ML20094K912
| ML20094K912 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 03/20/1992 |
| From: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-89-10, WM-92-0043, WM-92-43, NUDOCS 9203230289 | |
| Download: ML20094K912 (8) | |
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l WMF CREEK
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NUCLEAH OPERATING CORPORATION narto wn;m erwoe<it eins ces.a e.,wi.. onn.
March 20. 1992 kH 92-0043 U. C. Nuclear Regulatory Cornission ATTNs Document Control Desk M *d 'a Statien P1-137 Washington, D. C.
20$$5 References i.ett er dated February W.1992 to B. D. Vithers,
'lCNOC from R., D. Har tin. NRC Subjects Docket No. 50-482:
Response to Notice of Deviation Gentlemeni The attachment to this letter providen Wolf Creek Nuclear Operating Corporation's (WCNOC) response to a Notice of Detistion concerning the f ai3ure to imple.nent rouaitments associated to. the provisions of Generic letter 89-10
" Safety Related Motor-operated Valve leoting and SurvLiliance."
Also doctunent ed in the reference was an associated Notice of 71olation and proposed c3vil penalty.
WCNOC's respense to the Notice of Violation is provided in a separate sutaittal.
l If you have any questions concerning this u tter, please contact me or l
Hr. S. G. Wideman of my staff.
Very truly yours.
hv J
Part. D.. Withers President and l-Chief Executive Officer BDW/aem Attachment l
cci A. T. Howell (NCC), w/a R. D. Martin (NRC), w/a G. A. Pich (NRC), w/a V. D. Reckley (NRC). w/a f
920323b289 920320 PDR ADOCK OSOOO4EJ f' p
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PDR PO Box 41' i Durangton. KS 66839 s Phore (313) 364 8831 An Eqd Ogortafety EmRarer M F HCVE1
o ttachment to WM 92-0063 page 1 of 8 14' ply to Notice of Deviation ytekuroundl On Febreary 20, 1992 the kegional Administrator of Region IV issued VCNOC a Notico of Levistion. This Notice of Deviation was a result of an incpection
($0 482/91-04) conducted November 4-6, 1991.
The inspection examined *lolt Creek Huclear Operationg Corporation (WCN00) safety-rela.ted motor-operated valve (HOV) testing and surveillance program for implementing commitments to Generic Letter 89-10 ' Safety Related Motor-operated Vavle Testing and Surve111ance'.. By letter dated December 26, 1989 WCNOC committed to meet 7
the schedule requirements of Generic Letter (GL) 89-10.
Specifically, paragraph *1' af GL 89-10 which established a schedule for the development of an MOV program to satisfy the requirements established in the generic letter and its supplemento.
WCNOC was-ineffective in completing the connitment and the.following deviations were cited in the Notice of Deviatioat As of November 6, 19911 1.
The licensee's GL 89-10 program failed to consider any design basis-parametets other than differential pressure in its design basis reviews.
2.
The licensve's GL 89-10 program failed to establish a method to properly size MOVs and select switch settingo by not considering margins 'for rate of loading effecto or torque switch repeata'uility, nameplate ratings vice stall rstings of the motorst diagnostic
+t equipment inaccuracies:
the performance of diagnostic tests at greatet th:.n 100 percent voltages and, the performance of weak-link analyses.
3..
The licensee's GL 89-10 program failed to develop procedures for the perfonnance of design hr.ei s testing (including design differential presnures and flows),
acceptance criteria fur the test, and feedback mechanisms.
4.
LThe licensee's OL-85-10 program did not have provisions for periodic verification of MOV operability or post-maintenance testing.
5.
The licensee's 4L 89-10 program did not have adequate. provisic,ns for l
ccalyning MOV failures, for justifying corrective action, and for
. trending those failures-and' corrective actions.
Introduction (L The deviations listed above identify five examplos of a failure to establish-a ' program to ensure that MOVs will pecform their intended safety-related
-functions, as' required by kCNOC's commitments to Generic Letter 89-10.
As discussed with the NRC during an enforcement conference on December 6.1991, all five deviations have been determined to be a result of insufficient management.nversight of the MOV program.
Therefore, section 1 of this response addresses maragement oversight issues.
Section II addresses the five specific deviations described in the Notice of Deviation.
