IR 05000482/1987003

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-482/87-03

ML20236F846
Person / Time
Site:	Wolf Creek
Issue date:	07/30/1987
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Withers B WOLF CREEK NUCLEAR OPERATING CORP.
References
NUDOCS 8708040050
Download: ML20236F846 (2)

Text

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JUL 3 01987 In Reply Refer To:

Docket: STN 50-482/87-03 Wolf Creek Nuclear Operating Corporation ATTN: Bart D. Withers President and Chief Executive Officer P. O. Box 411 Burlington, Kansas 66839 Gentlemen:

Thank you for your letter of June 30, 1987, in response to our letter and tiotice of Violation dated March 17, 198 We have reviewed your reply and find it respo'nsive to the concerns raised in our Notice of Violation. We will l

review the implementation of your corrective actions during a future inspection l to determine that full compliance has been achieved and will be maintained.

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Sincerely, Orldnal Signed By J. E. Gegtlardo J. E. Gagliardo, Chief Reactor Projects Branch cc:

Wolf Creek Nuclear Operating Corporation ATTN: Otto Maynard, Manager of Licensing P. O. Box 411 Burlington, Kansas 66839 Gary Boyer, Plant Manager Wolf Creek Nuclear Operating Corporation P. O. Box 411 Burlington, Kansas 66839 Mr. Robert D. Elliott, Chief Engineer i

Kansas Corporation Commission l Fourth Floor, Docking State Office Building i

Topeka, Kantas 66612-1571 Kansas Radiation Control Program Director

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U. S. Nuclear Regulatory Commission April 16, 1987 j ATTN: Document Control Desk Washington, D C. 20555 Letter: WM 87-0125 ,

Re: Docket No. 50-482 '

Reft Letter dated 3/17/87 from JEGagliardo, NRC, to BDWithers, WCNOC ,

Subj: Response to Violations 482/8703-01, 02, 03 and 04 )

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Attached is response to violations (482/8703-01, 02, 03 end 04) which were documented in the Referenc These violations concerned temporary modifications, locked valves, and as built drawing If you have any J

questions concerning this matter, please contact me or Mr. O. Maynard of i my staf Very truly yours, b/

Bart D. Withers President and Chief Executive Officer

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BDW:jad Attachment cc: P0'Connor (2)

RHartin JCummins

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l P.O. Box 411 / Burhngton, KS 66839 i Phone: (316) 364-8831 An Eausi OpportuMy Err # oyer M FNcNET

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Attcchmrnt to WM 87-0125 Paga 1J o .

Violation (482/8703-01): Failure To Perform Activities In Accordance With ,

Established Procedures s

Finding:

Technical Specifications (TS) 6.8.1 requires that, " Written procedures shall

. be established, and maintained covering . . . The applicable procedures recommended in Appendix A of Regulatory Guide (RG) 1 33, Revision 2, February 1978." Section 9.e of Appendix A states, " General procedures for control of maintenance, repair, replacement, and modification work should be prepared before reactor operation is begun." TS 6.8.1 also states that

" Major procedures are written to meet the requirements of ANSI N18.7-1976/ANS 3.2 . . . . " Section 5.2.7 of ANSI N18.7 states, " Maintenance or modification of equipment shall be preplanned and performed in accordance with written procedures, documents, instructions, or drawings appropriate to the circumstances . . . ."

Contrary to the above, on February 17, 1987, the NRC inspector observed three plastic shields attached with aluminum tape, plastic tie wraps, and a

, pipe clamp at three locations adjacent to the shaft on Centrifugal Charging Pump "B" (PBG05B) (High Pressure Injection Pump); however, these modifications had not been accomplished in accordance with a licensee procedur .

Reason For Violation:

The three plastic shields attached with aluminum tape, plastic tie wraps, and a pipe clamp adjacent to the shaft on Centrifugal Charging Pump "B" (PBGOSB) were installed by Hechanical Maintenance at the request of Health Physics to control airborne contamination for ALARA consideration The mechanic discussed the request with the health physics individual, the duty Shift Supervisor, and his coordinating supervisor. The involved individuals did not feel the installation of the temporary shields altered the design, fur.ction , or method of performing the function of the Centrifugal Charging Pump and therefore was not significant enough to have impacted the safety of operation !

Corrective Steps Which Have Been Taken and Results Achieved:

i A temporary modification order was initiated, epproved and put in place upon {

discovery by the NRC Resident Reactor Inspector (RRI). It was also I determined that an unreviewed safety or environmental question did not exis .

