ML20035B769
| ML20035B769 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 03/26/1993 |
| From: | Jonathan Montgomery NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| References | |
| NUDOCS 9304050093 | |
| Download: ML20035B769 (5) | |
Text
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pQCEGo UNITED STATES y_
a NUCLEAR REGULATORY COMMISSION E D 'n ( ' I REGION IV o
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611 RYAN PLAZA ORIVE, SUITE 400
?, 's g( jf AR UNGTON, TEXAS 76011-8064
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MAR 261993 Docket:
STN 50-482 License: NPF-42 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 50-482/92-32 RESPONSE Thank you for your letter of March 15, 1993, in response to our letter and Notice of Violation dated February 1,1993.
Your response indicated that the instructions for removing the bearing from the shaft of a spent fuel pool cooling pump allowed the craft to use experience and training to select an appropriate tool to remove the bearing.
In addition, your response stated that the bearing was damaged and was being replaced, so further bearing damage was not of concern. The worker used a brass hammer to remove the_ bearing, and the pump shaft was not damaged during the bearing removal.
Your response noted that the bearing removal methodology used has been discussed with the pump manufacturer and that they concurred that the methology was appropriate in this instance.
While we do not consider a brass hammer to be a normally acceptable
" equivalent" substitute for a bearing puller, the fact that the bearing was already damaged indicates that the method used to remove the bearing was acceptable in this instance and that this decision was within the skill of the craft.
In view of this, we have concluded that there was no violation of Technical Specification 6.8.1.a.
Sincerely,
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' dofn"M. Monte morv y \\
Deputy Regional AdminTstrator cc:
Wolf Creek Nuclear Operating Corp.
ATTN: Otto Maynard, Director Plant Operations P.O. Box 411 Burlington, Kansas 66839 I
9304050093 930326 h
PDR ADOCK 0500 2
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Wolf Creek Nuclear Operating [
Corporation i
Shaw, Pittman, Pot'e & Trowbridge l
ATTH: Jay Silberg, Esq.
i 2300 M Street, NW Washington, D.C.
20037 Public Service Commission i
. ATTN:
C. John Renken Policy & Federal Department P.O. Box 360 Jefferson City, Missouri 65102 U.S. Nuclear Regulatory Commission i
ATTN:
Regional Administrator, Region III l
799 Roosevelt Road Glen Ellyn, Illinois 60137 j
Wolf Creek Nuclear Operating Corp.
ATTN: Kevin J. Moles Manager Regulatory Services P.O. Box 411 Burlington, Kansas 66839 i
Kansas Corporation Commission
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ATTN: Robert Elliot, Chief Engineer Utilities Division 1500 SW Arrowhead Rd.
1 Topeka, Kansas 66604-4027
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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 66B39-1798 Kansas Department of Health and Environment Bureau of Air Quality & Radiation Control ATTN: -- Gerald Allen,- Public Health Physicist Division of Environment forbes Field Building 321 Topeka, Kansas' 66620 f
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Wolf Creek Nuclear Operating 3.
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Kansas Department of Health and Environment ATTN:
Robert Eye, General Counsel 0
LSOB, 9th Floor 900 SW Jackson
- c Topeka, Kansas 66612 i
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Wolf Creek Nuclear Operating IMR 2 61993 Corporation ErcEt61ons:(IE01)?]
bcc distrib. by RIV:
J. L. Milhoan Resident Inspector Section Chief (DRP/A)
DRP DRSS-FIPS Section Chief (RIII, DRP/3C)
RIV File SRI, Callaway, RIII MIS System Lisa Shea, RM/ALF, MS: MNBB 4503 Project Engineer (DRP/A)
Section Chief (DRP/TSS)
DRS 020055
l MAR 261993 Wolf Creek Nuclear Operating ;
Corporation bcc to DMB (IE01) bec distrib. by RIV:
J. L. Milhoan Resident Inspector Section Chief (DRP/A)
DRP DRSS-FIPS Section Chief (RIII, DRP/3C)
RIV File SRI, Callaway, RIII MIS System Lisa Shea, RM/ALF, MS: MNBB 4503 Project Engineer (DRP/A)
Section Chief (DRP/TSS)
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'Q Premdent grid VM 93-0043 cn.ef Executwo omcer a
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U. S. Nuclear Regulatory Commission i
ATTN: Document Control Desk Mail Station P1-137 Washington, D. C. 20555 i
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, VCNOC, to NRC
Subject:
Docket No. 50-482: Responre to VJolation 482/9232 01 Gentlemen:
Attached is Wolf Creek Nuclear Operating Corporation's,(WCHOC) response to Violation 482/9232-01 which was documented in Reference 1.
