ML20114A962
| ML20114A962 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 08/21/1992 |
| From: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-89-04, GL-89-4, WM-92-0136, WM-92-136, NUDOCS 9208240171 | |
| Download: ML20114A962 (4) | |
Text
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W6LF CREEK
' NUCLEAR OPERAT8NG CORPORATION Bart D. Withers -
President Ord Chief Executrue Othccr WM 92-0136 U.
S. Nuclear Regulatory Commission ATTN: Document Control Desh Mail Station P1-137 Washington, D.
C.
20555 Re f e re etce :
Letter dated July 24, 1992 from A.
B.
Beach, NRC to B.
D. Withers, WCNOC
Subject:
Docket No. 50-482:
Response to Violation 482/9209-01 Gentlemen:
-Attached is Wolf Creek' Nuclear Operating Corporation's (WCNOC) response to Violatien 482/9209-01 concerning a violation ef Technical Specification 4.0.5.
If you have any questions concerning this - matter, please contact me or Mr. Kevin J. Molas of my staff.
Very truly yours, Bart D. 1'it hers President and Chief Executive Officer BDW/jra Attachment ec:
A.
T, Howell (NRC), w/a J.
L. Milhoan (NRC), w/a G. A.
Pick (NRC), ~ w/a W.
D.
Reckley (NRC), w/a 240061
[f[O/
8240171 920821 ADC;CK 0500 2
. Box 411. Burkngicrt KS 66839 : Phone- (316) 364-8831 g
- An Eqtal Opporturuty Empioyer M F HCVET
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' Attachment to WM' 92-0136 Page-1 of 3 REPLY TO A NOTICE OF VIOLATION Violation 48?/9209-01: Violation of Technical Specification 4.0.5 Findino:
During an NRC inspection conducted June 1-5,
- 1992, a violation of NRC
- requirements was identified.
In accordance with the " General Statement of Policy:and Procedure for NRC Ir. formation Actions, 10 CPR Part 2, Appendix C, a
the violation is listed belew:
The WCGS Technical Specification 4.0.5 requires, in part, that inservice testing of ASME Code Class 1, 2,
and 3 pumps and valves be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code
.and. applicable Addenda.
Section-X2 of the ASME Boiler and Pressure Vessel Code, paragraph IWP-4120, states that, - "The full-scale range of each instru'nent shall be three'. times the reference value or_less."
Contrary to the above, inservice testing of an ASME Code Class 2 pump, Containment. Spray Pump A,
was conducted on May 20, 1992, utilizing. a temporary differ.ential pres.sure gauge with full-scale range of 0-10 inches water - colurm.
The' reference value fet ;he-specific differential pressure was 2.24 inches of water column.
E,eason For The Violation:
On June 4, 1992,.during an=NRC-inspection of the Wolf Creek Generating Station
- 'WCGS) - Inservice Testing 2 (IST)- Program, it was - identified that a temporary differential pressure gauge, used in surveillance testing.of Containment Spray Pumps A &.D, was not in compliance with Section XI of the American Society of Mechanical Engineerc (ASME) Boiler and Pressure vessel Coce, paragraph IWP-
-4120.
Investigation into the condition revealed that use of the 0-10 inch ' water column (inwc) gauge was previously identified prior to the NRC_ inspection and that a 990 model Contro1otron was in.the process of being calibrated for use
- in lieu of the 0-10 inwc gauge.
Additionally, upon initial discovery of this condition, the IST-engineer conducted a ' review - which determined that use of the 0-10-inwe gauge would not have prevented the Containment Spray Pumps from meeting their acceptance criteria.
However, this condition and resulting corrrative actions were'not documented as required by plant procedures.
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Att'achme nt to WM 92-0136 Page 2 of-3 9
Tc - be in ' compliance with the ASME Code, it would be necessary to have a
. reading __of 3.33 inwc or higher with the 0-10 inwc gauge or use a gauge with a smaller range.
Differential pressure gauges with a range less than 0-10 inwe are not available onsite for use.
Because of the time frame since the initial utilization of this gauge, it cannot be determined if a conscious decision was originally. made - to use a gauge that did not meet ASME Code requirements.
Failure.of the IST engineer to immediately document this condition in
[
accordance with the plant procedures is attributed to a personnel error, i-
-Corrective Action That Has Been Taken And P.esults Achieved:
When this ' condition was identified during the NRC inspection, a Corrective Work Request (CWR) was initiated to document the ASME Code non-compliance. An operability review'was conducted in accordance with administrative procedure ADM 02-024,
" Technical-Specification operability."
The Engineering
--Disposition to the CWR concluded that use of the gauge had no effect on the ability of the pumps to perform their design function and that the intent of ASME Section. XI was met; Additionally, - an evaluation of reportability.was performed and the condition was determined to not be reportable.
Because this condition had been identified prior to the NRC inspect 3on, a 990
.model Controlotron was already in the process of being calibrated for use in
-lieu of. the 0-10 inwc gauge.
Surveillance procedures STS EN 100 -A&B,
" Containment Spray P ump ~ A (B) Inservice Pump Test," have been revised to replace the gauge with the Controintron.
Correctly.e-Action That Will'Be Taken To Avoid Further Violations:
Al review by WCGS: personnel of the IST Program against the guidance in Generic L-Letter 89-04, " Guidance on Developing _ Acceptable Inservice Testing Programs,"
i had identified several enhancements needed to strengthen the program.
As a l'
result of'this review, an independent assessment of the IST Program by an outside consulting firm was initiated.
Several' weaknesses and improvement
--items were identified in the firm's assessment report.
Performance I -
. Improvement ' Request s have been initiated to address the assessment items.and are'being factored into the overall IST Program review.
Also, as recommended by the consulting firm, creation-of a " Bases Document," is being evaluated to idsntify ' the testing -requirements for _each component and-the basis for-inclusion or exclusion in the IST Program.
A ' review of other IST pump - procedures identified other instances where the
-range of the. instrument was not in accordance with ASME Section XI.
These-other instances - of code non-compliance were also documented and engineering l_
- evaluations. subsequently determined that they also had-no effects on system cperability, l --.
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Attachment to WM 92-0136 Page'3 of 3 Administrative procedure ADM 05-200, "ASME Code Testing of Pumps and valves,"
was revised to clearly identify what actions must be.taken to address ASME Code non-compliance conditions.
This change ensures that ASME Code non-compliance conditions identified in the future are documented in accordance with the corrective action program. Additionally, this procedure revision has been' discussed with the IST engineer to enev_e awareness of the requirement to immediately document and address these conditions.
~
During the week of July 20, 1992, the IST engineer attended an NRC Symposium on Inservice Testing of Pumps and Valves.
This provided the engineer with
. insights into issues and-problems which are present throughout industry so that-they can.be addressed and monitored for their effects on the WCGS IST Program.
Performance of surveillance procedures STS EN-100 A&B have been satisfactorily completed for the Containment Spray Pumps with the Contro1otron being used instead of the 0-10 inwc gauge.
Date When Full Compliance Will Be Achievedt Full-compliance will be achieved by March 1, 1993 upon completion of the IST Program review in conjunction with the actions taken in Licensee Event Report 482/91-007-00.
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