Low Power Physics Testing,"
Revision J.
As stated in paragraph 9. the inspector concluded that the
' reactor startup was well controlled and' represented a cautious approach to i
criticality.
The inspector noted that the procedure required an initial determination of pressurizer and reactor coolant boron concentration.-but
. failed.to establish any limits-on the maximum difference permitted. The:
l-inspector also noted that Step 4.22Lstated that:
" Values given for the
-various parameters-(for example, Flow Rates) are intended to be approximate and for guidance only and shall not be construed as absolutes." The procedure also did not require a test log nor establish any other requirement for the test perfomer to document deviations from the procedure based on Step 4.22._
The inspector expressed concern that this very general statement permitted the test performer t,o deviate from any value-in the procedure without having to
' document.the deviation nor the reason for the deviation. During the reactor startup. Steps 6.3.20 and 6.3.23 required the performer to dilute at a rate of 30 rW.
During the reactor ~startup on October 30, 1994, the inspector cbserved the reactor-engineer recommend that the dilution rate be reduced to 15 gpm to permit pressurizer and reactor coolant system boron concentrations to equalize. When questioned, the reactor engineer stated management considered this acceptable because of the flexibility permitted by-Step 4.22.
The reactor engineer-did not document this decision nor the basis.for it. The Itcensee stated that while this may be strictly true, management has considerable confidence in the minimum. qualification requirements of reactor cngineers..The inspector concluded that the flexibility permitted by n e procedure and the-failure of the procedure to require documentation or permitted deviations constituted a weakness in the guidance provided by the procedure. The licensek stated that a-test log would represent an improvement but emphasized that they did not consider the potential-procedure weakness to-have any impact on nuclear safety.
5.3 System Enoinee'rina involvement On October 12, 1994..the-inspector observed as'the licensee performed 515 BG-1008 ' Centrifugal Charging System B Train Inservice Pum) Test,"
Revision 14. - This surveillance was being performed to establisi new reference values-for: future testing of the system.
The inspector noted good communication in the field, good communication between the field and the control room, and good use of procedures. Additionally, the inspector noted that system engineering was actively involved throughout the surveillance.
The system engineer for the system observed the start of the pump and checked
.the' pump thoroughly as it was running.
A different system engineer was conducting the. surveillance.
The surveillance was completed satisfactorily.
The inspector.' concluded that system engineering involvement during this sur_veillance was very good.
-v
%r
L.
15-5.4 Noise Event During the refueling outage the licensee installed numerous sensors and monitoring soutpoent in order to capture data on a potential noise event caused by reactor coolant system movement associated with the heatup. During Refueling Outage V. the noise event-generated a seismic acceleration of 0.34 g.
During Refueling Outage VI, the noise event generated a seismic acceleration of 0.18 g.
During this refueling outage, a noise event occurred on October 28, 1994, with an acceleration slightly above 0.05 g.
Within hours of the event,:the licensee determined that.the data collected showed that the energy release caused by this event was bounded by calculations used to bound the previous noise events. The-inspector concluded that the licensee l
preparation for a possible noise event during this out3ge, and the prompt analysis to bound the event represented good anticipation and good l
. reparation.
Following the noise event, the licensee issued a press release p
L
.and the Vice President Plant Operations placed a hold on restart until engineering completed their report documenting the analysis of the event.
The l
inspector concluded that this hold on plant restart was appropriate.
5.5 Conclusion initial troubleshooting effort for the SFP cooling pump bearing failure was good. However, engineering failed to consider broader implications of their findings in that they did not address other pumas that may have had similar problems until questioned by the inspectors.
T1e inspector concluded-that -
Procedure RXE 01-002 had several weaknesses.
The procedure allowed the-performer to deviate from any value in the procedure without having to document or justify these deviations. Additionally, this
)rocedure required that initial boron concentrations in the pressurizer and tie reactor coolant-system be measured but did not specify a maximum allowable difference between the two. During STS BG-100B, the inspectors noted that engineering involvement during this surveillance was very good.
Licensee pre!)aration for a' possible noise event during this outage and prompt analysis to >ound the -
event, represented good anticipation and good preparation. The licensee's
. decision to place a hold on restart until engineering completed their report on the noise event _was conservative and appropriate.
6 PLANT SUPPORT ACTIVITIES (71750) 6.1 Manual Valve Repackina with lmoroper Protective Clothina-lThe inspector observed activities associated with repacking Valve BG 8483A, the Coolant. Charging Pump A Discharge Valve FC V121 inlet isolation valve, funder WR 90000-92 on September 28, 1994.
The only HP protective clothing the mechanic wore _was a pair of rubber gloves. The mechanic used good mechanical work practices during removal of the installed packing, and carefully contained all of the removed material in a plastic bag.
The mechanic immediately passed the bag to the HP tt:chnician providing continuous coverage.
The HP technician frisked all the removed packing and found contamination on the last ring of packing.
The inspector noted that with the removal of t.he
' last ring of packing, the mechanic exposed the contaminated charging system fluid to atmosphere, and therefore, breached the system.
The inspector reviewed the WR, found that the work was properly authorized, and noted adequate instructions regarding work technique and the specification of the replacement packing. The WR specified that RWP 94-2100 would be used for this work.
The inspector reviewed the RWP and determined that it required full protective clothing when working in contaminated areas, lhe general area around the repacked valve was not estabitshed as a contaminated area, but when the last ring of packing was r6 moved from the valve, it was determined to be contaminated, and the charging system which was open to the atmosphere with l
thevalvepackingremoved,wascontamlnated.
Procedure RPP 03-505, " Selection of Protective Clothing," 'or ex)on 1, required protective clothing to be Revisi selected based on actual ected conditions.
Since the work was to breech a known contaminated system, tie minimum set of protective clothing for this job was required to be full protective clothing per Radiation Protection.
This observation was discussed with the lead HP technician who had instructed the craftsman to follow the observ'd practice e
during the valve ce)acking.
The requirements of the RWP were discussed with the HP technician w1o agreed that the verbal instructions to the craftsman did not comply with the written requirements of the RWP and RPP 03-505, but believed the instructions, were adequate to control any 10tential contaminatiot given the scope of work. The RWP was revised on Septem>er 30, 1994, to be less restrictive in its requirements and allow the HP technician more flexibility in establishing the necessary contamination controls for each circumstance.
Although no contamination control problems were encountered during the observed activity, the inspector concluded that the failtre of the activity to be performed in accordance with the requirements of the RWP and RPP 03-505 was the first example of a violation of TS 6.11 (Violation C, 482/9412-03).
The licensee responded by initiating PIR 94-1672.
6.2 Good Radiological Controlled Area (RCA) Material Release Practices The inspector observed that the HP techaician monitored hand-carried items to be removed from the RCA in a very conscientious and thorough manner.
The technician used an appropriate combination of frisking and smearing to ensure that all releas"- material was free of contamination.
The inspector concluded that the technt;ian performed this activity well.
6.3 Contaminated Area Entry With improperly Worn Protective Clothina On October 6.'the inspectors observed the licensee performed work activities on CCP B.
The inspectors noted an operator entering the contaminated area with unzipped coveralls.
The operator also f ailed to tape the "ubber gloves and booties to the coveralls. After entering the contaminated area, the operator ztpped the coveralls and proceeded to manipulate a valve.
The
17 9
inspectors questioned the operator as to the RWP activity requirements.
The operator ex)lained that the RWP required only a minimum set of protective clothing, w11ch consists of cloth booties, rubber shoe covers, and gloves.
After noting that the operator signed RWP 940005, Revision 0, the inspectors asked the lead HP technician about this contaminated area entry.
The lead HP technician explained that the RWP allowed a minimum set for a walk-thru and that HP considered this contaminated area entry a walk-thru.
Procedure RPP 02-105, 'RWP," Revision 6, Section 9.3.1, stated that:
" Protective equipment specified on the RWP is a minimum requirement which all personnel accessing the RWP must comply with, unless otherwise directed so in the special instructions." Procedure RPP 03-505, " Selection of Protective Clothing," Revision 1, Attachment 11.1, note 4, defined a walk-thru as: "wal k-thru - contact with contaminated equipment / components is N01 likely and work is 80_1 performed." Additionally, this attachment required a full set of protective clothing for any activity other than a walk-thru or a reach across in an area of 1,000 to 50,000 Deta/ Gamma dpm/100 sq cm of smearable contamination. After further discussions, the HP supervisor of radwaste initiated PIRs 94-1935 and 94-1936. HP further explained, that while the procedures do not require the use of tape, general employee training instructs all employees to tape gloves and booties to the coveralls, and HP expects everytne wearing a full set of protective clothing to use tape.
The inspector concluded that the operator's entry into the contaminated area with improperly donned coveralls to be a violation of the RWP and, therefore, a second example of a violation of TS 6.11 (Violation C, 482/9412-03).
6.4 Chemistry Technician Failed to Follow the Chemistr_v Procedure On October 30, 1994, the inspector observed a chemistry technician perform a boric acid concentration titration analysis of a primary sample in accordance with Procedure CHM 02-050, " Determination of Boron (Titration Method),"
Revision Step 9.2.15 of the procedure required the technician to add two scoops of mannitol and five drops of phenolphthalein indicator solution.
The inspector observed the technician add three partial scoops of mannitol and an indeterminate amount of phenolphthalein.
This f ailure to follow the procedure is a third example of a violation of TS 6.8.1.a (Violation A, 482/9412-01).
The itcensee initiated PIR 94-1943 to evaluate and determine corrective actions, and counseled the technician.
6.5 Chemistry Technician failed to Frisk On October 30. 1994, the inspector noted that a chemistry technician exited a contaminated area in the primary sample laboratory without frisking, then proceeded to handle objects in presumed clean areas of the laboratory.
Procedure AP 25B-100, " Radiation Worker Guidelines," Revision 0, Step 6.6.3, requires radiation workers to perform a hands, feet, and face frisk after exiting a contaminated area.
The inspector concluded that this is a third example of a violation of TS 6.11 (Violation C, 482/9412-03).
The licensee 3
responded by initiating PIR 94-1938 and counseling the technician.
6.6 Conclusions The inspeptors identified three e:tmples of a violation of 15 6.11.
The first two examples dealt with poor dress out practices while working in a contaminated area. The last example identified a poor frisking practice in the chemistry lab. Additionally, the inspector identified an example of a violation of TS 6.8.1.a when a chemistry technician failed to follow the r;uantitative requirements of a procedure in deterniining the boric acid concentration of a )rimary sample.
Last, the inspectors noted good practices while observing HP 1andling of hand carried items exiting the RCA.
l 7 COMPLEX SURVEILLANCE (61701)
The inspectors observed the following complex surveillance test required by TS to verify that the licensee performed the tests in accordance with TS, i
utilized sufficient oversight to coordinate the complex activity, used i
te:hnically adequate procedures, used appropriate test equipment, and properly l
dispositioned any test results, which failed to meet the acceptance criteria.
l l
7.1 Integrated Diesel Generator and Safequards Actuation Test - Train A On October 15-16, 1994, the inspectors observed portions of the preparation for and performance of Surveillance procedure STS KJ-001A, " Integrated D/G and Safeguards Actuation Test - Train A," Revision 12.
The briefing provided prior to the performance of the test was satisfactory.
The personnel performing the procedure in the control room were qualified reactor operators who performed the test in accordance with the procedure.
Good communication existed within the control room and between the control room and the field.
The test supervisor ensured all test performers understood each test sequence prior to proceeding.
The inspector noted that the test performers used equipmerit within the marked calibration period.
System engineering and quality control representatives observed the test.
The inspector reviewed the procedur9 and the test results and verified that the test met the TS requirements identified in the procedure.
Both the procedure and the results were found to be complete and satisfactory.
The loss of offsite power in conjunction with a safety injection signal portion of the test was performed satisfactorily with one deficiency of note.
ESW self-cleaning strainer driver motor thermal overloads tripped on actuation.
The licensee identified the issue as a test deficiency and wrote a WR to troutleshoot and repair the problem.
The shift supervisor entered 15 Action Statement 3.7.4 until the licensee verified that manually turning the strainer one revolution in the forward and reverse directions eliminated the problem. Once the strainer was verified to function properly again, the licensee closed the WR and the shift supervisor exited TS Limiting Conditions for Operation 3.7.4.
The inspector noted that the same ovnicads had inexplicably tripped in June 1994.
The licensee completed exteasive troubleshooting, but could not
I
)
19 identify the root caute for the tripping of the driver motor thermal overloads.
They suspected that the root cause was binding inside the strainer as a result of debris lodging under one of the distributor arm seal plates.
Engineering observed that turning the strainer manually one revolution in both the forward and reverse directions appeared to eliminate the problem.
The corrective action taken was to revise System Operating Procedures SYS OP-001,
" Weekly Equipment Rotation and Readings," Revision 3, and SYS EF-201, "ESW Screen Wash and Self Cleaning Strainer Operation," Revision 7, to ensure that the strainet was manually actuated and run for 2-minutes weekly to eliminate any buildup of debris.
The engineering disposition titled, "ESW Strainer A Overload," for WR 03181-94, recommended the weekly rotation and further recommended that the strainer be inspected internally at the next available No action was taken to enter this recommendation into any opportunity. _
tracking system.
The inspector expressed concern regarding the licensee's failure to take further action to identify the root cause and the failure to take actions +.o implement the system engineer's inspection recommendation to inspect the internals.
The licensee asserted, that based on the NRC review of the initial failure documented in NRC Inspection Report 50-482/9/.-06, paragraph 2.2, the strainer was not required for ESW system operability.
The inspector noted that Update Safety Analysis Report, paragraph 9.2.1.2.2.1, described the strainer as.a component in this safety-related system, and further noted that the discussion in NRC Inspection Report 50-482/94-06, paragraph 2.2, emphasized the context of the actual environmental conditions at the time of the prior strainer failure.
The unexplained tripping of the strainer when it was called upon to function raised questions regarding its operability. While the inspector acknowledged that this strainer would not be required at all times for the ESW system to perform its safety function, the self-cleaning function of the strainer may be required for the system to perform its safety function during certain environmental conditions.
At the conclusion of the inspection period, the licensee acknowledged that no documented plans existed for further corrective action for this strainer failure. of Procedure KGP-1210. " Performance improvement Requests,"
Revision 10 identified the failure of a safety-related piece of equipment to perform its intended safety function on demand or as expected as significant.
Procedure KGP-1201. " Corrective Action," Revision 1, required that a Performance improvement Request (PIR) be initiated to determine the cause and corrective actions to prevent recurrence for significant hardware failures.
The inspector concluded that the failure to initiate a PIR was a fourth example of a violation of TS 6.8.1.a (Violation A, 482/9412-01).
7,2 Conclusions The inspector identified a violation when the licensee failed to initiate a PlR following a repeat failure of an ESW strainer. The complex surveillance observed was performed in an adequate manner with good communication and supervisory oversight.
4 e.
8 REFUELING ACTIVITIES (60710) 8.! Observed Refuelina Activities
- The inspectors observed activities associated with refueling activities.
Specifically, the inspectors observed the removal and reinstallation of several fuel assemblies from the core and their subsequent movement thr: ugh the transfer canal. Contractor personnel performed the core alterations under the direct supervision of a licensed senior reactor operator.
The supetvisor maintained an appropriate level of involvement in ongoing activities. The inspector noted continuous communications with the control room as required by TS 3.9.5, and also noted the audible indication of source range nuclear instrumentation as required by TS 3.9.2.
The contractors performing the refueling equipment mani)ulations and fuel movements were attentive to l
indications on the fuel landling machine regarding status and vosition indicating lights as well as load readings from the refueling mast load cell.
HP technicians appropriately posted the reactor cavity as a contaminated area.
Workers used tied off safety harnesses when not on the bridge. Workers also tied off or taped safety glasses, dosimetry, and other small items required to perform the refueling to prevent these items from dropping into the reactor cavity.
On September 27, 1994, while observing fuel offloading, the inspector observed what appeared to be a piece of foreign material on the edge of the core barrel, and aointed it out to the senior reactor o>erator in charge of fuel handling. Tie senior reactor operator looked at tie object with a pair of binoculars, contacted rea.ctor engineering and continued offloading fuel.
i Shortly thereafter, the workers moved the fuel assembly closest to the object.
After the offloading was complete, the licensee performed their scheduled foreign object search and retrieval procedure.
During the foreign object search and retrieval, the licensee took a closer look at the object and identified it as a piece of Q-tape (clear with fibers).
They then retrieved and examined the. tape and concluded that due to its physical characteristics, it could not have been in the vessel during the previous cycle and probably washed into the vessel during reactor vessel and refueling cavity flooding.
However, the licensee also stated that no tape of this type was known to have been used in the area.
The inspector concluded that the failure of the licensee to identify and remove the foreign object prior to moving the adjacent fuel assembly increased the likelihood of moving it further into the vessel and was, therefore, a poor practice.
The licensee initiated PIR 94-1682 for review of this matter.
8.2 Conclusions The observed refueling activities were well conducted and supervised.
The e
contractors appeared experienced and knowledgeable operating the refueling equipment. Appropriate radiological' and safety precautions were implemented by t.he personnel involved and 15 requirements were met.
The licensee's
. failure to identify and remove foreign material from the reactor was a poor prsctice.
9 RESTART FROM REFUELING (71711) 9.1 Reactor Physics Testina The inspector walked down portions of the Charging Train B, Safety injection Train B, and AFW systems.
The inspector found system valves in the proper i
position with locking devices where needed.
The inspector noted that housekeeping had degraded in the CCP B and Safety injection Pump B rooms, but not to the extent to impact system operability.
This observation included such items as a valve locking chain on the floor under a valve, numerous tools left on and near the pump skids, a valve packing washer left on a support, a welding hood and braccets left on a room cooler, and bags of material left in f
the room.-
The inspector observed the reactor startup on October 30, 1993 The shift supervisor and supervising operator used good command and control techniques, and the reactor operators used good communication techniques, especially during rod movement.
The. inspector noted reactor startup procedural weaknesses as described in paragraph 5.2.
Despite these weaknesses, the inspector concluded that operators controlled the restart well, conducting a cautious approach to criticality.
During the startup, the shift supervisor periodically questioned the operators to ensure that they were continuously anticipating criticality, and considering appropriate contingency actions.
On October 31, 1994, inspectors observed as reactor engineering and operations personnel performed rod worth calculations.
The task was completed in accordance with Procedure RXE 01-002. The reactor er.gineer and contractor supervising the activities and taking the data were knowledgeable on the procedure. The inspectors noted good communication batween the supervisor and the operator controlling the rods and that the operator was briefed befors proceeding on to each new step.
