ML20062F327
| ML20062F327 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 11/16/1990 |
| From: | Bailey J WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NO-90-0287, NO-90-287, NUDOCS 9011270215 | |
| Download: ML20062F327 (4) | |
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j LF CREEK W@ NUCLEAR OPERATING CO John A. BaHoy Vice President Wclear Operatene November 16, 1990 NO 90-0287 j
U. S. Nuclear Regulatory Conunission ATTH: Document Control Desk Mail Station P1-137 Washington, D. C.
2055!,
Raference: Letter dated October 19, 1990 from-F. J. Collins, NRC to B. D. Withers. WCNOC
Subject:
Docket No. 50-482-Response to Violation 482/9031.01 Gttntlemen t Attached is Wolf Creek Nuclear Operating Corporation's (WCNOC) response-to 4
violation 482/9031-01 which is documented in the Reference.
Violation 482/9051-01 concerned the failure to have-an ' approved procedure.
The Reference also transmitted violation 482/9031-02 concerning the failure.to take adequate corrective action and requested' additional information regarding the overall actions to correct' the apparent continuing work control problems and an assessment of.the effectiveness of the corrective action program at Wolf Creek Generating Station.-
The-response to this portion of the_ Reference will be provided as established with Mr. A. T. Howell, NRC.
As a result of discussions on November 14,'
- 1990, between tk. A. T. Howell, NRC. and Mr. H. K. Chernoff, WCNOC, concerning the similarities of three NRC requested responses to NRC, violations and concerns, it was agreed that WCNOC will provide a combined response to these items by December 7, 1990.
This submittal will provide a response to the remaining items requested in Inspection Report 482/9031 and the response to violation 482/9034-02, concerning the failure of the corrective actian program to ensure that hardware failures and nonconforming conditions are, evaluated to assure equipment operability.
Additionally, this submittal will provide the information verbally requested on November 12,1 1990 by Mr. A. T. Howell,
- NRC, concerning WCNOC's previously submitted response to violation 482/9028-01.
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P.O. Box 411 / Burbngton, KS 66839 / Phone: (316) 364-8831 An Equal opporturwty Empeoyer MF4CVET :
NO 90-0287 Page 2 of 2 l
If you have any questions concerning this matter,.
please contact me or Mr. H. K. Chernoff of my staff.
i Very truly yours, l
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John A. Bailey Vice President j
Nuclear Operations
.i JABlaem cci A. T. Howell (NRC), w/a R. D. Martin (NRC), w/a
-j D. V. Pickett (NRC), w/a 4i M. E. Skow (NRC), w/r i
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Attachment to NO 90-0287 Page 1 of 2 Violation (482/9031-01):
Failure to Have an Annroved Procedure Finding: Technical Specification 6.8.1-requires approved written procedures for activities affecting safety.
WCGS administrative Procedure ADM 07-100 Revision 45,
' Approval and Distribution of WCGS Procedures,"
paragraph 4.3.1,
- requires, in part, that Revision 0 of nonnuclear safety-related procedures be approved by the plant safety review committee (PSRC) to ensure the procedure is appropriately classified and that it receive plant manager approval signature.
Contrary to the above, on May 16, 1990, a test of the main generator voltage performed without a procedure which had been approved by the regulator was PSRC and did not receive the plant manager approval. signature.
Reason For Vloistion:
The reason for the violation was the failure of the personnel involved to recognize the adjustment of the main generator _ voltage regulator as a special test requiring an approved procedure in accordance with ADM 07-100,
" Preparation, Review,- Approval and Distribution of WCGS' Procedures".
-Upon initiation of Work Request No.
01379-87, Maincenance Engineers determined l
that the tdjustment was a nonnuclear safety-related activity'and-that work request dtructions.were adequate for this activity.
This; determination was base on the failure to recognize the significance of the activity on plant ope:.eion and the effect on safety-related equipment.
Corrective Sceps Which Have Been Taken And Results' Achieved:
I Operations and Maintenance Management have. reviewed recent events related to inadequate work control practices and detenmined that work on equipment in service will be performed under ' procedural controls.
Under special circumstance the requirtment to have'a procedure for the work activity may be waived with the approval of both the Manager Operations and Manager Maintenance and Modifications.
Proceduralizing work activities on in
. service equipment ensures that appropriate reviews are _ performad to determine the effect of activities-on plant operation and safetv-related equipment.
A review'of the preventative maintenance (PM) activities was performed to identify those activities that require the equipment to be.in service while-conducting the.PM.
Procedures are being developed and will be in place prior to the performance of the PM activity.
For corrective maintenance activities on equipment in service procedures are developed as the need arises.
Corrective Steps Which Will Be Taken To Avoid Further Violations:
In order.to formalize'the above process, procedure ADM 08-201,
" Control of Maintenance and Modifications" is being revised to incorporate.the use of procedures for performing maintenance activities on equipment in service.
o Attachment to NO 90-0287 Page 2 of 2 Date When Full Compliance Vill Be Achieved:-
Full compliance will be achieved by December 3. 1990 with the revision to ADM 08-201, which will require the use of procedures when performing preventative and corrective maintenance work activities on equipment that is in service.
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