IR 05000482/1993019
| ML20057E086 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 09/29/1993 |
| From: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Carns N WOLF CREEK NUCLEAR OPERATING CORP. |
| References | |
| NUDOCS 9310070259 | |
| Download: ML20057E086 (4) | |
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i th" "f Cu UNITE D ST ATES l
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NUCLEAR REGULATORY COMMISSIOrd
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REGION IV
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AR LINGTON, T E XAS 76011-8064
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SEP 29 l92 i
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l Docket:
STN 50-482 i
Iicense: NPF-42
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Wolf Creek Nuclear Operating Corporation i
ATTN: Neil S. Carns, President and
Chief Executive Officer i
P.O. Box 411 Burlington, Kansas 66839 l
l SUBJECT:
NRC INSPECTION REPORT 50-482/93-19
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l Thank you for your letter dated September 15', 1993, in response to our
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letter and Notice of Violation dated August 16, 1993. We'have reviewed your
reply and find it responsive to the concerns raised in our Notice of.
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Violation. We wW review the implementation of your corrective actions
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during a future inspection to determine that full compliance has been' achieved i
and will be maintained.
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Sincerely,
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l A. Bill Beach, Dir et r L
Division of React roj c l-cc:
Wolf Creek Nuclear Operating Corp.
ATTH: Otto Maynard, Vice President Plant Operations P.O. Box 411-(
Burlington,-Kansas 66839 i
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Shaw, Pittman, Potts & Trowbridge l
ATTN: - Jay Silberg, Esq.
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2300 N Street,.NW Washington, D.C.
20037 n t.11 R'
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5000482
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Wolf Crbek Nuclear Operating-2-
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Public Service Commission ATTN:
C. John Renken
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Policy & Federal Department P.O. Box 360
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Jefferson City, Missouri 65102 U.S. Nuclear Regulatory Commission ATTN:
Regional Administrator, Region III l
799 Roosevelt Road Glen Ellyn, Illinois 60137
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l Wolf Creek Nuclear Operating Corp.
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ATTN: Kevin J. Moles Manager Regulatory Services
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P.O. Box 411 l
l Burlington, Kansas 66839
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l Kansas Corporation Commission
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ATTN:
Robert Elliot, Chief Engineer Utilities Division
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1500 SW Arrowhead Rd.
Topeka, Kansas 66604-4027 Office of the Governor State of Kansas Topeka, Kansas 66612 i
Attorney General 1st Floor - The Statehouse Topeka, Kansas 66612
Chairman, Coffey County Commission Coffey County Courthouse Burlington, Kansas 66839-1798
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Kansas Department of Health and Environment Bureau of Air Quality & Radiation Control ATTN:
Gerald Allen, Public l
Health Physicist Forbes eld Bui di g 2 Topeka, Kansas 66620
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Wolf Creek Nuclear-3-Operating Corporation i
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J. L. Milhoan Resident Inspector l
Section Chief (DRP/A)~
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Section Chief (RIII, DRP/3C)
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Lisa Shea, RM/ALF, MS: MNBB 4503 Project Engineer (DRP/A)
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a WQLF CREEK NUCLEAR OPERATING CORPORATION
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i September 15, 1993 V {p t -7 v q Neil S. " Buzz' Carns q
I I President and WM 93-0115 chief Executive Otheer l
U. S. Nuclear Regulatory Ccmmission ATTN:
Document Control Desk Mail Station Pl-137 Washington, D.
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20555 Reference: Letter dated August 16, 1993 from A. B.
Beach, NRC, to
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N.
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Carns, WCNOC l
Subject:
Docket No. 50-482:
Reply to Notices of Violation 482/9319-01 and 9319-03
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Gentlemen:
Attached is Wolf Creek Nuclear Operating Corporation's (WCNOC) " Reply to Notices of Violation 482/9319-01 and 482/9319-03" which were doewmented in the Reference (NRC Inspection Report 50-482/93-19),
Violation 482/9319-01 concerns two exanples of failure to follow radiological protection procedures.
Violation 482/9319-03 concerns inadequate work instructions for installation of a new disc in Containment Spray Pump
"B" Discharge Isolation Valve ENHV0012 which resulted in profuse leakage during post maintenance testing.
The NRC identified both incidents as Severity Level IV violations.
If you have any questions concerning this matter, please contact me at (316)
364-8831 ext. 4000 or Mr. K.
