IR 05000482/1986034

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-482/86-34

ML20212P668
Person / Time
Site:	Wolf Creek
Issue date:	03/11/1987
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Withers B WOLF CREEK NUCLEAR OPERATING CORP.
References
NUDOCS 8703160189
Download: ML20212P668 (2)

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IMR 111987 In Reply Refer To:

Docket: STN 50-482/86-34 Wolf Creek Nuclear Operating Corporation ATTN: Bart D. Withers-President and Chief Executive Officer P. O. Box 411 Burlington, Kansas 6C839 Gentlemen:

Thank you for your letter of March 2,1987, in response to our letter and Notice of Violation dated January 29, 1987. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintaine

Sincerely, Ostgina! Signed D/

J. E. Gagliardo J. E. Gagliardo, Chief Reactor Projects Branch cc:

Wolf Creek Nuclear Operating Corporation ATTN: Otto Maynard, Manager of Licensing P. O. Box 411 i

. Burlington, Kansas 66839 Gary Boyer, Plant Manager f Wolf Creek Nuclear Operating Corporation

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w'E ' P. O. Box 411 Burlington, Kansas 66839 b0 Forrest Rhodes, Vice President, Nuclear Operations et Wolf Creek Nuclear Operating Corporation

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March 2,1987 U.S. Nuclear Regulatory Conmission ATTN: Document Control Desk Washington, D.C. 20555 Ietter: WM 87-0057 Re: Docket No. 50-482 Subj: Response to Inspection Report 50-482/86-34 Gentlemen: .

This letter is written in reponse to your letter of January 29, 1987, which transmitted Inspection Report STN 50-482/86-3 As requested, the violations (482/8634-01 and 02) identified in the Inspection Report is being addressed in four part (a) The reason for the violation if admitted; (b) The corrective steps which have been taken and the results achieved; (c) Corrective steps which will be taken to avoid further violations; and (d) The date when full compliance will be achieved.

Violation (482/8634-01): Failure To Have An Adequate Procedure For Draining The Reactor Coolant System l Finding:

Technical Specification (TS) 6.8.1 requires that, " Written procedures shall be established, implemented, and maintained covering . . . The

, applicable procedures reconmended in Appendix A of Regulatory Guide (RG)

l 1.33, Revision 2, February 1978," Section 3.a of Appendix A states that l draining the reactor coolant system should be covered by written procedure These procedures shall be written in accordance with ANSI N18.7-1976/ANS-3.2, .Section 5.3 which requires that activities affecting safety at nuclear power plants shall be described by written procedures of a type appropriate to the circumstances, w ; RO. Box 411/ Buriington, KS 66839 / Phone: (316) 364-8831

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NM 87-0057 March 2, 1987 Page 2 .

Procedure SYS EC-200, Revision 6, " Changing Ievel in the Spent Fuel Pool or Refueling Pool, " has been established to inplement these requirement ;. Contrary to the above, SYS E -200 was found to be inadequate to effectively 1986,. during

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control pool level requirements in that on November 29, draining of the refueling pool /RCS, the Residual Heat Removal (RHR) pumps became airbound on two separate occasion Numerous NRC and Industry notices had previously identified RHR pung air binding to the license Reason For Violation If Admitted:

Following loss of suction to both RHR pumps during lowering of the refueling pool / reactor coolant system level on November 29, 1986, it was correctly believed the cause was due to lowering the level at too fast a rat Both RHR pumps were restored to service. Evaluation of this event concluded that even though visual water level was at or just above the vessel flange when cavitation occurred, the drain down rate was too fas To better identify voiding in the upper part of the Reactor Pressure Vessel, an extra tygon tube was installed for additional level determination and one (1) additional operator was placed in containment to view the tubing as well as the actual

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pool water leve Both were in direct comunication with the Control Roo A second pump down was attempted at a slower rate using system operating procedure SYS T-200, " Changing Level in the Fuel Pool or Refueling Pool".

During the second attempt the tygon tubing indicated a rapid level decrease in the Reactor Pressure Vessel and the punp down was inmediately terminated with one RHR pump losing suction. Water level was increased and the RHR pump returned to service. Water level was subsequently lowered to half-pipe using a much slower rate with the letdown syste Subsequently, it was realized that during previous punp downs, when a loss of RHR did not occur, the reactor vessel upper internals and fuel were not installe During drain down with fuel in the vessel and the upper internals installed, a loss of RHR was experience Our review of the numerous NRC and Industry concerns of RHR punp cavitation events did not i

identify the sudden loss of water in the reactor pressure vessel while a

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visible water level existed above the vessel flange. To the best of our knowledge, this phenomenon had not been identified in the past. 'Iterefore, the reason for this violation is attributed to inadequate procedures for pumping down the refueling pool / reactor coolant systen with the vessel upper

