ML20095J043
| ML20095J043 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 03/27/1992 |
| From: | Bailey J WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20095J037 | List: |
| References | |
| NUDOCS 9205010054 | |
| Download: ML20095J043 (11) | |
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NO 92-0101 U. S. Nuclear Regulatory Commission ATTH:
Document Control Desk Mail Station P1-137 Washington, D. C.
205$$
Reference:
Letter dated February 26, 1992 from A. B. Beach, NRC to B. D. Withers, VCNOC
Subject:
Docket No. 50-482:
Response to Violations 482/9136-01, 9136-02 and 9136 03 Gentlemen:
Attached is Wolf Creek Nuclear Operating Corporation's (WCHOC) response to violations 482/9136-01, 9136 02 and 9136-03 which were documented in the Reference.
Violation 482/9136-01 and 02 involve multiple er mples of inappropriate procedures or failures to follow procedures.
The responses to these violations provide the specific Jauses and corrective actions applicable to the cited examples.
- .n adi... ion, the response o these violations contain a discussion of more comerwensive corrective actions which are being taken or planned to iq covo the o.Ality of WCNOC procedures and to ensure full compliance with these prwedt.res.
Violation 9136-03 involves inadequate corrective actions.
'he attached response addresses the actions being taken in response to this Jpecific violation.
VCNOC is also pursuing a more comprehensive program to achieve improvements in the VCNOC corrective action.
These efforts have previously been described in VM 92-0040 reply to Notice of Violation (EA v1-161).
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PO Bos 411/ Burhngt>n, KS 66839 e Phone:(316) 364 8831
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An Eosai opportun,ty Employer M F He YET
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NO 92-0101
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Page 2 If you have any questions concerning this matter, please contact me or Mr. S. G. Videman of my staff.
Very truly yours.
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t John A. Bailey Vice President operations JAB /jra Attachment cci A. T. Howell (UKC), w/a R. D. Hartin (NRC), w/a G. A. Pick (NRC), w/a W. D. Reckley (NRC), w/a I
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Atqschment to NO 92-0101
,.*v Page 1 of 9 REPi.Y TO A NOTICE OF VIOLATION Violation (482/9136-01):
Failure To Have Appropriate Procedure,s FinJingi Technical Specification (76; 6.8.1.a requires that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Appendix h of Regulatory Guide (RG) 1.33, Kevision 2.
February 1978.
Criterion V.
' Instructions.
Procedures, and Drawings,' requires, in part, that activities affecting quality shall be prescribed by procedures of a type appropriate to the circumstances.
Three examples of violating this requirement are stated below:
1.
RG 1.33, Appendix A, Item 2.j, requires general operating procedures for going from HOT STANDBY to COLD SKUTDOVN, Mode 3 to Mode 5, respectively.
This is accomplished by GEN 00-006, Revision 17,
' dot Standby to Cold Shutdown.'
Step 4.21.2 of GEN 00-006 requires the determination of which centrifugal charging pump (CCP) is to remain operable with the plant operating in Mode 4 and requires that the breakers for the remaining CCP and the positive displacement pump be racked out.
Contrary to the above, on January 6, 1992, with the plant operating in Mode 4 Step 4.2.1.2 was inappropriate to the circumstances because it did not explicitly prevent placing a CCP control switch in the pull-to-lock position.
The control switch for CCP A was placed in the pull-to-lock position. which rendered the pump inoperable.
CCP B breaker was racked out, and the positive displacement pump was left in operation.
2.
RG 1.33, Appendix A.
Item 8.b(1)(1),
requires procedures for surveillance tests, inspections, and calibrations of the reactor l
protection system.
This is accomplished, in part, by STS 1C-735.
t
' Analog Channel Operational Test Nuclear Instrumentation System Intermediate Rang; N-35 Protection Set I
" Analog Channel Operational Test Nuclear Instrumentation System Intermediate Range N-36 Protection Set II.'
Section 5.2.4 of STS IC-235 and STS IC-236 provides for the establishment of the intermediate range high level reactor trip setpoints.
Contrary to the above, on January 11. 1992. Section 5.2.4 of STS IC-235 and STS IC-236 s1= inappropriate to the circumstances because licensee personnel failed '. o incorporate an approved procedure change into i
l Section 5.2.4.
? tis resulted in the improper establishment of high level reactor trip setpoints for both channels of intermediate range l
monitors
t to if0'92 N01 Attcc
' Pago 2 of 9 3.
