ML20151A474
| ML20151A474 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 07/11/1988 |
| From: | Bailey J WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| ET-88-0097, ET-88-97, NUDOCS 8807200009 | |
| Download: ML20151A474 (7) | |
Text
a W$LF CREEK NUCLEAR OPERATING CORPORATION John A. Bailey Vce President Enneenng and hkal Sw*n Ju}yjj,jg68 ET 88-0097 U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Mail Station PI-137 Washington, D. C. 20555 Re fe renc e : Letter dated June 10, 1988 from L. J. Callan, NRC, to B. D. Withers, WCNOC
Subject:
Docket No. 50-482:
Response to Violations 482/8817-01 02, and 03 Centlemen:
Attached is Volf Creek Nuclear Operating Corporation's respons,e to vio'.ations 482/E817-01, 02, and 03 which were documented in the Re ference.
Violation 482/8817-01 involved the failure to have procedures appropriate to the circumstances, 482/8817-02 involved the failure to maintain adequate and complete records, and 482/8817-03 involved the falliire to take adequate and timely corrective actions.
If you have any questions concerning this matter, please contact me or Mr. O. L. Maynard o f my sta f f.
Very truly yours, John A. Bailey Vice President N
Engineering & Technical Services O
R$1 JAB /jad OO Attachmenf OW cc B. L.
Bartlett (NRC), w/a gg oc D. D. Chamberlain ( NRC), w/a
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R. D. Martin (NRC), w/a Q
P. W. O'Connor ( NRC), w/ a (2) p!
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P.O. Box 411/ Burbngton, KS 66839 / Phone: (316) 364 8831 s
An Equal Opportunny Euporw uf NC,YET m
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Attachment.to ET 88-0097 i
Pago 1 of 6 Violation (482 /8817-01): Failure to Have Procedures Apgrogriate to the__ Circumstances Finding:
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, dated February 1978.
Regulatory Guide 1.33 addresses procedures that include surveillance requirements.
Appendix B,
Criterion V of 10 CFR 50 requires that procedures be appropriate to the c irc um s t a nce s.
Contrary to the above, between May 2, 1985, and April 15, 1988, the licensee pe r fo rmed daily surveillances on the loose parts monitoring
- system, utilizing a surveillance procedure inappropriate to the circumstances.
Reason For Violation:
On April 14, 1988, at approximately 1130 CST, it was determined, following an internal surveillance, that the daily channel check on the loose-part detection system had att been adequately performed beginning on May 2, 1985. The surveillacce procedure STS CR-001, "Shift Log for Modes 1 and 2",
did not meet the expanded channel check requirements identified by the Technical Specification (T/S)
Basis which re ferenced Regulatory Guide 1.133.
There fo re, the channel check required by T/S 4.3.3.9.a was not being fully met for the loose part detection system.
The requirement for listening to each channel was originally in the surveillance procedure but was deleted when the first revision was made on May 2, 1985.
Therefore, this event occurred from May ',
1985 until April i
15, 1988, when the requirement was again incorporated into the surveillance procedure.
The root cause of this event was determined to be two separcte errors.
The first by contractor procedure writers in deleting the requirement to audibly monitor each channel from the surveillance procedure when a revision was made.
The second by the individuals involved in the procedure review process in not identifying this inadvertent deletion. A detailed recreation I
of the circumstances surrounding the revision to the surveillance procedure could not be made because some of the personnel involved are no longer employed at Wolf Creek Generating Station.
Therefore, the cause of the requirement being deleted from the surveillance procedure could not be d e t e rm in ed.
Corrective Steps _Which Have Been Taken and Results Achieved:
i A temporary p roc ed u re change to require an audible check of each channel April 15, each shi f t was incorporated into the surveillance procedure on l
1988. This change will be made a permanent part of the surveillance l
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Attachment to ET 88-0097 Page 2 of 6 procedure when the next permanent revision to the surveillance procedure is made.
The channel check is pe r fo rmed each shift instead of daily as required to simplify the surveillance procedure.