-Where numbers have been used,.the nembers correlate directly with the' deviations
-identified above..
httachmenttoUM 92-0043 page 2 of 8
- 1. Management oversight Issues Rensors For The Deviation u i
The five deviations identified are a result of one or more of the following three management factors a.
Insufficient recognition of _the program complexity and emergent j
industry issues associated with Generic Letter 89-10 The provisions of Generic Letter 89-10 were treated su an extension e1 the program developed to addressBulletin 85-03,
' Motor Operated Valve-Common Mode Failures During plant Transients Due to Improper Switch Settings *.
Since the HOV program was viewed as an extension of the earlier.
.less detailed program, management did not recognize the dynamic nature of emerging industry issues associateo with HOV design.
I maintenance, and testir.s.
and therefore did not ensure the program was j
upgraded to meet the new and additional requiremente.
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b.-
Insufficient defirition of organizational responsibilities and interfaces.-
VCNOC management inappropriately assumed that the existing organizational structure (2 Maintenance Engineers and 3 Nuclear plant i
Engineers) could implement the provisions of Generic Letter 89-10.
As-a result, no single organization or position perceived ownetship of the overall program.
In addition, given the long time frame for implementation of the provisions of Generic Letter 89-10 management failed to focus on resource needs or program impact.
c.
Inappropriate interface between the HOV program and other ertablished programs.
WCHOC : management failed to recognize ~ that emerging MOV tysues identified by-personnel were not-being addressed or resolved in accordance with _ appropriate upper tier VCNOC programs such as design / configuration, 'reportability, and corrective action.
-Without proper management guidance and input, appropriate interface between the MOV. program and other programs was not developed.
Corrective Stene Which Have-Br.e,n Taken add Results Achieved,1 i
VCNOC has rastructured nyersight of the MOV program.
This restructuring addressed each of the. management -issues identified as reasons for_ the deviation.
a.
Intufficient recognition of, the program complexity-and emergent j
15
- industry issues associated with Generic Letter 89-10 On November-8, 1991. exe_cutive management-initiated an.immediate stop work-to all MOV design, maintenance and testing activities.
prior to
-re-commencing MOV_vark, associated procedures were-reviewed, revised or l-
_ written to ensure that_short_ term activitien necessary to demonstrate operability _of safety-related MOVs were in full' compliance with the provisions-of Generic Letter 89-10.
Design procedures were developed
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.kttachmenttoWM 92-0043 l
Paga i nf 8 e
to address design basis issues, configurctien, sizing, margin, weak link and switch satting issues.
In addition, the procedures specify i
conservative inputs so that analytical methoda would conservativaly envelope the credible system and fic1d conuitions which may be encountered by-the MOVs under design-basis conditions.
To ensure that industry issues and feedtsck were incorporated into the MOV program, the MOV team established contact with a broad cross-section of MOV talent in the industry.
The MOV Team also employed four i
differer.t consultant organizations who were' actively involved in the implementation of Generic Letter 89-10.
The MOV Team established working contacts with other licensees who have similar plant design and j
plant vintage.
These contacts were veed to compare design besis l
parsmeters and analytical methc4s.
Dialogue with memberJ of the NRC staff was also beneficial in focusing attention on industry MOV issues and methods.
Feedback from all of these sources was incorporated into th< A0V Program procedures.
Using _the new and revised procedu.tes, the MOV Team re-evaluated the qualii! cation of all safety related MOVs which may have been effected by p.evious MOV program activitiec.
Torque / thrust requirements were determired for each identified MOV as well as torque /thrvat cepabilities of the as-installed MCV configuration.
Tests were also performed to ensure that the as-lett switch settings allow the MOV. to develop the required thrust under static conditions.
Discrepancies between the required thrust and the POV capability, as well as test r
deficiencies were resolved prior to restart from the fifth refueling outage.
Resolution involved any enmbination of physical modification of the MOV.
revisions to operating procedurou and/or adjustment of switch settings.
In all, 120 MOVs were evaluated to ensure compliance with the revised MOV program requirements.
Since restart, representatives from the MOV Team have attended industry meetings and-seminars to gain further insight into emerging MOV
. issues.
This feedback has also.been incorporated into the scope of the MOV program. WCNOC remains active in the MOV user groups.
WCNOC manatement has clearly satablished the mission lof the MOV prejram to focus on the' ability of the MOV to perform its safety-related functiona under design basis-conditions.