RG 1.33, Appendix A,
Ites 8.b.
requires specific implementing procedures for each surveillance test, inspection, and calibration listee la the Technical Specifications.
This is accamplished, in part, by Precedure STS PE-019E, Revision 6,
'RCS Isolation Check Valse Leak Test.'
Step 2.16 of STS PE-019E requires that the motor-operated safety injection accumulator isolation valves ce manually lifted off of their seat to equalize pressure across the valves, after completion of the respective accumulator discharge check valve test.
Contrary to the above, safety injection accumulator isolation valves could not be lifted off of their closed seats without the potential for motor operator damage because procedure step 2.16 ves inappropriate to the circumstances.
Step 2,16 failed to spicify that the control switch seal-in circuit be placed in ' normal',
rather than the
'raintain closed' position.
As a result, on January 8, 1992, motor operator damage associated with Safety Injection Accumulator Isolation Valve EP HV-8808B occurred when technicians lifted the valve off of its closed seat with its control switch in the ' maintain closed' position.
Reason For Violations 1.
On January 6,
- 1992, at 0230 hours0.00266 days <br />0.0639 hours <br />3.80291e-4 weeks <br />8.7515e-5 months <br /> with the unit in Mode 4 Hot
- Shutdown, the positive displacement pump (PDP) was started and Centrifugal Charging Pump (CCP) A was ' secured because of low flow normal-cavitation concerns with the CCP.
CCP A was placed in the after-stop" position.
CCP B had been previously removed from swrvice.
At 0359 hours0.00416 days <br />0.0997 hours <br />5.935847e-4 weeks <br />1.365995e-4 months <br /> the unit entered Mode 3. Hot Standby, and the hendewitch placed in the ' normal-after-stop' position.
At 0427 for CCP B was
- hours, CCP B and safety injection pumps A and B were restored to operable status. On January 6, 1992, at approximately 1958 hours0.0227 days <br />0.544 hours <br />0.00324 weeks <br />7.45019e-4 months <br />.
the unit commenced a cooldown to Mode 4 to repair a leaking relief valve.
At 2126 hours0.0246 days <br />0.591 hours <br />0.00352 weeks <br />8.08943e-4 months <br /> the unit entered Mode 4.
The CCP B breaker was racked out to comply with procedure GEN 00-006
' Hot Standby to Cold Shutdown'.
On January 7, 1992, at 0749 hours0.00867 days <br />0.208 hours <br />0.00124 weeks <br />2.849945e-4 months <br />, it was discovered that the CCP A handswitch had been inadvertently placed in the
' pull-CCP to-lock' position at approximately 1956 hours0.0226 days <br />0.543 hours <br />0.00323 weeks <br />7.44258e-4 months <br /> on January 6, 1992.
A was then started and the PDP secured following the discovsry that both CCPs were inoperable while in Mode 4.
l At the time of discovery, the allowed outage time specified in the Techasesi specification had not been exceeded, therefore, r.o violation i
of the Technical Specification had occurred.
j_
The operators f a d. led to recognize that a CCP had to be operable as required by the Technical Specifications for operation in Modes 4, 5,
I Cold Shutdown, and 6. Refueling.
However, a temporary procedure change l
was initiated to allow the described condition for Modes 5 and 6 in response to the low flow cavitation concerne.
This failure to nadequate procedural recognize the requirements is attributed to guidance which did not provide clear and consistent precautions or limitations to assist in understanding CCP operability during the discussed evolutions.
A contributing factor was the infrequent amount of time the unit is operated in Mode 4.
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Attachm nt to NO 92 0101 Page 3 of 9
,l 2.
Review of this event identified several factors which contributed to the failure to properly perform the surveillance test procedures.
As allowed by procedure, temporary procedure changes to surveillance test procedures STS IC-235 and STS 10 236 were not issued as permenent changes to avoid incorporating the newly calculated setpoint values into the permanent revision process before the final setpoint values were obtained at 100 percent power.
- Instead, temporary procedure changes were written and approved as valid through January ll, 1992.
On January ll, 1992, at approximately 1715 hours0.0198 days <br />0.476 hours <br />0.00284 weeks <br />6.525575e-4 months <br />, copies of STS IC-235 and STS IC-236 were issued in anticipation of performing the procedures within twelve hours prior to physics testing as required by T/S Surveillance Requirement 4.10.3.2.
The temporary procedure changes were issued with the procedures.