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Following loss of suction to the RHR punp(s), water level was quickly restored and RHR pump (s) returned to servic Water level was subsequently lowered using the letdown system, at approximately 100 gpm flo Temporary procedure change number MA86-0867 was issued for station procedure FHP 02-001, Revision 5, to limit the reject rate to the RWST during drain down to 1000-1500 gpm while greater than two (2) feet above the vessel flange and to approximately 250 gpm when less than two (2) feet above the flang ,

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WM 87-0057 Page 3 March 2, 1987 Corrective Steps which Will Be Taken o Avoid Further Violations:

Additionally, system operating procedu':e, SYS EC-200, has been revised to incorporate the lessons learned from th.s inciden The procedure requires use of the letdown system after the level has been lowered to approximately two (2) feet above the vessel flang Wis violation and response has been placed in operations required reading program to ensure operations personnel are cognizant of the need for adequate evaluations of abnormal or unexplained operations event We Date When Full Compliance Will Be Achieved:

Full Coupliance has been achieve Violation (482/8634-02): Violation. Of Technical Specification -

Fire Suppression System Surveillance Finding:

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TS 4.7.10.3.b requires that, "Each of the required halon systems shall be

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demonstrated operable at least once per 18 months by verifying the system, including associated ventilation system fire dampers . . . actuates manually and automatically . . . . "

Contrary to the above, as identified in Kansas Gas & Electric (KG&E) Quality Program Violation (OPV) 11/86-180, STS MT-032, Revision 4, " Single-Zone Halon System Checkout;" STS MT-036, Revision 3, "Two-Zone Halon System Checkout;" and STS MT-037, Revision 3, "Six-Zone Halon System Checkout," failed to address the verification of danper actuatio These STS's were being relied upon to meet TS surveillance requirement This violation is a repeat of Violation 482/8541-0 Reason..For.. Violation If. Admitted:

On November 24, 1986 it was determined that surveillance procedures STS MT-032, STS MT-036 and STS MT-037 failed to address verification of the five l dampers to actuate during Halon System surveillance testin Technical

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Specification Surveillance Requirement 4.7.10.3.b requires, in part, demonstration of Halon System operability by verifying that the system, including associated Ventilation System fire dampers and fire door release l mechanisms, actuate' manually and automatically upon receipt of a simulated actuation signal at least once per' eighteen (18) months.

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T@i 87-0057 Page 4 March 2, 1987 A previous similar occurrence was discussed in violation 482/8541-0 As discussed in our response to that violation, a comprehensive review of Fire Protection related Technical Specifications to ensure procedural conpliance was completed in early 198 This review was performed, by the NCGS Fire Protection Coordinator with assistance from respective WCGS groups having responsibility for Fire Protection related surveillance procedure This review did not identify the discrepancies identified in this violation, apparently due to personnel not fully understanding the intent of the surveillance requirement Corrective Steps Which Have Been Taken and Results Achieved:

Following discovery of this situation, the affected Halon Systems were declared inoperable and fire watches for the affected areas were established in accordance with Action Statement 'a' of Technical Specification 3.7.1 The required verification of fire damper actuation was successfully completed and documented on a Work Request on December 2, 1986. Following completion of this testing, the Halon Systems were declared operable and the fire watches were terminate _

The surveillance procedures identified in this violation are 18 month surveillances related to Fire Protection HVAC system Therefore, an independent review of HVAC related, infrequently performed surveillances was initiated by operations results engineering group who did not perform the previous revie Corrective Steps Which Will be Taken To Avoid Further Violations:

We independent review of infrequently performed HVAC surveillance procedures has been completed to ensure Technical Specification requirements are fully met by approved surveillance Test Procedures. All recommendations resulting from the review, including Procedural enhancements and human factor considerations will be added to the procedures prior to the next performance date of the procedur Surveillance procedures, STS MT-032, STS MT-036 and STS MT-037 will be revised to include a provision for verification of fire damper actuation upon receipt of a simulated actuation signa The Superintendent of Maintenance will hold a group discussion with Fire Protection and the appropriate Maintenance personnel involved in writing and reviewing surveillance procedures to stress the importance of ensuring all Technical Specification requirements are verified; and specifically reviewing the past procedural inadequacies discussed abov The Date When Full Compliance Will Be Acheived:

The STS MT-032, 036 and 037 revision process will be completed by March 31, 1987. The group discussions have been conpleted.

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. WM 87-0057 Paga 5 March 2, 1987 If you have any questions concerning this matter, please contact me or M ,

.O. L. Maynard of my staff.

- Very truly yours,

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Bart D. Withers President and 011ef Executive Officer ,

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RMartin JCumins

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