All involved w re noted to use good self-checking techniques.
9.2 Conclusions The inspector concluded that operators controlled the restart well, conducting a cautious approach to criticality.
The personnel who accomplished the
-necessary tasks used appropriate procedures and good communication and solf checking techniques.
10 FOREIGN MATERIAL EXCLUSION CONTROLS (2515/125)
The objective of-this inspection was to ensure that the licensee had implemented effective procedures to prevent foreign material from inadvertently entering safety systems during maintenance activities, outages, and routine operations.
w
rm y
)~
- 10.1 foreton Material Exclusion The _ inspector reviewed the following procedures that dealt with foreign
-material exclusion: Administrative Procedures ADM 01-110, " Housekeeping Control," Revision 13; ADM 01-034, " Internal / External System Cleanliness,"
Revision 14; and THP 02-004, " Refueling Cavity Exclusion Area," Revision 3.
Although these procedures outlined an adequate program to prevent the-introduction of foreign materials into safety systems, two weaknesses were identified.
The first was the failure of the reviewed procedures to provide guidance on action to be taken when foreign material is identified in a safety system. This allowed the foreign material (Q-tape) identified in the reactor in Section 7 of this report to remain in place after being pointed out.
The exclusion area boundary also failed to perform its function, in that, it allowed the piece of tape to enter the fuel pool and settle on the core barrel. -The results of a review by the licensee documented in PIR 94-1682 indicated that"the event sas isolated and that no corrective action was required.
The second possible weakness was the lack of guidance in the procedures on meeting the requirement to track personnel accountability within exclusion zones and the possible reliante on existing personnel tracking devices (local card readers or radiation work permits, for example).
Although the inspector did not identify any events where this had caused a problem, PIR 94 1852 questioned the adequacy of the procedures instruction on maintaining accountability within an exclusion area.
PIR 94-1851 identified a separate problem with the exclusion area around Diesel Generator B during bearing maintenance.
The exclusion area was set up so that workers could not access the west side of the engine to work if they entered at the manned entrance.
In adattion to the PIRs referenced above, the-inspector reviewed all PIRs that dealt with foreign material exclusion from the last year.
There were a number of instances where individuale failed to follow procedures. During inspections of the fuel building and reviews of material control logs on December 9,1993(PIR93-1624), July 13,1994(PIR94-1200), July 19,1994 (PIR94-1225), and October 14, 1994 (PIR 94-1781), the quality assurance group identified numerous clear plastic articles stored in lockers and items that cera %ged into the exclusion area around the SFP were not logged out.
To prevnd repeat occurrences, prior to Refuel Outage VII, discussions were held with werk group supervisors to stress the need to follow housekeeping procedures and to require that they review their work site at the end of the job to ensure housekeeping requirements were met.
These earlier corrective actions were not fully effective in that the problems were identified again in PIR 94-1781 toward the end of the outage.
The inspectors toured containment on October 26, 1994, to determine whether foreign material exclusion was a concern.
The plant was in Mode 4 and the licensee was in the process of removing the remainder of the equipment and debris from Refuel Outage Vll.
The inspector noted that housekeeping was good.
Inspection of the containment recirculation sump verified that it was
23 t
t free of debris and that the screen material was in good condition. No foreign l
material exclusion concerns were identified, i
10.2 Conclusions The program for foreign material exclusion was found to be adequate with some procedural weaknesses noted.
These dealt with the control of exclusion areas, direction requiring expedient identification and removal of foreign material i
found, and lack of direction in maintaining personnel accountability.
Recent PIRs also highlighted a continuing problem in fcilowing the procedures in the area of material control.
11 LER REVIEWS - ONSITE (92700)
The inspectors reviewed the following LERs for accuracy; effective root cause determination, reasonable safety analysis, and appropriate corrective action.
-The inspectors verified the completion of corrective actions described in the LER on a sampling basis to provide assurance of the completion of corrective actions.
11.1 (Closed) LER 482/94-009:
Positive Reactivity Addition Without an Operable Baron injection Flow Path On September 18. 1994, the licensee made a positive reactivity addition by adding hydrogen peroxide to the reactor coolant system for the )urpose of initiating a crud b"rst.
Later, the licensea discovered that tits occurred without an operable boron injection flow path as required by TS 3.1.2.3.
After the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> _EDG A surveillance run, the licensee discovered that the overspeed trip _ limit switch was loose and could have tripped the EDG during a seismic event.
This condition was not discovered until efter the hydrogen peroxide addition.
The licensee tagged out CCP B as required by TS 3.1.2.3 for cold overpressure protection, and the loose overspeed limit switch rendered EDG A inoperaale as an emergency power source for CCP A.
As a result, no operable boron injection-flow path was available as required by TS 3.1.2.3.
The licensee's root cause investigation determined that the loose overspeed trip limit switch was a result of normal vibration from the diesel operation during the 24-hour operability test.
This vibration caused the screws to disengage and, therefore, allowed the limit switch to move freely.
The licensee's corrective actions were to replace the loose limit switch and coat the retaining screws on the new limit switch with locking compound to prevent disengagement during normal diesel operation.
Additionally, the licensee inspected the overspeed trip limit switch for EDG 0, found that it appeared normal, and coated its retaining screws with lotking compound.
The inspector concluded that the licensee's corrective actions appeared appropriate to prevent recurrence.
l
)
l I
24-11.2 (Clased) LER 482/94-012:
Failure To Correctly Calibrate Refuelina Macaine Load Monitor On September 25, 1994, the licensee began core offload w'ith the refueling machine load monitor incorrectly calibrated such that the automatic overload cutoff was set 100 pounds in the nonconservative direction. At the time of discovery, 11 heavy fuel assemblies had been moved without an automatic load cutout set 250 pounds above the weight of the assembly as required by TS 3.9.6.
The licensee determined that the cause of the event was an unclear surveillance procedure and personnel misunderstanding the requirements for field-calibration of the load monitor.
The licensee stopped core alterations, inspected all 11 assemblies and.found no damage, recalibrated the load monitor, and enhanced the applicable procedure.
The inspector concluded that-the corrective actions appeared appropriate to prevent recurrence.
t
ATTACHNDli 1 1 PERSONS CONTACTED N. S. Carns, President and Chief Executive Officer T. A. Conley, Superintendent, Radiation Protection l
M. K. Covey, Shif t Engineer 1-T, M. Damashek, Supervisor, Regulatory Compliance R. D. Flannigan, Manager, Regulatory Services L
D. E. Gerrelts, Superintendent, instrumentation and Control R. N. Johannes -Chief-Administrative Officer R._E. Kopecky, Shift Supervisor-W. M. Lindsay., Manager, Performance Assessment 0.,L.-Maynard,'Vice President Plant Operations P. M. Martin, Superintendent. Operations B. T. McKinney, Manager, Operations
-T. S.-Morrill, Manager.-Quality Control-W. B. Norton, Manager, Nuclear Engineering F. T. Rhodes Vice President Engineering
-C. E.-Rich,' Jr., Superintendent riectrical Maintenance' R. L. Sims, Supervisor, Operations Support J. D. Weeks Assistant to Vice President Plant Operations S. G.-Wideman, Supervisor, Licensing M. G. Williams, Manager -Plant Support 1he above licensee personnel attended the exit meeting, in addition to the personnel listed above, the inspectors contacted other personnel during this.-
inspection period.
2 EXIT MEETINR An exit meeting was-conducted on November 7, 1994.
During this meeting, the insper, tors reviewed the scope and findings of the report.
The licensee did not identify as proprietary any-information provided to, or reviewed by, the inspectors..
t ATTACHMENT 2 l
ACRONYMS I
AfW auxiliary feedwater CCP centrifugal charging pump i
CCW component cooling water DC direct current EDG omergency diesel generator-ESW essential service water gpa gallons aer minute HP health p1ysics
.l&C instrumentation and control LER licensee event report:
0Tdi over temperature delta T PIR perfcreance th9rovement request PMR plant modification request RCA radiologically controlled area RHUT recycle hold up tank RPP radiation protection procedures RWP radiation work permit SFP spent fuel pool TS Technical Specifications
+
WR work request I
s 4
__y
l}
1 n
W@_LF_C_R_EEK December 30, 1994..
Otto L Maynard
}'f WO 94-0221
~6 U. S. Nuclear Regulatory Commission i
ATTH: Document control Desk Mail Station P1-137 Washington, D. C.
20555 References better dated $!ovember 16, 1994, from A. B. Beach, NRC, to N. S. Carne, WCNOC
Subject:
Docket No. 50-482:
Reply to Notices of Violation 482/9412-01, -02 and -03 Oentlement Attached is Wolf Creek Nuclear Operating Corpo ation's (WCNOC's) Reply to Notices of Violation 482/9412-01,
-02, and.03 which were documented in the Reference (NRC Inspection Report 50-482/9'-12).
Violation 482/9412 01 concerned four exaspples of WCNOC personnel failure to follow procedures.
Violation 482/9412-02 concerned two examples of WCNOC's failure to ensure personnel adhered to t.he policy on the use of overtime.
Violation 482/9412-03 concernad three examples of WCNOC's failure to correctly implement the Radiation Protection Program.
WCNOC's response to these Notices of Violation is in the Attachment to this letter.
The corrective actions for these violations are comprehensive and will ensure WCNOC's compliance with the applicable regulations and procedure requirements.
If you should have any questions regarding this response, please contact me at (316) 354-8833, extension 4450, or Mr. R. D. Flannigan at extension 4500.
Very truly yours, ll Otto L. Maynard 01N/jad Attachment cc L. J. Callan (NRC), w/a D. D. Chamberlain (NRC), w/a J. F. Ringwald (NRC), w/a g
J. C. Stone (NRC), w/e
'/ 6,d s.J.13 PO Boa 411/ Burlington, KS 66&39 / Phone (316) 3644831 gm,m f 3p
,,g,c, L3"#
An [oual Opportunity Empiover WFMCNET
I e
Attachment t3 WO 94-02a Page 1_Cf 10 i
maniv to Moticas.of Violation 9412 01. -019 #.
d1 Violation 482/9412-01:
Failure to follow procedure.
"A, Technical Specification 6.8.1.a
- states, in part, that written procedures shall be established and implemented covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2.
(1) Regulatory Guir's 1.33, Appendix A,
Section 7.a.
requires procedures covering the liquid radioactive waste system.
Procedure SYS HE.;01,
' Boron Recycle Holdvp Tank Operations,"
Revision 9,
Step 4.4.1, requires that the operator perform Section 4.2 for proper system alignment for recycling and sampling to transfer water from the Recycle Holdup Tank B to the spent fuel pool.
Contrary to the above, on September 30, 1994, an operator failed to perform Section 4.2 of Procedure SYS HE 201, and thereby incorrectly transferred unsampled Recycle Holdup Tank A to the spent fuel pool instead of Tank B as planned.
(2) Regulatory Guido 1.33, Appendix A,
Section 1.c, requires administrative procedures covering equipment control.
Administrative Procedure ADM 02-102,
" Control of Lockd Component Status," Revision 28, Step 4.12, requires that all valves required to be locked be rechecked prior to entry into Mode 4.
Contrary to the abov; on October 26, 1994, Valve BB V0149 was found inadequately locked such that it could be repositioned without removing the locking device.
(3) Regulatory Guide 1.33, Appendix A,
Section 10, requires procedures covering chemical and radiochemical control.
Chemistry Procedure CHM 02 050,
' Determination of Boron (Titration Method)," Revision 6, Step 9.2.15, requires that two scoops of mannitol and five drops of phenolphthalein be added to the sample container in preparation for the titration.
Contrary to the above, on October 30,
- 1994, a chemistry technician added three partial scoops of mannitol and an indeterminate amount of phenolphthalein to the sample container.
(4) Regulatory Guide 1.33, Appendix A,
Item 1.d, requires
. administrative procedures to address procedure adherence.
Procedure AP 15C-002, " Procedure Use and Adherence," Revision 0,
Section 6.3.4, requires that the intent and direction provided ia the procedure be followed during the course of activities. of Proceduro KGP 1210, " Performance Improvement Requests," Revision 10, identifies the failure of a
t AttCchment to WO 94 0221 Page 2 of 10 h
safety-related piece of equipment to perforn, its intended r4 safety function on demand or as expected ax significant.
Procedure KGP-1201, " Corrective Action," Revisica 1,
requires that a Performance Improvement Request (PIR) be initiated to determine the cause and corrective actions to prevent recurrens., for significant hardware failures.
Contrary to the above, on october 16, 1994, Essential Service water Self-Clcaning Strainer A,
a safety-related component, failed to operate when the drive motor thermal overloads tripped on actuation and a PIR was not initiated."
W mainn of violationn The Wolf Creek Nuclear Operating Corporation (WCNOC) agrees with the above noted violations.
Raaman for Violationt
)
noot causer Example # 1:
The root cause for this examole is cognitive personnel error, in that, the operator failed follow proceiur.1 step 4.2.
Example # 2:
The root caues for this example is cognitive personnel error, in that, the individual who secured and locked Valve BB V0149, failed to apply good self che.: king practice 3.
%e individual should have verified the chain was correctly run and the.
as elack was removed, prior to securing the valve and w
leaving the area.
Example # 3:
The root caue for this example is cognitive personnel error, in that, the individual did not perform the titration as required by the procedure.
Example # 4:
The root cause for this example is cognitive personnel error, in that, the individual did not initiate a Performance Improvement Request (PIR) for the ESW Strainer failure as requi:.ed by the WCNOC Corrective Action Program.
The root cause for the generic aspects of the above noted examples is inconsistent enforcement of Management's expectations to all plant personnel.
Contributino Factors!
A contributing f actor to generic aspects of this violation is the failure on the part of WCNOC to develop clearly defined consequences for procedure non-l compliance problems.
' Attachment t3 WO 94-02.i 9
iPage 3 Cf 10.
^
~
i v
. = = et.a m* ~
e-6--
' - sta m-ka---
PIR1 94-1675 was initiatodi to: address the specifir.. aspects - of the first example.-
Procedure SYS HE-201 was revised.
Thi1 revision clarified the Jrequirements_for placing the "B"
tank in recirculation.
PIR 94-1911 was initiated to = address the specific aspects of the secord-example. :The chain on Valve 38-V0149 was repositior.ed and correctly secured.
-The individual who locked Valve 3a V0149l was. counseled by the Shift
-supervisor.
PIR 94-1943 was -initiated to address the - specific aspecia of the third example;5 The individual who failed to _ follow _ procoJure -- CHN 02-050 : was counseled on the - need for verbatim procedural cosplian=e. - PIR4 94-1943 was placed in Chemistry Required Reading-to make-all: Chemistry personnel aware management's expectations on procedural-coupliance.
Chemistry personnel were notified' at the wiekly chemistry meeting- (on November' 23, 1994) to identify other procedural enhancements, that were needed, and that any ; procedural problem that prevented a task from being completed must be corrected prior to performing the task.
PIR 2116 was initiated to address the specific aspects of the fourth cenple.
ei.
94-2133 was initiated to address _ the _ generic - aspects of this violation.
M a result the following corrective actions were implemented.
Carrantive Stepa That Will Re Taken to Avald Furkhar violatianan WCNOC-Management will cornunicate its expectation-consequence standard to all plant personnel. 'This action will be completed by January 30, 1995.
WCNOC will_ set aside-.a. day -dedicated to the. subject of the "Use Of Procedures." ' During this day... there will be meetings. with all groups. where the Vice' President Plant Operations reemphasize what managemeent's expectations for' the use of procedures and review the; disciplinary actiora for failure to follow procedure.:
Managers and' supervisors will meet with their people to review the procedures they frequently use to ensure everyone is. aware of what the-raquirements are in the procedures.
Additionally, management's expectations will_be discussed to ensure plant personnel have a clear understanding of management's expectations.
During these meetings the disciplinary policy will be reviewed to ensure all personnel.have a clear understanding of the consequences of not following procedures.
The-Vice President Operations has established a _
- Topic Of The Week" program.
'This program will focus management attention on procedures which personnel have experienced problems fo. lowing properly.
This program will be used as long as it is deemed appropriate by plant management.
The implementation of this program is considered by WCNOC as an enhancement to the operation of the station and not as-a regulatory commitment.
=.
r" L'
=
-1,
. Attachment-t3 WO 94 02h.
~"
Page 4 Cf 10
.. f Opta uhan Full compliaana hill na Anhieveda Full. coupliance with Technical. Specification 6.8.1.a has been achieved.
Corrective actions to prevent recurrence of the problem will be completed bi January 30,.1995.
t 0
Atta:hment to WO 94-05.A P ge.5 Cf 10 4
violation 482/9412-02: Concerned two examples of WCNOC's failure to assure personnel adhered to its policy on the use of overtime.
- B.
Technical Specification 6.2.2.f.
requires that the amount of overtime worked by unit staff members performing safety-related functions shall be limited in accordance with the NRC Policy Statement on work hours (Generic Letter No. 82-12).
Generic Letter No. 82-12 states that individuals should not be permitted to work more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in 7 days.
Contrary to the above, on October 13, and October 19,
- 1994, operators worked in excess of the Technical Specifications guidelines without authorization in that a refueling SRO worked 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in excess of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in 7 days and a licensed operator performing valve lineups in the containment exceeded 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in 48
-hour period."
Adutismian of violatiant WCNOC agrees with the above noted violations, a==---
for violatiani Root causei Example # 1:
The root cause for this example is cognitive personnel error, in that, the Operations Supervisor within the Wolf Creek Outage Control Center failed to communicate to his relief and to the individual the limits of the working
-hours ; extension, and the -individual involved did not verify the-hours authorized prior to comencing work.
Example # 2:
TA root cause for, this example is cognitive personnel error, in that, the Operations Supervisor and the individual involved thought that by being sent home and directed to return later that evening the working day wo reset, consequently no authorization to exceed working hours was requind or requested.
Contributina'Factoran Review ' of previous violations of wfd.ing hour limits indicates that the greatest potential for exceeding working hour limits occur during refueling outages.
When workers are scheduled for consecutive 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts any holdover can cascade to cause the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period to be exceeded.
Correctiva 9 tans Taken and Resulta Achiavadt Several actions have been taken which helped prevent WCNOC personnel from exceeding the working hour limits.
These included periodic reinforcement of
l Attr hment t3 WO 94-022A Page 6 of 10 the working hour policy by management, placing the working hours limits in the General Employee Training, and listing the working hour limits in the Refueling VII Outage Handbook.