WCNOC design and static L
test 3ng procedures are in full compliance with the deaign basis confirmation provisions of Generic Letter 10. _
Feedback from I
emerging industry issues and lessons learned have been incorporated
-into :those _ procedures.- -provision
- are also in place to ensure-that-WCNOC remains-cognizant Lof-and Incorporates the latest industry 1
developments regarding MOV design, maintenance and testing.
b.-
Insufficient definition. of organlaational responsibilities and ir.terfacesr I
L on November 8,.1991 the MOV Teen was formed.
A division level manager was assigned ovecal]
responsibility for all aspects of -the MOV program.-
ihe NOV Team was comprised of engineering, operations and maintenance personnel.
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ttachment to WM 92-0043 Page 4 of 8 The Director plant Operations issued a directive requiring that all design, maintenance, and testing activities associated with safety related MOVs be coordinated with the MOV Team.
This directive was discussed at the morning management meeting and was reinforced at the outage shift turnover meetings.
Procedures were cevised to define organizational responsibilities and specify Interface expectations.
c.
Inappropriate interface between the MOV program and other upper tier programs:
Specific actions were taken to ensure that the MOV activities appropriately interface with higher tier programs at WCN00, including i
corrective action, operability, reportability and design / configuration control.
Procedures were revised or rewritten to include steps to ensure that MOV work appropriately interfaced with the WCNOC programs for corrective action, operability, reportability and design /configuratier, control.
In addition to the procedures, management rapresentatives frequently stressed the expectation that upper tier programs be used during regular morning meetings with the MOV Team members.
During the meetings. -management representatives also solicited input on emerging 4
issueo which could effect operability, reportability and/or require corrective actions. The meetings were used as a forum to define issues and resource requirements, and direct resolution through the approprir.te program, The following paragraphs describe actions taken to remediate past weaknesses in.
MOV program compliance with the WCNOC dnsign/ configuration control program.
I Previous program documents and procedures which deviated from the requirements of the design / configuration control program were either superseded or-revised to require interface with. the appropriate existing procedures.
Procedures required new design work under the MOV program to use existing design and_ configuration control procedures, These procedures also required use of design basis records as the source of-
-design inputs.
Needed design record information was obtained from the original equipment manufacturer.
All accessible, safety related MOVs were walked down to establish the as-left conf!guration of-critical MOV characteristics, including actuator size,T ractor nameplate, spring pack size, and torque switch setting.
A The as-left MOV configuration was compared to the original design configuration, and to the configuration required by the new requirements of-the MOV program,.
Any discrepancies were documented a
in the appropriate corrective action document.-
.The-enhanced program invoked the WC;10C corrective ection program _ta ensare that all issues which could affect operri 'ity were identified.
documented anl trackad through resolution beforu restart from the fifth refueling-outage.
Speciile actions included:
j
Attachment to VM 92 0043 Page 5 of 8 j
1 Discrepancies identified during the design / configuration reviews were j
documented in Corrective Work Requests (CWR).
The dit prepancy evaluations were documented in design dispositions to the CWR, along with reanired repair / rework requirements in accordance with station procedurec.
in addition, the Manager of the MOV Team issued a guideline document for the standard format and content for the MOV I
evaluatior. dispositions.
This guideline required that the root cause for each identified discrepancy be identified in the disposition with a reference to the document which evaluates the root cause for further r
corrective action.
Programmatic concerns which could affect other MOVs were documented in Performance Improvement Requests (PIR) in accordance with KGP-1210, 1
" Performance Improvement Requests'.
Each PIR was evaluated for the affect the problem could have on MOV operability.
Those PIRs which could affect operability were resolved through the remedial corrective action stage prior to restart from the refueling outage.
Each of these PIRs was evaluated for root cau7e. Given the root cause, an evaluation l
was performed to determine other h0Vs which could be adversely affected by the same root cause.
These othet MOVs were then added to the scope of the MOV restr(t pcog"at.
Remedial corrective action work was "empleted prior to restu t from the out age.
In all, 120 safety related h7Vs were evaluated priot to restart.
PIRs which were juJged to n,t.!f::c MOV operability.
as well as all IIR preventive corrective actions, were tracked and have been it.corporated into tho MOV sec }a document.
The MOV scope document defines and outlines remainitg activities and issues to be addressed in the WCNOC MOV program.
The above actions have resulted in the integration of MOV program elements with upper tier programs.