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. Corrective Steps Which Will Be Taken To. Avoid- Further Vi_olations:

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Upon discovery by the NRC RRI a Wolf Creek Event Report (WCER) was generated

. describing this violation, immediate corrective action taken, 'and recommended corrective,'actio'ns'jopreventre'urrenc'e c s The'.WCER.has been

'placed in required. reading for Operations Maintenance, Health Physics, and Instrument and Controls. personnel to ensure their awareness that any i modifications to equipment, including temporary shielding must be' properly evaluated and approved prior to installation. Additionally,. this event was

. discussed by the Plant Safety Review Committee at the March 3, 1987 meetin '

The Date When Full Compliance Will Be Achieved:

Full compliance has been achieve Violstion (482/8703-02): Failure To Lock Valves In Accordance With ,

Procedure  !

l Finding: 1 TS 6. requires that, " Written procedures shall be established, and maintained covering . . . The applicable procedures recommended in

,_ Appendix A of Regulatory Guide (RG) 1.33, Eevision 2, February 1978."

Appendix A of RG 1.33 states that, "The following . . . safety-related i activities . . . should be covered by written procedures . . . 1.c.~

l Equipment control (e.g., locking and tagging)."

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Checklist (CKL) GL-121, Revision 6, " Auxiliary Building Heating, Ventilating, and Air Conditioning (HVAC) System Valve Lineup " had been established and implemented in accordance with the above TS and required, in part, that the handwheels to Valves GLV132 and GLV138 be locked closed Contrary to the above, on February 12, 1987 the NRC inspector observed Valves GLV132 and GLV138 closed but not locke Reason For Violation:

The reason for valves GLV132 and GLV138 not being locked as specified by system Checklist (CKL) GL-121, Revision 6 " Auxiliary Building Heating, Ventilating, and Air Conditioning (HVAC) System Valve Lineup " was due to operations personnel not locking the valves when restoring the syste The root cause for valves GLV132 and GLV138 not being locked as specified: by '

system Checklist (CKL) GL-121, was the result of Shift Supervisor directio The Shift Supervisor, after referring to administrative procedure, ADM 02-102, Revision 12, " Control of Locked Component Status" found no requirement for these valves to be locked, and subsequently ordered them to be placed in the closed position. He did not refer to the checklist requirements recognizing that the required locked valves per the requirements of Regulatory Guide 1.33 are addressed in ADM 02-10 The checklist is established for system level lineups and it is within the Shift Supervisor's authority to manipulate / deviate during operation, however, the checklist should have been refered to during restoration revie These valves (GLV132 and 138) are not required to be physically locked in position to satisfy the programmatic guidelines of Appendix A to Regulatory Guide 1.33.

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Corrective Steps Which Have Been Taken and Results Achieved:

Valves GLV132 and GLV138 were locked as specified in tha checklist and the checklist was reperformed for the other valves that were listed to be locked in positio No other discrepancies were found as a result of reperforming the checklis Corrective Steps Which Will Be Taken To Avoid Further Violations:

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The Shift Supervisor has been counseled as to the need to refer to valve lineup checklists and locked valve requirements when restoring systems to service following any outage activitie Additionally, the Operations Section has issued a letter to all operations personnel regarding the need to accurately track systems status through properly restoring systems to servic A copy of this violation has been placed in Operations Required Readin The Date When Full Compliance Will Be_5chieved:

Full compliance has been achieve ,  ! l Violation (482/8703-03): Failure To Have Drawings Reflect As-Built Status

Finding:

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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 . . . . "

Drawings M-12GG02(Q), Revision 0; M-02GLO1(Q), Revision 14; and M-12GLO2(Q),

Revision 0, had been established and implemented in accordance with 10 CFR I l

Part 50, Appendix B.

l Contrary to the above, during walkdowns conducted on February 11 and 12, 1987, the NRC inspector identified the following selected examples of documentation deficiencies on quality (Q) drawings which did not reflect plant as-built status:

- Valve GLV055 is not shown on Drawing H-12GG02(Q), Revision 0

- Valve GLV070 and associated line are not shown on Drawin6 f M-02GLO1(Q), Revision 14

- Valve GLV078 and associated line are not shown on Drawing M-12GLO2(Q), Revision 0 Reason For Violation:

The iteins in question are primarily limited to non-process connections within the envelope of the vendor supplied HVAC equipment skids where detailed assembly drawings (i.e. shop drawings) were not provided. Without detailed drawings these connections could easily have been overlooked during construction and startup with regards to the detailed configuratio l

