ML20148D212
| ML20148D212 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 03/18/1988 |
| From: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| WM-88-0073, WM-88-73, NUDOCS 8803230350 | |
| Download: ML20148D212 (3) | |
Text
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W$LF CREEK NUCLEAR OPERATING CORPORATION l
l Bart D. Withers Preend.nt and cw n.cuw. ome.
March 18, 1988 VM 88-0073 U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D. C.
20555
Subject:
Docket No. 50-482:
Response to Violation 482/8806-01
Reference:
Letter dated February 17, 1988 from L. J. Callan, NRC, to B. D. Withers, WCN00 Gentlemen:
Attached is a detailed response to violation 482/8806-01 which was documented in the Reference.
Violation 482/8806-61 concerns a failure to have procedures appropriate to the operational circumstances.
If you have any questions concerning this matter, please contact me or Mr. O. L. Maynard of my staff.
Very truly yours, a
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55M Bart D. Withers 8 Tyt-President and
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Attachment to VM 88-0073 Page 1 of 2 March 18, 1988 Violation (482/8806-01):
Pailure to Have Procedures Appropriate to the Circumstances Pinding:
Technical Specification 6.8.1 requires that written procedures shall be established including the applicable procedures recommended in Appendix A of Regulatory Guide 1 33, revision 2, February 1978.
Regulatory Guide 1 33 addresses procedures that include draining the reactor coolant system and operating the shutdown cooling system.
Appendix B, Criterion V, of 10 CPR 50 requires that procedures be appropriate to the circumstances.
Contrary to the above:
A.
Procedure GEN-00-007, Revision 8,
"Mode 5 - RCS Drain Down," dated October 2, 1987, was not appropriate to the circumstances.
Steps were not included to ensure that the reactor vessel was vented prior to disconnecting "Conosocle." Also steps were not included that ensured indicated reactor pressure vessel water level was accurate.
B Procedure EJ-120, Revision 9,
"Startup of a Residual Heat Removal Train," dated October 2,
- 1987, was not appropriate to the circunstances.
The procedure did not include appropriate quantitative acceptance oriteria for the operation of Valve BG-HV-101 to preclude initiating a CCV system water hammer event.
Reason Por Violation:
A.
Successful use of procedure GEN-00-007, "Reactor Coolant System Drain Down",
during Refuel I indicated procedural adequacy for this evolution.
Therefore, during subeequent procedure reviews, no procedural inadegumeios were identified.
l r
l The troubleshoo k k vities following tne event on January 24,
- 1988, peas 1Me' design deficionoy in the reactor pressure vessel identified a water level i=M - "n that was not adequately compensated for in the l
procedure.r 9
l l
B.
Procedure EJ-120, "Startup of a Residual Heat Removal Train", did not provide sufficient detail to secure proper operation of Yalve EG-HV-101.
This procedure had been used successfully during Refuel I for this l
evolution without incident which indioated procedural adequacy.
Therefore, during subsequent proceduro reviews, the procedural inadequacy was not realized.
Corrective Steps Vhich Have Been Taken and Resulta Achieved:
l A.
Pollowing failure of the reactor vessel and pressurizer to vent prope rly, control room personnel evaluated the situation and attempted l
to establish an alternate vent path for the reactor vessel by l
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'b Attachment to UM 88-0073 Page 2 of 2 i
March 18,1988 disconnecting the head vent rig from the pressurizer and routing it to a separate vent path.
The pressurizer was vented through its own vent path.
This attempt to vent the reactor vessel utilizing this line up, was also unsuccessful.
The reactor versel head was finally vented using the RVLIS connection to the vent rig.
Inmediate actions were taken by management to determine a root cause for the event.
These actions included daily discussions with plant staff and continuous oversight of the troubleshooting activities in progress to identify a probable root cause.
Various nitrogen pressure tests were performed which may have cleared any blockage that may have been present in the head vent line.
This cannot be proven based on the test results obtained.
During RCS filling and venting, flow was verified through the reactor head vent valves with no abnonnalities noted.
Because the root cause of the head venting failure has not yet been conclusively determined, GEN-00-007 has been enhanced to require reactor head venting through the head vent and the RVLIS connection to provide redundant means for head venting to ensure venting to sero psig prior to Conoseal disassembly.
B.
A detailed engineering evaluation of this event was performed to evaluate system integrity.
Based upon a review of the system stress i
levels under a
variety of assumed design loadings, specific examination / inspection points were reoosamended for areas of piping, pipe
- supports, weldsents, and equipment most likely to experience an i
overstressed condition.
Subsequent inspections of these recommended performed and the resulta verified the integrity of the CCW areas were system.
In additieep.a tube side hydrostatio test was performed on the RHR Heat Exohangspi The results of this hydrostatio test verified the integrity of
.3 sat Exchanger tube-to-shell pressure boudary.
In I
order to prool
. $ unterhammer events in this system, a procedure change was issem6 ( SYS EJ-120 which limits the closure of the CCW inlet to the R Q rexchangers to ensure OCW flow through the RHR heat l
exchangers is ined during this evolution.
f A'
Correctiv'e Stepe Which Will Be Taken To Avoid Purther Violations:
l 1
A.
An Engineering tvaluation Request (EER) has been issued to provide j
additional methods with increased reliability for RCS level indication during RCS drain down.
3.
A review of all system operating procedures has been completed to ensuro appropriate quantitative acceptance criteria is included to prevent waterhammer events in similar system configurations.
Date When Pull Compliance Vill Be Achieved:
Full compliance hao been achieved.
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