A review of this surveillance procedure has been performed to ensure that this surveillance procedure meets the requirements of the appropriate Regulatory Culdes.
Corrective Steps Which Will Be Taken To Avoid Further Violations:
As a result of an unrelated event reported in LER 87-060, a review of the T/S Bases has been conducted to ensure that the requirements in the Bases included in surveillance procedures.
are Inspection Report 482/8817 discusses a work request written in 1987 on two channels of the loose part monitoring system.
The disposition of this work request was identified in the inspe.. tion report as a missed opportunity to identify and correct the surveillance problem. Missed opportunities of this type abould be significantly reduced by the recently increased emphasis on determining root cause at Wolf Creek. Licensee Event Report 87-029 was also identified as a missed opportunity in the Inspection Report.
Changes and enhancements taken as corrective action in LER 87-029 and LER 87-060 should prevent future occurrences of events of the type identi fied in this violation.
Date When Full Compliance Will Be Achieved:
Full compliance has been achieved.
Violation (482/8817-02): Failure to Maintain Adequate and Complete Records Finding:
The Code of Federal Regulations, 10 CFR 50, Appendix B, Criterion XI, "Test Control,"
- requires, in part, that a test program shall be established to assure and demonstrate that structures, systoaa, and components will perform satis f ac torily in service in accordance with written test procedures which
'ncorporate design requirements.
Fur the rmo re,
test results shall be documented and evaluated to assure that test requirements have been satisifed.
Contrary to the above, Plant Modification Requests (PMRs) 08".3 and 0950 work packages completed in May 1985 did not contain evidence that post-modification testing had been accomplished or evaluated.
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Attachment to ET 88-0097 Page 3 of 6 Reason For Violation:
The requirement to perform post maintenance, installation and modification testing was recognized and accomplished, however, during the transition from construction work controls to operational work controls some requirements concerning documentation of retests were misinterpreted.
Plant Modification Request (PMR 0823) was completed on April 24,
- 1985, by implementing work request 91362-85.
Retesting was completed the same day by pe r forming a partial surveillance test, STS10-215, which tested the P-4 interlock modi fication, however, it was not documented in the "retest" bloch of the work request.
Plant Modification Request (PMR 0950) was completed on May 4,
- 1985, by implementing work request, 06948-85.
Retesting was completed the same day by pe r f o rm ing a partial surveillance test, STS 1C-215, which tested the appropriate breaker contacts af fected by the modification, however, it was not documented in the "retest" block of the work request.
The reason for this violation was inadequate instructions concerning retesting in Administrative procedure ADM 01-057, "Work Request",
which led to confusion over the interpretation of when and how a retest should be documented.
Corrective Steps Which Have Been Taken and Results Achieved:
A WCGS Quality Program Violation identi fied a failure to document the functional acceptability or operability of equipment returned to service af ter maintenance activities. As a result of this Quality Program Violation definitive instructions were provided for in a revision to ADM 01-057, which provided a basis to train supervisors and employees in the proper documentation of post maintenance testing requirements.
Corrective Ste,ps Which Will Be Taken To Avoid Further Violations:
The present administrative controls which are in place in the work request and plant modification progtte= require proper documentation that test requirements have been satisf actorily completed.
Date When Full Compliance Will Be Achieved:
Full compliance has been achieved, i
Attachment to ET 88-0097 Page 4 of 6 Violation (482 /8817-03):
Failure ~ to Take Adequate and Timely Corrective Actions Finding:
Code of Federal Regulations, Title 10, Part 50, Appendix B, Criterion XVI,
- states, in part, "Measures shall be established to assure that conditions adverse to quality, such as fail':as, malfunctions, deficiencies, deviations, defective materials and equipment, and nonconformances are promptly identified and corrected." Also, the licensee's Updated Safety Analysis Report, Revision 0,
paragraph 17.2.16.1,
- states, in part, "Corrective action control measures have been established to assure that conditions adverse to quality are gromptly identified,
- reported, and corrected to preclude recurrence Contrary to the above, Wolf Creek Event Report 86-49 was issued on June 24,
- 1986, to initiate corrective action fo r the high failure rate of surveillance tests on the containment hydrogen analyzers.
