ML20113H520

Responds to NRC Re Violations Noted in Insp Rept 50-482/92-08.Corrective Actions:Effluent Radiation Levels Immediately Returned to Normal & Procedure Re Hydrogen Recombiner Inlet Pressure Control Valve Revised

ML20113H520
Person / Time
Site:	Wolf Creek
Issue date:	07/30/1992
From:	Withers B WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
WM-92-0127, WM-92-127, NUDOCS 9208040195
Download: ML20113H520 (5)

Text

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4 LFCREEK W@ NUCLEAR OPERATING Bart D Withers Presdent and Cnitt ( aucutwo Offn.et July 30, 1992 WM 92-0127 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, D. C. 20555

Reference:

Letter dated June 30, 1992 from A. B. Beach, NRC '

to B. D. Withero, WCNOC

Subject:

Docket No. 50-4G2: Response to Violation 482/9208-01 and 9208-02 Gentlemen:

Attached is Wolf Creek Nuclear Operating Corporation's (WCNOC) response to Violations 482/9208-01 and 9208-02 concerning a failure to have appropriate procedures, and failing to follow procedures, respectively.

If you have any questions concerning this matter, please contact me or Mr. S. G. Wideman of r.iy staf f .

Very truly yours, Bart D. Withers President and Chief Executive Officer BDW/aem Attachment cci A. T. Howell (NRC), w/a J, L. Milhoan (NRC), w/n G..A. Pick (NRC). w/a V. D. Reckley (NRC), w/a i

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Attachment to WM 92-0127 Page 1 of 4 REPLY TO A NOTICE OF VIOLATION Violation 482/9208-01: Failure To Have Arrropriate procedurer.

findinn [

TS 6.8.1.a requires that written procedures shall be established.

Implemented. and maintained covering the applicable procedurca recommended in Appendix A of RG 1.33. Revision 2 February 1978. 10 CFR Part $0 Appendix B. Criterion V. ' Instructions, procedures, and Drawings.'

requires, in part, that activities affecting quality shall be prescribed by  ;

prt,cedures of a type appropriate to the circumstances. One example of violating this requirement is stated below:

RG 1.33. Appendix A. Item 7.c.(1), requires procedures for the collection, storage, and discharge of gaseous waste. This is accomplished, in part, by Procedure SYS HA-200. Revision 10 ' Waste Gas System Startup and Shutdown."

Contrary to the above, on April 23, 1992 SYS HA-200 was determined to have

- been inappropriate to the circumstances because it did not provide adequate guidance for placing the waste gas-decay tank in service. As a result, an inadvertent radioactive release of gaseous waste occurred in the radwaste building.

Reason For Violation '

At 0300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br /> ou April 23 1992, a ' Process Radiation - High" alarm was received in the Control Room. It was aubsequently determined that a ono pound-per square inch (psi) decrease in Waste Gas Decay Tank (WCDT) #4 had occurred when the Radwante Operator placed the tank in recirculation mode, i It was determined that all controls and equipment were in the proper configuration as the Radwaste Operator was preparing to start the waste gts compressor bowever, while reviewing the next few steps of the startup procedure, the high pressure VGDT that was in service began . pressurizing the hydrogen recombiner past tue relief setpoints. The sample lines f rom the recombiner have relief valves that lift at 50 psi and discharge to the room ventilation system when in the standby mode (the mode the system was in at.the time).

This event occurred as a result of the inlet pressure control valve being in- the manual position as required by system procedure SYS HA-200 ' Waste Gas System Startup and Shutdown.'- which allowed immediate pressurization of the recombiner. .It was necessary in the past for the valve to be in manual because _of- the _ poor discharge pressure from .che compressors. . Nett -

compressor internals are now present which can' allow operators to start the system with tho' valve in the automatic position. It was not identified- i

- until this event had occurred that the proceduru should be changed because the procedure was as written for- operation of the. system in the manual

- position. An additional factor in the system relief valves lif ting was '

that the recombiner sample isolation valves were in an open position, as specified - by ' system procedure SYS . HA-205 " Gaseous Radwaste Syst.em Gas Analyzer Racks (HA-161/HA-162) and Catalytic Hydrogen Recombiners (SHA01A/SHA01B Oparations.' while- the hydrogen- analyzero were in the standby mode.

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Attachment to VM 92-0127 Page 2 of 4 I

Cerrective Aq, tion TlatJas Beett,,Taken And ResultMdL eved i Effluent radiation levels immediately returned to normal following the  ;

initial spike. Control Room Operators cleared the process radiation alarm, reset the radiation monitor and notified Chemiatty personnel of a pos e.tble  ;

radioactive gas release. The dose rates of the telease were subsequently calculated and determined to be signif.fcantly below the regulatory limits.

93rective Act.ipn That Vill Be Tahnti t To Avoid Further Violations:

I System Procedure 3YS HA-200 has been revised to ensure that Hydrogen Recombiner Inlet Pr?ssure Control Valva PCV 1103 is in th6 automatic position and initially set to control at 20 psi to prevent rapid  !

pressurization. Additionally, system procedure SYS HA-205 has been revised i to ensure the analyzer rack instrument sample isolation valves are closed until the system is recirculating and all parameters are stable. These actions should be sufficient to prevent overpressurizations during startup transients, ,

Date When Full.CompU,ance Vill Ee Achieveds ,

Full compliance has 1" en achieved.

