ML20012D991

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Responds to NRC Re Violations Noted in Insp Rept 50-482/90-02.Corrective Actions:Procedure CNT-660, Rigging Revised to Incorporate safety-related Manway Covers Which May Be Removed W/O Addl Safety Evaluation
ML20012D991
Person / Time
Site: Wolf Creek 
Issue date: 03/22/1990
From: Withers B
WOLF CREEK NUCLEAR OPERATING CORP.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
WM-90-0069, WM-90-69, NUDOCS 9003290193
Download: ML20012D991 (2)


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j LF CREEK W4) NUCLEAR OPERATING tortD Wilhore Prees n:an cw me aom 4

f March,22,L1990 A,

yM 90-0069L y

.U.' S. Nuclear _ Regulatory Commission

' ATTN: Document Control' Desk-Mail Station P1-137 Washington', ~ D. 'C.: 20555

Reference:

Letter dated February 20, 1990- from S. J. Collins, NRC, o

to B. D. Withers, WCNOC:

Subjects.

Docket No. 50-482: Response to Violation 482/9002-

~01'and=02:

Gentlemen:

Attached is Wolf Creek Nuclear Operating Corporation'_s -(WCNOC)-fraponse 'to

-violation 482/9002-01 and-_02 which.were documented:: in the' Reference.

Violation-482/9002-01 involved:the. failure to perform _.a safety _ evaluation.

m Landz violation _.- 482/9002-02 involved inadequate corrective action on chainfalls.

3 If you'have any questions,concerning this' matter,

.please ' contact me or Mr. H. K. Chernoff of my staff.

Very truly yours,~

Bart D. Withers President and Chief Executive Officer BDW/jad Attachment cc R. D. Martin (NRC), w/a D. Persinko (NRC), w/a f

p D. V. Pickett (NRC), w/a i

M. E. Skow (NRC), w/a 9003290192 900 2C 2 PDR ADOCT 0 5 0(? O 4 8 1

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P.O. Sex 411/ Burhngton, KS 66839 / Phone: (316) 364 8831

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1 Attachment to WM 90-0069 Page.l of 2 A

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i Violation'(482/9002-01) - Failure to Perform a Safety Evaluation-l L

.Findinni j

LTitle 10 CFR Part 50.59,: paragraph (b)(1), requires, 'in part,- that records.

of changes must include a written-safety evaluation which provides the. bases for: the detennination that. the change does not involve an unreviewed safety -

c question.

Contrary to the above, on January 2, 1990, the.inspectorsLidentified that.

the licensee temporarily removed.a missile shield to one of two trains of essential service water, which constituted a change to. the ;facilityf=as described in the safety' analysis report, without first performing a written safety evaluation.

This is a repeat of a previous violation (482/8907-01).

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-Reason For Violations a

Removal and' reinstallation of the "A" train Essential Service Vater valve-

-pit-manway cover was accomplished under Work Request 05117-89.

This action resulted in a change to the facility as described in the-Wolf Creek Generating Station Updated Safety Analysis Report in that the manway cover has a design function of a missile barrier-Performing this-action without performing the necessary safety evaluation was due to a' failure of personnel to realize that this activity constituted.

a change to the facility.

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,1 Corrective Steps Which Have'Been Taken And Results Achieved:

Procedure CNT-660,

" Rigging' has been revised to incorporate safety-related a

manway. covers which may be. removed without an additional safety evaluation 4

as.the safety evaluation performed for the procedure revision identified that no unreviewed safety question exists.

This procedure revision and safety evaluation was reviewed by the Plant Safety Review Committee.

H Corrective Steps Which Will Be Taken To Avoid Further Violations The identification of specific safety-related manways covers, that may-be

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removed in accordance with CNT-660,

" Rigging" provides the required safety evaluation for pulling these manways.

Date When Full Compliance Will Be Achieved:

Full compliance has been achieved.

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Attachment to WM 90-0069 iPage 2.of 2' 1

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i Violation (482/9002-02):

Inadeauste Corrective' Action on Chainfalls J

Findinns

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' Title.10 CFR'Part-50, Appendix B, Criterion XVI ' Corrective Action' states,;

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in part, that in the case of significant conditions adverse to-quality, the j

i measures shall assure-that the cause of-the condition is determined'and corrective action taken to preclude repetition.

1 Contrary to the above, on January 12, 1990, the-inspectors identified a 1

repeat condition adverse to quality for which inadequate corrective action 1

had been taken in that the inspectors observed a'chainfall tied off to the l

fuel oil supply line to

'B' Diesel Generator,-

a. condition potentially affecting the operability of the diesel generator, which was the repeat of.a condition-identified to the licensee on March 7, 1988.

Reason For~ Violation:

Previous corrective actions have been ineffective in providing positive controls as these actions were directed primarily at. specific. situations while overall programmatic controls were not fully addressed.

Corrective Steos Which Have Been Taken And Results Achieved:

The hoist--pull chains observed to be tied off to-the fuelioil supply line

B' Diesel Generator-was. removed-and-tied ?off. at a hook provided.

Operations-personnel. inspected other: areas. of the plant to correct any.

similar problems.

'i Corrective Steos Which Will Be Taken To Avoid Further Violations:

A written communication describing the correct use and storage of r

cranes / hoists will be distributed to appropriate plant personnel by April 6

-1990.

Procedure ADM 01-110,

' Housekeeping Control' requires periodic

= inspections to assure adequacy of housekeeping practices.

The Housekeeping Inspection-Record will be revised by April 20, 1990 to include a check for proper securing of hoist pull chains.

As an additional enhancement, permanent tie-offs and signs will be provided,'

as practicable, to remind personnel to properly secure the hoist pull chains 4

upon completion of work activities. The watchstation log and reading. sheets will be revised to include the checking of hoist pull chains by operations personnsl.

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Date When Full Compliance Will Be Achieved:

Full compliance will be' achieved by August 1, 1990.

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