J. Moles of my staff at ext. 4565.
Very truly yours,-
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Neil S. Carns President and Chief Executive Officer NSC/jad Attachment ec:
W.
D.
Johnson (NRC), w/a J.
L. Milhoan (NRC), w/a G. A.
Pick (NRC), w/a W. D. Reckley (NRC), w/a M. A.
Satorius (NRC), w/a h
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RO. Box 411/ Burhngton, KS 66839 / Phone: (316) 364-8831
"/ " U 7N gf An Equal Opportunity Employer M/F/HC/ VET
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Attachment to WM 93-0115
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Reply to Notice of Violations 482/9319-01 and 482/9319-03 i
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l Violation 482/9319-01:
Failure to Follow Procedures: Two examples of failure to follow radiological protection procedures.
Findings:
Technical Specification 6.8.1.a states that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, dated February
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Regulatory Guide 1.33, Appendix A,
Item 7.e. (1) requires radiation protection precedures for access control to radiation areas, and Item 7.e.(2)
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requires procedares for radiation surveys.
These are accomplished, in part, by Procedure RPP 02-215, " Posting of Radiological Controlled Areas," Revision 7,
and Procedure RPP 02-205, " Radiological Survey Frequency Requirements,"
Revision 2.
1. Procedure RPP 02-215, Step 9.1.2, specifies, in part, that posted radiation areas must be clearly and conspicuously marked at all accessible sides and entrances.
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l Contrary to the above, on July 13, 1993, workers removed a posting sign that identified a radiation area in the radiological restricted area.
The area where the posting was removed was the east truck bay door in the south truck bay of the radioactive waste building.
2. Procedure RPP 02-205, Step 9.1, specifies, in part, that Procedure 02-205, Attachment 11.1, will be used to document the performance of routine daily f
radiation surveys.
Further, Procedure RPP 02-205, Attachment 11.1 states,
in part, that the radiological survey status boards will be updated following the completion of daily surveys.
Contrary to the above, on July 13, 1993, NRC inspectors identified that the radiological survey status board for the radioactive waste building had not been updated since June 22, 1993.
Admission of Violation:
WCNOC agrees that in both cases a violation of Technical Specification 6.8.1.a occurred. However, root cause investigation concluded that the second example of this violation occurred also as a result of inadequate procedure guidance rather than just a failure to follow procedures.
Also, Health Physics personnel conducting radiological area surveys should have been more alert to the need for updating the status board.
I Reason for Violation:
1. As noted by the NRC Inspector, the barrier and posting sign at the truck bay door were removed to facilitate disassembly and removal of scaffolding.
Investigation revealed that the work crew had moved the barrier without contacting Health Physics personnel.
The workers had received proper radiation worker training and were knowledgeable of posting requirements.
They are considered by Health Physics personnel to have a high regard for radiation protection practices and procedures.
This occurrence is considered to be an isolated case of exercising poor judgment rather than willful disregard of proper radiation protection guidelines.
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l Attachment to WM 93-0115 Page 2 of 7
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2. On May 12, 1993, a radiation area was posted outside the Radiological Waste Building due to processing of spent resin within the truck bay.
The truck br v itself was a high radiation area.
These postings were properly ret ^cted on the Radiological Status Board.
On June 17, 1993, the processing was complete and the truck bay area was reduced to a radiation area.
The outside area was surveyed the same day (a routine monthly radiological survey) and remained posted as a radiation area as well.
The status board was again appropriately updated.
On June 23, 1993, spent resin shipment 93C47 was prepared and sent out.
The contaminated area posting at the process shield and the outdoor radiation area posting were taken down, and the radiation area posting was placed across the truck bay rollup door.
No update was made to the status board.
This was the condition until the time of the NRC Inspector's tour on July 13, 1993.
The root cause for not keeping the Radiological Status Board updated was determined to be more a matter of inadequate procedural guidance rather than just a failure to follow procedures. The Health Physics department is comprised of several groups including the operations group and the radwaste group.
The responsibility for keeping the status board updated belongs to
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the designated "HP Senior Technician" (or the " Shift Technician" on back shifts) who is a member of the operations group.
This responsibility is found in procedure RPP 01-120, Revision 2,
" Health Physics Shift Logs and Shift Turnover," Step 9.5.5.