Additlonal Informatice;

- A similar waste gas release had occurred on March 3, 1992 during placement of a high pressure vaste gas decay tank in recirculation while the system was in the low pressure mode (an example of violation 482/9202-02, " Failure -

To Have Appropriate Procedures'). The. root cause of the March 3 event wan i determined to be a failure of system procedure SYS HA-200 to t, t a t e that prior to switching waste gae decay tanks, ensure the syrtem is in the proper operational line-up for the pressures contained in the oncoming .

waste gas decay tank The event discussed in this response may have resulted in 9 similar ,

outcome; however, the operator was in the proper pressure mode. This a procedural inadequacy is unrelated and therefore the investigation into the March 3 event would not have identified the procedural inadequacy discussed in this response, e

Violation 482/9208-02: Failpro To Follow Procedures Findinns .

Technical Specification (TS) 6.8.1.a' requires-that written procedureu shall be. established, implemented, and maintained covering the applicchie

. procedures recommended ir. Appendix A of Regulatory Guide (RG) J.33, Revision 2, February 1978. RG 1. 33, - Appendix A, -Item 9.a. requires that maintenance that can affect the performance of safety-related equipment should= be and performed . in accordance with wrltten procedures, properly-documented preplanned instructions, or drawings appropriate to the circumstances. Thi s --.is accomplished, in _part .. by_. Procedure ADM . 01 - 05 7 .

Revision 24, " Work Request."

Step 2'1 of Procedure ADM 01-057 requires that the work request will be used to document and control work'on plant systems.

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e Attachment to WM 92-0127 Page 3 of 4-Contrary to the above, on May 21, 1992, licencee personnel performed maintenance on the reach-rod attachment for Valve Bd V322 (boric acid filter drain valve) without a work request. The work was pe rf ornied to remove interferences and allowed the valve to be positioned fulf.y closed, i

EeJIrn For The Violation On' Hay 21, 1992, following changeout of the Boric Aeld Filter, the diachragm and stem to Boric Acid Fifter Drain Valve BG V322 was found to be damaged. The bonnet assembly was replaced in accordance with the work instructions for Work Request (WR) 02652-92. Valvs BG V322 was opened and closed several times to ensure proper operation. The system was restored

-end post maintenance testing was performed to check the bonnet vent plug with the valve in service.

A short time later, the Boric Acid Tanks (BAT) were placed on recirculation. After approximately 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. Control Room Opetators identified a decrease in BAT levels of 7.5 percent each. The level decrease was determined to be the result of a bolt - on the val'ie-to-reach rod attachment coming -in contact with a support, thereby preventing full closure of valve BG V322. Hechanical Maintenance personnel adjusted a stud and nut on the reach rod to allow the valve to completely close.

It was subsequently identified . that the stud and nut adjustment had been performed without the issuance of a WR. An investigation revealed that the Mechanical Maintenance personnel responsible for the adjustment.were aware of the work performed on valve BG V322 during the -previous shift but perceived the adjustment as a part of the retest on VR 02652 92. -They were

. unable to locate WR' 02652-92 that night, not knowing the work request had already been processed for closure. -The work was noted-in the daily work log used for . turnover. Additionally, during review of the log the next morning, the supervisor also failed to identify that VR 02652-92 had already been processed .for closure and also perceived the adjustment as

-continuing work on VR 020$2-92.

This event is - attributed to a personnel error in falling to follow administrative procedure ADM 01-057, ' Work Request ' which requires issuance of a WR.to document and control work performed on plant systeme.

Also contributing to this event was a work program -inadequacy where the program in place did not provide the worker an easy method to locate the WR paperwork. There was no method for personnel to determine if a package was

-to be worked or completed.

Additionally, it was determined . that had the post maintenance testing, following the boric acid filter replacement. - been ef fective. the. problem with valve BG V322 not fully closing may have been discovered and the work completed under a revision to WR 0265h92 prior to its closure,

' Corrective Action That Has Been Taken And Respits Act}ieved:

-- Following -- adjustmen t of the - valve - and ensuring that there would be no leakage from the BAT. Control Room Operators transferred inventory from PAT' L 'B' to BAT-"A* and added boric acid to BAT *B' from the Boric Acid Batching

Tank. In accordance with system procedure SYS BG-206 ." Boric Acid System l Operaticn.'

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Attachment to VH 92-0127 Page 4 of 4 l 1

Following identification that a WR should have been used for the  !

adjustments performed on valve EG V322. VR 03080-92 was written to document l the activities.

1 Corrective Action-That Wjl1 *e Taken To Ayoid Further Violstions i A meeting was held with the involvec' senior. lead, and cupervision personnel to review and understand the sequence of events. Also, although unrelated to this event, the Supervisor Mechanical Maintenance has been holdit'g review sessieno on the use of administrative procedure ADM 01-057 and the vork request process. These sessions are conducted in small groups

. to encourage opennets and feedback on the program and process. At the time of this event, the involved crews had not participated .In the review l session. . Further corrective action is to complete a review. session with I the remaining Hechanical Maintenance personnel. Additionally, improvement I han - been made to assist Me hanical Maintenance personnel track the status ,

and work package- of items that had not been previously included on the >

seven day work schedule.

Since the occurrence of this- event. the post maintenance testing  !

requirements as specified in administrative procedure ADH 01-057 have been i revised. The post taaintenance test block on the WR f orm has been changed to require. more specif.ic inform tion on the test, including: Test i De9cription, Responsible Group. Acceptance Criteria. and Results.

Hafntenance management and. supervision continue- to monitor the effectiveness of post maintenance wating.

Date When Full Comn11ance Vill _1t,,. Achieved:

Full compliance ~ will be achieved by. Sept. .ber 10, 1992, following completion of-the-review sessions with the remaining Mechanical Maintenance personnel- who have not participated in- the review sessions of '

administrative procedure ADM 01-057.

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