ML20127D453
| ML20127D453 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 01/11/1993 |
| From: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| WM-93-0006, WM-93-6, NUDOCS 9301150229 | |
| Download: ML20127D453 (8) | |
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NUCLEAR OPERATING CORPORATION January 11,1993 Dart D. Withers Prevdent arid WM 93-0006 chief t. ecui>ve off.cc, U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, D. C.
20555
Reference:
Letter dated December 11, 1992 from A. B. Beach, NRC, to B. D. Withers, WCNOC
Subject:
Docket No. 50-482:
Response to Violations 482/9231-01, 9231-02, and 9231-04 Gentlemen Attached is Wolf Greek Nuclear Operating Corporation's (WCNOC) response to violations 482/9231-01, 02, and 04 which were documented in the Reference.
Violation 482/9231-01 involved the failure to revise Alarm Response Procedure ALR 00-047E to provide an alternate method of draining the Refueling Water Storage Tank.
Violation 482-50/9231-02 involved inadequate post-maintenance test procedures, and violation 482-50/9231-04 concerned a failure to' properly implement a procedure when changing the operating pump f rom the. centrifugal charging pump to the positive displacemer* pump.
If you have any questions concerning this matter,-please contact me at (316) 364-8831 extension 4000 or Mr. Kevin J. Moles at extension 4565.
Very truly yours, a
j Bart D. Withers President and Chief Executive Officer BDW/jan Attachment cc A. T. Howell (NRC), w/e J. L. Milhoan (NRC), w/a G. A. Pick (NRC), w/a W. D_ Reckley (NRC), w/a m.
9301150229 930111 PDR ADOCK 05000482 G
'PO. Box 4 M i Burkngton. KS 66839 ' Phone; (316) 364 8831 O
An Equal Opportun4y Ernp: oyer M F HCVET I ft
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Attachment to WM 93-0006 Page,1 of 7 j
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'l Reply to a Notice of Violation Violation (482/9231-01):
Failure to Revise Alarm Response Procedure Findinn:
Technical Specification (TS) 6,8.1.a requires that written procedures:shall be established, implemented, and maintained covering the applicable - procedures recommended in Appendix A of Regulatory Guide (RG) 1.33, Revision 2,
dated-February 1978.
RG 1.33, Appendix A, Item 5, specifies, in part, that. alarm procedures should contain guidance for immediate operator action.
Alarm Procedure ALR 00-047E, Revision 4, 'RWST LEV.HILO,' Step 4.4.3, directs personnel to drain the refueling water storage tank (RWST) to the floor-and equipment drain system by using valve BN V017, RWST drain valve.
Contrary to the above, on October 22, 1992, after determining that the normal drain path from the_ refueling water storage tank, downstream of Valve BN V017, was blocked by a flange,-the licensee failed to change ALR 00-047E to provide an alternate method of draining the tank.
Reason For The Violation:
On October 15, 1992, at 1035 CST, a RWST high level alarm was received-in the control room.
In accordance with Alarm Response Proceduct ALR 00-047E Chemistry was requested to sample the RWST and the Auxiliary Building Watch was requested to drain some of the tank.
At 1100 CST, Valve BN V017.-RWST drain valve, was opened to drain some of the contents. 1At 1125 CST, with:no apparent level change to the RWST the Control Room Linstructed the _ Auxiliary -
Building Watch to mechanically massage Check Valve LF V034, but again no level change was noticed.
At 1139 CST, Valve BN V017 was closed.
At 1229 a lineup was completed to drain.the RWST to the Spent Fuel Pool using procedure SYS'EC-200.
This alternate metho'd-of draining the RWST was, therefore, conducted in-accordance with an approved procedure.
It was later determined that a flange downstream of Valve BN V017 contained a blank, therefore preventing flow-through the valve.
An Information Tag was placed;on the Chemical and Volume Control System Panel to nralfy operators Valve LN V017 was inoperable and that:
alternate methods of draining.the tank should _ be. used.
The. Shift Supervisor.
chose to use the Information Tag for configuration control until-the bicckage in the _ line could be removed in' the near future.
This decision was made primarily because Procedure ADM 02-110. " Control of Information Tags
- does not provide guidance on when a temporary procedure change is necessary in place of1 or in conjunction with an information tag.
As-a result a temporary procedure -
change was not initiated.
However, appropriate actions were-taken_to drain' the RWST.
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. Attachment to WM-93-0006
.Page,2 of-7 Corrective-Steps That Have Been Taken And Results Achieved:
Alarm Response Procedure ALR 00-047E, 'RWST LEV HILO'-was revised and approved-on December 12, 1992, to include an alternate method ' of draining the RWST.