These actions were not totally offective and the following was also done:
PIR 94-17'10 was initiated to address the specific aspects of the first example.
The individual involved was aware of the working hour limitation and, in fact, initiated a request to get approval to exceed the administrative limit.
However, due to an inaccurate estimate of the number of hours to complete the assigned task and a miscommunication between the individual and his supervisor and the on-coming supervisor during the shift change, the individual worked more hours than approved.
Upon discovery the approval was received.
This PIR was placed in Operation's required reading to ensure all personnel, including supervisors, are aware of the circumstances of the event.
PIR 94-1842 was initiated to address the specific aspects of the second example.
The operations Outage Manager failed to recognize the effect on exceeding working hour guideline on an individual working a partial shift, returning home for a rest period and then returning later to work an entire shift, in the same 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period.
The individual involved also failed to recognize the impact of working a partial shift followed by a full shift.
Since another working hour incident had recently occurred and was being routed in required reading, an electronic mail message was sent to all operation's personnel emphasizing the importance of complying with working hour guidelines.
The individual who failed to comply with the policy on working hours was counseled by his shift Supervisor on the importance of following administrative procedures.
These are the only instances of the individuals involved exceeding working hour requirements. All individuals were aware of the policy requirements on working hours.
PIR 94-2135 was initiated to address the generic aspects of this violation.
As a result, the following corrective actions were implemented.
Procedure ADM 01-0*D,
' Guidelines For WCGS Staf f Working Hours" was revised and re-issued as AP 13-001, Revision 0,
" Guidelines For WCGS Staff Working.
Hours."
The revision included adding a section on responsibilities.
Specifically, Step 5.3 requires that all personnel are responsible for being cognizant of their hours worked, complying with the work hour limitations of the procedure and informing their supervisor that an overtime assignment may violate the requirements of this procedure.
Managers and supervisors were notified concerning the changes to this procedure.
Additionally, information concerning this procedu.e and individual responsibilities were published in a weekly publication available to all personnel.
Integrated Plant Scheduling has included in the outage preparation program a need to reinforce the working hour policy.
In addition to listing the working hour limits in the outage handbook, prior to each outage, the policy statement on working hours and management's expectations will be issued to all outage personnel.
'm Att*chment t3 WO 94 02'21 Page 7 of 10 Management will continue to reinforce the working hour policy by periodically issuing policy statements reviewing the working hour limitations and-management's expectations that all personnel will be personally responsible for ensuring they do not exceed the limits.
Procedure compliance was addressed in PIR 94-2133.
This PIR was issued to address the generic aspects of Notice Of Violation 482/9412-01.
The " Guideline For WCOS Staf f Working Hours" procedure will be the " Topic Of The Week" during the week of March 20, 1995.
nata ask== Fu11 e - le==aa will na kahtavads Full complian :e with Technical Specification 6.2.2.f has Dean achieved.
l t
=
e~
k, a,
Attachment to WO 94-0221 Page 8 of 10 Violation 482/9412-03: Concerned three examples of WCNOC's failure to correctly inplement its Radiation Protection Program.
'C.
Technical specification 6.11 sta'tes that procedures for personne1' radiation protection shall be prepared consistent with the requirements of 10 CFR 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposures.
(1) Radiation Protection Procedure RPP 02-105, 'RWP [ Radiation Work Permit)," Revision 6, Step 9.3.1, states that the protective.
equipment specified on the radiation work permit is to be per Procedure RPP.03-505,
" Selection of Protective Clothing,"
Revision 1.
Procedure RPP 03-505 requires protective clothing to be selected based on the known or expected contamination levels in the work area.
Radiation Work Permit 941200, Revision #
0, requires a full set of protective clothing for accers to contaminated areas.
Contrary to the above, on September 28, 1994, a licensee employee removed contaminated packing from a valve in a known contaminated system without wearing - a full set of protective clothing.
(2) Procedure RPP 02-105,
'RWP,"
Revision 6,
Step 9.3.1, states that the protective equipment specified on the RWP is a minimum requirement, which all personnel accessing the RWP must comply with.
Radiation Work Permit 940005, Revision 0, requires a full set of protective clothing for contaminated access.
Contrary to the above, on October 6, 1994, a licensee employee accessed a contaminated area in centrifugal charging pump room B without a full set of protective clothing in that the coveralls were not zipped up prior to entry.
- Radiation Worker Guidelines," Revision 0 Step 6.6.3, requires radiation workers to perform a hands, feet, and face frisk after exiting a contaminated area.
Contrary to the above, on October 30,
- 1994, a chemistry technician failed to frisk after exiting a contaminated area."
(This involved an individual reaching across a radiological control area boundary to manipulate a valve.)
ad=4maion of violationn WCNOC agrees with the above noted violations.
__a
.. -, e..
. ~. :
LAttachment to WO 94-0221
- Page 9.of 10; i
Spanam.far.Vialatian Root causai Exagle # 1:
-The root cause for this -example is cognitive personnel error, in that, the
' Health Physics -Technician failed to follow the Radiation ' Work Permit- (RWP) revision requirements set forth in procedure RPP 02-105, Revision 6,
- RWP.*
WCNOC's Health Physics Program allows the Health Physics Technician to r9 duce protective requirements, when the environmental conditions permit, as long as the RWP is revised to reflect the reduction.
Example # 2:
Although the environmental conditions did not warrant, nor did the RWP require plant _ personnel to don coveralls the operator voluntary elected to use l
- coveralls.
The root cause for this example is cognitive personnel error, in l
that, the individual contrary to the WCNOC Health Physics Program, failed to correctly wear the coveralls.
Example # 3:
The root cause of this example is an inadequate procedure, in that, procedure AP-258-100 did not add-ess frisking requirements for a reach'across situation as described in the above noted example, Carrective Etapa Taken and Rasulta lahlavadt PIR 94-16*l2 was initiated to address - the - specific aspects of the first example.
PIR 94-1936 was initiated to address the specific aspects of the second example.
PIR 94-1936 was placed in the Operations Required Reading Program.
This action was taken - to familiarize personnel with the event and the requirement to don protective clothing correctly.
- PIR._ 94-1938 was initiated to address the specific aspects of the third example.
PIR 94-2134 was initiated to identify the above noted concerns, to insure a root" cause _ evaluation for the above noted concerns was performed, and to assure corrective actions to prevent recurrence were implemented.
PIR 94-2134 was placed in the. Health Physics Required Reading Program.
This action was taken to familiarize personnel with the events, their root causes, and the corrective actions implemented to prevent recurrence.
f*arrective s>maa That Will Re Takan to Avoid Fur hme Violatiaam:
e Procedure AP 25B-100, " Radiation Worker Guidelines" will be revised.
This revision will clarify the frisking requirements for reach across situations.
-This revision will be completed by January 30, 1995.
4 ' '*
Attachment to WO 94-0221 Page 10 of 10 The Vice President Operations-has established a
- Topic Of The Week" program.
This program-will focus management attention on procedures which personnel have experienced problems following properly.
This program will _ be used as long me it is deemed appropriate by plant management.
The implementation of this program is viewed by WCHOC as - an enhancement to the operation of the station and not as a regulatory conunitment.
During the week of January 9,
1995, various procedures associated with Radiation Worker Practices will be the ' Topic Of The Week."
These events and similar events will be discussed, nata tek-puli e - li==aa mill na takinvade Full compliance with Technical Specification 6.11 has been achieved.
Corrective actions to prevent recurrence of the problem will be completed by January 30, 1995.
l O
J
,', /
\\-.
N aLEAR REGULATORY COMMISSIONT i
- (
S ctoioN iv k.,,,. f sii nvaN PL Aza onivt, suit t soo
.w~cro~. m.s 7.oi..os.
JAN 2 41995 Wolf Creek Nuclear Operating Corporation A1TN: Neil S. Carns, President and Chief Executive Officer P.O. Box 411 Burlington, Kansas 66839
SUBJECT:
NRC INSPECTION REPORT 50-482/94-12 Thank you for your letter of December 30, 1994, in response to our letter and Notice of Violation of December 1, 1994.
Based on our review of your ;esponse, we have no further questions at this time on your proposed corrective actions.
We will review the implementation of these actions during a future inspection to ensure they have been effective in precluding future noncompliance.
Sincerely, n
l pv.A. Bill Beach, Director l
Division of Reactor Projects i
i Docket:
50-482 License: NPF-42 Wolf Creek Nuclear Operating Corp.
ATTN: Vice President Plant Operations P.O. Box 411 Burlington, Kansas 66839 Shaw, Pittman, Potts & Trowbridge ATTN: Jay Silberg, Esq.
2300 N Street, NW Washington, D.C.
20037 U.S. Nuclear Regulatory Commission ATTH: _ Regional Administrator, Region III 801 Warrenville Road Lisle, Illinois 60532-4351 Wolf Creek Nuclear Operating Corp.
ATTN: Manager Regulatory Services P.O. Box 411 Burlington, Kansas 66839 N
,_ a,
]y Wolf Creek Nuclear Operating Corporation.
Missouri-Public Service Commission
-: ATTN:. Assistant Manager Energy Department-P.O. Box,160 Jefferson City, Missouri 65102 Kansas Corporation Comission ATTN: Chief Engineer Utilities Division 1500 SW Arrowhead Rd.
-Topeka, Kansas 66604-4027 Office of the Governor-State of Kansas Topeka, Kansas 66612 Attorney General
-Judicial Center l
301 S.W. 10th 2nd Floor l
Topeka, Kansas 66612-1597 County' Clerk Coffey. County Courthouse
-Burlington, Kansas 66839-1798 Kansas Department of Health and Environment Bureau of Air & Radiation ATTN:
Public Health Physicist Division of Environment Forbes Field Building 283 Topeka, Kansas = 66620 c.
}
L E A P R E G U L A T O P Y COMMISSlot s
[
.. n a e a c et w u 200 y
m,scros u us vu eou c...+
..,...... n Wolf Creek Nuclear Operating Corporation ATTN:
Neil S. Carns, President and Chief Executive Officer P.O. Box 411 Burlington, Kanst.: 66839
SUBJECT:
NRC INSPECTION REPORT 50-482/95-05 AND NOTICE OF VIOLATION This refers to the inspection conducted by Mr. J. F. Ringwald and Ms, J. L.
Dixon-Herrity of this office on March 12 through April 22, 1995.
The inspection included a review of activities authorized for your Wolf Creek Generating Station facility.
At the conclusion of the inspection, the findings were discussed with those members of your staff identified in the enclosed report.
Areas examined during the inspection are identified in the report.
Within these areas, the inspection consisted of selective examinations of procedures I
and representative records, interviews with personnel, and observation of activities in progress.
The purpose of the inspection was to determine l
whether activities t.uthorized by the license were conducted safely and in
(
accordance with NRC requirements.
Based on the results of this inspection, certain licensed activities appeared to be in violation of NRC requirements, as specified in the enclosed Notice of Violation (Notice).
Violation A resulted from two failures of your personnel to follov your surveillance test procedures. We are concerned by the first event because a licensed operator did not exercise sufficient care to distinguish between Panels RP332 and RP333 during surveillance testing. We are concerned by the second event because technicians failed to exercise sufficient care to perform only the steps specified during a partial surveillance test performance.
Violation B resulted from improper maintenance causing a locked high radiation area door to be unlocked for a period of approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. While Violation B was identified by your staff, it is being cited because the conditions for enforcement discretion as given in 10 CFR Part 50, Appendix B, Section VII.B,(2) were not satisfied with regard to comprehensive corrective actions in that you did not plan to perform a detailed root cause determination until after the inspector questioned your evaluation of the event. No response to this violation is required because of your self-identification and the corrective actions implemented.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response.
In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence.
Your response may reference or include previous docketed correspondence. if the corresnondence adequately addresses the required response. After reviewing your response to this
./
/ >
vsmwm
Y
-e' T
Wolf Creek Nuclear Operating.- Corporation-Notice, including-your proposed corrective actions and the results of future inspections, the MC will determine whether further NRC-enforcement action is necessary.to ensure compliance-with NRC regulatory requirements.-
In-accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of
.this letter, its-enclosure (s)', and your response will be placed in the NRC-PublicLDocument Room (PDR).
To the extent possible, your response should not include any personal privacy, proprietary,,or safeguards information so:that it can be placad in.the PDR without redaction, However, if you find it necessary to include such-information, you should clearly indicate-the specific information that you desire not to be placed:in the PDR and provide-the legal basis to support.your= request for withholding the information from the'public.
The-responses directed by this -letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the: Paperwork Reduction Act of 1980, Pub. L. No 96.511.
Should you have any questions concerning this inspection, we will be pleased to di_scuss them with you, i
Sincerely,-
SW ff
[tv'A. Bill--Beach, Director-Division of Reactor Projects Decket:
50-482
' License: NPF-42
Enclosures:
1..' Notice of Violation 2.
NRC' Inspection Report
.50-482/95-05 cc w/ enclosures:
Wolf Creek Nuclear Operating Corp.
ATTN:Vice President Plant Operations
=P.O. Box 411
- Burlington, Kansas 66839 Shaw, Pittman, Potts & Trowbridge
'. ATTN: Jay Silberg, Esq.
2300 N' Street.1NW Washington D.C.
20037 l
4 Wolf Creek Nuclear Operating
- Corporation U.S. Nuclear Regulatory Commission ATTN:
Regional Administrator, Region 111 801 Warrenville Road Lisle, Illinois 60532-4351 Wolf Creek Nuclear Operating Corp.
ATTH: Manager Regulatory Services
.P.0, Box 411 Burlington, Kansas 66839 Missouri Public Service Commission ATTN: Assistant Manager Energy Department P.O. Box 360 Jefferson City, Missouri 65102 l
Kansas Corporation Commission ATIN: Chief Engineer Utilities Division i
1500 SW Arrowhead Rd.
Topeka, Kansas 66604-4027 Office of the Governor State of Kansas Topeka, Kansas 66612 Attorney General Judicial Center 301 S.W. 10th 2nd Floor Topeka, Kansas 66612-1597 County Clerk Coffey County Courthouse Burlington, Kansas 66039-1798 Kansas Department of Health and Environment Bureau of Air & Radiation ATTN:
public Health Physicist Division of Environment Forbes Field Building 283 Topeka, Kansas 66620 i
o
7 v
ENCLOSUREll NOTICE _OF VIOLATION Wolf Creek Nuclear Operating Coiporation:
Docket:
50-482-Wolf _ Creek Generating Station-License:: NPF During an NRC:inspectios conducted March 12 through April 22, 1S95, two-violations of NRC requirements were identified, in accordance with.the.
" General Statement of Policy-and Procedure for NRC Enforcement Actions',"
10 CFR Part 2,_ Appendix C'(Enforcement Policy), the violations are listed-
-below:
A.
Technical' Specification 6.8.1.a-states, in part, that written procedures j-shall be established and implemented covering the~ applicable procedures L
recommended in Appendix-A of Regulatory Guide?l.33,--Revision 2.-
Regulatory. Guide 1.33, Appendix-A, Section 8, requires procedures for performing surveillance tests.
L-(1) Surveillance Procedure STS-IC-6188, " Slave Relay Test K6188 Train 8 Safety ~ln.jection," Revision 11, Step 8.1.3, requires that Fuse Block FU42 be removed _from Auxiliary Relay Panel RP333 prior to proceeding with the surveillance-test.
i Contrary-to the above. on April. 17.-1995, operators failed to perform Step 8.1.3 of: Surveillance Procedure STS 1C-6188, resulting in the-test tripping of the only operating condenser air removal-pump.
(2) Administrative Procedure AP 15C2002, " Procedure Use and Adherence,"
Revision 2, Step 6.6.7. permits procedure cover sheets to be annotated to direct the= performance of.specified sections of a surveillance procedure.
-Contrary to the above, on April 18._1995, instrument and controls technicians replacing Card'BBTY0421L completed Step 5.3.20 sf Surveillance Procedure ST5 IC-500E, " Channel Calibration DT/TAVG H
Instrumentation loop 2," Revision 12, a step-not specified to be t
performed'on the cover sheet.
This is a Severity Level IV violation.
(Supplement !) (482/9505-01)'
-B.
Technical Specification 6.12.2 requires that areas accessible to personnel
.with radiation levels greater.than 1000 mR/h at 45 cm (18 inches) from the radiation source be'provided with locked-doors to prevent unauthorized entry.
Contrary to the above on January 10,-1995, Radwaste Building Door 74021 was found unlocked when it was costed as a locked high radiation area k WSC 6c S7 Tf))
t-1 -
boundary and could have permitted unauthorized entry into an area with radiation levels greater than 1000 mR/h at 45 cm.
This is a Severity Level IV violation.
(Supplement 1)-(482/9505-03)
Pursuant to the provisions of 10 CFR 2.201, Wolf Creek Nuclear Operating Corporation is hereby required to submit a written-statement or explanation to
-the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk,-
Washington, D.C. 20555 with a copy to the Regional Administrator, Region IV, 611;Ryan Plaza Drive, Suite 400, Arlington, Texas 76011, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of-the date of. the letter transmitting this Notice of Violation l
(Notice). This. reply should be clearly marked as a " Reply to a Notice of
- Violation" and should include for each violation:
(1) the reason for the--
violation, or, if contested, the basis for disputing the violation, (2);the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance.will be achieved.
Your response may reference or include previous docketed correspondence, if the correspondence adequately-addresses the required response, i f an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken.
W. here good cause
- is shown, consideration will be given to extending the response time.
Dated at Arlington, Texas, this 22nd day of May 1995 n
l
ENCLOSURE 2 U.S. NUCLEAR REGULATORY COMMISSION REGION IV
~ NRC Inspection Reporti: 50-482/95 Operating License: NPF Docket: 482 Licensee: Wolf Creek Nuclear Operating Corporaticn P. O. Box 411 Burlington, Kansas 66839 Facility Name: Wolf Creek Generating Station (Wolf Creek) inspection At: Coffey County, Buelington, Kansas Inspection Conducted: ' March 12 through April 22, 1995 inspectors:
J._ F. Ringwald, Senior Resident inspetor J. L. Dixon-Herrity, Resident inspeu, -
T. R. Meadows, Operator Examiner I
s C h'
' Approved:
L 1
IL l
D. F. Kirsch,' Acting Chief f
-Da
-Reactor Project Branch B g
Inspection Summary Areaseinspected: Routine, unannounced inspection including plant status, operational safety verification, maintenance observations, surveillance observations, plant support, followup - operations, and followup - plant support.