Administrative procedure ADM 07-100,
" Preparation, Review, Approval And Distribution of WCGS Procedures "
requires that temporary changes to be used in the performance of surveillance testing shall be referenced at the applicable procedure step prior to procedure usage.
Since it was possible that the surveil!ance test procedures would not be performed prior to exp!:ation of the temporary changes, requiring new temporary procedure changes to be processed, the temporary procedure changes were not referenced at the applicable procedure steps at the time the procedures were issued for use.
The temporary procedure changes were verified to be valid and attached to the surveillance procedures.
The Surveillance Test Routing Sheets, which are attsched to the front of the surveillance test procedures to be performed and includes s verification that the procedure is the current revision with all temperary changes attached, was initialed and dated.
During shift turnover on the night of January 11, it was identified that the temporary procedure changes had not yet been referenced and incorporated at the applicable procedure steps.
The Instrumentation and Control (I&C) Technician who was to perform the test was assigned responsibility of updating the procedure.
- However, when it came time to perform the test, the I&C Technician was involved in other activities and the surveillance tect procedures were assigned to other qualified 16C personnel.
Seeing that the Surveillance Test Routing Sheet verification had been signed, the I&C test performers arsumed that the temporary procedure changes had been properly incorporated.
Therefore, I&C personnel failed to follow procedures when the temporary procedure changes were not referenced at the applicable procedure step prior to procedure usage.
3.
On January 8,
- 1992, because of concerns about piping movement during the performance of surveillance procedure STS PE-019E,
'RCS Isolation Check valve Leak Test,' a procedure change was issued to manually crack l
open, and subsequently energize open, Safety Injection (SI) Accumulator l
Isolation Valves EP HV8808A, B, C.
& D.
The procedure was performed that same day by the day shift for valves EP HV8808C & D without experiencing any problems.
After shift turnover, the engineering personnel responsible for the testing reported to the Control Room and were told to manually crack open valve EP 8808B.
While turning the l
handwheel, a grinding noise was heard.
Investigation into the cause
+.
1 Attachmont to NO 92-0101 Page 4 of 9
,)
revealed that the control switch was not removed from the ' maintained closed' position to the ' normal' position. After unlocking the valve -
i it was declutched and mtnually placement of switch to ' normal' removed from its seat.
The valve was then energized to its open position without experiencing any problems.
Upon closing, a grinding noise was again heard.
After disassembly of the valve actuator, it was determined that the gears had been damaged by the engaged clutch during the initial attempts to operate the valve.
As a result of the electrical logic while the control switch was in
' maintained closed',
the valve motor operator drove the valve closed while it was being opened manually.
Test personnel and operators were not fully aware that this would happen with these motor opetated valves.
Therefore, this event is being attributed to an inadequate procedure in that the procedure revision did not specify that the switch should be placed in the ' normal' position prior to manually lifting the valve from its seat.
A contributing cause was the lack of knowledge that certain MOVs will attempt to reclose, if manually opened, unless the handswitch is placed in ' normal'.
Corrective Actions Thst Have Been Taken And Results Achievedt 1.
On January 7, 1992, upon discovery that the CCP A handswitch was in the pull-to-lock position, CCP A was immediately started and the PDP secured.
Procedures GEN 00-006 and GEN 00-002,
' Cold Shutdown to Hot Standby',
will be revised to provide better instructional guidance in relation to this event.
2.
Upon notification from ILC personnel, Control Room operators halted the i
low power physics testing.
I&C personnel estimated that the values used in the January 11, 1992, calibration had resulted in the setpoints heing set at approximately 36 percent rather than less than or equal to l
25 percent of Reactor Thermal Power (RTP) based on the prestart-up l
estimates.
Technical Specification 2.2.1, applicable in Mode 2. Start-up, and Mode 1 Power Operations, below the low setpoint power range neutron flux interlock setpoint, requires the immediate range trip setpoint to be set at less than or equal to 25 percent with an allowable value of less than or equal to 35.3 percent.
Technical Specification 2.2.1, action statement b, requires that with the Reactor Trip System instrumentation or interlock setpoint less conservative than the allowable value, either adjust the setpoint consistent with f
the trip setpoint value of less than or equal to 25 percent of RTP and determine within twelve hours that the as-measured value of the setpoint error of the affected channel is less than the total allowance provided in Table 2.2-1 when the calculation provided in T/S 2.2.1 is applied, or declare the channel inoperable and apply the applicable action statement requirement of T/S 3.3.1 until the channel is restored to operable status with its setpoint ad justed consistent with the trip setpoint value.
