IR 05000482/1987015

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-482/87-15

ML20237J860
Person / Time
Site:	Wolf Creek
Issue date:	09/01/1987
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Withers B WOLF CREEK NUCLEAR OPERATING CORP.
References
NUDOCS 8709040100
Download: ML20237J860 (2)

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'SEP.1- 1987 i

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~ In Reply Refer:To: . -

Docket: ' STN 50-482/87-15 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 August-21,1987, in response .to our letter and Notice of Violation dated 'uly J 22, 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, Ori;inal cws ry U. E. Gar;&rda 1 J. E. Gagliardo, Chief

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Reactor Projects Branch

cc:

Wolf Creek. Nuclear Operating Corporation

~ ATTN: Otto Maynard, Manager of Licensing P. O. Box 411 '

Burlington, Kansas 66839 I

~ Gary Boyer, Plant Manager Wolf Creek Nuclear Operating Corporation

~ O. Box 411 Burlington, Kansas 65839-Mr. Robert D. Elliott, Chief Engineer Kansas Corporation Commission

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Fourth Floor, Docking State Office Building

. Topeka.. Kansas 66612-1571 Kansas Radiation Control Program Director bec: _see ( next page) / ,

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Wolf Creek Nuclear Operating -2-Corporation bectoDMB'(IE01)

bcc distrib.- by RIV:

RPB Myron Karman, ELD, MNBB (1)

RRI' R. D. Martin, RA SectionChief(RPB/B) DRSP RPSB W. L. Forney, RIII RIV File Resident Inspector, RIII MIS System RSB RSTS Operator Project Inspector, RPB D. Weiss, RM/ALF R. Hall-P. O'Connor, NRR Project Manager (

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W4$tF CREEK {' ~ ~

NUCLEAR OPERATING CORPORATION -

a$Q Bart D. Withers

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$'n"fc*,$e's. ome., August 21, 1987 WM 87-0217 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Reference: Letter dated 7/22/87 from JEGagliardo, MRC, to L BDWithers, WCNOC Subject: Docket No. 50-482: Response to Violations 482/8715-01 and 482/8715-02 Gentlemen:

Attached is a detailed response to violations 482/8715-01 and 482/8715-02 which were documented in the Referenc Violation 482/8715-01 concerns a failure to comply with Technical Speci fication (TS) 4. Violation 482/8715-02 concerns a violation of Technical Speci fication 4.3.3.11, Containment Purge System Surveillanc If you have any questions concerning this matter, please contact me or Mr. O. L. Maynard of my staf Very truly yours, Bart D. Withers President and Chief Executive Officer BDW/jad I Attachment cc: P0'Connor (2)

! RMarti n JCummins

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Attachment to WM 87-0217 Page 1 of-4 August 21, 1987

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Violation (482/8715-01): Failure to Comply With Technical Specification (TS) 4. Finding:

Technical Specifications 4.0.5 requires, in part, that, " .. Inservice

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testing of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda as required by 10 CFR Part 50, Section 50.55a(g)...."

Section 50.55a(g)(5)(iii) of 10 CFR Part 50 requires, "If the licensee has determined that coaformance with certain code requirements is impractical for its facility, the licensee shall notify the Commission ...."

o Contrary to the above, on June 23, 1987, the NRC inspector, through a routine review of work requests and discussions with licensee personnel, became aware that a section of safety-related, ASME Code Class 3, piping downstream Valve EFV090 had not been properly pressure tested after a through-wall repair and would not be tested until next refueling outag The licensee had failed to notify the Commissio Reason For Violation:

. Foll owing the through wall repair of the section of safety-re16ted, ASME Code Class 3, piping downstream of Valve EFV090, a hydrostatic test was perfo rme Subsequent to the hydrostatic test, it was discovered that the hydrostatic test equipment configuration was improper resulting ' in the pressure test not meeting the required 224 psig hydrostatic test pressur The reason for the violation was a failure to recognize the applicability of Technical Specification 4.0.5 to post maintenance testi n Technical Speci fication 4.0.5, Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2, and 3 components, was interpreted to be applicable only to inservice testing and not post maintenance testin Corrective Steps Which Have Been Taken and Results Achieved:

On June 23, 1987, Wolf Creek requested and received, by teleconference with

, the NRC. temporary relief from ASME Section XI in order to delay performing a new pressure test until the next refueling outag Additionally, relief was requested and granted for delaying testing of two other sections of safety-related piping which have been repaired but cannot be pressure tested with the unit in Mode 1. On June 30, 1987, the above verbal relief request along with the technical justification was formally submitted to the NR _ _____________ -

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Attcchment to WM 87-0217 Page 2 of 4 August 21, 1987 1 '

Corrective Steps Which Will Be Taken To Avoid Further Violations:

For this hydrostatic test, the pressure indicator was located in a spot which did not give a true indication of the pressure at the location of the through-wall repai This resulted in not meeting the hydrostatic test pressure, even though the pressure indicator showed the required pressure was met. To prevent recurrence of the hydrostatic test pressure not meeting the required test pressure because of an improper test equipment con figura tion , the procedure governing hydrostatic testing has been changed to ensure the correct pressure is indicated at the location that the repair was mad The Superintendent of Maintenance has instructed the maintenance engineers by a written memo of the requirements of Technical Specification 4.0.5 and o

10 CFR 50.55a(g)(5)(iii). /

Date When Full Compliance Will Be Achieved:

Full compliance has been achieve Violation (482/8715 02): Violations of Technical Specifications-Containment Purge System Surveillance Finding:

TS Surveillance 4.3.3.11 requires that, "Each radioactive gaseous ef#1uent monitoring instrumentation channel shall be demonstrated OPERABLE by perfomance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION, and ANALOG CHANNEL OPERATIONAL TEST at the frequencies shown in Table 4.3-9."

Step 3.a of Table 4.3-9 requires that, quarterly, the Analog Channel Operational Test (ACOT) be performed for the containment purge system noble gas activity monitor (GT-RE33) providing alam and automatic termination of relea se, and that the ACOT shall also demonstrate that automatic isolation of the containment purge pathway occurs when the instrument indicates measured levels above the Alarm-Trip Setpoin Contrary to the above, on July 1, 1987, the licensee determined that TS Surveillance 4.3.3.11 was not adequa tely perfomed between October 1985 and October 1986 and between December 1986 and June 1987, in that, the surveill ance procedure for performing this surveill ance, STS IC2758, Revision 4, " Anal og Channel Operational Test Containment Purge System Radiation Monitor GT RE33," failed to demonstrate that automatic isolation I of the containment purge pathway occurred when radiation monitor (GT RE33)

indicated measured levels above the Alarm-Trip Setpoin This violation is a repeat of Violations 482/8541-01 and 482/8634-0 i l

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' . 2 ' /. : ~. ' Attachment to'WM 87-0217 Page 3 of 4

. August 21, 1987-Reason for Violation: '

L On July _ 1,- 1987, during review and revision of the Analog Channel Operational Test ( ACOT) procedures 'for the Contaimnent Purge Radiation Moni tors GT RE22 and GT RE33,. Instrumentation and Control personnel u discovered that Technical Specification 4.3.3.11 Surveill ance Requirements ( were not being completely satisfie This occurrence was reported to the l NRC as a Technical Specification violation in LER 87-029-00 on July 31, L 198 Technical Specification 4.3.3.11 requi res, in part, demonstration of -

automatic pathway isolation and control room alarm annunciation, when the Containment Purge Radiation Moni tors indicate measured levels abnve the Alarm-Trip Setpoint value, on a quarterly basis. During review and revision'

of. the ACOT procedures for GT RE22 and GT RE33, Instrumentation and Control personnel discovered that these procedures did not address verification of

, ,. automatic pathway isolatio It was then verified that this surveillance requirement was not being satisfied quarterly 'via any other surveillance procedur Investigations into - this occurrence determined that this surveillance requirement had previously been included in the ACOT procedures. In July of 1985, difficulties were encountered in the performance of these procedures because of the system lineup specified in the procedure Consequently, during a subsequent procedure revision in October of 1985, this requirement was deleted from the ACOT procedure The reason for the violation was an

. inadequate review of the procedure revisio Corrective Steps Which have Been Taken and Results Achieved:

Control Room personnel were notified of this discrepancy tnd declared GT RE22 and GT RE33 inoperable at approximately 1555 CDT. An eritry was made into Action Statement "b" of Technical Specification 3.3.3.11, which requires suspension of effluents via the affected pathway. 0n July 2,1987, portions of surveillance procedure STS GP-001, " Containment Penetration Integri ty Verification", were utilized to initiate a manual Containment  !

Purge Isolation Signal and test the circuitry not covered by the existing ACOT procedure Upon sati s fac tory completion of this testing at approximately 1336 COT on July 2, GT RE22 and GT RE33 were declared operable l

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and Action Statement 3.3.3.11 "b" was exite A new procedure is being developed to satisfy the surveillance requirement of verifying proper pathway isolation on a quarterly basi In order to prevent recurrence of this event, an enhancement has been made to the procedure change review proces This enhancement programmatically requires  !

the individual proposing to change a surveillance procedure document that j the proposed change, when incorpora ted, will continue to meet the ]

requirements of the surveillance progra l l

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I~ Attachment to WM 87-0217 Page 4 of 4 August 21, 1987 l

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

The requirement that the individual proposing to change a surveillance procedure, document that the proposed change, when incorporated, will continue to meet the Technical Speci fica tion surveillance requirements should avoid further violations of this typ Date When Full Compliance Will Be Achieved:

The enhancement has been made to the procedure change review proces The procedure under development which will satisfy the surveillance requirement of veri fying proper pathway isol ation will be issued prior to the next a quarterly performance date which is scheduled to be completed on October 2, 198 V' , .,

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