Corrective action for this program had neither been determined nor implemented by the licensee on May 05, 1988.
Reason For Violation:
In an effort to resolve Wolf Creek Event Report (WCER) 86-49, several actions were taken to identify why the containment hydrogen analyser instrumentation was drifting out of calibration and how this problem could be corrected. The actions taken include:
a)
Trending of AS-FOUND values for past surveillances b)- Implementation of vendor recommendations c)
Inquiries to other users of the instrumentation d)
In-house troubleshooting and improvement ef forts None of these actions provided a significant gain in instrument pe r fo rmanc e or identified the cause of the problems being experienced with the l
instrumentation.
Discussions with other instrument users indicates that calibration drift problems are common and probably inherent with the instrument analyzer process involved ( thermal trans fer).
Because WCNOC had not determined the root cause of the problem, no final course of action had been determined at the time of the NRC inspection.
Corrective Steps Which Have Been Taken and Results Achieved:
Discussions with Consip Delphi, the vendor, resulted in three suggestions that addressed possible leakage in the area of the analyzer, stabilization times for the analyzer catalyst a f ter ramples are applied, and finally, flow regulation to the analyzer.
Implementation of the vendor suggestions provided no significant gain in instrument pe r f o rm an c e.
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Attachment to ET 88-0097 Page 5 -of 6
Testing frequency has been increased to weekly from monthly.
This effort has not resulted in substantially dif ferent results.
WCNOC continues to maintain a weekly testing schedule and monitor the results for improved incidence of acceptable AS-FOUND readings.
The testing periodicity may be reduced further if a positive trend is reflected.
In addition to reducing the periodicity as discussed above, calibration methods continue to be looked at to ensure that correct instrument set up and optimum calibration adjustment are maintained.
It should be noted that the analyzers have always calibrated into tolerance, with any adjustments performed immediately following the AS-FOUND data taking.
Because no efforts taken by WCNOC have been successful in significantly improving instrument performance an Engineering Evaluation Request (EER 88-CS-01) was issued to evaluate the replacement of the existing containment hydrogen analyzers with analyzers that are not subject to flow, pressure or mositure sensitivities.
Corrective Steps _Which Will Be Taken To _ Avoid Further Violations:
The hydrogen analyzer performance will be improved by replacing the existing hydrogen analyzers with analyzers that are not subject to flow, pressure or moisture sensitivities or by providing another acceptable resolution resulting from the disposition of-the Engineering Evaluation.
Actions have been taken which should provide for improved promptness in correcting problems of the type identified in this violation.
The actions include restructuring the daily planning meeting to focus more on problems and corrective actions necessary to prevent recurrence.
The meeting is attended primarily by management personnel to provide the necessary level of authority to resolve problems and take corrective actions.
The meeting is normally attended by one or more of the Corporate Of ficers to provide senior management support.
The interaction between organizations in the daily meeting will help to focus ef forts into a single direction so that each organization is aware of what is required to accomplish any given task.
In
- addition, these meetinds ensure that individual work assignments are being performed by the organization with the proper experience and expertise to accomplish the task in the most ef fective manner.
Date When Full Comgliance Will Be Achieved:
Full compliance will be achieved upon resolution of the EER.
This resolution is currently scheduled to be complete by Refuel 4.
Trending Of High _ Failure Rates And Reduced Periodicitt Of Testing:
Trending of failure rates identified through corrective maintenance is currently provided by the I&C Instrument files.
File log entries are made for any corrective maintenance performed and the file logs are reviewed by I&C Supervisors.
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Attachment to ET 88-0097
' ige 6 of 6 Trending for surveillance activities ( AS-FOUND vs.
Tolerance Range) will be accomplished in a similar manner.
Loop files will be established and updated to provide trending for calibration /setpoint drif t.
This additional trending of fort will be fully implemented by September 30, 1988.
Reduced periodicity of testing is a practice that will be implemented anytime a gain in instrument confidence can be achieved.