This can be and was appropriately accomplished by : transferring water to the Spent Fuel Pool utilizing Procedure SYS EC-200 which does not require the1useL of Valve BN V017.
Corrective Steps That Will Be Taken To Avoid Further Violations:
Procedure ADM 02-110
" Control of Information Tags" will be revised to provide guidance on when a temporary procedure change is required in-place of or in conjunction with an information tag.
This procedure change will be completed-by June 1, 1993.
Date When Full Compliance Will Be Achieved i
WCNOC is curreatly in compliance with TS 6.8.1.a and Regulatory-Guide 1.33.
l Additional guidance on temporary procedure changes will be available by June 1, 1993, upon revision of Procedure ADM 02-110.
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Attachment to WM 93-0006 Page,3.of 7 Violation (482/9231-02)
Inadeaunte Post-Maintenance Procedures Finding:
Technical Specification 6.8.1.a requires that - written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision'2, dated February 1978.
Regulatory Guide 1.33, Appendix A, Item 9.a. requires _that maintenance that affects the performance of safety-related equipment should _ be properly _
preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.
This is accomplished, in part, by Procedure ADM 01-057, Revision 25, " Work Request."
, Step 2.A of Procedure ADM 01-057 specifies that post-maintenance testing is used to verify that the maintenance was performed correct *>, that the equipment performs its intended function, and that a new deficiency _ has not been created.
Contrary to the above, the post-maintenance test procedures performed on September 17, 1992, in accordance with procedures and instructions specified on Work Request 04681-92 did not determine that Valve BN HV8812B, Limit Switch Rotor 3,
was not properly adjusted.
The misadjustment rendered Valve BB PCV8702B inoperable, which would have prevented placing Train B residual heat removal in service for long-term hot leg recirculation cooldown, if needed, for approximately 55 days.
Safety sinnificance The violation states that the inoperability of the interlock rendered Residual Heat Removal (RHR) Train B incapable of being used for hot leg recirculation.
The more correct wording would have been to state that the - inoperability - of the interlock would have caused difficulty in placing RHR _ Train B in service for normal low pressure RHR cooling.
Hot leg recirculation ~ when used in conjunction with discussions of the RHR system means the ' post-accident LOCA lineup where the Containment Recirculation Sumps supply water to the-RHR pump which in turn supply water to-the RCS_ hot legs via an RHR connection to loops 2 and 3. and also supply water to both ~ Safety. Injection (SI)_. pumps for injection into all four hot legs via separate SI connections.
The interlock problem would in no way have inhibited -' the post-accident lineup.
Itc would have inhibited the lineup of B RHR suction to the loop 4-hot, leg, but this is not the same as hot ~1eg recirculation - and is not as safety-significant as those interlocks in the post-LOCA mode malfunctioning.
Reason For Violation:
in On September 17, 1992, corrective Work Request 04681-92 was performed to -
repair the soft clutch mechanism and replace the motor pinion gear of Valve BN p
_HV8812B, Maintenance to the valve utilized MOV Setpoint Document E-025-00007.
Due to a data transfer - error-from WCMA to E-025-00007, Rotor 3 ' to BN HV8812B was incorrectly set.
Performance of Procedure STS BN-201, " Borated l
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-Attachment to WM-93-0006.
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Page,4 of 7-Refueling Water Storage System Inservice Valve Test' was required as a posti maintenance tect.
STS BN-201 provides guidance for stroke time testing of valves that are located in the flow path from the refueling water storage tank to safety-related pumps.
This is accomplished, in part, by stroking Valve BN HV-8812B and verifying the indicating light on the control-switch, and measuring the valve closing time.
STS BN-201 was successfully completed with no problems identified.
On November 7,
1992, while operators performed.STS BN-201, it was noted that the engineered safety features status panel light indications for Valve BN HV8812B occurred in a different order than expected.
STS BN-201 does not require operators to monitor _the status panel indicating lights. Although STS BN-201 was successfully completed, this post-maintenance testing did not identify that Limit Switch Rotor 3 was incorrectly set.
Several additional factors contributed to the failure to identify Rotor 3'to Valve BN HV-8812B was incorrectly installed.
Section 8.2 of Procedure MGE-E00P-02,
- Limitorque Operator Maintenance",
requires workers to request operators to cycle the valve being worked and verify the correct Indicating Light, Computer, Status Panel, and Interlocking Contacts.
During restoration on September 17, 1992, the status panel was inoperable due to a blown fuse.
The interlock contacts were also not checked because of the assumption that the interlocked valve -would be stroked during post-maintenance testing.