Results:
Plant Operations Operations performance continued to be generally very good with noted exceptions. A self-revealing violation occurred when an operator failed to follow a surveillance procedure step that resulted in the tripping of the only operating condenser air removal pump. The prompt identification of the tripped pump represented good attention to detail and good surveillance test preparation (Section 2.1).
Af ter -the inspector questioned the Technical Specification (TS) clarification on feedwater isolation valves, licensee management ultimately agreed that the previous interpretation was not
' appropriate and revised the TS clarification.
General operating practices were found to be very good, with noted examples of potential improvement in N d O O6'J.y f
/7/p
2 shift briefings and two-way communication (Section 2.4).
Inattention to detail and a failure of operators to implement previously identified corrective actinns was exhibited when operations personnel drained the self-cleaning strainer in preparation for maintenance and created a potentially hazardous working environment for electric 61 maintenance (Section 3.1).
Maintenance Maintenance performance was generally good.
The licensee identified a violat io: caused by inadequate maintenance on a door locking mechanism when a locked high radiation area door was found open.
The licensee initiated a detailed root cause evaluation only after the inspector discussed the issue with the Maintenance Manager (Section 8.2).
Maintenance technicians exhibited inattention to detail by using a piece of degraded equipment to clean a safety-related motor control center (Section 3.1).
Poor planning on the part of maintenance was evident when oil was drawn out of a bearing by the negative pressure inside of a tent set up to support sand blasting (Section 3.2).
Electricians were confused by weak procedure steps which did not contain instructions for electricians to perform all the measurements recommended by the ver. dor technical manual.
Electricians appropriately contacted their supervisor when they encountered the confusing procedure steps (Section 3.3).
Instrumentation and control (l&C) technicians failed to follow procedures during a summing / amp card change out, causing a delay in the completion of the task, then failed to notify their supervisor of the error or initiate a Performance improvement Request (PIR) (Section 3.4).
Engineering Engineering performance declined somewhat during this report period.
Engineering evaluations of past industry concerns over temporary startup strainers were appropriate to address the concern at Wolf Creek, but failed to ensure that the as-built drawings reflected the plant's actual configuration J
(Section 5.1.1).
The inspectors identified an unresolved issue when an j
opening was noted in the wall separating the trains in the 1988-foot pipe chase of the auxiliary building at Wolf Creek, but not at Callaway (Section i
5.1.2).
An early criticality more than 500 percent millitho (pcm) below the estimated critical position was caused by a personnel error on the part of an engineer in the fuel design group and by inappropriate assumptions and weaknesses in the core modelling computer code. While communication problems between the core design and reactor engineering groups have continued to occur since a violation was cited in NRC Inspection Report 50-482/93-14, completed and planned corrective actions demonstrate that management regards these errors seriously (Section 5.2).
The inspector identified that the system engineer for Class IE 4160 vac switchgear was unfamiliar with the issue described in NRC Information Notice 94-02, "Inoperability of General Electric Magne-Blast Breaker Because of Misalignment of Close-Latch Spring" (Section 5.3).
1
_A
~3-Plant Support e
Plant Support performance was generally' good.
The inspector identified a weak security escort practice that'was promptly-corrected (Section 6.1).-
o Management Overview I&C-technicians did not initiate a PIR following the identification of a procedural violation during a surveillance' test; licensee personnel did not perform a detailed root cause evaluation-until que::tioned by the inspector following a failure to maintain a locked high radiation door closed; continuing communication problems between the core design and reactor engineering groups; and, the creation of potentially: hazardous working conditions-represent examples of where-the corrective action program did not function as effectively during each stage of the corrective action process as it could have.
t Summar_y of Inspection Findinos:
o Violation 482/9505-01 was opened (Sections 2.1 and 3.4).*
-c Violation 482/9505-03 was opened (Section 8.2)..t o
Unresolved Item 482/9505-02 was opened (Section 5.1.2)'.
1 o
Violations-482/9412-01,.-02, and -03 were closed-(Sections 7.1, 7.2, and -
8.1, _ respectively).
o- -Unresolved item 482/9419-03 was-closed (Section 8.2)./ -
Attachments:
o Persons Contacted and Exit Meeting o
Acronyms 1
h
^
w DETAILS 1 PLANT STATUS -(71707)
At:the beginning of this inspection period, the plant was in Mode 3.
On March :2,- 1995, operators restarted the reactor but achieved criticality with rods more than 500 pcm below the estimated criticai position and above the rod insertion limit as discussed in paragraph 5.2 of this report. _ Operators
- returned to Mode 3 and, after an initial review, restarted the reactor on March 13, 1995.- Operators stabilized the plant at 100 percent power on March 16, 1995, and operated at essentially 100% power for the remainder of the inspection period.
The President and Chief Executive Officer implemented
_a reorganization which eliminated the Technical Services Department and-reassigned the Vice President Technical Services to the position of Vice President Engineering following the announcement of the imminent retirement of the former Vice President Engineering.
I 2 OPERATIONAL SAFETY VERIFICATION (71707)
The inspectors performed this inspection to ensure that the licensee operated the facility safely and in conformance with license and regulatory requirements. The methods used to perform this inspectim included direct
- observation of activities and equipment, observation of control room operations, tours of the facility, interviews and discussions with licensee personnel, independent verification of safety system _ status and-TS limiting conditions for operation, verification of corrective actions, and review of f
facility records.
2.1 Ooerator Surveillance Error On April 17, 1995, the only operating condenser air removal pump tripped when operators performed Surveillance-Procedure STS 10-618B, " Slave Relay Test K618B Train B Safety Injection,"-Revision 11.
The pump tripped because operators failed to remove Fuse Block FU42 from Auxiliary Relay Panel RP333 as required by Step 8.l'.3 of the procedure. Operators did not perform this step because they incorrectly assumed that this fuse block had already been removed.
Earlier on the same shift, they removed Fuse Block FU42 from
-Auxiliary Relay Panel RP332 during the performance of Surveillance Procedure STS-IC-618A.
They had not completed the restoration from the test and, therefore, had not replaced this fuse block. This led to the inaccurate assumption that the fuse block had already been removed. The failure to perform Step 8.1.3 of Surveillance Procedure STS IC-618B is the first example of a violation of TS 6.8.1.a (482/9505-01).
The control board operator promptly noted that the only operating condenser air removal pump tripped off and immediately started the standby pump.
The operations manager informed the inspector that the operators anticipated this potential and stood near the pump controls during the test should the test
performance trip the operating air removal pump.
The inspector concluded that this represented good attention to detail and good preparation for surveillance test performance.
The licensee counselled the operator and initiated PIR 95-0899.
During the preliminary evaluation of this event, operators determined that procedural enhancements would reduce the likelihood of this error recurring. After discussions with the inspector, the operations manager concluded that the procedure was adequate as written.
The inspector reviewed the procedure, concluded that the procedure was appropriate to the circumstances, and had adequate detail to prompt the test performer to remove the correct fuse block.
2.2 Commitment Trackina On April 5, 1995, the licensee informed the inspector that a commitment date had not been met.
The response letter committed the licensee to a review of incident Investigation Team Report 94-04 and to reissue the revised report during March 1995.
The licensee completed the review prior to the commitment date but did not issue the revised report until April 14, 1995.
The inspector l
did not consider this length of a delay to represent a safety significant l
concern.
The inspector reviewed the licensee's commitment tracking program and found I
that the regulatory compliance department maintained a computer database of all commitments, from this database, the licensee issued monthly reports to all departments, and 45-day look ahead reports were distributed within regulatory compliance. The inspector found that the commitment missed in April 1995 was the only commitment missed out of 234 since January 1, 1993.
At the end of the report period, the licensee was tracking 12 open commitments. The licensee initiated PIR 95-0768 to document the missed commitment and to establish appropriate corrective actions. The inspector determined that the licensee's program adequately tracked commitments.
2.?
Inoperable Feedwater Isolation Valve On April 17, 1995, while performing a surveillance test on feedwater isolation valves, the operators noted that, after testing Valve AE FV-0039, Main Feedwater Isolation Valve A, it did not indicate full open. As permitted by the procedure, operators partially closed and reopened the valve in order to fully open it.
This fully opened the valve and also caused the pressure in both accumulators to drop below 4700 psig, the pressure below which operators cannot be assured that the accumulator will close the valve in less than 7 seconds as required by TS 3.3.2.
Sixteen minutes later, the system restored the pressure of both accumulators to greater than 4700 psig. The inspector noted that during this time the shift supervisor only entered TS Action Statement 4.0.5.
The shift supervisor explained that TS Clarification 13-85 stated that "With both the red and yellow train actuator on a valvt INOPERABLE. corrective action to restore the valve shall be initiated immediately per TS (Technical Specification) 4.0.5.
Refer to L.C.0. [ Limiting Condition for Operation] 3.6.3."
TS 3.6.3 listed the valve with a footnote 1
.(
6 referring-to TS 3.3.2.
The shift supervisor stated that since TS 3.3.2 applied to engineered safety features logic-signals and not to the valves, TS 3.3.2 did not apply in this case.
The inspector requested that the Office of Nuclear Reactor Regulation (NRR)-interpret this TS.
The-NRR Project Manager stated that TS 3.3.2 did apply in this case, and the operators should
'have entered TS 3.3.2, Table 3,3-3, Functional Unit 5.a. Action 27.
The reason for this-interpretation was that the footnote for Valve AE FV-0039 specifically stated that TS 3.3.2 applied to feedwater isolation valves.
Since TS 3.3.2 includes RESPONSE TIMES as shown in Table 3.3-5, and feedwater isolation' is listed-in Table 3.3-5 as items 2.a.2, 3.a.2, 4.a.2, and 8.b, all requiring a RESPONSE TIME of s 7 seconds, an inoperable feedwater isolation L
valve would require entry into TS 3.3.2, Action 27.
The inspector discessed this-position with licensee management who stated that they disagreed with this position and believed that TS 4.0.5 was the only applicable TS action statement for this condition.
Subsequent discussions with NRR clarified that i
this interpretation did not extend to all components with response times
-listed in Table 3.3-5 of TS 3.3.2, but only applied to the Feedwater Isolation Valves because of the footnote in TS 3.6.3.
Licensee management subsequently agreed with this interpretation.
Licensee management then promptly issued TS Clarification 4-95, which superseded TS Clarification 13-85 and incorporated the requirement to enter TS 3.3.2 Table 3.3-3, Functional Unit 5.a. when the valves have mechanical problems as well as logic / relay problems.
The inspector concluded that management's decision to incorporate this
-interpretation into TS Clarification 4-95 was appropriate.
On May 24, 1994, the licensee submitted a TS amendn, it request to add an additional-TS limiting condition for operation of the feedwater isolation valves. This, amendment would add a 4-hour shutdown requirement for a single
-inoperable feedwater isolation valve and would require entry -into TS 3.0.3 if more than one feedwater isolation valve were inoperable. This amendment is-expected to be issued during the next few months. -The licensee stated that they plan to modify TS Clarification 4-95 when this TS amendment is approved.
The inspector also noted that TS Clarification 13 -85 stated that "With 2 or more red train actuators OR two or mrre yellow train actuators INOPERABLE, the respective train of engineered safety features actuation system actuation shall be declared IN0PERABLE per Tech.-Spec. 3.3.2 Table 3.3-3 Item 5.a."
The inspector questioned this and noted that, with more than two inoperable accumulators in each train, the licensee would exceed the permitted number of
-inoperable channels. The licensee acknowledged this and has incorporated a clarification in TS Clarification 4-95 which required an entry into TS 3.0.3 when they have two or more red and two or more yellow inoperable actuators.
The inspector concluded that this clarified management's guidance.
2.4 Operations Review The inspectors evaluated several aspects of operation, including shift turnover', control room practices, and general operating procedures,
E,
'53
.7.
o 2.4.1 LShift Turnovers and Management Presence T_he inspector. assessed the individual operator turnover and board walkdowns as professional and detailed, with an aggressive: questioning attitude of plant 4
readiness. While most~. turnovers were very good to excellent Lone reactor
- operator-turnover stood out as being outstanding.
The shift supervisors and supervising operators exhibited a safety-first attitudettowards controlling the flow of plant. scheduled maintenance and surveillance ~ testing. --The Vice-President Plant Operations implemented a quiet hour between 6:30 and-7:30 for both morning and evening shift turnovers, and only permitted nonturnover-activities in the control, room that were immediately critical to= safe plant-operation. The shift briefing imediately following turnover was adequate but,;at times, brief. The operations staff was permitted, but-not necessarily encouraged to share observations and comments.
The noise level in the contro11 room coupled with'the lack ^ of-vocal projection on the part of_ some operators -
p made it very difficult for all attendees to hear everyone's comments. ' The-i
- Operations Manager or. Superintendent 0perations consistently attended most-shift briefings, but did not consistently participate.
As a result, a _. number
=of opportunities to reenforce management expeciations at; shift turnover were missed. The-inspector concluded that the shift turnovers were generally-very good.
2.4.2: Comand-and Control, Comunications, and Control Board Operations
--The-inspector noted that the supervising operator:and shift supervisor aggressively addressed plant problems,'particularly those affecting nuclear safety. Comand and control-were noted to be very good. There were times, especially.early in the shift, where the supervising operator' appeared to be.
potentially distracted by paperwork. Shift comunication was assessed as
- adequate but, at times, inconsistent' between_ individuals. While operators:
, consistently _ used two-_way comunications, -the inspector noted-a number of-
- examples where the two-way comunication was not crisp and had the potential
= to contribute.to miscomunication.
The inspector-noted that operators were
= aware and supervision reinforced the need for additional attention to-comunication when substitute' operators filled' vacancies during a particular shift. The inspector noted numerous. examples of good self-checking techniques
-during control board operation.
The inspector concluded that comand-and.
. control, comunication, and control board operations were generally very good.
2.4.3 : General' Operating Procedures The inspector. assessed the adequacy of the following plant operating
-procedures by ' independent walk through and interviews with licensed operators:
>* = GEN 00-002, Cold S/D to Hot Standby
~ GEN 00-003, Hot Standby to Minimum Load
' GEN 00-004, power Operations m'
_ GEN 00-005; Plant S/0 From 100X Power
- 1 GEN 00-006. Hot Standby to Cold S/0
e.
4 The inspector determined that these procedures were adequate fn that they could be performed efficiently by trained licensed operators.
No system or operating inconsistencies were identified.
The inspector concluded that control room operating-practices were found to be generally very good with a few noted opportunitir:s for improvement.
3 MAINTENANCE OBSERVATIONS (62703)
Daring this inspection period, the inspectors observed and reviewed the selected maintenance activities listed below to verify that personnel complied with regulatory requirements and licensee procedures including:
receiving permission to start; requiring quality control _ department involvement, proper use of safety tags, proper equipment alignment and use of jumpers, appropriate radiation worker practices, and use of calibrated tools and test equipment; documenting the work performed; and requiring proper postmaintenance testing.
Specifically, the inspectors witnessed portions of the following work requests (WRs):
1 WR 00329-95 Enhancement Painting of the Diesel Generator, the Surrounding Structures, and Room WR 00460-95 Internal Inspection of Self Cleaning Strainer WR 01406-95 Time Response Testing of NB Cubicle 115 Magne-Blast l
Breaker WR 01838-95 Summing Amplifier Card BBTYO421L Change Out WR 02344-91 Magne-Blast Breaker Prop Spring Replacement WR 05772-90 Paint Packing Gland Area WR 50850-94 Essential Service Water (ESW) Pump House Motor Control Center (MCC) NG05E Circuit Breaker Inspection WR 50859-94 480 volt alternating current (ac) NG005EAFI MCC and
-Feeder Breaker Inspection and Test WR 50861-94 ESW MCC Transformer Meggar Test MPE'E009Q-02 Preventive Maintenance of NB Cubicle 116 Magne-Blast Breaker RNM-C-1301 MCC 186/T Lockout Relay Test Selected observations from the activities witnessed are discussed below.
.g.
3.1 ESW MCC and Feeder Brer'er inspection On March 22, 1995, the inspector observed portions of the inspection and cleaning of the 480 volt ac NG005EAFl MCC and feeder breaker.
Electricians performed the work in accordance with the instructions contained in WR 50859-94 and Maintenance Procedure MGE E00P-07, " Motor Control Centers, and Control Panels, Cleaning, inspecting, and Testing," Revision 7, with one exception.
The inspector noted that electricians used an air compressor to blow dust out of the breaker buckets and asked one of the electricians if this was a common practice.
The technician explained that Procedure MGE E00P-07 allowed low pressure air to be used to remove dust and debris from the MCC.
Both the inspector and the technician noted that the gauge read 45 nsig and was broken.
The electrician stopped the individual performing the
'k from using the compressor and removed it from the job site.
Electricians ised brushes to remove the dust during the remainder of the task.
The inspector discussed the use of air for this purpose with the supervisor responsible for the job.
The supervisor stated that the use of air was acceptable, but not desirable, in high dirt accemulation areas and that it should have been 25 to 40 psig.
The licensee initiated PIR 95-0574 to document the use of a degraded piece of equipment.
The inspector verified that the procedure did allow the use of low pressure air, but noted that it did not provide a definition for low pressure.
The inspector discussed the concern with the maintenance engineer responsible for the procedure.
The engineer stated that supervision reminded electricians of the definition of low pressure air (30 psig) during a staff meeting after the PIR was written and that this knowledge was within the skill of the craft. The engineer also explained that the nozzle used with the air compressors had relief holes drilled in them to limit the pressure of air delivered, so the gauge did not reflect the pressure at the nozzle. The inspector concluded that the use of a degraded piece of equipment to clean safety-related equipment represented inattention to detail.
The inspector noted that the floor in front of the MCC was wet with scattered small puddles. The inspector discussed this practice with the supervisor responsible for the job.
The supervisor stated that it was a poor practice.
The supervisor also indicated that the electricians did not expect the wet environment, but took all conceivable precautions to protect personnel working on the MCC, Electricians verified that the bus had been deenergized and grounded, personnel followed work procedures, and most of the tools being used were insulated.
The supervisor also stated that water on the floor had been previously identified as a concern in PIR 94-0124.
The inspector discussed the concern further with safaty personnel and determined that working on electrical equipment in that environment was a poor practir., but was safe in this case due to the precautions taken.
The inspector reviewed the corrective actions resulting from PIR 94-0124.
The operations staff added the PIR to required reading and determined that drain hoses would be used to drain the water from the self-cleaning strainer in the future.
However, operators did not follow this corrective action.
Instead of
10 using drain hoses, an elevated scaffold plank was used as a channel to guide the water away from the area.
Water splashed off the plank and onto the floor.
