ML20091M555
| ML20091M555 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 01/22/1992 |
| From: | Bailey J WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-NUREG-1022 NO-92-0028, NO-92-28, NUDOCS 9201290135 | |
| Download: ML20091M555 (5) | |
Text
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1 LF CREEK V R) NUCLEAR OPERATING John A, Badey v c. en,. oent January 22, 1992 OP"" "'
NO 92-0028 U. F. Nuclear Regulatory Commission ATTH:
Document Control Desk Mail Station P1-137 Washington, D. C. 20555
Reference:
Letter dated December 23, 1991 from A. B. Beach, NRC to B. D. Withers WCNOC
Subject:
Docket No. 50-482:
Response to Violations 482/9131-01 and 482/9131-02 Gentlemen Attached is Volf Creek Nuclear Operating Corporation's (WCNOC) response to violations 482/93?1-01 and 482/9131-02 which were documented in the Reference _
Violation 9131-01 involved a failure to make a timely NRC notification and violation 9131-02 involved an inadequate corrective action.
If you have at questions concerning this matter, please contact me or Mr. S. G. Vidtman of my staff.
Very truly yours.
John A. Bailey /
Vice President Operations JAB /jra cc:
A. T. Howell (NRC), w/a R. D. Martin (NRC), w/a G. A. Pick 'NRC), w/a W. D. Reckle.v (NRC), w/a e e,,
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9201290135 920122
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PDR ADOCH 050004e2 G
PDR P.O Box 411 < Burlington, KS 66839 / Phone. (316) 3648831 An Equa Opportunity Employer M F HC/ VET
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Attachment to NO 92-0028' I
Page~1 of-4 Response to Violations 482/9131-01 and 482/9131-02 Violation (482/9131 01):
Failure to Hake Timely NRC Notification Findinn Title 10 CFR $1.72(b)(2)(ii) requires NRC notification as soon as practical and in all casco, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of the occurrence, of any event o:
condition that results in manual or automatic actuation of any engineered safety feature,1 including the reactor protection system. However, actuation of an engineered safety feature, including the reactor protection system,-
that'results from and is part of a preplanned sequence during testing or reactor operation, need not be reported.
Updated' Safety ' Analysis Report (USAR) Sections;7.1.1.2.c and -e define the containment purge isolation and control room ventilation isolation systems, respectively, as emergency safety features actuation systems that are needed to_ actuate the equipment and' systems required to mitigate the consequences of postulated accidents.
1 Contrary.to the above, Cht October 2,
- 1991, the licensee failed to make a 10 CFR Part 50.72 notification within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for an automatic actuation of an engineered safety feature.
Valid control rocm ventilation isolation and-containment purge isolation signals were received when an operator reestablished a purge of the pressurizer relief tank.
General Procedure GEN 00-007 Revision 4,
"RCS Drain Down,"
which was referenced to ree:tablish.the purge.-
did not-identify the engineered safety feature
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actuation as a stated objective.
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Reason for Vio1ation:
Fallure to make the timely notification resulted from a misinterpretation of the -reporting guidelines.
LA caution statement had been added to P-ocedure GEN 00-007,
'RCS Drain Down',.to make Control Room-operators aware that a CPIS/CRVIS might-occur during veneing of the pressurizer _ relief tank with
{1 the-containment purge exhaust system securad.
It was understood that by adding _the caution statement. _ : tne occurrence of a CPIS/CRVIS resulting - from.
this sctivity :would-be considered prepl anned actuations.
Subsequent discussionfof the reportir.g requirements with the NRC Resident'Inspectnr and NRC Region IV, personnel concluded _that'the event was_ reportable because it occurred from.a valid _ signal and the-actuation'was not a stated objective-of the procedure..
Corrective Stens'Which Have'Been Taken And'Results Achieved:
performed l on An event notification pursuant to 10 CFR S0.72(b)(2)(ii) was October 18,
- 1991, with a substquent event discussion in Licenseu Event Report 482/91-018-00 on-October-28, 1991.
Wolf Creek Generating Station Standing Order 11,-
'NUREG 1022" was revised on October 24.
1991.to' include.
further guidance detailing interpretation of what ' preplanned"'means in the context of-NUREG-1022.
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Attachment to NO~ 92-0028 Page 2 of'A 4
4 Correctivq Stena Which Will Be Taken To Avojd Further Violations No further actians are planned at this time.
Action taken is sufficient to prevent recurreice.
Dnt e When Full-Comoliance Will Be Achieved:
Full compliance was achieved on October 24, 1991.
Violation (482/9131-02):
Inadequate Corrective Action Pinding1 y
Criterion XVI of 10 CFR Part 50, Appendix B.
"Currective Actions," requires, in part, that measures shall be estaolished to assure that conditions.
adverse to quality, such an.f ailures, malfunction, deficiencies, deviations, defective _ material.and equipment, and nonconformances are promptly identified _ and corrected..
This is accomplished, in part, by Wolf Creek Nut'.nar Operating Corporation Procedure ADH 01-0$3, ' Work Requests."
ADH_01-057, Section-2.1' states: J. "The work request will be used tos
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document and control.. ork performed on plant systems:
and (B) identify, w
document, disposition,. control and correct ncnconforming items not under warehouse control."
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' Contrary to _tho above, a work request was not issued for Flow Transmitter.
EH_PT-922..