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Contributing to the problem was a startup request (SFR 1-GB-18) which requested a design change in the vents and drains from piping to tubing and corresponding valve types for some of the equipmen The Engineering Disposition approved 'the request but for a larger-scope of; equipment and also allowed the change to be implemented using a typical' detail prior. to revising the design drawings.- Without the issuance of these drawings it appears that both the field during implementation and the design engineer during drawing incorporation misinterpreted the disposition, thus contributing to the proble Although the configuration in the field did not match the design documentation, the equipment would have performed their intended design functions as process piping was not affecte Corrective Steps Which Have Been Taken and Results Achieved:

l All of the vendor supplied HVAC skids are in the process of being walked down for the as-built condition and the affected drawings will be subsequently revised as require The package will bo issued in accordance with the Wolf Creek's Plant Hodifiestion Program which will provide for reconciliation with plant operating procedure ,

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The program utilised during construction and startup no longer applies. The

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current modification process includes identification of all affected drawings prior to issuance of the modification package and a complete review of all drawings during final closeou Therefore, no corrective action is required at this time to avoid further violation The Date When Full Compliance Will Be Achieved:

The affected drawings will be as-built by the end of June 198 Violation (482/8703-04): Failure To Establish Adequate Procedures Finding:

TS 6. requires that, " Written procedures ,shall be established, implemented, and maintained covering . . . The applicable procedures recommended in Appendix A of RG 1 33, Revision 2, 1978." Appendix A of RG 1.33 states that "The following . . . safety-related activities . . . should be covered by written procedures . . . Equipment control (e.g.,

locking and tagging)."

Administrative Procedure (ADM)02-101, Revision 16 " Temporary Modifications," had been established and implemented in accordance with the above TS to control temporary modifications. Step 5.5 of ADM 02-011 states.

l "the placement of temporary modifications authorized by approved procedures l are excluded from the requirements of this procedure provided the procedure addresses installation and restoration of the modification."

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Atttchm:nt to WM 87-0125 Pega 5 of 5

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Contrary to the above, on February 24, 1987, the NRC inspector observed a !

temporary chart recorder which had been connected to the containment normal I aump level recorders in accordance with Off Normal'Procedu're OFN 00-023, l Revision 2, " Loss of BOP Computer," was not required to be removed by this

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procedure nor was the recorder removed when the' procedure was exite q Reason For Violation: -

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l The reason for this violation was off-normal procedure, OFN 00-023. Revision l 2, " Loss of BOP Computer", not adequately requiring double verification for installation and removal of the chart recorder used to monitor containment sump level Corrective Steps Which Have Been Taken and Results Achieved: l l

The temporary containment sump level recorder was promptly removed upon notification of the discovery by the NRC RR Off-normal procedure OFN 00-023 has been revised to reference a new surveillance procedure. STS LF-001, -

Revision 0, " Containment Normal Sump Inventory and Discharge Determination",

which provides for installation and removal, including double verification,

,_ of the containment sump level recorders on loss and restoration ce the BOP compute )

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

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The development of the new surveillance procedure, STS LF-001, provides the tracking mechanism to ensure the temporary chart recorder is removed and double verified following return to service of the DOP compute The Date koen full Compliance Will Be Achieved:

Full complianc9 has been achieve I

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a, i C Eart D. Withers  ! I President and iJ ,

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June 30,1987 l U.S. Nuclear Regulatory Comnission ATTN: Document Control Desk Washington, D.C. 20555 Letter: WM 87-0180 Re: Docket No. 50-482 Ref: WM 87-0125, dated 4/16/87, from BDWithers, WCNOC to U.S. NRC Subj: As-Built Drawings i

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The purpose of this letter is ;e document a change in the date for completion of revising the HVAC drawings to as-built condition In the l

reference response to violation 482/8703-03, it was stated that a walkdown I will be conducted and as-built drawings will be completed by June 30, 198 (

The walkdown of vendor supplied HVAC equipment skids in the power block has been complete The walkdown identified the need for a larger number of design drawing changes than originally anticipated. A plant modification package with preliminary as-built drawings will be issued by August 17, 198 Final as-built drawings will be issued by Decenber 31, 198 If you have any questions concerning this matter, please c ontact me or Mr. O. L. Maynard of my staf Very truly yours,  !

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L Bart D. Withers President and Chief Executive Officer BDW:jad cc: P3'Connor (2) j RMartin l JCummins  !

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PO. Box 411/ Burlington KS 66839 / Phone-(316) 364-8831 j An Equal opportunity Employer M F:HCVET