The licensee initiated PIR 95-0909 to document this second occurrence and identify corrective actions.
Although tne floor had less water by the MCC this time than during the previous situation, the inspector determined that the failure to implement the corrective action identified as a result of PIR 94-0124 represented a f aMure of the correct 4ve 1tction program.---Asa result ~,- thi4 created an unnecessary potential hazardous working condition for personnel scheduled to work in the area.
3.2 Preparation for ESW Pump Packing Gland Paintino On March 22, 1995, the inspector observed maintenance technicians prepare the packing gland on ESW Pump A for painting. Maintenance technicians installed a tent from the above lower motor bearing down to the floor to contain the sand during the painting preparation on the surface of the gland.
When a negative pressure was drawn on the tent to contain the sand, oil was drawn out of the bearing.
The maintenance technicians quickly identified the problem, stopped work, and notified the control room and their supervision.
The tschnicians moved the tent below the bearing and the work continued.
Engineering determined that drawing the oil out did not damage the bearing. The licensee f
initiated a WR to change the oil in the bearing.
The inspector concluded that the corrective actions taken were appropriate and that proper planning could
(
have prevented the problem.
3.3 Magne-Blast Breaker Procedure Weakness On March 22, 1995, the inspector noted that the electricians were confused during the performance of Step 7.10.14 of Procedure MPE E009Q-02 on the Magne-Blast Breaker from Train A, NB Breaker Cubicle 116. This step required the electricians to measure the clearance between both the driving and latching pawls and the ratchet wheel. While the signature page required the electricians to measure the clearance for both pawls, Step 7.10.14 only provided instructions for measuring the clearance for the latching pawl.
The inspector noted confusion on the part of the electricians regarding the technique for performing these measurements and then initially measured only the driving pawl clearance.
The electricians contacted their first-line supervisor who came to the field and provided adequate guidance for measuring the clearance for both pawls.
The inspector concluded that it was appropriate for the electricians to contact their supervision when it was apparent that they did not understand how to take the pawl measurements. The inspector further concluded that the procedure was weak in that it did not provide procedure steps to perform all the measurements iecommended by the technical manual. The procedure was subsequently enhanced to provide additional guidance to the tecP icians regarding pawl measurements,
3.4 Summina Amplifier Card Replacement On April 18,_1995, the inspector observed 1&C technicians replace Summing Amplifier Card BBTYO421L in instrument Protection Set 2.
WR 01838-95 instructed 'he I&C technicians'to perform a number of steps in Surveillance-Procedure L.! IC-500E, " Channel Calibration DT/TAVG -Instrumentation Loop 2,"
Revision _12, to identify "as found" and "as left" data. _ The technician marked the steps to be performed but, after starting the work, continued from Step 5.3.19 to 5.3.20, instead of proceeding to Step 5.4 as required by the surveillance test routing sheet.
The technician's performance of a surveillance test procedure step not directed by the surveillance test routing sheet is a second example of a violation of TS 6.8.1.a-(482/9505-01).
As a result, the technician installed an unneeded test-lead. At the l
conclusion of the procedure, the-technicians found that the procedure steps did not direct the removal of the. lead _ inadvertently installed during Step 5.3.20.
The technicians stopped work and had the surveillance test l
routing sheet revised to add steps to remove the lead.
The inspector noted l
that the practice of performing only scattered steps as directed by the l
surveillance test routing sheet had the potential to confuse the technicians and directed the technicians to perform selected steps in a manner contrary to their training. While this error did not impact safety-related equipment,-it did result in confusion and a delay in exiting the limiting-conditicn for operation.
This occurrence was of further concern because the individuals-fa'iled to discuss the error with their supervision, and failed to initiate a PIR until after the inspector questioned licensee management. The licensee initiated
'PIR 95-0919 to evaluate and track corrective actions.
4 SURVEILLANCE OBSERVATIONS (61726)
The inspectors sampled-selected surveillance tests required by TS to verify that personnel performed the tests in accordance-with TS, used technically adequate procedures and appropriate test equipment, and properly dispositioned any test results which failed to meet the acceptance criteria.
Specifically,-the inspectors witnessed the following surveillance tests:
STS PE-014A Personnel Airlock Test i
STS PE-006 Charcoal Adsorber in-place Leak Test Safety-Related Units STS KJ-005B Manual /Aut-Start, Synchronization, and Loading of Emergency o.esel Generator NE02 STS AL-102 AFWP-B Operability Test STS IC-470A Gaseous Ranvaste H, and 0, Monitors HA-161, Train A Channel Calibration
l
- sa
-Selected observations from the test activities witnessed are discussed below.
4.1 Emergency Diesel Generator Test Procedure Weakness On April 5, 1995, the inspector observed operators perform Surveillance Procedure STS KJ-005B, " Manual / Auto Start, Synchronization, and Loading of Emergency Diesel Generator NE02," Revision 21.
The inspector' verified that this test sa'isfied the surveillance requirements of TS 4.0.5, 4.8.1.1.2.a.1-6, and 4.8.1.1.2.f.
Step 5.2.1.6 did not clearly identify which meter operators were to use to nonitor for the megawatt reading of the diesel generator power load. After interviewing a trained licensed operator, the inspector found that the procedure does reference a drawing and computer point identification number, indirectly identifying the proper meter to read.
The inspector determined that,-although obscure, the step could be used by a trained operator. The inspector concluded that, while the procedure was-adequate, it had the potential to be confusing, and this step was weak, j
5 ONSITE ENGINEERING -(37551) l i
The inspectors reviewed and evaluated engineering performanco related to reactor engineering support of operations.
5.1 As-Built Differences in the Plant 5.1.1 Temporary Startup Strainers-While performing system walkdowns, the inspector noted that the spacers at the suction of the component cooling water-pumps were different from the spacers used on other safety-related pumps. The inspector-reviewed the piping and instrumentation diagrams for the different systems and found that the drawings.
depicted temporary startup strainers where spacers were supposedly' located in the field.
The inspector discussed the concern with an engineer from the support engineering group.
The engineer identified Operational Assessment Reviews 86-0014 and 85-0345, which verified through review of past wor 6 requests that all of the temporary strainers had been removed and replaced with spacers.
PIR 95-0592 was written to identify the failure to update the design documentation to reflect the current configuration of the plant. The inspector concluded that the licensee had responded to industry events and NRC concerns appropriately, but did not follow through with the corrective actions to ensure that their documentation reflected the actual plant configuration.
5.1.2 Auxiliary Building 1988-Foot Pipe Chase Optional Opening The inspectors noted that there was an access hole in the wall between the two trains on the 1988 foot level pipe chase of the auxiliary building at Wolf Creek, but not at Callaway.
The inspectors discussed this difference with design engineering personnel, who were not aware of the difference, but later identified Field Change Request 1-0855-C, which requested that the change be made to the original design.
The inspector reviewed the field change request and found that it had requested a temporary opening be left to allow the t
13 completion of work activities north of the opening.
The recommended action was that a 2-foot 8-inch by 6-foot 8-inch opening be left, then closed with reinforced masonry after the work in the area was complete in the early part of 1983.
The inspector reviewed Drawing Change Notices C-0Cl23)(Q)-ll-1, C-001915(Q)-19-1, and C-0Cl241(Q)-14-? and found that the opening was identified as an " optional opening" in the drawings. Updated Safety Analysis Report figure 1.2-10. " Equipment Location Auxiliary M ilding Partial Plan El. 1988'-0" & 2012'-0"," did not identify an opening. No further documentation of the change was found.
The engineer wrote PIR 95-0418 to research the question 'nd evaluate whether the opening presented a safety concern and whether a change would be needed to the Updated Safety Analysis Report. The inspector did not identify an immediate safety concern.
This issue will remain unresolved pending the completion of PIR 95-0418 (402/9505-02).
5.2 Early Criticality On March 12, 1995, operators established critical reactor operation on Bank C 53 steps when the estimated critical position (ECP) calculation predicteu at
)
criticality on Bank C at 187 steps. While this was above the rod insertion limits. it was 1075 pcm below the ELP. Operators maintained this position whil seactor engineering evaluated the condition.
Since nuclear engineering per v al were not able to explain why the core was so much more reactive than the CCP estimate, operators returned to Mode ' and conducted a second approach to criticality on March 13, 1995. The seccc approach to criticality ECP predicted criticality at 79 steps on Bank C, and criticality was achieved at 95 steps on Bank C.
Nuclear engineering petsonnel initiated P!R 95-0411 to evaluate the cause of the early criticality.
The basis for the decision to restart included nominal core performance since refueling and an understanding of weaknesses in the Babcock & Wilcock N000LE core modeling computer code as a result of very little data on this core in a hot zero power condition.
The inspector concluded that the licensee's immediate response to the early criticality was good.
Dur:ng the evaluation of PIR 95-0411, nuclear engineering personnel recognized that there have been several communication problems between the core design group and reactor engineering during the past 2 years.
As a result, nuclear engineering initiated PIR 95-0680.
This PIR fccused on the Nuclear Parameters and Operationt Package as a communication tool between core design and reactor engineering. Two of these errors were examples of a violation issued with NRC Inspection Report 50-482/93-14.
In addition, PIR 94-2284 addressed the failure of the core design group to include U-234 data in the isotopic inventory tables for Region 10 fuel in the Nuclear Parameters and Operations Package. While this did not create an operational concern, it did prevent reactor engineering from completing special nuclear material inventory reports without additional data. These continuing communication errors between these two groups during the period when the licensee has assumed the responsibility for reattor core design is of concern because the potential exists for these communication problems to result in inappropriate reactor operational decisions which could jeopardize thermal limits.
The licensee completed Self i
Assessment 95-009, " Reload Design," on April 3, 1995, and issued nine PIRs associated with one weakness and eight recommendations for improvement.
The Manager, Nuclear Engineering, stated that these errors are being taken very seriously and that PIR 95-0512, Self Assessment 95-009, and the circumstances surrounding the early criticality were being used to develop aggressive corrective actions to resolve the communication problers tetm en the core design and reactor engineering group.
During the evaluation of PIR 95-041), nuclear enginsering found that core design found a personnel error in the calculation associated with Calculation AN 94-019.
The error was that the core designer assumed that the predicted axial offset at the planned critical condition assumed a rodded core at that rod position, whereas reactor engineering traditionally used this value as an unrodded value and, therefore, added the effect of the rods at the planud critical condition.
Nuclear engineering initiated PIR 95-0680 to address the cause of this error. Nuclear engineering also determined that the core modeling computer code contained basic weaknesses which did not exist in the current Westinghouse ANC code.
Nuclear engineering has benchmarked the Westinghouse ANC code for Wolf Creek and has initiated the appropriate licensing documents to use this code starting in Cycle 9.
One principle weakness of the N000LE code was the need to bias the code generated values with actual data taken from hot zero and hot full-power conditions.
Since the licensee only had limited hot lero power data, the bias used to adjust the N0ODLE code for the March 12, 1995, critical condition was not appropriate.
This coupled with the error addressed by PIR 95-0680 accounted for t1e discrepancy between the ECP and the actual critical condition on March 12, 1995. Comparable calculations using the ANC code without any bias value produced a very close ECP of the March 12, 1995, criticality without the application of any bias.
The inspector concluded that, while communication problems between core design and reactor engineering continue to occur, corrective actions planned and in process demonstrate a commitment on the part of the Manager, Nuclear Engineering to correct these problems, 5.3 System Engineer Unfamiliar with industry information On March 22, D95, during Train A NB system Magne-Blast breaker maintenance, the inspector noted that the NB system engineer was unfamiliar with NRC Information Notice 94-02.
The inspector questioned the system engineering electrical supervisor and determined that the supervisor expects system engineers to be familiar with recent industry experience documents applicable to their systems.
The supervisor stated that the system engineer had been it, training when this Information Notice was issued and had not learned of the issue af ter the completion of the training. The supervisor and system engineer took immediate action to ensure that the system engineer became familiar with recent industry experience relating to the NB system.
The inspector concluded that the supervisor's expectations were appropriate, and the corrective actions were appropriate.
l l
6 PLANT SUPPORT (71750)
The inspectors sampled selected activities in the different areas of p1 F.
support and verified that they were implemented in conformance with licensee procedures and regulatory requirements.
6.1 Potentially ineffective Securitv Escort On' March 30. 1995, the inspector observed 3 security escort located in a portable +1ndowed structure approximately 40 feet from the north entrance of the-administration building.
The licensee tasked this escort with observing all personnel exiting the northeast door of the administration building.and stopping anyone who required escorted access to the protected area.
The licensee posted another escort at the south door of the administration building and chained all remaining doors, thus verifying that the two escorts could observe all exits from the building. After noting a large truck pass between the escort and the northeast door, and later observing a prolonged conversation between the escort and another individual, the inspector questicned whether the escort could adequately perform his/her escort function at that' location and whether the escort was distracted.
The licensee responded by relocating the portable windowed structure to a location directly opposite the northeast door of the administration building, approximately 15 feet from the door, and by giving all escorts an additional briefing on their escort duties.
The inspector concluded that placing the visitor at-the initial location had the potential to render the escort ineffective. On April 21, 1995, the inspector asked if the licensee had initiated a PIR, No PIR had been written but, after the inspector's discussed this issue with the Assistant ~ to the Manager Plant Support, the S'Jperintendent Security initiated PIR 95-0952 on April 25, 1995.
The inspector concluded that the licensee's initial corrective actions were appropriate.
7 FOLLOWUP-0PERATIONS (92901) 7.)
(closedl Violation 482/9412-01:
Failure to Fnilow Procedures This item involved four exau.ples of licensee personnel failing to follow
-procedures. -Corrective actions involved initiating PIRs for each violation, enhancing procedural guidcnce, counselling the individuals involved, placing one applicable PIR in required reading, and initiating PIR 94-2133 to address the generic aspects of this violation.
Corrective actions to address the generic aspects of this violation included communicating management's expectation-consequence standard to all plant personnel, initiating a standdown day dedicated to the subject of the "Use of Procedures," requiring
-managers and supervisors to meet with their people frequently to ensure management's expectations are well understood and discipline policies relating to procedure use are understood, and the establishment of a " Topic of the Week" program where various license programs will be discussed among managers and then with licensee personnel.
The inspector concluded that these actions appear appropriate to address the concerns associated with this violation.
_ _ _ _.m._
t i
16-1 7.2 1 Closed) Violation 482/9412-02:
Overtime _ Limits Exceeded i
This item involved two examples where licensee personnel exceeded the TS overtime limits without the authorization required by TS or the licensee's I
program.
The licenses initiated PIRs for each of the examples, placed the first-plR in the operations department-required reading program.-and scat elec'ronic mail to all operations personnel regarding the second example.
The i
licensee applied discipline where appropriate. Management initiated PlR 94-2135 to address the generic aspects-of this violation. As a result, the licensee revised administrative procedures, incorporated working hour
-1 imitations into the integrated plant scheduling program, and addressed the procedural-compliance aspects of these events into the corrective actions associated with NRC Inspection Report 50-482/9412-01.
The inspector concluded that'these actions appear appropriate to address the concerns associated with this violation.
8 FOLLOWUP'- PLANT SUPPORT (92904) 8.1.
(Closed) Violation 482/9412-03:
Radiation Protection Procram Not i
followed This item involved three examples where licensee personnel failed to comply i
with radiation protection program procedures.
The Itcensee initiated PIRs to
~ ddress the three events and placed the one pertaining to operators in-a operations ri luired reading.
The licensee initiated PIR 94-2134 to. identify the concerns in all-three examples, placed the PIR in health-physics required 4
reading, enhanced administrative procedures, and addressed the procedural compliance aspects of these events into the corrective actions associated with
=
NRC Inspection Report Violation 482/9412-01.
The inspector concluded that these actions appear appropriate to address the concerns associated with this violation.
8.2 (Closed) Unresolved item 482/9419-03:
Locked Hioh Radiation Area Door 1
Found Open-This item involved the failure of the licensee to maintain the. door to Room 74021alocked.
The item was not resolved because the licensee had not completed a root cause determination of the lock failure.
The licensee initiated PIR 95-0097, but did not classify it as significant. The licensee did not-initiate a root cause of failure determination until after the inspector questioned the failure.
The licensee subsequently concluded tnat inadequate maintenance on the door approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> prior to discovery
-caused the locking failure. Maintenance also determined that the security department locksmith performed the maintenance, yet the maintenance department
- had been assigned responsibility for maintenance of door locking mechanisms.
Whtn personnel identified the initial problem with the locking mechanism, the ecurity locksmith and a mechanical maintenance super.isor discussed the
-problem and'the supervisor asked the locksmith to repair the lock since all mechanical maintenance personnel assigned to the supervisor were engaged in other work assignments.
Maintenance personnel involved in the root cause of
1.,
l failure also determined that the locksmith did not use a WR and, therefore, l
1
- the work control process did not review the work.
The licensee installed a steel hasp on Door 74021 on March 15, 1995, to permit the use of an external locking device.
The licensee determined that, while radiation levels in the room were greater than 1000 mR/h at 45 cm, no personnel were-unintentionally exposed as a result of this event. Additional corrective actions-included:
reviewing doors with a similar design and reviewing the failure to use a WR with applicable personnel.
The inspector concluded that these actions appear-to address the concerns raised by this event.
The failure of the licensee to maintain Door 74021 is_a violation of 15 6.12.2 (482/9505-03) _ The licensee-identified violation is being cited because the conditions for enforcement discretion as given in 10 CFR Part 50, Appendix B, Section VII.B.(2) were not satisfied with regard to comprehensive corrective actions in that the licensee-did not plan to perform a root cause failure evaluation until questioned by the inspector. Since the licensee completed a root cause determination and the identified corrective _ actions, no response to this violation is required.
4 g
.__._c.
ATTACHMENT 1 1 PERSONS CONTACTED E. L. Asbury, Supervisor, Configuration Management T. A. Conley, Superintendent, Radiation Protection T. M. Damashek, Supervisor, Regulatory Compliance H. G. Cales, Jr., Manager, Design Engineering R. D. flanntgan, Manager, Regulatory Services C. W. Fowler, Manager, Maintenance and Modifications R. W. Holloway, Superintendent, Modifications B. T. McKinney, Manager, Operations W. M. Lindsay, Manager, Performance Assessment R. L. Logsdon, Assistant to Manager, Plant Support
- 0. L. Maynard, Vice PresideN N ** Operations R. W. Miller, Superintendent. % A Rai Maintenance T. S. Morrill, Assistant to W., D ",ident Engineering l
G. J. Neises, Supervisor Core Design, Safety Analysis J. M. Pippin, Manager, Integrated Plant Scheduling C. A. Redding, Compliance Specialist, Regulatory Services R. Robinson, Assistant Supervisor, I&C R. L. Sims, Supervisor, Operations Support B. B. Smith, Superintendent, Planning J. D. Stamm, Manager, System Engineering J. D. Weeks, Assistant to Vice President Plant Operations D. M. Williams, Assistant Superintendent Electrical Maintenance M. G. Williams, Manager, Plant Support The above licensee personnel attended the exit meeting, in addition to the personnel listed above, the inspectors contacted other personnel during this inspection period.
