ML20034H303
| ML20034H303 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 03/11/1993 |
| From: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| WM-93-0043, WM-93-43, NUDOCS 9303170094 | |
| Download: ML20034H303 (4) | |
Text
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LF CREEK Wt)NUCLEAROPERATING CO March 11, 1993 sart o. witners ChYe'fE\\" u"t we Othee, WM 93-0043 U. S Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, D. C. 20555
References:
- 1) Letter dated February 1, 1993 from A. B. Beach, NRC, to B. D. Withers, WCNOC
- 2) Letter NA 93-0055, dated March 2, 1993, from R. C. Hagan, WCNOC, to NRC
Subject:
Docket No. 50-482: Response to Violation 482/9232-01 Gentlemen:
Attached is Wolf Creek Nuclear Operating Corporation's (WCNOC) response to violation 482/9232-01 which was documented in Reference 1.
Violation 482/9232-01 involved the failure to follow written work instructions during the removal of Spent Fuel Cooling Pump "A" inboard bearing.
In Reference 2, WCNOC requested and was granted an extension until'Fbrch 15, 1993.
This was based upon a telecon between Mr. Chris Kennedy of Region IV and Mr. Terry.L.
Riley, on March 2, 1993.
If you have any questions concerning this natter, please contact me at-(316) 364-8831, extension 4000 or Mr. Kevin J. Moles of my staff at extension 4565.
Very truly yours.
Bart D. Withers President and Chief Executive Officer BDW/jan Attachment cc:
J. L. Milhoan (NRC), w/a G. A. Pick (NRC), w/a W. D. Reckley (NRC), w/a W. D. Johnson (NRC), w/a 170049 9303170094 930311 PDR ADOCK 05000482
((6 j G
PDR PO. Box 411 i Burhngton, KS 66839 / Phone: (316) 364-8831
/
An Equal Opportunity E@ oyer M T NCVET L
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Attachment to WM 93-0043 Page 1 of 3 Reply to Notice of Violation Violation 9232-01: Failure to Properly Implement Procedure f
Failure to follow instructions.
During the implementation of Work Request 05923-92 the mechanic used a hammer instead of a bearing puller to' remove the inboard bearing from the shaft of Spent Fuel Pool Cooling Pump "A'.
Findinn:
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' Technical Specification 6. 8.1.
- requires that written procedures shall be established, implemented, and naintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, dated February l
1978.
Regulatory Guide 1.33, Appendix "A',
Item 9.a. states that maintenance affecting the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented i
instructions, or drawings appropriate to the circumstances.
j Step 2.16 of the work instructions for Work Request. 05923-92 states that the f
inboard bearing of the spent fuel pool cooling pump will be removed using a i
bearing puller or equivalent.
Contrary to the above, on December 8, 1992, while implementing Work-Request ~
i 05923-92, licensee personnel used a hammer to remove the inboard. bearing from i
the shaft of Spent Fuel Pool Cooling Pump A instead of a bearing puller.'
l Admission Or Denial Of The Alleged Violation:
WCNOC denies the-alleged violation.
Reason For Denial of The Violation:
The work instruction for Work Request 05923-92 stated:
2.16 RWO Remove inboard bearing (168A) using a bearing puller or equivalent. NEVER use a hammer to drive shaft through bearing!
The step allowed the craf t to use experience and training to select an appropriate tool to remove the bearing.
The NRC inspector had initially read this step to say that a hammer could never be used. This was clarified with the inspector during followup discussions. The step would have stated:
'NEVER use a hammer", instead of "NEVER use a hammer to drive the shaft through the bearing!*, if a hammer was an unacceptable tool for use in removing the bearing.
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Attachment to WM 93-0043 Page 2 of 3
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Performance Improvement Request (PIR) MA 93-0008 was initiated to investigate the inspector's concern, identify the root cause (if any) and to recommend corrective actions for his concern.
Based on the investigation the following was determined:
1)
The bearing was demaged during normal pump operation and further bearing f
damage was not of concern.
The bearing removal and replacement was the subject of the work instructions.
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2)
Tha work instructions stated to " Remove inboard-bearing (168A) using a l
bearing puller or equivalent. NEVER use a hammer to drive shaf t e
through bearing!" This instruction prohibits the worker from using a'
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hammer to drive the shaft through the bearing to avoid damaging the-shaft.
It does not prohibit the use of a hammer to remove an'already damaged bearing.
3)
The worker followed the work instructions and did not use a hammer to drive the shaft through the bearing.
j 4)
The worker used a brass hammer to remove the bearing. Thus, there was minimal risk in damaging the shaft.
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5)
The pump shaft was not damaged.
6)
It is WCNOC's position that the substitution of a hammer in place of a-I bearing puller was a decision within the skill-of-the-craft, and was an equivalent and acceptable alternative to using a bearing puller for this situation.
i Based on the above it was determined that the work instructions were not violated. The worker performed the bearing removal in a manner which was consistent with his~ knowledge and abilities.
i Based on interviews conducted for PIR I MA 93-0008, the following supports the conclusion that the use of a hammer in this case was within the " skill-of-the-Craft":
- 1) The Mechanical Maintenance Supervisor and the worker involved believed that
_i the instructions as written allow for the substitute method, and that the method used is within what would be considered, " good craft practice" or
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- skill-of-the-craft".
- 2) Mechanical Maintenance supervision. and the worker involved are in agreement that the method used was appropriate for the circumstances.
- 3) Three of the most senior Mechanical Maintenance Engineering instruction writers believe that the instructions were not misinterpreted and that the actions taken by the worker were appropriate.
4' Attachment to WM 93-0043 Page 3 of 3
- 4) The. methodology used ' to remove the bearing was discussed ' with the pump manufacturer.and-they concurred with the methodology used in this instance.
liowever, in an effort to prevent future work instruction interpretation.
concerns the Manager Maintenance and Modifications has issued a memo to all Maintenance Department Personnel clarifying management's expectation regarding:
1)
Expected level of detail for work instructions.
2)
. Field interpretation of work instructions.
i 3)
Using skill-of-the-craft.
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