IR 05000482/1991007
| ML20035H623 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek |
| Issue date: | 04/27/1993 |
| From: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| References | |
| NUDOCS 9305060108 | |
| Download: ML20035H623 (3) | |
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Docket: STN 50-482 License: NPF-42 J Wolf Creek Nuclear Operating Corporation ATTN: Bart D. Withers ' President and Chief Executive Officer P.O. Box 411 Burlington, Kansas 66839 , . . . SUBJECT: NRC INSPECTION REPORT 50-482/93-01. Thank you for your -letter dated February 25, 1993, which provides a , revised schedule'for the completion: of corrective actions identified.in Licensee Event Report 50-482/91-007-and response to Violation 482/9209-01. We I have reviewed your request to extend the commitment date to October 29, 1993, and find it acceptable.
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Sincerely, i j . Bill-Beach, Director , Division of Reactor Projects cc: ) l Wolf Creek Nuclear Operating Corp.
R ATTN: Otto Maynard. Director
l P1 ant Operations- .j P.O. Box 411 Burlington, Kansas 66839 I Shaw, Pittman, Potts & Trowbridge ATTN: Jay Silberg. Esq.
2300 M Street, NW
Washington, D.C.
20037 Public Service Commission ATTN: C. John Renken Policy & Federal Department ' P.O. Box 360-t Jefferson City, Missouri 65102 'O { 93050'0108 930427 k'
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- .- . . . Wolf ' Creek Nuclear Operating-2-Corporation U.S. Nuclear Regulatory Commission ATTN: Regional Administrator, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Wolf Creek Nuclear Operating Corp.
ATTN: Kevin J. Moles Manager Regulatory Services P.O. Box 411 Burlington, Kansas 66839 Kansas Corporation Commission ATTN: Robert Elliot, Chief Engineer Utilities Division 1500 SW Arrowhead Rd.
Topeka, Kansas 66604-4027 Office of the Governor State of Kansas Topeka, Kansas 66612 Attorney General 1st Floor - The Statehouse Topeka, Kansas 66612 Chairman, Coffey County Commission , Coffey County Courthouse Burlington, Kansas 66839-1798 . Kansas Department of Health l and Environment ' Bureau of Air Quality & Radiation Control ATTN: Gerald Allen, Public , Health Physicist i Division of Environment Forbes_ Field Building 321 Topeka, Kansas 66620 Kansas Department of. Health and Environment ATTN: Robert Eye, General Counsel LSOB, 9th Floor 900 SW Jackson , l Topeka, Kansas 66612 t . . .-- . -
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. l i LF CREEK W@ NUCLEAR OPERATING i February 25, 1993 Bart D Withers WM 93-0030 President and CNef Executive otheer U. S. Nuclear Regulatory Comission ATTN: Document Control Desk Mail Station F1-137 Washington, D. C.
20555 Reference: 1) Letter NO 91-0169 dated June 21, 1991 from J.
A.
Bailey, WCNOC to U. S. Nuclear Regulatory Comission 2) Letter NO 92-0079 dated March 27, 1992 from J.
A.
Bailey, WCNOC to U.
S. Nuclear Regulatory Comission 3) Letter WM 92-0136 dated August 21, 1992 from B. D.
Withers, WCNOC to U.
S. Nuclear Regulatory Comission Subject: Docket No. 50-482: Revised Schedule for Completion of Corrective Action on IST Valve Program / Procedures Upgrade Gentlemen: The purpose of this letter is to provide a revised schedule for the completion of corrective actions identified in Licensee Event Report (LER) 482/91-007-00 and Response to Violation 482/9209-01.
Reference 1 transmitted LER 91-007-00 concerning an inadequate inservice testing (IST) procedure used to perform certain valve testing at Wolf Creek Generating Station (WCGS).
Reference
transmitted Response to Violation 9209-01 concerning inservice testing of an ASME Code Class 2 pump contrary to the requirements of Technical Specification 4.0.5.
BACRGROUND As part of the corrective actions associated with these events, Wolf Creek Nuclear Operating Corporation (WCNOC) committed to undertake a complete technical review of IST procedures to ensure their technical adequacy and compliance with the ASME Code.
LER 91-007-00 made the original comitment to review and revise IST procedures as necessary to meet the requirements of Nuclear Regulatory Comis sion (NRC) Generic Letter (GL) 89-04.
Specifically, WCNOC committed to review procedures for refueling IST activities prior to the fifth refueling outage and to complete the review of other IST procedures by March 31, 1992.
The review of and necessary changes to refueling IST procedures were completed as scheduled prior to the beginning of the fifth refueling outage in September, 1991.
However, the schedule for the review and procedure changes of the remaining IST procedures was delayed and a revised schedule for completion of the comitment was submitted by Reference 2.
This revised schedule stated that review of IST pump procedures would be completed by March 31, 1992, with the necessary procedure changes being' ,ompleted by May 31, 1992.