Because MOV Setpoint Document E-025-00007 was incorrect, testing the interlock contact for continuity would not have identified the incorrect setting.
Corrective Steps That Have Been Taken And Results Achieved:
MOV Setpoint Document E-025-00007 has been revised appropriately. A review of similar design documents was also performed.
Four documents contained lsimilar-mistakes and have been corrected.
These changes should prevent a similar-error f rom occurring in the future.
To enhance post-maintenance testing, status panel indication tests are presently being 'added to applicable Surveillance Technical Specifications (STS) procedures for Motor-operated Valv s.
_ADM 08-240, " Post thintenance Testing" _was revised on December 21, 1992 ' to establish WCNOC-97, " Recommended - Post Faintenance Testing". and an electronic post-maintenance database.
Corrective-Steps That Will Be Taken To-Avoid-Further Violations:
i l-The post-maintenance testing instructions for Motor-operator Valves will be added to applicable work requests as a supplemental sheet stating specific-retest functions.
The instructions will be added to WCNOC-97 as part of the ongoing collection of recommended and mandatory tests.
A component specific electronic matrix of mandatory and recoamended post-maintenance tests -is presently in test, and if successful, may eventually replace or augment WCNOC-97.
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Attachment to WM 93-0006 Page,5 of 7-Date When Full Compliance Will Be Achieved:
Revision of E-025-00007 and' similar documents prevented a similar condition from occurring, therefore WCNOC is in compliance with Technical-Specification 6.8.1.a and Regulatory Guide 1.33, Appendix A.
It is anticipated that the use.
of the component specific electronic matrix will be successful in eliminating.
problems of this nature when it becomes available and has been adequately tested.
In the interim WCNOC-97 provides a selection of available tests to be specified to assist in developing post-maintenance testing instructions.
WCNOC-97 was implemented on December 23, 1992.
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Attachment to WM 93-0006 Page,6 of 7 Violation (482/9231-04):
Failure to Properly Implement an Approved-Procedure Findina:
Technical Specification 6.8.1.a requires that written procedures shall-be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33. Revision 2, dated February _
1978.
Regulatory Guide 1.33 Appendix A,
Item 3.n, recommends-that instructions for startup, shutdown, and changing modes of operation should be prepared, as appropriate, for the chemical and volume control system.
This is accomplished, in part, by Procedure SYS BG-201, Revision 15.
- Shifting Between Positive Displacement Pump and Centrifugal Charging Pumps."
Step 4.2.6 of Procedure SYS BG-201 requires that operators close Valve BG HV8109, positivo displacement pump recirculation valve, when changing the operating pump from a centrifugal charging pump to the positive displacement pump.
Contrary to tha above, on October 1,
1992, during the implementation o f.
Drocedure SYS LG-201, the operator did not perform step 4.2.6.
_With Valve BG HV8109 open, a direct path was created from the positive displacement pump to the volume control tank, which resulted in an.approximately 20-second decrease in letdown flow and a loss of charging flow.
Reason For Violation:
Procedure SYS BG-201
" Shifting Between Positive Displacement and Centrifugal Charging Pumps", contains instructions to place the Positive Displacement Pump (PDP) in service and secure Centrifugal Charging Pump (CCP)
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Step 4.2.6 of SYS BG-201 requires the operator to close PDP recirculation valve BG _.
HV8109. On October 1, 1992, while executing Procedure SYS BG-201, Revision 15 step 4.2.6 of the procedure was not performed.
The root - cause of this incident was determined to be cognitive personnel error. in that there was a failure to follow procedure-by the operator performing SYS BG-201.
Corrective Steps That Have Been Taken And Results Achieved:
On October 2, 1992, the personnel involved with this incident were counseled on their responsibility to-ensure procedures are properly executed.
Corrective Steps That Will Be Taken To Avoid Further Violations:
To further ensure personnel -are aware of the importance of procedural adherence, the personnel involved in this incident will prepare a presentation on the incident.
This presentation will be addressed to operations and will.
stress the importance of procedural adherence. It is believed that counseling by peers (i.e.,
" positive discipline") will be more effective than more routine disciplinary. measures.
The presentation is scheduled to be completed by February 28, 1993.
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- Attachment to.WM 93-0006-
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Page,7;of 7 I
Date When Full Compliance Will Be' Achieved WCNOC Operations-add Senior Management continues _to stress the importance_of adherence to procedures.
Existing policies and Operation's practices already require this.
Therefore, WCNOC-is - currently in : compliance with Technical Specification 6.8.1.a and Regulatory Guide 1.33 in this regard.
The ' positive' discipline' presentation will-be completed by February 28, 1993.
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