ML20151D153
| ML20151D153 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 04/06/1988 |
| From: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| WM-88-0087, WM-88-87, NUDOCS 8804130425 | |
| Download: ML20151D153 (4) | |
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W$LF CREEK NUCLEAR OPERATING CORPORATION i
Bart D. Withers
$*.'fEfw. ome.,
1 April 6,1988 VM 88-0087 U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D. C. 20555
Reference:
Letter dated March 7,1988 from L. J. Callan, NRC, to B. D. Vithers, WCN00
Subject:
Docket No. 50-482:
Response to Violation 482/8804-01 Gentlemen:
Attached is a detailed response to violation 482/0R04-01 which was documented in t/A Reference.
Violation 482/8804-01 concerns a failure to have procedures appropriate to the circumstances.
If you have any questions concerning this matter, please contact me or Mr. O. L. Maynard of my staff.
Very truly yours, c
M Bart D. Withers President and Chief Executive Officer BDW/jad Attachment 00:
B. L. N rtlett (NRC), w/a R. D. Martin (NRC), w/a P. W. O'Connor (NRC), 2 w/a 8804130425 880406 PDR ADOCK 05000482 G
PDR PO Box 411/ 8vrkngton, KS 66839 / Phone:(316) 364 8831 p
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Att: chm:nt to WM 88-0087-Page 1 of 3 April 6, 1988 l
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Violation (482/8804-01): Pailure to Have Procedures Appropriate to the Circumstances Pinding:
Criterion V of Appendix B to 10 CPR Part 50 and the licensee's approved _
quality assurance plan requires that activities affecting quality shall be prescribed by procedures appropriate to the circumstances, and that these procederes include appropriate quantitative or qualitative acceptance criteria.
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Contrary to the above A.
Procedures QCP 7.1, - Revision 1 "Receipt Inspection", dat9d July 19,.
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- 1984, was not appropriate to the circumstances in that ambiguous instructions were provided which resulted in a failure to ' properly perform and document receiving inspection of the reactor head 0-rings.
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B.
Procedure PHP 02-O'io, Revision 2, "Reactor Vessel Head 0-Ring Removal and Installation", dated September 1, 1987, was not appropriate to the oircumstances in that the procedure did not provide appropriate j
uantitative acceptance criteria for the inspection of 0-rings nor did sit provide necessary specifioity in terms of inspection performance.
t Reason For Violation:
A.
The current revision (and ali previous revisions) of QCP 7.1 requires all items to be inspected for physical damage (e.g. 6eratches, gouges) and important dimensions unless the marking on the package prohibits l
unpacking.
However, not all delicate, specially packaged items are identified by marking on the package prohibiting unpacking.
l In this specifio case, the Level II QC Inspector involved determinei that removing the protective tape from the 0-rings would expose the O-l rings to a very real potential for damage. The inspection for physical damage was therefore conducted by randomly examining the taped surfaces t
of the 0-rings for obvious evidence of damage or rough handling that would have resulted in outs, nicks, scratches or gouges.
l The inspector's action regarding protection of the 0-rings was l
appropriate.
- However, the applicable Receiving Inspection Report should have been annotated to identify the method of physical damage inspection (i.e.
examination of the protective tape rather than the i
actual 0-ring surfaces).
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.o Attachment to VM 88-0087 Page 2 of 3 April 6, 1988 Because of the indirect method of physioni damage inspection, it was not possible for the inspector to perform dimensional inspections on the 0-rings.
As a result, the inspector should not have marked the dimensional inspection as "acceptable" but rather marked it as "not applicable".
It should be be noted that detailed dimensional and physical inspections are perfo rmed on the 0-rings in the field immediately prior to installation.
Review of procedure QCP 7.1 Rev.
1 revealed that the procedure was inadequate in that it only allowed indirect physical inspection where the package marking specifically restricted unpacking.
The procedure was also inadequate in that it did not provide clear instructions to the inspector regarding the anno tation of ths Receiving Inspection Report when alternate inspection methods were employed and the requirement to "N/A" specific attributes not inspected during receipt.
B.
PHP 02-010, Revision 2,
"Reactor Vessel Head 0-ring Removal and Insta11stion", inspection acceptance criteria as stated in steps 7.6.3 and 7.6.3 1 was that any nicks, scratches, or other undesirable conditions vould not be noceptable.
Even though it was known that scratches of.002 inches or less on the 0-ring surface could be acceptable for use, it was felt that the extra handling of the 0-ring to adequately quantify such a scratch could potentially cause more damage than originally found.
Procedure PHP 02-010 identifies the installation and inspection sequence as:
Steps 7.6.1 and 7.6.2 prepare inner 0-rings for inspection and installation Step 7.6.3 invokes inspection of 0-ring I
Step 7.6.4 raises 0-ring close to groove Step 7.6.5 repeats steps 7.6.1 through 7.6.4 for the outer 0-ring Step 7.6.7 installs 0-ring into the 0-ring grooves on the vessel head The procedure identified that the inspec tion occur prior to the j
inatallation of the 0-ring per the steps noted above.
The Quality inspections during this evolution were performed out of sequence and l
t' tis procedural violation was addressed by the Ocality Report of Procedure Violation 88-001.
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Attaohment to VM 88-0087 Page 3 of 3 April 6, 1988 Corrective Steps Which Have Been Taken and Results Achieved:
A.
Procedure QCP 7.1, Revision 2, was issued on December 17,
- 1984, to clarity how "not applicable" attributes are required to be documented on the Receiving Inspection Report.
B.
Additional information for inspection criteria became available just prior to the 0-ring replacement in January, 1988.
These detailed instructions were issued in Plant Modification Request 2449 and included specifio acceptance criteria for 0-ring, vessel head and flange mating surfaces. This detailed information was utilized for the 0-ring replacement in January for the inspection activities.
Corrective Stepa Which Will Be Taken To Avoid Further Violations:
A.
Procedure QCP 7.1 will be revised to clarify when indirect physical inspection methods may be employed due to the nature of the items and its packaging requirements.
The revision will also address the requirement to annotate on the Receipt Inspection Report when exceptions or alternatives to standard inspection methods have boon utilized.
Furthermore, a Receipt Inspection Plan will be developed to specifically delineate the receipt inspection instructions to be utilized for receipt of Reactor Vessel 0-rings.
These actions will be completed by June 1, 1988.
B.
The enhanced inspection criteria for the 0-rings and mating surfaces are being incorporated into procedure PHP 02-010, to further clarify inspection attributes, accept / reject criteria, and inspection sequence, j
Ihte When Pull Compliance Vill Be Achieved:
A.
Procedure QCP 7.1 will be revised by June 1, 1988.
l B.
PHP 02-010 will be revised by June 1, 1988.
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