_This_ flow transmitter was identified on June 28,
- 1991, as the cause of erroneous surveillance results.for STS CV-210, Revision 5, "ECCS Inservice Check Valve-Test." An a result of this-deficient flow transmitter not- -being corrected, inaccurate flow data was obtained during.the-performance-of STS EM-003 Revision 7 "ECCS Flow-Ealance,"
on l November 8, 1991.
FT-922 was found out of. calibration following the test even-though it had been calibrated 3 days earlier-.
Reason for Violation:
-On June'28, _1991, WCNOC was informed of a problem at the Callaway station regarding-the verification of safety injection (SI) flow rates in accordance
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with. Technical _ Specification 4.5.2h.-
Wolf Creek Generating Station.(WCGS)
Technical-Specification 4.5.2h requires the performance of a' flow balance test.following completion of modifications to. the -emergency core cooling
-system; 'nubsystems that ~ alter the cubsystem flow characteristics and
, verification.that-the total pump flow rato is less-than or equal to 665 gpm.
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~ Attachment to'NO 92-0028 Page 3 of 4 i
A Programmatic Def f.cl ency Report (PDR) was initiated to evaluate the applicability of this problem to WCGS.
The evaluation included a review of flow data for _the SI pumps from the previous performance of STS CV-210 "ECCS Inservice Check Valve Test",
and partial STS EM-003, "ECCS Flow Balance *,
On June 28, 1991 partial performance of STN IC-246A, " Calibration of Safety Injection Pumps A & B Discharge Flow boops",
was conducted to determine if flew transmitter EM FT-0922 for SI pump "B" flow was within tolerance.
As a result of this
- test, EM FT-0922 was found to be out-of-tolerance.
The evaluation indicated that this flos transmitter had a history of being out-of-tolerance.
The PDR concluded that the SI pump flows did not exceed the Technical Spacification limits and was closed.
In NRC Inspection Report 91-18, the inspector stated, "The decision to replace EM FT-0922 during the upcomin6 outage and to include additional acceptance criteria in STS CV-210 is being evaluated by PDR TS91-028".
The PDR failed to further evaluate the out-of-tolerance conditions for EM FT-0922 to determine if additional corrective action on the transmitter was necessary.
As discussed below, a
work: request is not required to be issued in accordance with WCGS procedures.
Corrective Steps Which Have Been Taken And Results Achieved:
During the performance of STN IC-246A on June 28, 1991.
EM FT-0922 AS FOUND data was -outside the tolerance range as specified in the procedure.
In accordance with Step 5.14 of the procedure the transmitter was adjusted within the tolerance range and STN IC-246A wa-
>mpleted.
A work request-was not initiated since adjustment vaa cc,.eted in accordance with STN IC-24eA and there was nc failure of the transmitter.
Procedure ADM 08-807, "IEC Group Surveillance Testing" requires out-of-tolerance conditions be identified in 'the Deficiency Section of the Surveillance Test Routing Sheet.
The Shift Supervisor is to be immediately notified if the instrument _cannot be brought back 'into tolerance or an Allowable Value has been exceeded.
For any instrument failure encountered duringLthe performance of a surveillance procedure, the test performer is required to initiate a work request to_ document the nonconformance.
Procedure ADM 02-300,- _" Surveillance Testing" requires that when a test
- deficiency is _ identified, the test performer coordinates with the Shift-Supervisor to determine the actions to be taken to resolve the deficiency.
TheLactions to be taken may include termination or suspension of the test-if the deficiency -warrants, generation of a work request,_
request an engineering evaluation or other actions. Therefore, in a-idance with the above procedure a test deficiency may not be a nonconformat.
as defined :in ADM.01-057, " Work Request".
Procedure STN IC-246A was performed on September 4, 1991 and EM FT-0922 was within the required tolerance ranges.
In preparation for performing STS CV-210, a partial performance of STN IC-246A was c?nduct9d on November 9, 1991.
Transmitter EM FT-0922 AS FOUND data was outside the I
tolerance -range. and _subsecuently adjusted within the tolerance range in-accordance with STN IC-246A.
During the performance of STS CV-210 on November 8,'1991, a test deficiency was identified when SI pump "B" exceeded l
665 gpm by 2.2gpm.
Procedure STS EM-003 was performed to adjust the cold
. leg._ safety injection' throttle valves to bring SI pump flow within the technical specification value.
As a result of the test deficiency on-e--
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[li Attachmedt to NO 92 0028
-Page 4 cf 4 STS CV-210, a post test calibration was performed on EH. FT-0922 AS FOUND data-was outside the tolerance range.
Corrective Work Request 6083-91.was
' initiated _and transmitter EH FT-0922 was replaced on November 21.
1991 due to recurring calibration con:arns.
Correc(ive Steps Which Will Be Tnken To Avoid Further Violationsi As discussed in letter WM 92-0002 dated January 6, 1992, WGNOC is continuing to enhance the corrective action program.
In August 1991, a change was made--
to the corrective action program which revised the Programmatic Deficiency Report to the Performance Improvement Request.
The intent of this change was.to eliminate the confusion surrounding the definition of
" programmatic-adverse _-to quality" and _ expand the scope of the program to conditi condition that could adversely effect plant performance or work includ uni activitzwa.
A discussion. of this event and the need to ensure that the
-condition is adequately addressed in a timely manner will be included-as p
part of the=
corrective action program training being provided by July 1.11992.
I Date'When Full Comoliance Will Be Achieved:
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~ Full compliance will be achieved by July 1,
'1992 with the-completion of training on the corrective action program, c
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