2 NRC PERSONNEL A. B. Beach, Direr. tor Division of Reactor Projects L. J. Callan, Administrator-Region IV J. L. Dixon-Horrity, Resident inspector J. f. Ringwald, Senior Resident inspector 3 EXIT MEETING An exit meeting was conducted on April 21, 1995.
During this meeting, the inspectors reviewed the scope and findings of the report.
The inspector acknowledged the licensee's initial disagreement with the TS interpretation issue which was ultimately resolved as described in paragraph 2.3.
The licensee did not identify as proprietary any information provided to, or reviewed by, the inspectors.
~
1.
l**,
ACRMYMS ac alternating current cm centimeter ECP estimated critical. position ESW essential service water 1&C instrumentation and control MCC-motor control center mR/h millirem per hour NRR Office of Nuclear Reactor'. Regulation pcm percent millirho PIR
. performance improvement request psig pounds'per square inch gage TS.
Technical Specifications WR-work request
=
1 Et
...,: n n
~,
NUCLE;n rtEGUL A TORY COMMISSION
\\(".
as: a.
/
.n. < t, o, n o,,
.. v.w July 10,1997 Otto L. Maynard, President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, Kansas 60839
SUBJECT:
NRC INSPECTION REPORT 50-482/9710 AND NOTICE OF VIOLATION
Dear Mr. Maynard:
An NRC inspection was conducted May 18 through June 28,1997, at your Wolf Creek Generating Station reactor f acility. The enclosed report presents the scope and results of that inspection.
During this inspection, four citable violations of NRC requirements were identified in the areas of Operations and Plant Support, Violation A addresses a failure of Wolf Creek to adequately monitor and ensure compliance with the medical requirements associated with operators performing licensed duties. This is a concern because the NRC identified the issue and the failure to ensure that operators have corrective lenses for respiratory equipment cou;d endanger both the individuals and their capability to protect plant equipment during an emergency. Violation B, which addresses problems with your control of overtime, is of concern because of the repetitiveness of this problem, especially since it had been previously cited in NRC Inspection Report 50 482/94 12.
Violation C addresses problems with your compliance with Technical Specification 4.5.2.c.2, which requires a visual inspection of containment be performed at the completion of each containment entry when containment integrity is established. Violation D addresses problems with the compliance of your staff with the requirements to wear thermoluminescent dosimetry whenever they enter a radiological controlled area of the plant.
During the exit meeting on June 27,1997, the Chief Operating Officer expressed the position that if programs and procedures were adequate, but personnel failed to comply with them, the ensuing events did not constitute a problem with corrective actions.
Instead, the problem was one of human periormance. The NRC acknowledges that human performance can be separable from programmatic and procedural deficiencies. However, repetitive instances of human performance f ailures cannot be ignored and must be addressed by licensee corrective action programs.
The violations are cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding these violations are described in detailin the enciesed report. Please note that you are required to respond to this letter and should follow the instructions specified in the f6C7i k
s 4
t Wolf Creek Nuclear Ope,ating Corporation 2
F to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements, in accordance with 10 CFR 2.700 of the NRC's " Rules of Practice," a copy of this letter, its enclosures, and your response will be placed in the NRC Public Document Room (PDR).
To the extent possible, your response should not include any personal privacy, proprietary, or cafeguards information so that it can be placed in the PDR without redaction.
, Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely,
/sfVV
. got c/
omas P.
n, ector ivision of Reactor rojects Docket No.: 50-482 License No.: NPF 42
Enclosures:
- 2. NRC Inspection Report 50 482/97 10 cc w/ enclosures:
Chief Operating Officer Wolf Creek Nuclear Operating Corp.
P.O. Box 411 Durlington, Kansas 66839 Jay Silberg, Esq.
Shaw, Pittman, Potts & Trowbridge 2300 N Street, NW Washington, D.C. 20037 Supervisor Licensing Wolf Creek Nuclear Operating Corp.
P.O. Box 411 Burlington, Kansas 66839 Chief Engineer-Utilitier Division
t 1
. 6 e
l Wolf Creek Nuclear Operating Corporation 3-i i
Kansas Corporation Commission 1500 SW Arrowhead Rd.
Topeka, Kansas 66604 4027 Office of the Governor State of Kansas
-Topeka, Kansas 66612 r
Attorney General Judicial Center 301 S.W.10th -
2nd Floor Topeka, Kansas 66612 1597 County Clerk i
- Coffey County Courthouse.
Burlington, Kansas 66839 1798 Vick L Cooper, Chief 4
' Radiation Controf Program I
Kansas Department of Health and Environment' Bureau of Air and Radiation Forbes Field Building 283 Topeka, Kansas - 66620 l
Mr. Frank Moussa Division of Emergency Preparedness 2800 SW Topeka Blvd F
Topeka, Kansas'- 66611 1287-
' I a
x
,w,qr.
-,v-
--p--
-g
-y e
+-e-.r,m--
,,yn,
,-m-.---,,
e e, - -, - - e 1
td k
liNGLaS.VBL1 NOilCE OF VIOLATION Wolf Creek Nuclear Operating Corporation Docket No.:
50 482 Wolf Creek Generating Station License No.:
NPF 42 During an NRC inspection conducted on May 18 through June 28,1997, foui violations of NRC requirements were identified, in accordance with the General Staternent of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violations are listed below:
A.
10 CFR Part 50, Appendix B, Criterion V, states, in part, "... activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances.... Instructions, procedures, or drawings shallinclude appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisf actorily accomplished."
Contrary to the above, on May 8,1997, the NRC inspectors discovered that there were no instructions or procedures to ensure that alllicensed operators, who were required to wear corrective lenses as a condition of their individual licenses, had corrective lenses of the appropriate type available should these individuals be required to wear self. contained breathing apparatus while performing licensed duties.
This is a Severity Level IV violation (Supplement il (50 482/9710 01).
8, 10 CFR Part 50, Appendix B, Criterion XVI, specifies that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, or deviations are promptly identified and corrected, in the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude recurrence.
Contrary to the above, as of May 24,1997, a significant condition adverse to quality repetitive examples of workers engaging in safety related work in excess of the Technical Specification 6.2.2.f limits without the review and approval of management was identified, but actions were not taken to determine and correct the cause of the repeat of these violations. Specifically, the licensee responded to Violation 8 of NRC Inspection Report 50 482/94-12, but the corrective actions were inadequate to preclude recurrence, and this condition was not recognized until l
questioned by the NRC inspectors.
This is a Severity Level IV violation (Supplement I) (50 482/9710 02).
1 YY /3 O M0
}$
t 2
C.
Technical Specification 4.5.2.c.2 requires in part that a visual inspection be performed: (1) For all accessible areas of the containment prior to establishing CONTAINMENT INTEGRITY and (2) Of the areas affected within containment at the completion of each containment entry when CONTAINMENT INTEGRITY is established.
Contrary to the above:
1)
On October 18.1997, the licensee identified that Technical Specification Clarification 010 85 directed plant personnel to perform the required containment inspection once each day after re establishing containment integrity rather than after establishing containment integrity each time following containment entries. The licensee implemented the clarification numerous times cince the clarification was developed in 1985.
2)
On May 20,1997, containment integrity was established after three separate containment entries without the performance of the required containment inspection.
This is a Severity Level IV violation (Supplement I) (50 482/9710 03).
D.
Technical Specification 6.11 requires, in part, that procedures for personnel radiation protection be adhered to for all operations involving personnel radiation exposure.
Administrative Procedure AP 25A 001, " Radiation Protection Manual," Revision 2, Stop 6.8.1, requires that personnel requiring access into the radiological controlled area be issued personnel radia' ion dosimetry devices which must be worn et a!!
times within the radiological controlled area.
Contrary to the above:
1)
On March 20,1997, an engineer and a quality control inspector entered a high radiation area within the radiological controlled area without weerino the thermoluminescent dosimetry they had been issued.
2)
On June 12,1997, two mechanics entered the radiological controlled atea without wearing the thermoluminescent dosimetry they had been issued.
This is a Severity Level IV violation (Supplement IV) (50-482/9710-06).
Pursuant to the provisions of 10 CFR 2.201, Wolf Creek Nuclear Operating Corporation is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555, with a copy to the Regional Administrator, Region IV,611 Ryan Plaza Drive, Suite 400, A:lington, Texas 76011, and a copy to the NRC Resident inspects at the f acility that is the subject
l 1
.t i
3-i I
. of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clea,iy marked as a " Reply to a Notice of Violation". and should include for each violationt (1) the reason for the violation, or, if contested, the -
basis for disputing the violation, f 2) the corrective steps that have been taken and the results achieved, {3) the corrective steps that will be taken to avoid further violations, and 1
~
f(4) the date when full compliance will be achieved. Your response may reference or-1 include previous docketed correspondence, if the correspondence adequately addresses the required response.' If an adequate reply is not received within the time specified in this
- Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken..Where good cause is shown, consideration will be given to extending the response time, I
Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it sheufd not include any personal privacy, proprietary, or safeguards-informatio1 so that it can be placed in the PDR without redaction. However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be placed in the PDR, and provide the legal basis to support your
--request for withholding the information from the public--
f Dated at Arlington, Texas -
.this 10th day of July 1997 t
1 i
i LNCLOSURE 2-U.S. NUCLEAR REGULATORY COMMISSION
+
{
REGION IV -
-Docket No.:
60 482 License No.i NPF 42 Report No.:
50 482/97 10
[
Licensee:
. Wolf Creek Nuclear Operating Corporation j
. Facility:
Wolf Creek Generating Station Location:.
1550 Oxen Lane, NE-Burlington, Kansas Dates:-
May 18 through June 28,1997 Inspectors:
J. F. Ringwald, Senior Resident inspector J. L. Dixon Herrity, Resident inspector Approved By:
W. D. Johnson, Chief, Reactor Projects Branch 8 ATTACHMENT: Supplemental Information t
b f
l i
- -Q)Ol()()Z.WZ~~
Nlf
..e I
2 EXECUTIVE.
SUMMARY
Wolf Creek Generating Station NRC Inspection Report 50 482/07 10 1
Doerationg The licensee identified that they had re established containment integrity following L
containment entries during a forced outage without performing the required I
containment cleanliness surveillance inspection as required by Technical Specifications. The licensee had reported numerous examples of this Technical Specification violation in Licensee Event Report (LER) 9614 due to an inappropriate Technical Specification Clarification that was cancelled. Corrective actions for LER 9614 failed to prevent the additional examples of this violation (Section 08.1 and 08.2).
The inspector identified a violation of 10 CIR Part 50, Appendix B, Criterion XVI, after discovering that the licensee's corrective actions for a previous violation of the Technical Specification limitation on overtime usage and previous similar licensee findings, failed to prevent recurrence of additional occurrences (Section 06.2).
The inspector identified a violation of 10 CFR Part 50, Appendix B, Criterion V, after discovering that the licensee had no administrative controls to ensure that operators had corractive lenses required by the conditions of their individual licenses for-
- performing licensed duties while wearing respiratory protection. The licensee subsequently identified examples where operators did not have the required corrective lenses for use with respiratory protection equipment (Section 06.1).
Licensee response to an extraction steam valve body to bonnet leak was appropriate. Operators controlled the plant during the manual reactor trip and properly followed the applicable procedures, immediate corrective actions were appropriate (Sectiore 01.11.
Operators responded properly to a main feedwater pump speed controller failure.
Effective corrective actions following a simiter failure 10 years ago resulted in corrective actions that usisted operators during this event in recovering with only a very minor impact on plant parameters (Section 01.2).
MEmtenanen The inspector identified enhancements to the licensee's surveillance procedures to calibrate the seismic monitor af ter noting differences between the procedure and the vendor technical manual recommended calibration technique (Section M3.2).
I
o 3
- Enaineerino
(-
The licensee identified that surveillance procedures for adjusting power range nuclear instruments f ailed to comply with Technical Specification surveillance requirements. This was determined to be a noncited violation (Section E4.1).
l-l PJant suonort The licensee identified two repetitive examples of a failure to follow Technical Specifications involving entries of radiation workers into the radiological controlled area without the required thermoluminescent dosimetry. One of the two entries involved entry into a high radiation area without the required dosimetry. - This was determined to be a violation (Section R1.2).
The inspector observed an effective emergency plan technical support center drill' and critique (Section PS.1).
4 4
Reoort Details S,ummary of Plant Status The licensee operated at essentially 100 pertient power from the beginning of the i
inspection period until May 20,1997, when operators manually tripped the reactor in response to a large steam leak (described in Section 01.11. Operators restarted the plant and returned to essentially 100 percent power on May 26,1997, where they operated l
through the end of the inspection period.
- l. Operations 01 Conduct of Operations 01.1 Manual Reactor Trio in Responst, to Unisolable Extraction Steam Leak a.
insoection Scone The inspector observed control room operators reduce power then manually trip the reactor in response to a turbine extraction steam valve body.to bonnet leak. The inspector observed the operators' actions following the trip, reviewed the subsequent forced outage, and reviewed the licensee's posttrip evaluation and corrective actions, b.
Qbservations and Findinos On May 20,1997 at 2:02 p.m., operators in the control room noted a 3 megawatt electric loss of load and received notification of a steam leak under the 2065 foot level of the turbine building. The shift supervisor dispatched operators to verify the report and evaluate the severity of the leak. The operator determined that the leak was on the 2033 foot level, but due to the steam in the area could not confirm the location of the source. Control room operators commenced a controlled load reduction and ordered an evacuation of the turbine building. The shift supervisor and operations manager decided to manually trip the reactor due to the size of the leak and the receipt of alarms due to grounds on the nonsafety electrical bus, Operators tripped the plant at 2:57 p.m. All safety related equipment responded as designed. Subsequent inspections revealed that the leak was from the body to bonnet joint on Valve AF FVOO58C, the third stage extraction steam isolation valve to High Pressure Feedwater Heater 78.
The licensee disassembled the valve and found that the bonnet flange bolting was potentially undertorqued. No damage was noted on the valve flange. The gasket was replaced with a new corrugated iron gasket wrapped with graphite tape. The licensee found that thst volve had last been disassembled in April 1993. At that time, mechanics replaced the body to bonnet corrugated iron gasket with a gasket made from Garlock 9800 compressed sheet material. Engineers calculated that the
.......... _ J
t
.s.
l t
I mechanics apphed a cold compressive load on the gasket of approximately
}
5500 psi. The manufacturer recommended a compressive load between 5500 and 15,000 psi, The licensee determined that the optimal compression was potentially j
net achieved, and the minimum load recommended by the vendor may not have i
been adequate for long term reliability.
The inspector reviewed the licensee's immediate corrective actions. Engineering personnel identified additional high pressure and high temperature equipment that I
the subject gasket material had been used in and evaluated the application. As a result, engineering found the same gasket materist in the body to bonnet joint of one other extraction steam valve. Maintenance personnel replaced the i
body to bonnet gasket of this valve during the forced outage with a corrugated iron gasket wrapped with graphite tape. Engineers identified eight other valves i
i potentially susceptible to this problem. These valves were determined to not pose a significant threat of leakage prior to the next refueling outage because either the torque applied was adequate, or they were used in lower temperature fluid systems.
l While engineering concluded that these valves were currently acceptable, they.
recommended that the gaskets be replaced during the refueling outage in September.1997.
+
c.
Gpnclusions The operators responded to the identification of a nonisolable extraction steam system valve leak in an appropriate manner by manually tripping the reactor. The licensee response to the event and the immediate corrective actions taken were appropriate.
l
.01.2 Main Feedwater Pumo Soeed Controller Failure I
a.
Insoection Scoce Operators in the control room responded to the failure of the flow controller for Main Feedwater Pump B. The inspector observed a portion of the operators' response to the event, b.
Observations and Findinas On May 30,1997, all four steam flow feed flow mismatch annunciators alarmed.
Control toom operators immediately noted that the controller for Main Feedwater Pump B, Controller FC SK 509B, had failed to zero output and shifted to the manual mode, and that the feed regulating valves responded by opening fully. The operator
-immediately took manual control of Main Feedwater Pump B using the General
. Electric speed controller and controlled steam generator levels, The inspector observed operators refer to the appropriate alarm response procedures. Due to quick response of the opwators, the effect on the plant was limited to a very small l
l l
l'w m,,,
-~
s~
,--m
, - + -- ~
J,,v,.,,,--r
..v,
,.,,cn,n n-r.,,e
e n
e i
6-l
[
i change in steam generator level. Operators controlled the main feedwater pumps in j
manual until the driver card was replaced the next day.
According to the plant manager, approximately 10 years ago, a similar event resulted in a significant transient before operators were able to tecnver steam generator level. Af ter stabilizing the plant during the previous event, operators recognized that if the General Electric speed controller manual signal was adjusted l
to the nominal steady state output, and a similar failure occurred again, they could quickly shift control to the General Electric speed controllers and maintain feed
[
pump speed control with very little effect on steam generator level. Operators L
subsequently incorporated this practice into si.nulator training. The May 30,1997, event and operator response demonstrated that the corrective actions for the previous event significantly minimized the consequences of the controller failure.
~
c.
Conclusions Appropriate operator response prevented a controller failure from causing a significant' plant transient. The appropriate operator response was a direct result of
+
effective and lasting corrective actions stemming from a similar event which occurred approximately 10 years ago.
04-Operator Knowledge and Performance 04.1 Clearance Order Status a.
Insoection Scoce (71707)
The inspector reviewed clearance orders to ensure that they were properly prepared and implemented, b.
Observations end Findinas l
The inspectors noted no concerns with the clearance orders reviewed. However, the inspectors identified a possible vulnerability in the licensee's program. The operations representative to the work control center maintained the original clearance orders in the work control center during the day shift from Monday I
through Friday, and returned them to the control room at other times. Operators maintained copies of the clearance orders in a second set of books in the control room. However, the current status of the clearance orders including changes occurring during the time the books were kept in the work control center were not easily accessible to control room operators. While each clearance order change was approved by the shif t supervisor, the licensee's program did not require copies of these changes to be maintained in the control room Consequently, operators had the potential to refer to copies of clearance orders that may not have reflected all of t
the changes, and therefore would not provido ready access to accurate current l:
plant alignment for response to events, if needed.