Because it was e1timated that the setpoints exceeded the calculated value for the T/S allowable value of 35.3 percent of RTP, and more than twelve hours had already lapsed since the plant had entered Mode 2.
Control Room operators declared both Intermediate Range Channels inoperable.
Technical Specification 3.3.1 requires two operable Intermediate Range Channels.
The action statement for T/S 3.3.1 states that with the number of the channels l
l
f Attachmsnt to NO 92-0101 Page 5 of 9
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operable one less than the minimum channels operable requirement and with the thermal power level below the intermediate rangs neutron flux interlock setpoint, restore the inoperable channel to operable status prior to increasing thermal power above the interlock setpoints or with thermal power above the interlock setpoint but below 10 percent of RTP, restore the inoperable channel to operable status prior to increasing thermal power above 10 percent of RTP.
Technical Specifiestion 3.3.1 does not provide an action statement for inoperability of more than one channel.
Consequently, Control Room operators entered T/S 3.0.3 on January 13, 1992, at 0735 hourt, and !&C personnel were instructed to reperform STS IC-235 and STS IC-236.
j Cn January 13,
- 1992, at 0805 hours0.00932 days <br />0.224 hours <br />0.00133 weeks <br />3.063025e-4 months <br />.
Control Room operators began to bring Shutdown Bank *B' to its full-out position, while inserting Control Banks in normal overlap to cos;pensate for the positive reactivity addition.
At 0817 hours0.00946 days <br />0.227 hours <br />0.00135 weeks <br />3.108685e-4 months <br />, Shutdown Bank
- B' rods were positioned in their full-out position in accordance with T/S 3.1.3.5 and the action statement was exited.
At 0835 hours0.00966 days <br />0.232 hours <br />0.00138 weeks <br />3.177175e-4 months <br />.
IEC personnel coc1menced reperformance of partial surveillance test procedures to properly calibrate the intermediate range trip setpoint as less than or equal to 25 percent of RTP.
At 0919 hours0.0106 days <br />0.255 hours <br />0.00152 weeks <br />3.496795e-4 months <br />, I&C notified Control Room operators that the partial surveillance test STS IC-235 had been successfully completed, thus restoring Channel N-35 to operable status and T/S 3.0.3 was exited and the appropriate action statement l'o r T/S 3.3.1 was entered.
At 0936 hours0.0108 days <br />0.26 hours <br />0.00155 weeks <br />3.56148e-4 months <br />, the partial surveillance test STS IC-236 was successfully completed, thus restoring Channel N-36 to operable status and the action statement for T/S 1.3.1 was exited.
Using actual intermediate range current data taken during the performance of STS RE-011
'RCS Total Flow Rate Hensurement.' on January 24,
- 1992, an evaluation of the January 11, 1992 setpoints concluded that these setpointe did not exceed the actual values for the T/S allowable values.
Therefore, the Intermediate Range Channels were j
3.
Following observance of the noise, the breaker for the valve was racked cut with the valve in its normal position.
A work request was issued j
to troubleshoot and/or repair valve EP HV8808B.
Some actuator components were discovered to be damaged.
The valve was repaired, tested, and returned to service.
Correttive Action That Vill Be Taken To Avoid Further Violations:
1.
All GEN 4.nd SYS procedures will be reviewed by December 31, 1992 to ensure app.opriate precautions / limitations are clearly incorporated.
(
2.
To prevent racurrence of this event, a step was added to RXE 01-002.
i l
' Reload Low Power Physics Testing,' that requires Reactor Engineering l
personnel to verify that the surveillance test procedures used to adjust and test the Intermediate and Power Range Channels within twelve hours of physics testing use the setpoint values based on the correction factors determined for the current cero load.
Because this verAfication will be performed by persons not involved in the testing of the Intermediate and Power Range
'hannels, this independent verification should prevent this event's rc 4rrence. Additionally, the l
f Attachm3nt to NO 92-0101 Page 6 of 9 details of this event were issued as required reading for applicable IEC personnel to emphasize the importance of ensuring that all aspects of proper procedure performance have been completed prior to procedure perfornance and during the post-test review.
3.
To prevent recurrence of this event, STS PE 019E has been revised to require placing the handswitches to valves EP HV8800A, B, C, & D in the
' normal' position prior to manually opening the valve.
Also, a list of all motor operated valves with a similar logic has been prepared and provided to the Operations, Maintenance and Modifications.
Instrumentation and Controls, and Training groups.