Routine surveys as described in RPP 02-205, Revision 2,
" Radiological Survey Frequency Requirements," are performed by the operations group and reviewed by the Shift Technician who forwards the results to the HP Supervisor Operations. The area outside the. Radiological Waste Building was surveyed on June 17, 1993, on the routine monthly
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schedule and was determined to still be a radiation area.
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radiological conditions was noted on a job related (special) survey performed by a radwaste group technician or. June 23, 1993. This survey was verified by the HP Supervisor Radwaste and placed in the shipment file.
The routine monthly survey was not performed again until July 19, 1993, six
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days after the inspector's tour.
There was no procedural requirement for a copy of the special survey to be routed to the HP Senior Technician, and it was not done.
Thus, the status board was not updated as required.
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Corrective Steps Taken and Results Achieved:
1. Immediate corrective actions were taken upon being made aware of the condition including restoration of the radiation area barrier tape and posting sign.
The work crew involved and their. foreman were counseled by
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Health Physics supervision about contacting Health Physics personnel when i
needing radiological postings removed to facilitate work efforts.
Performance Improvement Request (PIR)-TS 93-0705 was also initiated on July l
13, 1993, to document and investigate the occurrence under WCNOC's
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Corrective Action Program.
In addition, PIR TS 93-0705 has been placed in
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required reading for all Maintenance personnel.
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Health Physics professional staff and management routinely tour the Radiologically Controlled Area to verify implementation of appropriate radiological practices.
These tours have indicated no recurring problems
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or negative trends in the area of postings.
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At,tachment to WM 93-0115 Page 3 of 7 2. Immediate corrective actions were taken upon being made aware of the condition by updating the Radiological Status Board.
The status board was verified to be correct as of 1830 CDT on July 13, 1993.
Performance Improvement Request (PIR) TS 93-0705 was initiated on July 13, 1993, to document and investigate the occurrence under WCNOC's Corrective Action Program.
Procedure change MI 93-1065 was initiated to procedure RPP 02-210,
" Radiation Survey Methods," Revision 5, and approved on August 12, 1993.
This change requires all Health Physics Technicians to update the status board when conditions warrant and to forward a copy of surveys which affect the status board to the Shift Technician.
In addition, this event has been discussed with all Health Physics Supervisors.
Even though procedural guidance was lacking, personnel conducting surveys should have been more alert to the need for updating the status board.
Supervisors are ensuring that personnel conducting surveys understand the requirement to reflect accurate survey posting data.
i Corrective Steps That Will Be Taken to Avoid Further Violations:
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The corrective actions described above are considered -appropriate and sufficient to avoid further violations.
Therefore all corrective actions are complete.
Date When Full Compliance Will Be Achieved:
1. Corrective actions were completed on July 13, 1993, with completion of counseling the work crew involved and their foreman.
2. Corrective actions were completed on August 12, 1993, with the issuance of procedure change MI 93-1065.
Actual or Potential Consequences of This violation:
WCNOC recognizes that the primary concern in this matter is that failure to properly maintain radiation area postings and survey maps could lead to i
unnecessary increases in personnel radiation exposure.
The Radiological Status Board is used for general information purposes and is not a primary mechanism for radiological exposure control.
It should be noted that the incorrect information indicated a more restrictive condition than actually existed.
The failure to maintain a radiation area posting is of much greater l
concern.
However in this case, the posting was down for a relatively short period, the workers involved knew that it was a radiation area, and no overexposure or unexpected exposure occurred.
This has also been shown to be an isolated case Thus, there was never a condition in which the heaJth and j
safety of the puk
'er of plant personnel were not assured.
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.Attachm2nt to t?M 93-0115 Page 4 of 7 i
Violation 482/9319-03:
Inadequate Work Inst ructions :
Inadequate work
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instructions resulted in excessive seat leakage during post maintenance testing.
Findings:
Technical Specification 6.8.1.a states that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, dated February 1978.
Regulatory Guide 1.33, Appendix A, Item 9.a, requires that maintenance that affects the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.
This is accomplished, in part, by Procedure ADM 01-057, " Work Requests," Revision 26.
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Step 7.16 of Procedure ADM 01-057 specifies, " Develop work instructions in sufficient detail necessary to perform safe and effective work."