Violation 482/9232-01 involved the failure to f ollow 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 March 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 matter, please contact me at (316) 364-8831, extension 4000 or Mr. Kevin J. Moles of my staff at extension 4565.
Very truly yours, J
Bart D. Withers President and Chief Executive Officer BDW/jan Attachment cc:
J. L. Milboan (NRC), w/a G. A. Pick (NRC), w/a W. D. Reckley (NRC), w/a W. D. Johnson (NRC), w/a
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RO. Box 411/ Burtington, KS 66839 I Phone: (316) 364-8831 An Eaust Opportunny Empoyer hAf 4CVET
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Attachment to WM 93-0043 f
g Page 1 of 3 Reply to Notice of Violation Violation 9232-01: Failure to Properiv Implement Procedure Failure to follow instructions.
During the implementation of Work Request I
05923-92 the mechanic used a hamer instead of a bearing puller to remove the inboard bearing from the shaft of Spent Fuel Pool Cooling Pump 'A'.
Finding:
' Technical Specification 6.8.1.a requires 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. states that maintenance affecting the performance of safety-related equipment should be properly i
preplanned and performed in accordance with written procedures, documented i
instructions, or drawings appropriate to the circumstances.
Step 2.16 of the work instructions for Work Request 05923-92 states that the inboard bearing of the spent fuel pool cooling pump will be removed using a bearing puller or equivalent.
Contrary to the above, on December 8, 1992, while implementing Work Request 05923-92, licensee personnel used a hamer to remove the inboard bearing from the shaft of Spent Fuel Pool Cooling Pump A instead of a bearing puller."
Admission Or Denial Of The Alleged Violation:
WCNOC denies the alleged violation.
l Reason For Denial Of The Violations The work instruction for Work Request 05923-92 stated:
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2.16 RVO Remove inboard bearing (16BA) using a bearing puller or equivalent. NEVER use a hamer to drive shaf t through bearing!
i The step allowed the craft 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 hamer could never be used. This was clarified with the inspector during followup discussions. The step would have stated:
'NEVER use a hamer', inctead of 'NEVER use a hamer to drive the shaf t through the bearingI*, if a hamer was an unacceptable tool for use in removing the bearing.
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Attachment to WM 93-0043 Page 2 of 3 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 damaged during normal pump operation and further bearing damage was not of concern.
The bearing removal and replacement was the subject of the work instructions.
2)
The work instructions stated to " Remove inboard bearing (168A) using a bearing puller or equivalent. NEVER use a hammer to drive shaft through bearing!* This instruction prohibits the worker from using a 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.
4)
The worker used a brass hammer to remove the bearing.
Thus, there was ~
minimal risk in damaging the shaft.
5)
The pump shaft was not damaged.
6)
It is VCNOC's position that the substitution of a hammer in place of a l
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.
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's
- 1) The Mechanical Maintenance Supervisor and the worker involved believed that the instructions as written allow for the substitute method, and that the j
method used is within what would be considered, ' good craf t practice" or l
- skill-of-the-craft".
- 2) Mechanical Maintenance supervision. and the worker involved are in agreement that the method used war 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.
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b Attachment to VM 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.
However, in an effort to prevent future work instruction interpretation concerns the Manager Maintenance and Modifications has issued a memo to all Maintenance Lepartment Personnel clarifying management's expectation regarding:
1)
Expected level of. detail for work instructions.
2)
Field interpretation of work instructions.
3)
Using skill-of-the-craft.
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