Comnrehensive Corrective Actionst Volf Creek Nuclear Operating Corporation is aggressively addressing performance and program improvement issues based upon a review of Quality Assurance Audits and Surveillances. Licensee Event Reports, NRC Inspection Reports, and INPO Assesstents.
These issues formed the initial basis for the Management Action Plan (HAP) which was discussed in the Reply to Notice of Violation EA 91-161 (letter VM 92-0040 dated March 20, 1992).
In addition to the items discussed in WM 92-0040, the MAP also specifically addresses improvements in procedural guidance.
The objective of this effort is, in part, to enhance proceduto usability and ensure compliance.
WCH00 has scheduled a meeting on April 17,
- 1992, to provide the Nuclear Regulatory Commission a more comprehensive description of this program.
Date When Full Compliance Vill Be Achieved:
Full compliance will be achieved on December 31, 1992, upon completion of the review of GEN and SYS procedures Violetion (482/9136-02):
Failure To Follow Procedures l
Findinn l
TS 6.8.1.a requires that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of RG 1.33 Revision 2, February 1978.
Two examplos of violating this requirement are stated below:
1.
RG 1.33, Appendix A, Item 8.b(1)'.k),
requires specific procedures for surveillance tests on control rod operability and scram time tests.
This is accomplished by Surveillance Procedure STS RE-007 Revision 5
" Rod Drop Time Measurement.'
Step 5.4.22.10 of STS RE-007 requires personnel to reconnect all control rod drive mechanism lif t coils in the bank being tested using the lift coil disconnect switches.
Contrary to the above, on January 10,
- 1992, the lift coil disconnect switches for seven rods in Control Dank B were not reconnected.
This resulted in a red control urgent failure alarm during rod withdrawal on January 12 1992.
0 Attachasnt to NO 92-0101 Pago 7 of 9 l
2.
RG 1.13, Appendix A,
Item 8.b91)(1),
requires procedures for surveillance tests, inspections, and calibrations of the reactor prctection system.
This is accomplished, in part, by STS IC-507A, Reviolon 5, ' Calibration Steam Line Pressure Transmitters.'
Step 5.10.4 of STS IC-507A requires the isolation of Main Steam Pressure Transmitter AB PT-526.
'ontrary to the above, on January 18, 1992, instrumentation and control technicians isolated AB PT-525 instead of AB PT-526.
This resulted in a steam generator level transient.
au r For The Violations 1.
On January 12,
- 1992, while manually withdrawing control banks in overlap for the approach to criticality, a rod control urgent failure alarm was received in the Control Room when withdrawal contenced in control bank B.
Investigation identified that all rods on control bank B,
with the exceptien of Rod K-14, were found to have their lift coil disconnect switches in the disconnect position.
It was determined that these svitches were not returned to the connected position during performance of surveillance procedure STS RE-007,
' Rod Drop Time Heasurement,' as required by step 5.4.22.10.
This event is attributed to failing to follow procedures resulting from ineffective communications.
The ineffective communications resulted from the failure of test personnel on one end of a communication link to confirm the completion of certain steps by test personnel on the other end of the link.
2.
On January 18,
- 1992, while performing STS IC-507A.
Revision 5,
' Calibration Steam Line Pressure Transmitters '
an Instrumentation t Control (ILC) technician mistakenly isolated Hain Steam Preasure Transmitter AB PT-525 rather than AB PT-526.
This resulted in a loss of pressure compensation of the Steam Flow Channel for Feedwater Control Valve AE FCV520 which caused it to throttle down and decrease the level in Steam Generater (S/G)
'B'.
As in the first example, this communication was also taking place through a communication link.
An interview with the personnel involved revealed that the field technicians were not communicating with each other in a fashion conducive to stimulate and enhance self checking attributes.
Review of the procedure detennined that when followed, the procedure is accurate, clear, and concise.
Therefore, this event is being attributed to a failure to follow procedures which resultad from ineffective communication.
Corrective Actione That Have Been Taken Ar.d Results Achieved:
1.
Control Room operators inserted the control rods in bank A to 113 steps to ensure proper overlap when withdrawal recommenced.
The fift coil disconnect switches for bank B were reconnected and the rod control urgent failure alarm was reset.
Rod withdrawal was recommented.
The individual responsible for failing to follow the procedure was counseled on the need to follow procedures and to receive confirmation of completed steps when instructions are given over a communication link.
Attachm2nt to NO 92-0101 Page 8 of 9 e
.s 2.
Upon receipt of the S/G
'B' flow mismatch alarm, the operators selected manual on the feedwater control valve and opened it to return feed flow above steam flow.