Contrary to the above, the work instructions in. Work Request 00758-93 for Valve ENHV0012, Containment Spray Pump B discharge isolation valve, did no_t
include sufficient instructions to properly perform the valve disc replacement.
The instructions provided no information about the disc being supplied oversized and requiring machining.
This resulted in Valve ENHV0012 leaking profusely during post maintenance testing on March 30, 1993.
Admission of Violation:
WCNOC agrees with the NRC violation as stated above.
Reason for Violation:
Weak-link calculations by the Motor uperated Valve (MOV) group indicated that the " ears" that hold the disc to the stem on Containment Spray Pump
"A" and
"B" discharge isolation valves, ENHV0006 and ENHV0012 respectively, were the weak-link.
To increase the margin of safety, Engineering issued Plant Modification Request (PMR) 04439 to replace these discs with an improved design. New discs were ordered from Anchor-Darling to be installed during the sixth refueling outage.
The disc in ENHV0012 was replaced first under Work Request (WP 00758-93.
The disc is not a. common replacement item and is not identifie sa recorn oded spare part by the vendor manual.
Disc replacement is also
.o t covered in the vendor manual, which is heavily relied on by Maintenance
.n preparing work instructions.
Maintenance also believed that, because the disc was ordered i
using the same part number, specifications, and drawing, the disc seating surfaces would match and no machining would be necessary.
This knowledge-based oversight, due to a lack of reference information on the replacement parts, is considered to be the root cause in this event.
During subsequent investigation and discussion with Anchor / Darling personnel, j
Technical Advisory which addresses it was learned that Anchor / Darling has a special manufacturing provisions for certain replacement parts to ensure they j
can be field fitted.
This advisory, TA-118, first issued November 8,
1983,
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states that flex wedge discs are supplied with an additional 1/32 inch j
material per face.
This is an Anchor / Darling internal document and was never formally transmitted to WCNOC until requested in this investigation.
It was f axed to WCNOC on August 26, 199 *
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At,tachment to WM 93-0115 Page 5 of 7 Consideration was also given to the question of whether the use of a blue-check to verify the fit of the new valve disc should have been included in the work instruction or considered skill of the craf t.
Blue-checking the fit is an excellent practice which should be standard for any work that may affect the seating surfaces.
However, the practice is normally used for final fitting associated with the repair of seating surfaces to remove nicks, scratches, or pits, or to fix leak-by conditions rather than rough sizing of a disc. This is true in procedure MGM MOOC-ll, " Valve Lapping," Revision 4, the vendor manual, and a brief review of past work requests.
Had Maintenance been
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aware the disc was supplied oversized, the work instructions would have called l
for rough sizing (machining) and then a blue-check and lapping sequence.
Because they believed the replacement disc to be an exact fit, blue-checking
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was not considered. Craft personnel inspected both the seat and the new disc.
l As no defects were found, they did not question the absence of blue-check j
instructions.
The ndndset of Maintenance ano craft personnel to consider l
blue-checking an activity associated only with lapping and repair of old discs l
is considered a contributing factor to this occurrence.
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The new disc was installed in ENHV0012 with no difficulty.
During replacement i
of the disc in ENHV0006, it was discovered that the disc was oversized and would not fit.
Maintenance personnel contacted the MOV group to see if they~
had any additional information that would help in identifying the problem. An Anchor / Darling representative was on site who was familiar with the manufacturer's standard (procedure), FES-15, on fit-up of replacement wedge
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discs.
He had this document faxed to the MOV team on March 29, 1993.
This document states that the discs are generally furnished with additional hardfacing to allow fit-up with the valve body by machining.
Consideration
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was given to he potential of a fit-up problem on ENHV0012, but reassembly had been accomplished with no difficulty and the valve was being set up for differential pressure (DP) testing to determine leak rate.
Therefore, based on this review, a conscious decision was made to continue with the test to see if it was acceptable.
When Containment Spray Pump
"B" was started in accordance with test procedure TP TS-90, "ENHV0012 MOV DP Test," Revision 0, excessive leakage (1000 gpm) was observed with the valve indicating a closed position.
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Corrective Steps Taken and Results Achieved:
The differential pressure test was immediately stopped when the high leak rate was observed. The old disc was reinstalled in ENHV0012 under WR 02055-93 with as necessary.
Subsequent DP testing was instructions to lap and blue-check satisfactory. The problem was initially thought to be a procurement issue and documented and investigated under Commodity Discrepancy Report (CDR) 93-was 0237.