The effecto of the previous weak MOV program interface with-the corrective action -programs-and design / configuration programs h0ve been _evalut.ted and appropriate remedial actions have been implemented.
The above retions tave ensured that MOVs will perform their intended safety-related functions.
Other Management Oversinht Actions In addition to the specific actions described above, VCNOC has implemented changes in the method used to oversee the definition and execution of Jnsues which are not directly resulting from the day-to-day, norati operation of the plant.
The director level of management has formed the Issues Review Group (IRG).
The -IRG -charter -was issued on January 9, 1992.
The IRG's nission is to ensure that responsibility and resources are appropriate 1y' assigned for significant. generic regulatory _and safety issues impacting operation.
In addition, the IRG receives feedback on the resolution of variour issues, and may direct additional independent reviews when deemed prudent.
The IRG is chaired by_the Director Plant Operations and-is comprised of the
= Director Plant Operations.
Director Nuclear riant Engineering, D! rector Neclear Services and: Director Quality and Safety.
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Attachment to VM 92-0043 Page 6 of 8 i
For significant issues, the IRG assigns a Project Manager, responsible for defining the scope of the issue, documenting a plan for resolution of the 1ssue identifying resources and training required to complete the issue, i
and providing periodic updates on progress to the IRG.
The IRG has been fttnctional since January 9,1992, and has identified a list l
of issues that are reviewed by the 10G, The list of issues is drawn from i
regulatory correspondence, INPO Significant Operating Experience Reports, and the VCh0C Industry Technical Information Program.
The IRG hab also reviewed the scope of work remaining under the MOV program, and has. assigned a Project Manager for the temaining MOV work.
Sufficient resources have been provided to ensure integrated resolution of the remeining MOV issues in accordance with the provisions of Generic Letter 89-10.
The current MOV Team is comprised of a Supervisor Engineer reporting to the Project Manager, with the resources of four design engineers, one
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(quipment-engineer, une operator, one test engineer and one maintenance engineer.
These resourcca are working from n single location inside the pr otected area, and are dedicated full timo to the performance of WCNOC's MOV progreen.
The team vill remain in place until all issues have been resolved and integrated into normal operations, at shich time the MOV program elements 'till return to the appropriate line organizations, i
Correctivo Steps Which Will Be Taken to Avoid Furthgr Deviations The actim.s described above are cufficient to prevent recurrence of the i
n management oversight weaknesses identified in the Notice of Deviation.
Management oversight har been restructured so that significant issues i
affecting the saft operation of Wolf Craek Generating Station (WCGS) are r9 cognized, adequately staffed and managed through resolution.
Oversight of the. MOV program has also been restructured.
The scope of work associated with Generic Lstter 09-10 has been developed and staffed, with methods in place ;to monitor performance.
The actions taken have brought WCNOC into compliance with those provicions of Generic hetter 89-10 which were required-to be completed by January 1, 1991.
Specific remaining actions associated l
with each of the five items in the Notice of Deviations are Addressed in aection II.
II. Specific Deviation issues 1
Corrective Steps Which Have Been Taken and Results Achievedi i
l
. 1.
The MOV.program ptocedures were revised, rewrit. ten or developed to define deslgn basis parameters for saiety-reinted MOVs.
The design basis parameters' included:-
Degraded terminal _ voittge and methods to calculate design basis minimum available voltage at AC and DC motor operators.
A determination of safety-related and non safety-related functions for. each MOV, incluuing valve mispositioning as postulated in the i
current WCNOC Licensing Basis.
i Maximum expected dit'farential pressure across the MOV.
for both the apen and closed direction of the valve as well as the temperature range, flow rate range, direction of flow, and actuadon stroke time
-for each direction of actuation.
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Attachment to WM 92-0043 Page 7 of 8 i
In addition, HOVs were reviewed to determine MOVs which could have been adversely affected by previous HOV activities.
The MOV team established design basis parameters for all MOVs identified es potentially affected in accordance with the new procedures.
2.
A procedure to define the methodology to be used to determine design requirements for MOV torque / thrust and tortue/thruet capabilities for a given MOV configuration was developed.
4%
This procedure incorporated c ted margins for torque switch repeatability, rate of lo
- affecta, and test equipment inaccuracies.
The procedure requi es the calculated available motor torque to be based upor the motor nameplate voltage under degraded-voltage condition.