This revised s 'V V , N 3 N' k PO. Box 411 Burhngton. KS 66839 Phone. (316) 364-8831 g)[[ An Equal opportunity Employer M F HC VET d A
. ___ . , . . . WM 93-0030 Page 2 of 4 schedule also stated that the review of IST valve procedures would be . completed by December 31, 1992, with the necessary procedure changes being completed by February 28, 1993.
In Response to Violation 9209-01 all commitments associated with LER 91-007-00 and Inspection Report 482/92-09 were consolidated and a date of March 1, 1993, was set to complete all actions associated with the IST program upgrade, f REASONS FOR EXTENSION OF CODMITMENT DUE DATE l ' The review of the IST pump procedures was completed by March 31, 1992, and the necessary procedure changes were completed by May 31, 1992.
Currently, there are approximately 90 IST procedures which require valve testing.
All of these procedures have been reviewed against the l requirements of GL 89-04 and the appropriate revisions have been , drafted.
Approximately two-thirds of the IST valve procedures are in the final review and approval process. However, these procedures cannot be finalized until Pump and Valve Inservice Testing Program Relief Request VR-24, which proposes the adoption of ASME/ ANSI OMa-1988, Part 10 in place of Section XI IWV, is approved by the NRC.
ASME/ ANSI OMa.
1988, Part 10 incorporates later industry provisions for valve testing ' and is considered by WCNOC to be a better method of testing than Section XI IWV.
Since the valve procedures were being rewritten and WCNOC will be required to adopt the provisions of ASME/ ANSI OMa-1988 Part 10 by 1995, a decision was made to make the necessary changes to meet the requirements of GL 89-04 and adopt the provisions of ASME/ ANSI OMa-1988, l ! Part 10 at the same time.
By combining the two efforts, the valve procedures will not have to be revised twice and the IST Program should be improved with the use of ASME/ ANSI OMa-1988 Part 10 prior to 1995.
Per discussions with the NRC Project Manager, Mr. William Reckley, it is expected that Relief Request VR-24 should be approved by February 26, 1993.
Following approval of the relief request, the IST valve procedures will be finalized and will include all upgrades to GL 89-04 and ASME/ ANSI OMa-1988, Part 10.
An IST Design Basis Document, which identifies the testing requirements for each component and the basis for inclusion or exclusion in the IST , Program, is in draft version and has been distributed within WCNOC for technical review.
The IST Design Basis Document is being developed based on recommendations by an engineering consulting firm to improve the IST program.
This document has been built on a computer database and is fully functional at this time.
It is taking longer than and at originally anticipated to complete the IST Design Basis Document this point it is not anticipated that all of the reviews and incorporation of comments will be completed by March 1, 1993.
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i - WM 93-0030 Page 3 of 4 An IST Design Basis review has identified an open items list which includes possible additions or deletions that could be made to improve i the IST program.
The IST Design Basis review open items must be ! completely addressed before the IST program upgrade can be considered complete.
There are approximately 200 additional testing requirements which will be addressed and the results will be documented.
Following the sixth refueling outage, the IST Design Basis review open items list will be reviewed in detail to determine if changes need to be made to the scope of testing in the IST program.
If changes are determined necessary, additional testing requirements will be added to existing procedures or new procedures will be required to be written.
The possible changes to the program are considered enhancements.
Procedure ADM 05-200, "ASME Code Testing of Pumps and Valves," is being revised and is in the final review and approval process.
Procedure ADM i 05-200 is being revised to incorporate improvements identified in i WCNOC's self assessment as well as NRC and INPO audits.
However, as ! with the IST valve procedures, procedure ADM 05-200 cannot be finalized until Relief Request VR-24 is approved by the NRC.
, IMPACT OF DUE DATE EKTENSION The review of all procedures _ to the requirements of NRC GL 89-04 has been completed and no outstanding immediate safety concerns are present in the IST program.
The changes to the IST valve procedures are improvements and the delay of issuance does not impact plant safety or affect compliance with Technical Specification 4.0.5 or ASME Section XI.
! The possible changes to the IST program based on the actions developed from the IST Design Basis review open items list are considered enhancements.
REVISED Cole (ITHENT DUE DATE Because of the additional work of adopting ASME/ ANSI OMa-1988, Part 10 and the other factors discussed above, rescheduling completion of the IST program upgrade is necessary.
The IST program upgrade, which includes revising IST valve procedures and ADM 05-200, finalization of r ' the IST Design Basis Document, and review and incorporation of the IST Design Basis review open items list, will be completed by October 29, i 1993.
, ,
.. ._ . . . .. _ . . . . . . WM 93-0030 ,.
Page 4 of 4 , t If you have any questions concerning this' matter, please contact me at (316) 364-8831, extension 4000 or Mr. Kevin J.
Moles of my staff at extension 4565.
{ Very truly yours,
i Bart D. Withers- ! President'and Chief Executive ' Officer
, BDW/jan ! t t cc W. D. Johnson (NRC) J. L. Milhoan (NRC) G. A. Pick (NRC) l ? W. D. Reckley (NRC). ! ( t
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