I
7 c.
fanctustons The inspector concluded that clearance orders were being handled in accordance with procedures. However, the inspector identified a potential vulnerability in the f ailure to always maintain copies of clearance order changes in the control room to provide operators with ready access to accurate current system alignment of systems for response to events.
06 Operations Organization and Administration 06.1 Corrective Lenses for Resoiratorv Protection Eauipment a.
Insoection Scone (71707)
The inspector reviewed the licensee's compliance with corrective lens requirements for licensed operators while using respirator protection during the conduct of licensed activities, b.
Observations and Findinag On May 6,1997, the inspector asked the shift supervisor if they had any mechanism to track respirator glasses for operators who had individual license conditions requiring them to wear corrective lenses while performing licensed duties. The shift supervisor stated that they maintained copies of the individual licenses in the shift supervisor's desk, and relied on each operator to ensure that they complied with the requirements of their license. The shif t supervisor also stated that there was no tracking program to ensure that operators requiring corrective lenses actually had them for use while utilizing respiratory protection equipment. Several days later, the inspector expressed this concern to the operations supervisor and asked if there were any operators who had corrective lens restrictions, but did not have corrective lens inserts for respiratory protection equipment. The operations superintendent acknowledged that no program existed, and therefore said that they could not determine whether all required corrective lenses were available or not. Several days later, the operations supervisor informed the inspector that they did not have required corrective lenses for all operators, and that the needed lenses were being ordered. On May 16,1997, the emergency preparedness manager initiated Performance improvement Request (PIR) 971450 to document the identification of this question from another licensee.
On May 20,1997, while the steam leak described in Section 01.1 was active, the inspector observed a licensed operator don respiratory protection equipment without corrective lenses for a nonlicensed activity. Later that day, the inspector asked the individual why corrective lenses had not been used. The operator responded by stating that the corrective lenses required by the individual license provided a minor eyesight correction, and from past experience, the correction provided by corrective lenses made for respiratory protection equipment did not improve the individual's f
8 eyesight while wearing respiratory protection equipment. As a result, the operator i
individually decided not to wear the corrective lenses while wearing respiratory protection equipment. The inspector noted that the hc6nse stated that corrective i
lenses were required any time the individual engaged in licensed activities, The inspector determined that the licensee did not have an administrative program to ensure that operators requiring corrective lenses actually had and used the required lenses for alllicensed duties, end that this was an activity affecting quality.
The failure to provide these administrative controls is a violation of 10 CFR Part 50, Appendix 8, Criterion V (VIO 50 482/9710 01),
c.
fanqigslons The inspector identified that the licensee f ailed to provide an administrative plogram to ensure that operators had and used the corrective lenses required by their individual licenses for alllicensed activities.
06.2 Overtime Reauirementh a.
Insoection Scone (71707)
The inspector reviewed the licensee's use of overtime and compilance with the Technical Specification requirement, b.
Observations and Findinos During April 1997, the inspector asked the licensee for the data pertinent to reviewing the licensee's compliance with Technical Specification overtime requirements. While compiling the data, the licensee noted that there had been a history of examples where they had not complied with the Technical Specifications requirements. NRC Inspection Report 50 482/94 12, which was issued on December 1,1994, addressed examples which occurred during the Refueling Outage Vll Corrective actions for this violation included several actions that heightened the awareness of personnel to these requirements. Since then, one example occurred in 1995 and four examples occurred in 1996. Nine examples have occurred in 1997. The licensee initiated PIRs for each of these occurrences and the corrective actions involved procedure revisions, actions to reinforce expectations with workers, and the statement that the discipline policy would be invoked if future examples occurred. PIRs 951533 and 96 0286 recognized that previous corrective actions were ineffect ve and attempted to address the repetitive i
l nature of these occurrences, but f ailed to prevent the subsequent occurrences.
While these examples of unauthorized overtime use without management approval occurred, the licensee also authorized overtime usage in excess of the overtime limits provided in the Technical Specifications a total of 118 times in 1995,545 times in 1996, and 101 times during the first 6 montns of 1997. While some of l
l
1 1
9 these author:2ations were related to plant outages, many of them were not.
Technical Specification 6.2.2.f requires the licensee to comply with the guidelines of Generic Letter 8212 which states that "Enough plant operatir": personnel should be employed to maintain adequate shift coverage without routine heavy use of overtime. The objective is to have operating personnel work a normal 8 hout day, 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> week while the plant is operating. However, in the event that unforseen problems require substantial amounts of overtime to be used, or during extended periods of chutdown for refueling, major maintenance, or major plant modifications on a temporary basb, the following guidelines shall be followed:... Recognizing that very unusual.:ircumstances may arise requiring deviation from the above guidelines, such deviation shall be authorized by the plant manager or his deputy, or higher levels af management, The paramount consideration in such authorization snati bo inat significant reductions in the effectiveness of operating personnel would be highly unlikely." Given the high number of deviations from the Generic letter 8212 guidelines, the inspector questioned whether each occurrence represented the ".. very unusual circumstances..." provided for in the Generic Letter. The Chief Operating Officer acknowledged that the number of authorizations for overtime above the Generic Letter 8212 guidelines had been excessive and that the numbers would be reduced considerably in the future.
The inspector reviewed the data provided by the licensee and noted that overtime data for verifying that exempt personnel complied with Generic Letter 8212 guidelines was not available. The inspector asked the Chief Administrative Officer how they monitored exempt personnel overtime use tu ensure that routine heavy use of overtime did not occur. The Chief Administrative Officer acknowledged such trending information was not available. The only data which was available were the authorization forms for overtime use in excess of the Generic Letter 8212 guidelines for exempt employees.
The inspector asked if the licensee routinely reviewed the use of overtime to evaluate compliance with the Technical Specification requirement. The Chhi Administrative Officer acknowledged that they did not. After recognizina the history of problems in this area, the licensee initiated PIR 971303.
Since the licensee f ailed to monitor and review the use of overtime on a periodic basis, this issue was only identified as a result of NRC inspection in this area. The licensee's failure to initiate actions to prevent recurrence of untsuthorized use of overtime exceeding the Technical Specification requirements, particularly after a previous cited violation and previous significant PIRs, represents a corrective action f ailure in this area. Since the work activities associated with several of the examples of workers exceeding the Technical Specification overtime requirements involved safety related work, this is a significant condition adverse to quality. The f ailure of the licensee to take adequate corrective actions to preclude recurrence of these events is a violation of 10 CFR Part 50, Criterion XVI (VIO 50 482/9710 02).
10-c.
Conclusions An NRC identified corrective action violation resulted from repeated occurrences of--
overtime use in excess of the Technical Specificatica requirements and the failure of the licensee to review and monitor the use of overtime, despite a previously cited violation and significant PIRs in this area.
08 Miscellaneous Operations issues 08.1 (Closedi LER 96 034: Failure to comply with Technical Specification 4.5.2.c for visualinspection of containment. Ori October 18,1996, the licensee identified that Technical Specification Clarification 010 85 was inappropriate to the_ circumstances.
The clarification allowed plant personnel to violate Technical Specification Surveillance 4.5.2.c.2 by providing the interpretation that the containment-inspection only had to be done daily rather than when containment integrity was rettored. The clarification was used by the licensee multiple times since it was initiated in 1985. The root cause was determined to be a misalignment between =
the Wolf Creek organization culture and the regulatory environment. The corrective actions taken in response to this LER were not effective, as illustrated in-Section 01.1.
The inspector concluded that the licensee failed to identify and take corrective actions to prevent recurrence of the violations, The failure to meet Technical Specification 4.5.2.c.2 due to the existence of an inappropriate Technical Specification Clarification is an example of a violation of Technical Specification 4.5.2.c.2 (VIO 50 482/9710 03).
'08.2 (Closed) LER 50 482/97 009:- Failure to Comply with Technical Specification - 4.5.2.c.2. This item involved a repeat occurrence of the issue discussed in Section 08.1 of this report._ The licensee discovered that they failed to perform a containment cleanliness surveillance inspection after reestablishing containment integrity following three containment entries on May 20,1997. The licensee initiated PIR 971477 to address the event, and PIR 971479 to address the failure L of previously identified corrective action as discussed in Section 08.1 of this report, This failure to perform the containment cleanliness surveillance inspections prior to establishing containment integrity is an example of a violation of Technical Specification 4.5.2.c.2 (VIO 50-482/9710 03).
08.3 (Closed) Violation 50 482/9618 02: Safety injection Pump A Operable Mode 5.
The corrective actions taken in response to this event were not adequate because the licensee f ailed to address the root cause. The root cause identified in
' PIR 96-0062 was that the test director did not completely identify or assess his actions. The problem arose from trying to hang a clearance order on both trains of safety injection pumps at the same time to support diesel testing. The corrective action was to add a caution to the integrated diesel and safeguards actuation test to ensure that the other train clearance order is being changed and that it complies 4
1
)
a
4 11 i
with Technical Specification 4.5.4.1. The inspector questioned whether this addressed the root cause of the event, in response to this concern, the licensee counsellad the test director and the shif t supervisor involved. The PIR was added to the refueling concerns training for operations personnel, in addition to those corrective actions, the licensee recognized a trend in the f ailure to completely address the root cause and identify effective actions in response to I.ERs 96 004 and 005. PIR 96 2592 was issued to address this trend. The corrective actions in response to this included forming a formal corrective action review board chaired by the Chief Operating Officer. This board will review the root cause determination and corrective action plan for all significant PIRs. Organization changes were implemented to provide operations personnel to support the j
corrective action process. Additional training was provided for managers and l
personnel implementing the corrective action program. The inspectors concluded that the licensee's corrective actions were appropriate.
08.4 (Onen) Unresolved item 50 482/9709 02: Containment Cleanliness. This item involved the inspector's identification of fire hose covers on containment fire hose stations inside containment during power operation. Engineering personnel evaluated this issue and documented their conclusions on Reportability Evaluation Request 07 032. The inspector noted that the licensee considered the evaluation complete, and it had been approved by the plant safety review committee. The inspector reviewed the evaluation and discussed the conclusions with the engineer who performed the evaluation. During the discussions the engineer stated that the fire h se was stuffed into the cover because it was a tight fit. The inspector noted that the evaluation did not evaluate the effect of the expected postaccident containment temperature on the ability of the hose cover hook and loop fasteners to remain fastened. The engineer acknowledged that this was not evaluated and stated that this was not considered necessary. The evaluation described an experiment that the engineer performed to determine how much force would be needed to remove the cover from the fire huse station. When the inspector asked the engineer if the experiment was ever performed with the hook and loop f asteners unf astened, the engineer stated that this was never considered. The inspector observed six fire hose stations in the plant, and noted that the covers were loosely hung over the fire hose stations, and that the cover did not provide a tight friction fit. Based on these questions, the inspector determined that the licensee's conclusion that none of the fire hose covers could come of t and be transported to the recirculation sumps, could not be verified. Since these various questions remained at the end of the inspection, this item will remain open pending resolution of these issues.
I
t k
12
[LEalntena.ng.g M1 Conduct of Maintenance M 1.1 General %mments on Maintenance Activities
- a. Inspection Scone 162707)
The inspectors observed all or portions of the following work activities.
105716 Task 3 Calibration check of the Emergency Diesel Generator A rocker tube oil reservoir level annunciator 109427 Task 1 Installation of a drain trap on instrument 119829 Task 2 Postmaintenance test for Component Cooling Water Pump C INC L 1000 N/A Calibration of instrument Air Compressor A temperature indicator RNM C 1301 Task 4 Calibration Check of Emergency Diesel Generator A volts per hertz relay STN SP 033 N/A Quarterly Channel Check for ST RE 33, containment purge radiation monitor
- b. Qbservations and Findinas The inspectors found no concerns with the maintenance observed.
-c.
Conclusions The inspectors concluded that the maintenance activities were being performed as required.
M1.2 General Comments on Surveillance Activities The inspectors observed all or portions of the following surveillance activities.
l l
l
4 4
l 13 a.-
Insoection Scope 161726)
STS IC 201 A, Revision 8 Analog channel operational test of TAVG, Delta T and Pressurizer Protection Set 1 partial to Test P 11 permissive STS IC 209A, Revision 5--
-4kV degraded voltage TADOT NB01 bus Separation Group 1 STS IC896, Revision 8 Channel calibration triax spectrum recorder (PASSIVEL seismic monitor l
STS KJ 015A, Revision 4 Manual / Auto start synchronization D/G NE01
- b. Observations and Findinas Except as noted in Sections M3.1 and M3.2, the inspectors had no concerns witl.
the surveillances observed.
c.- Conclusions Except as noted in Section M3.1 and M3.2, the inspectors concluded that the surveillance activities were being performed as required.
M3-Maintenance Procedures and Documentation M3.1 Failure to Test P 11 Permissive Inout Relav
- a. -
Inspection Scoce (375511-Engineers at Callaway determined that the an input relay in the pressurizer pressure P 11 circuits for Protection Channels I, ll, and ill were not tested. The inspectors reviewed the licensee's actions taken m response to this concern, b.
Observation and Findinas On June 4,1997, engineers at Callaway contacted engineers at Wolf Creek and informed them of a concern they had identified during a review in response to Generic letter 96 01, " Testing of Safety related Logic Circuits." The surveillance tests for the solid state protection system failed to overlap in that the input relay and contact for the safety injection block for low pressurizer pressure and low steamline pressure were not tested. This portion of the system was designed differently from the rest of the system in that the three lights on the annunciator panel remained on as long as the contact was open. When the system was placed in test, the contact _ remained open, so the_three lights for the circuit remained lit.
The system was normally in a f ail ssfe condition during operation in that manual l
i
4, l
14 Safety injection initiation was blocked until the contact was closed. Lowering pressurizer pressure below 1970 psig caused the contact to close and this removed the block on manual initiation of safety injection.
The licensee worked with the vendor and Callaway Plant personnel to devise a safe method to test the untested portion of the circuit with the plant operating. The licensee's general operating procedures required opsrators-to verify that the lights -
went out at 1970 psig and provided actions to be taken if they did not. The procedures used to test the system, STS iC 20l A. 202A, and *203A, " Analog Channel Operational Test of TAVG, Delta T, and Pressurizer Protection Set 1 -
Partial to Test P 11 Permissive," Revision 8, were modified to allow testing of the circuit. The inspectors observed technicians test the input relay using the revised methodology. The three channels functioned according to design. At the end of the inspection period, iicensee personnel were still working with the vendor and Callaway personnel to establish a long term solution. The long term corrective actions will be reviewed during a future inspection and will be tracked as an inspection' followup item (482/9710 04),
c.
Conclusions f
The licensee appropriately addressed concerns resulting from the identlication of an untested portion of the solid state protection system.
M3.2 Seismic Monitor Surveillance Test a.
jnsoection Scone (61726)
The inspee. tor observed portions of the surveillance test of the seismic monitor, b.
Observations and Findinos On June 16,1997, the inspector obseived instrumwnt and control technicians perform Procedure STS IC 896, " Channel Calibration Triax Spectrum Recorder (PASSIVE)," Revision 8. During the surveillance the inspector compared the procedure with the vendor technical manual and found several differences. The suggested data table in the vendor technical manual recommended that the technicians record the actual displacement measurements during sensitivity determination. The procedure only required the technicians to record the results of the calculation to convert the measurement from displacement to sensitivity. The procedure suggested that the technicians use a tool to move the plates while obtaining the displacement marks to avoid side loads that would affect the outcome of the measurements. The procedure did not specify how to obtain the displacements and the technicians performed this by hand.
After discussing the observations with the technicians and the first line supervisor, the inspector determined that the differences noted did not affect the outcome of
~
15 the observed surveillance test. However, to enhance the test, the first line supervisor decided to revise the procedure by August 30,1997, to address these differences.
c.
'g.nclusions The surveillance of the seismic monitor was being performed appropriately, inspector identified derferences between the procedure and the recommended testing method in the vendor technical manual resulted in the initiation of enhancemente to the surveillance procedure.
Ill. Enaineerina E4 Engineering Staff Knowledge and Performance E4.1 Eat!vre to Meet Technical specification 4.3.1.1 a.
Insnection Stone 137551)
The licensee determined that they were not meeting Technical Specification 4.3.1.1 regarding power range channel adjustments following calorimetric calculations. The inspectors reviewed the concern and the corrective actions taken, b.
Observations and Findinas On June 4,1997, an engineer in nuclear engineering questioried whether a change made in July 1996, to Procedures STS e 5-001, " Power Range Adjustment to Calorimetric," Revision 21, and STS SE 002, " Manual Calculation of Reactor Thermal Power," Revision 16, violated Technical Specification 4.3.1.1, Table 4.31, Power Range, Neutron Flux High Setpoint Note 2. Note 2 states that above 15 percent of rated thermal power, excore channel gains are to be adjusted to be consistent with calorimetric power if the absolute difference is greater than 2 percent. The engineer had initiated the change in response to Westinghouse Technical Bulletin ESBU TB 92-14-Rq, "Decalibration Effects of Calorimetric Power Measurements on NIS High Power Reactor Trip at Power Levels Less Than 70 Percent RTP." This bulletin recommended that if the nuclear instrumentation indicated power is greater than the calorimetric indicated power and the calorimetric power levelis less than 70 percent, the nuclear instrumentation channels should not be corrected by introduction of a gain shift to reflect the calorimetric power.
Based on this guidance, the licensee revised Procedures STS SE-001 and -002 on July 31,1996, to prevent a reduction of the nuclear instrumentation gain to match calorimetric powcr if the power levelis less than 70 percent. This change directed operators to not comply with the requirements of Technical Specification 4.3.1.1.
On May 25,1997, the licensee operated below 70 percent power in a condition
4 16-where Technical Specification 4.3.1.1 required adjustment of the nuclear instruments, yet the revised procedure directed operators not to make the required adjustment.
After identifying the concern, the licensee revised Procedures STS SE 001 and 002, initiated PIR 97 1635, and indicated that they planned to issue an LER.
The inspector reviewed the procedures and noted that an on the spot-change had
{
been approved on June 9,1997. B.dditional corrective actions included disciplining u
the engineer involved in the initiating error. The licensee indicated that resolution of PIR 971635 will also consider additional actions to reinforc: the importance of the review process, particularly with the individuals involved in rev: ewing these procedure changes. Since operators failed to make the required nuclear instrument adjustments, this is a violation of Technical Specification 4.3.1.1. This nonrepetitive, licensee-identified and corrected violation is being treated as a noncited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (NCV 50-482/9710-05).
c.