All test signals and isolated instruments were returned to normal.
Corrective Actions That Vill Be faken To Avoid Further Violations:
1.
To preclude recurrence of this event, surveillance procedure STS RE-007 was revised to incorporate c final verification at step 6.7 that the lift coil disconnect switches for all control rod drive mechanisms are in the connected position.
2.
IsC technicians have been counseled on the necessity and benefit of proper communication and its relation to "self-checking".
A shop policy has been developed which addresses proper communication techniques when communication links are used for field activities that are controlled by a remote authority, e.g., the Control Room.
Comprehensive Corrective Actions Wolf Creek Nuclaar Operating Corporation is aggressively addressing performance.and prsgram improvement issues based upon a review of Quality Assurat.ce Audits and Surveillances, Licensee Event Reports. NRC Inspection Reports, and INPO Assessments.
These issue-formed the initial basis for the Management Action Plan (MAP) da. cussed in WM 92 0040 Raply to Notice of Violation (EA 31-161).
In addition to the items discussed in WM 92-0040, the HAP also specifically addresses improvements in procedural guidance and communications.
The objective ot this effort is, in part, to enhance procedure usability and ensure compliance.
WCNOC has scheduled a meeting on April 17
- 1992, to provide the Nuclear Regulatory Commission a more comprehensive descriotion of this program.
Date When Full Comoliance Will Be Achieved:
Full compliance has been achieved.
Violation (482/9136 03):
Inadeauste Corrective Actions l
Finding:
Title 10 CFR. Part.PO Appendix B. Criterion B, Criterion XVI,
' Corrective Action." requires, in part, that measures shall be established to assure that conditions adverse to quality, such no failures, malfunctions, deficic..cier.
deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
Contrary to the above, in November 198P.
a water hammer event that occurred in the essential service water system piping that supplies the containment coolers was identified but not corrected.
Engineering Evaluation Request uB-EF-OR was initiated, but the significance of the event was not determined, nor were any corrective actions taken.
The water hammer event i
recurred during the 1991-1992 refueling outage.
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j Attachmsnt to NO 92-0101 Page 9 of 9 J
Reason For The Violation The water hamaer event was identified as occurring when Essential Service Water (ESW) Pump
'A' was stopped then restarted to verify EDG load rejection capability during performance of surveillance procedure STS KJ-001A.
' Integrated D/G and Safeguards Actuation Test - Train A*.
The water hammer was caused by draining of the ESW piping to the containment coolet s through the common header to components on lower elevations and out to the lake.
Draining stopped when vapor pressute equaled the water column height drop.
Upon pump restart, the surge of water flow through the drained piping caused the abrupt pressure transient and resulting water hammer.
After the 1988 occurrence. Nuclear Plant Engineering (NPE) personnel made an incorrect assumption during the initial review of the document which resulted in a low priority assignment.
This assumption was that only an enhancement was needed and that all other associated actions were corrected by others.
A second review noted that additional information was required in order to properly address the document.
The document was then returned for more information in July 1991.
This event is being attributed to an inadequate review resulting from an incorrect assumption.
This assumption was based on conflicting definitions tht subject document in NPE of Engineering Evaluation Requests (EER) procedures and ADM 01-053,
" Engineering Evaluation Requests.'
NPE procedures denote EERs as being used as a request for information only.
This is contrary to administrative procedure ADM 01-053 which denotes EERs an addressing technical concerns.
Corrective Actions That Have Been Taken And Results Achievede Corrective action has been taken to eliminate the water hammer during performance of surveillance procedure STS KJ-001A &
B.
An initial evaluation of the effects the water hammer had on the Essential Service Water System (ESW) piping did not identify any damage.
A thorough design review of the water hammer event has been initiated to confirm that a significant condition adverse to safety does not exist.
Completion of this review will occur by June 30, 1992.
Corrective Action That Will Be Taken To Avoid Further Violations:
To ensure that a similar condition doce not exist at the Wolf Creek Generating Station, a review of all open EERs within NPE responsibility will be completed by June 30, 1992.
The review will also prioritize these EERs.
Additionally, the discrepancy between the NPE procedures and ADH 01-053 will also be resolved by June 30, 1992.
Date When Full Compliance Will Be Achieved:
Full compliance will be achieved by June 30,
- 1992, upon completion of the thorough design review of the water hammer event, the review of open EERs within NPE's responsibility, and resolution of the procedure discrepancy.
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