The NRC tracked it as Unresolved Item URI 482/9308-01.
When that l
investigation showed that the discs were supplied in accordance with standard l
Anchor / Darling practices, PIR MA 93-0790 was initiated to investigate the root I
cause and document corrective actions.
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Attachment to WM 93-0115 Page 6 of 7
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WCNOC vendor manuals are periodically updated per the guidance in Generic Letter 90-03.
Anchor / Darling manual M-225-00019 has been revised twice since 1983 without incorporating Technical Advisory TA-ll8.
The advisory is
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considered an internal Anchor /Da rling document and therefore was not made available to WCNOC when the revisions were made.
Discussions with Anchor / Darling indicated that this information was not provided to WCNOC because supplying oversized valve discs, requiring nachining, lapping, and blue checking, was considered standard practice and did not warrant industry notification.
No apparent deficiencies were discovered in the vendor manual program.
However, because 12cportant information was not available to Maintenance, PIR SE 93-0945 was initiated to determine if the Industry Technical Information Program (ITIP)
should have included this information.
Subsequent investigation concluded that there are no mechanisms to ensure information of this nature will be consistently provided to WCNOC for inclusion into the ITIP.
It was therefore determined that no changes to the program are necessary.
The Supplemental Work Instructions data base used by Maintenance planners has been revised to show dimensional checks and blue-checking as a standard'
instruction when work is to be performed which will affect the seating surfaces, including new disc or seat parts.
This update was completed on September 7, 1993.
In order to heighten personnel awareness of this issue and reinforce the need to maintain a questioning attitude and attention to detail, PIR MA 93-0790 was
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issued to all Maintenance and craft personnel on September 9, 1993.
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discussions were held with Maintenance personnel discussing the contents of PIR MA 93-0790.
Co*rective Steps That Will Be Taken to Avoid Further Violations:
Wolf Creek Equipment Engineering requested additional information from Anchor / Darling regarding how much overlay material (stellite) is on the disc seating surfaces, fit up of the disc guides, and whether this type disc can be installed without machining.
The Anchor / Darling response was received on August 24, 1993.
This information, the Anchor / Darling Technical Advisory TA-118, and Anchor / Darling Standard FES-15 will be incorporated into vendor
manual M-225-00019 by September 30, 1993.
Because the Maintenance planning staff that writes work instructions refers to the vendor manual or supplemental work instructions data base, this will minimize similar knowledge-based errors in the future.
Incorporation of this information into a WCNOC procedure was considered but not deemed necessary due to the limited use and narrow scope such a procedure would have.
Training to refamiliarize Maintenance personnel on the topic of this violation will be offered as a followup to corrective actions associated with this i
violation.
This will involve including PIR MA 93-0790 in the next presentation of the Plant and Industry Events class (ES 13 108 00)
for Maintenance personnel and the Maintenance Concerns class (MM 13 108 01) for mechanical craf t personnel.
This training will emphasize the need to blue-check valves of this or similar type when any work activity is performed which affects the seating surfaces.
Craft training will be completed by December 10, 1993, and engineering support training will be completed before the seventh refueling outage. "'
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. Attachment to WM 93-0115 Page 7 of 7
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Date When Full Compliance Will Be Achieved:
With the issuance of required reading coupled with group discussions, and l
l revision of the Supplemental Work Instructions data base, full compliance has
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been achieved.
Actual or Potential Consequences of This Violation:
l The installation of the oversized disc in ENHV0012 resulted in failure of the
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initial differential pressure test, which in turn identified the problem.
Following any similar valve disassembly, some form of post maintenance testing would be required before returning the system or component to operable status which would identify such a problem. Also, the reactor core was off loaded at this time (Mode El and operability of the Containment Spray System was not
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required.
Therefore, there was never a condition in which public health 'and safety or plant safety were compromised.
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Wolf Creek Nuclear-3-Operating Corporation bec_to DMB (IE01).
bec"distrib. by RIV:
J. L. Milhoan Resident Inspector Section Chief (DRP/A)
DRSS-FIPS
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Section Chief (RIII, DRP/3C)
RIV File i
SRI, Callaway, RIII MIS System Lisa Shea, RM/ALF, MS: MNBB 4503 Project Engineer (DRP/A)
Section Chief (DRP/TSS)
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