ML20092B945
| ML20092B945 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 02/05/1992 |
| From: | Bailey J WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NO-92-0045, NO-92-45, NUDOCS 9202110192 | |
| Download: ML20092B945 (3) | |
Text
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4 LF CREEK W@ NUCLEAR OPEDATING John A. Dailey Wce President February 5, 1992 NO 92-0045 U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Mail Station P1-137 Washington, D. C. 20555
Reference:
1)
Letter dated January 2,
- 1992, from A.
B.
- Beach, NRC. to B. D. Withers, VCNOC
- 2) Letter WM 91-0172 dated December 5,
1991 from B. D. Withers, WCNOC to NRC
Subject:
Docket No. 50-482:
Response to Request for Additional Information Concerning Violation 482/9126-02 and 9126-03 Gentlemen The purpose of this letter is to provide additional information concerning violation 482/9126-02 and 9126-03 as requested in Reference 1.
Violation 482/9126-02 concerned the failure to restore a damper following a loss of instrument air.
Violation 482/9126-03 concerned the failure to control work practices resulting in both trains of two systems being l
The attachment to this letter provides Wolf Creek Nuclear Operating Corporation's (WCNOC) response to the request for additional information.
If you have any questions concerning this matter, please contact me or Mr. S. G. Wideman of my staff.
Very truly yours, 48
- /
u John A. Bailey
-Vice President Oper'tions i
JAB /aem I
Attachment cci
%. T. Howell (NRC), w/a R. D. Martin (NRC), w/a G. A. Pick (NRC), w/a W. D. Reckley (NRC), w/a C202110192 920205
- 0. Box 411 i Burhngton, KS 66839 / Phone. (316) 364-8831 DR ADOCK 050004 2
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Attachment to NO 92-0045 Page 1 of 2 Response to Request for Additional Informat.lon Reauest With regard to Violation 482/9126-02, we require additional l
information about the adequacy of.0ffnormal Procedure OFN 00-019 Revision 8,
' Loss of Instrument Air,' to identify and respond to this and similar events.
We also request that you assess the adequacy of the work controls for the work activity which resulted in isolating the air line.
Responce:
Procedure OFN 00-019, ' Loss of Instrument Air', was generated for l
responding to a complete loss of the instrument air system.
The l
procedure provides guidance in the event of a loss of air to check the air compressors, ensure the service air system headers is
- isolated, check the air dryers and stabilize pressurizer level.
If the leak is located in a specific instrument-air-header, the procedure provides the valve number and location for isolation of the header.-
Additionally, the procedure provides as a reference a list of valves by system and their failure position on a loss of air for assisting in restoration.
Procedure OFN 00-019, was not intended to provide specific actions to be 'taken when air is lost ' downstream of-branch isolation valves. To try to address every individual loss of air is not appropriate.
The procedure has been utilized in the past when a train of air dryers failed or as part of a maintenance activity when the entire instrument header' was depressurized.
WCNOC believes the OFN 00-019 was adequate for responding to the October 2, 1991 event.
However, a document identifying the loads off branch isolation valve would be beneficial to the operators for restoration of portions of the instrument air system during maintenance outages.
The Operations Department -and system engineer will implement a program for developing a-contrclied docwment identifying the loads by the end of April 1992.
WCNOC reviewed-the work controls associated with the activity which resulted in isolating the air line and found them to-be adequate.
During the performance of procedure STS PE-047B, air was found leaking on the regulator for valve KA FV-29.
Work Request 04506-91 was initiated on September 27, 1991 to repair the leaking regulator.
On October 2 - 1991, and Instrumentation and Control technician received permission from the Supervising Operator in the Control Room to work on the regulator.
The technician indicated to the control Room that KA FV-29 might close when the work was being performed.
When the work was completed and instrument. air restored, the Control Room failed to consider the affect upon the containment purge system and failed to utilize OFN 00-019 for restoration.
1
. +. _, -. V.
Attachment to No 92 0045 Page 2 of 2.-
Reauests
-In general, we found your response to. Violation 482/9126-03 to be adequate.
In -reviewing your corrective actions
- though, additional information is needed to determine how you will assess the adequacy of maintenance shift turnovers, We also require information on the guidance provided-to personnel responsible for reviewing work instructions to determine which-activities should be-governed by approved procedures and whether the work instructions will be reviewed prior to being implemented again.
Response
The need for effective shift turnovers has been discussed with
. Maintenance and_ Modifications Department Supervisors. _
This discussion 1 stressed the importance of proper communication of work in-progress and equipment status during shift turnovers.
Electrical and Mechanical Maintenance personnel maintain a daily work--log which.is used to clarify priorities.between obtfts and is reviewed daily by Electrical and Mechanical _ Maintenance supervisors.
Therefore,.
the adequacy of maintenance shift turnovers is monitored by periodic attendance of supervisors _at various shift turnovers and a review of the daily work log.
As identified in Reference 2, an interim checklist was developed-for maintenance personnel's use.in system restoration to -ensure-equipment is restored to its proper. configuration prior to signing-off that the work is complete.
For corrective work request packages. -this restoration guidance will be provided in ADM 08-206 ' Corrective Maintenance' by February 28, 1992.
Procedure ADM 08-202,
" Planning and Scheduling Preventative Maintenance Tasks' provides specific guidance for determining those-preventative work activities that should be governed by -
approved-; procedures.
During the review of work
_ package instructions as -discussed -in -Reference 2,
the guidance in ADM 08-202 or the interim checklist is-utilized to strengthen the restoration process' in' 'the work instructions.or in the-development of a_
procedure.
For_ preventative maintenance activities, the -need to strengthen the: restoration process in-work instructions or the development of a procedure _is performed
. prior to the performance of the activity..
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