.C.g.n. clusions Engineers exhibited good questioning attitude in identifying a failure to meet a Technical Specification requirement to maintain the nuclear instrumentation calibrated within two percent of the calorimetric. During the review of the change to the surveillance procedures, engineering and operations personnel failed to ensure that the procedure provided guidance consistent with the requirements of Technical Specificotions.
E8.1 (Closed) Unresolved item 50 482/9704-06: Use of vendor technical manuals for selecting substitute parts. This item involved the use of vendor technical manuals to select substitute parts without an equivalency evaluation based on their inclusion in a bulletin included in tha manual. The licensee contacted a former architect-engineer site manager and a quality assurance manager from the air conditioning unit vendor. Both individuals agreed w;th the licensee's interpretation regarding the use of the vendor technical manual for selecting substitute parts. The quality assurance manager said that the felt element would not be appropriate despite its appearance on the vendor bulletin page containing the designations of the approved filter cores simply because it was not grouped in the same column with the core initially suppl'd by the vendor. The quality assurance manager also said that if are of the filter core desbnations grouped with the one initially supplied with the unit weie not appropriate for use at Wolf Creek, the entry would have been lined out in that table.
The inspector concluded that the licensee interpreted the manual in a manner consistent with the expectations of the vendor. The inspector also concluded that the logic for selecting replacement parts was not consistent and could lead to future confusion and possible misinterpretation and inappropr. ate substitution of replacement parts. At the exit meeting, the licensee acknowledged this possibility
"U g
_v
-17 I-arid stated that it.was being considered as part of a planned e r technical l:
manual update project.
IV. Plant Support R1 Radiological Protection and Chemistry Controls
_ R1.1 Safety Iniection Pumo B a.
Insoection Scooe (71707. 71750)
Using Inspection Procedure 71707 and 71750, the inspectors evaluated the Train A and B switchgear rooms and safety injection Train B components to verify-operability.
b.
Observations and Findinos Equipment operability,= material condition, and housekeeping were adequate. The inspector noted that a leak in the outbobrd seal housing of Safety injection Pump B caused a large boric acid accumulation on the skid of the pump.- The accumulation occurred in a posted contaminated area on the pump skid. The inspector noted that this accumulation had worsened over the last several months and oilleaks had added to the accumulation. ~ The licensee initiated an action traest to repair the leak. On June 6,1997, the inspector discussed the issue with the radiation protection manager. The inspector noted the skid had been cleaned. on June 12 -
.1997. The inspector discussed the frequency of cleaning up this type of spill with radiation protection management. The skid had been cleaned 21/2 weeks before.
The pump outboard bearing area elso had a small but active leak. The licenser' was monitoring _the leak and the' area daily to ensure that the leakage remained on the skid and inside the posted contaminated area, and to track the status of the leak, c.
Conclusions The laspector concluded that safety injection equipment was being maintained in an operable condition and that the radiation protect:on department appropriately monitored a minor system leak.
R1.2 ' Restricted Area Entry Without Thermolum.nescent Dosimetry a.-
Insoection Scoce (71750),
The inspector taviewed the circumstances surrounding the licensee's discovery that on two occasions, properly trained radiation workers entered the restricted area without the thermoluminescent dosimetry required by administrative procedures, s
s a,
e 1
18-b.
- Observations and Findinas On March 20,1997; an engineer and a quality control inspector entered a high radiation area without wearing the thermoluminescent dosimetry required by Procedure AP 25A 001,." Radiation Protection Manual," Revision 2. The workers were wearing electronic dosimetry, and received 1 millirem and 2 millirem indicated dose, respectively. The licensee's computer controlled automated access system was not functioning -at the time, and as workers manually logged onto the radiation work permit, they obtained electronic dosimetry but failed to obtain and wear their
- issued thermoluminescent dosimetry, While in the high radiation ared, a.
3rker-noted that these two workers did not have ther noluminescent dosimetry. The I
workers exited the high radiation area while being escorted by a health physics technician, The licensee initiated PIR 97 0844 following the first occurrence on -
- March 20,1997, classified it significant, downgraded it to nonsignificant (thus deciding to not perform a detailed root cause determination with detailed corrective actions), and closed it on April 23,1997. Corrective actions included disciplining the workers involved,' suspending radiological controlled area access to the two workers until they received retraining from the radiatiol protectio ' superintendent, and discussing the event in the station newsletter admonishing all radiation workers to comply with radiation worker requirements. A PIR search identified one.
additional example of a worker inside the radiological controlled area without a thermoluminescent dosimeter, occurring in 1995.
On June 12,1997, two mechanics entered the restricted area without dosimetry
- and without logging in on a radiation work permit as required by Procedure AP 25A OO1. The licensee initiated PIR 97.1764 that day and classified it as significant, and as of the end of the inspection, had not closed it. The workers
. participated in a meeting in a room between the radiologically controlled area access desk and an acceptable but infrequently used door that led into the radiologically controlled area. 'The workers were'not signed onto any radiation work permit. At the conclusion of the meeting, the workers recognized that they needed to obtain-some measurements in support of the work they had discussed during the meeting.
The workers used the infrequently used door to exit the meeting room and enter the
~ radiological controlled area. After okaining the measurements, the workers recognized their error and reported their error to health physics personnel. The workers were disciplined on June 27,1997.
While these events were licensee identified, they are repetitive, suagesting that additional corrective action is needed to preclude future recurrence. The f ailure of radiation workers to wear the required thermoluminescent dosimetry during radiological controlled area entries is a violation of Technical Specification 6.11 (VIO 50 482/9710 06).
I
19 c.
Conclusions Radiation workers f ailed to e.1sure that they met all requirements prior to entering the radiological corstrolled area. These repetitive events demonstrate that corrective actions have not been successful in precluding recurrer.co.
R8 Miscellaneous Radiological Protectio.; & Chemistry Controls R8.1 Criticality Monitorino a.
insoection Scone (92904)
The inspector reviewed the status of the licensee's compliance with the requirements of 10 CFR 70.24.
b.
- Observations and Findinos On June 24,1997, the licensee received notification chat their request for exemption from 10 CFR 70.24 criticality monitoring requirements was approved by the US NRC Office of Nuclear Reactor Regulation. The exemption stated that "..
the staff concludes that the licensee's request for an exemption from the requirements of 10 CFR 70.24 is acceptabla and should be granted. Accordingly
... the Commission hereby grants Wolf ( teek Nuclear Operating Corporation and exemption as described in Section 11 above from 10 CFR 70.24...."
c.
Conclusions The inspector concluded that the licensee was exempted from the criticality monitoring requirements of 10 CFR 70.24 provided that they maintained in effect the assumptions and conditions described in the letter granting the exemption.
P5 Staff Training and Qualification in Emergency Preparedness PS.1 Emeroency Plan Drill a.
Insoection Scoce (71750)
The inspector observed emergency plan personnel actions in the technical support center during an activation drill.
b.
,.;ervations and Findinos On June 19,1997, the licensee conducted a drill which required emergency plan personnel to respond to and activate the technical support center. Emergency plan personnel activated the technical support center within the required m;.tivation time, and the staff began initial response activities without the need for specific direction l
iumi m-
20-from management personnel. Once the technical support center was activated, personnel conducted their initial briefing and established immediate priorities. The drill controllers then terminated the drill and asked the drill participants to conduct a entique. The critique was very detailed, and personnel raised concerns without apparent reservation.
c.
Conclusions The licensee conducted an effective technical support center activation drill, and critiqued their performance in an effective manner.
V. Manaaement Meetinos X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on June 27,1997. The licensee acknowledged the findings presented, in response to several issues, e.g. the issues discussed in Sections 06.2, 08.1, and R1.2, the licensee commented that if personnel f ailed to comply with adequate programs, then the ensuing events did not constitute a problem with corrective action, but with human performance. The inspectors acknowledged this concern. While human performance appeared to be a significant aspect of these occurrences, corrective actions must address human performance as well'as programmatic adequacy.
The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
ATTACHMENT SUPPLEMENTAL 'NFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee G. D, Boyer, Chief Administrative Officer O. L, Maynard, President and Chief Executive Officer B. T. McKinney, Plant Manager R. A. Muench, Vice President Engineering W. B. Norton, Manager, Performance improvement and Assessment C. C, Warren, Chief Operating Officer j
- q 2-INSPECTION PROCEDURES USED 1.
'IP 37551-Onsite Engineering IP 61726 LSurveillance Observations i
.. Plant Operations -
IP 71750 Plant _ Support Activities IP 7.1707
= Plant Ope ations I
IP 92904 Followup-Plant Support ITEMS OPENED. CLOSED, AN,0ISCUSSED f
I
.Ooened 9710-01 VIO Corrective lenses for respiratory protectlan equipment (Section 06.1).
.9710 02 VIO Overtime Requirements (Section 06.2). -
9710-03
-VIO Containment: tours during forced outage (Sections 08.1 and 08.2).
9710 04 IFl Evaluate final resolution of the P-11 input relay testing -
-(Section M3.1).
9710-06 VIO Restricted area entry without thermoluminescent dosimetry (Section R1.2).
Closed 50-482/9704-06 URI Use of vendor technical manuals for selecting substitute parts (Section E8.11 50-482/96-014
.LER Failure to comply with Technice! Specification 4.5.2.c for visual inspection..f containment (Section 08.1).
50-482/9618-02 VIO Safety injection Pump A operable - Mode 5 (Section 08.3).
50-482/97-009 LER Failure to comply with Technical Specification 4.5.2.c.2 (Section 08.2)
' Discussed 50-482/9709 02 URI Fire Hose Covers (Section 08.4)
%=,.
t 3
Opened and Closed 9710 05 NCV Failure to meet Technical Specification 4.3.1.1 (Section E4,1) l l
I l
l l
- W
} gg 9 y (=1.-
4 5
W4pLF CREEK W=f NUCLEAR OPERATING CORPORATION REGIONIV Gary D. Boyer Chief Administrative Officer August 8, 1997 CO 97-0056 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station F1-137 Washington, D. C.
20555
Reference:
Letter dated July 6, 1997, from T. P. Gwynn, NRC, to O. L. Maynard, WCNOC
Subject:
Docket No. 50-482:
Response to Notice of Violations'50-402/9710-01, -02, -03, and -06 i
Gentlemen:
i.
This letter transmits Wolf Creek Nuclear Operating Corporation's (WCNOC) response to Notice of Violations 50-482/9710-01,
-02,
-03, and
-06.
Violation 9710-01 cites a failure to have instructions or procedures to ensure that licensed operators had appropriate corrective lenses available for use with self-contained breathing apparatus.
Violation 9710-02 addresses examples of workers performing safety-related work in excess of the Tee nical Specification 6.2.2.f work hour limits.
Violation 9710-03 Identifies violations of Technical Specification Surveillance requirement 4.5.2.c.2.
Violation 9710-06 identified two incidents of personnel entering the Radiation Control Area (RCA) with incorrect dosimetry.
WCHOC's response to these violations is provided in the attachment.
If you have any questions regarding this response, please contact me at (316) 364-8831, extension 4450, or Mr. Richard D. Flannigan at extension 4500.
Very.truly
- urs, O J j\\
' Gary oyer GDB/jad Attachment cc:
W. D. Johnson (NRC), w/a E. W. Merschoff (NRC), w/a J. F. Ringwald (NRC), w/a J. C. Stone (NRC), w/a ctT-M 4(
h Mg/Q / e7
[4)pi PO. Box 411 / Burhngton, KS 66839 I Phone: (316) 364-8831 G
u
,. N * -~
h g,
o e
Wolf Creek Nuclear 2-Operating Corporation -
Supervisor Licensing l
Wolf Creek Nuclear Operating Corp.
P.O. Bo2 411
- Burlington, Kansas 66839 Chief Engineer l.
Utilitics Div'slon l-Kansas Corporation Commission 1500 SW Arrowhead Rd.
Topeka, Kansas 66604-4027 l
Office of the Governor l
State of Kansas Topeka, Kansas 66612 Attorney General Judicial Center 301 S.W.-10th 2nd Floor Topeka, Kansa i6612-1597 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 o
O 9
4 3.....
c' g
-Atttchment to CO 97-0056
-P:ge 2 of 8 Corrective 83m That Will Be Taken And The Date When -Full C<epliance Will se Achieved:
-* A procedure to track and monitor adherence ; of Licensed Operator restrictions is being - developed and will be issued - by Aug sst 29, 1997 e :- A reminder of the requirement that some licensed operat' ors are required to have appropriate eye wear to wear _ SCBAs' in ' the control room is being added +o the training material involving the donning.of SCBAs. This will be incorporated by August 29,1997.
I I
i
,,,,.'4; "i i
a, AttCchment ts CO 97-0056
~
- tage 4 ot 8
- Corrective Steps That will-Be Taken And The Date When Full Compliance Will Be Achieved:
Department' Heads will communicate to supervisors their expectations on adherence to work - hour limitations.
This will be completed by August 30, 1997.-
The Department Heads will communicate to employees their expectations on self tracking and reporting work hour limits.- This action will be completed by August 30, 1997.
- The: Plant-Manager-will meet with the Call Superintendents t a _-
communicate expectations for them to challenge each supervisor's justification-for exceeding the-work hour limitations.
This meeting will be cor. ducted by August 15, 1997.
l The Plant Manager will establish a-performance indicator on approved l
l work hour deviations by August 30, 1997.
This indicator will be a tool. for management monitoring of_ authorization frequency and justification;'
The Plant Manager will develop a method to monitor exempt employee hours worked.
The expectation and method will be communiciced to all supervisors and managers by September 15, 1997.
L
- . Procedure AP 13-001, Revision 2,
" Guidelines for WCGS Staff Working Hours", will be enhanced to provide better guidance.
This revision will be completed by August 22, 1997.
.iuality Evaluations will monitor implementation of AP 13-001 during
-defueling Outage Nine.
The results of this monitoring will be made available to management by November 30, 1997, t
x
/f1 a -
J
\\ #
Atn Ehment tb CO 97-0056
- Page 6 of 8
- The root _ cause-of this - event was determined to be inadequate program monitoring or management. The corrective actions following the concerns with the use of Technical Specification Clarifications addressed the need for literal compliances however, Wolf Creek employees have failed to meet. Operations' performance expectations when addressing literal compliance.
Corrective Steps Taken and Results Achievedt Licensee Event Report (LER) 97-009-01 was issued
- Status Charts provided incorrect information about performing contr.inmont inspections.
These documents were initially revised to ensure t.:ompliance with Surveillance Requirement 4.5.2.c.2.
- However, upon che receipt of Technical Specification Amendment-105, the
<:hangee made to these documents were no longer required.
Technical SpecAfication Amendment"105 was received on June 23, 1997, and the R2 Status Charts were revised to address Amendment 105.
This ensures compliance with Surveillance Requirement 4.5.2.c.2, and no further actions are required.
- The inability of the individuals involved to comply with Technical Specifications, along with the other noted ' occurrences of similar
- concerns, identifies the need for further site-wide discussions concerning the appropriate and expected use of literal compliance.
This was addressed at site-wide meetings held during July, 1997.
Corrective Steps That Will Be Taken And The Date When Full Compliance Will ne Achieved:
All Technical' Specification Clarifications deleted after September, 1996, will be reviewed to ensure applicable information is captured in Operations' procedures.
This review will be coordinated by Operations Support with the assistance of Licensed Operators.
This review will be completed by August 12, 1997,. and the appropriate procedure' revisions will be completed by September 16, 1997.
- To ensure the proper completion of future containment inspections, guidance will be added to STS EJ-001 concerning the-required performanc( and the scope of the inspection which should take place, j
This will be completed by August 31, 1997.
- To address-the root cause of this
- concern, discussions of Management's Expectations and literal compliance will take place with each Shift Supervisor, Supervising Operator and appropriate, members of Operations Training.
These discussions will be conducted by the Manager Operations, and will be completed by August 31, 1997.
will be revised to provide an acceptable definition of containment entry.
Based on the receipt of Amendment A05, the procedure will also Le revised to notify the Shift Supervisor, as required, to ensure completion of STS EJ-001 in accordance with Technical Specification Amendment 105.
AP 25A-100 will be revised by August 31, 1997
S w
7 '
- E'
- Attdchment't6 CO 97-0056-
,-l- * :1 P'g:3 8 cf 8 ;-
WCGS Health Physics will submit a' proposed design change.to be-
'o
-: evaluated-using the design change process. This design change will be submitted by January 1, 1998.
f t
1 4
0
-g.
1,%
h ka ma%
UNITE 3 ST ATES Q'*'y T
NUCLEAR RE2ULATORY COMMISSION L
REoloNfv 8
S11 RYAN PLAZA DHlvE.SulTE 400
'e,4, ARLINoToN. TEXAS 760114064 AUG I 51997 Otto L. Maynard, President and Chlef Executive Officer I
Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, Kansas 66839
SUBJECT:
NRC INSPECTION REPORT 50 482/97-10
Dear Mr. Maynard:
Thank you for your letter of August 8,1997, in response to our letter and Notice of Violation dated July 10,1997. We have reviewed your reply and find it responsive to the concerna 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, mas n
irector avision o eac r Projects Docket No.: 50-482 License No.: NPF-42 cc:
Chief Operating Officer
- Wolf Creek Nuclear Operating Corp.
P.O. Box 411 Burlington, Kansas 66839 Jay Silberg, Esq.
Shaw, Pittman, Pott. & Trowbridge 2300 N Street, NW Washington, D.C. 20037 1
70SAoovCW W
_________a
- C --
44y Wolf Creek Nuclear 2-Operating Corporation Superviser Licensing Wolf Creek Nuclear Operating Corp.-
P.O. Box 411 Burlington, Kansas 66839 Chief Engineer Utilities Division-Kansas Corporation Commission 1500 SW Arrowhaad Rd.
Topeka, Kansas 66604-4027
- Office of the Governor l
State of Kansas Topeka, Kansas 66612 l
. Attorney General l
Judicial Center
- 301 S.W.10th 2nd Floor -
-Topeka, Kansas 66612 1597 County Clerk Coffey County Courthouse Burlington, Kansas 66839 1798
' Vick L. Cooper, Chief Radiation Control Program Kansas Copartment of Health and Environment Bureau of Air and Radiation Forbes cield Building 283
-Topeka, Kansas.'66620 Mr. Frank Moussa Division of Emergency Preparedness
- 2800 SW Topeka Blvd Topeka, Kansas 66611-1287
__o s