It requires use of the reconciled design configuration of the MOV in determining calculation inputs, including the reconciled as installed motor rating.
The procedure requires thct developed thrust loads remain within the maximum allowsbles determined in the original design for the motor actuater and valve.
Any increase in thrust beyond. original design allowables was formally reconciled
'rith original design qualification in accorda r.ce with existing procadures.
This procedure vsa used to recalculate torqae/ thrust requirements and capabilities for those valves within the scope of item 1.
Discrepancies were resolved prior to restart from the fifth refueling outage.
Static testing performed after formation of the MOV team used nominal available voltage.
The test voltage was factored into the evaluation of static test results.
3.
Previous differential pressure (DP) tests which had been performed on MOVs were ovaluated in accordance with new procedures.
DP tests which were not performed under the same fluid system and line-up conditions l
at detined in functional scenarios or within the bounding physical parametern defined in the maximum expected differential pressure l
calculation, were invalidated and revoked as a basis for confirming that a MOV would perform its intended safety-related functions under design basis conditions.
4.
As an interim measure, the Director Plant operations issued a directive that all design, maintenance, and testing activities associated.with safety-related HOVs be coordinated with designated reptr.entatives of L
the MOV team, to ensure that activities comply with the revised Mov program requirements.
Th16 directive was discussed at the morning mr.nagement meeting and was reinforced at the outage shi i turnover meetings.
Diagnostic testing was performed on all safety-telated MOVs which had received maintenance or modifications during the fifth refualing outaBe+
5.
The previous MOV procedures were evaluated against the provisions of Generic Letter 89-10 and its supplements to ensure that the provisions of Generic Letter 89-10 are addressed by the WCNOC MOV program implementing procedures.
Where missing or weak program elements were L
identified which could affect the short term operability of MOVs. the discrepancies were resolsed by-revising or preparing new procedures.
All procedures.
defined
. organizational responsibilities and
, Attachment to WM 92-0043 Page 8 of 8 specified
'nterface expectations.
Program weaknesses, (such as inadequate failure analysis and corrective action) uhich could affect popslation of HOVs were also resolved through the operability of a remedial corrective action stage.
Missing or weak program elements, judged to not afrect operability of HOVs, (such as trending, formal feedback procedured, dynamic testing),
were lagged into a tracking document.
These open action itons have been subsequently incorporated into a formal MOV scope document which will guide the preparation of the remaining program and procedural wntx.
The above actions have brought VCNOC into compliance with those provisions of Generic Letter 89-10 which were required to be complete by January 1,
- 1991, and are necessary to confirm operability of safety-related MOVs at WCCS.
WCHOC management has clearly established
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the mission of the HOV program to focus on the ability of the MOV to perform its safety-related function unoer design basle conditions.
WCNOC design basis confirmation and static testing procedures are in full compliance with the design basis confirnation provisions Generic Letter 89-10.
Cerreq.tive Stens Which Vill Be Taken To Avoid Further Dev(nLigns And The Date When CorreStive Actions Will Be Comnleted:
1.-
A new program document defining implementation yof the provisions of Generic Letter 89+10 vill be issued.
In addition, procedures will be revised to address other instances of credible mispositioning.
-2.
Procedures will be envised to incorporate methc'.s to reconcile the diagnostic test voltage with the design basis voltage (during testing or test evaluation) so that diagnostic tests confirm the ability of the MOV to perform under design bas 16 conditions.
Procedures will also be revised to address the weak link anelysis and criteria for when this-analysis is required and methods used for the analysis.
3.
A procedure for overall dynamic testing will be written to identify l
purpose, objectives. _ design basis input parameters to be monitored, i
acceptance criteria and feed back mechanisms.
1 4.
The MOV prc, gram will be revised and procedures written-to addrees post-maintenance testing (when testing-is required, which testing is required for each type of valve function and interf acing or dOV diagnostic testir.g with other established test programs).
'These procedures will also identify criteria for when periodic testing is required-to verify operability.
l 5.
A tracking and. trending' program will be formalized within the overall MOV program to accommodate valve failures, corrective actions and provide data to enhance and provide for improved MOV preventative
. maintenance and periodic verification.
Necessary implementing ' procedures will be revised to require timely evaluation of calculation and - test results and documentatier. of
' discrepancies on appropriate corrective action documents, and in accordance with existing WCNOC procedures.
The above corrective actions will be completed July 31, 1992.
.m
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