ML20151Q848

Responds to NRC Re Violations Noted in Insp Rept 50-482/88-01.Corrective Actions:Upon Notification by Resident Reactor Inspector,Duty Shift Supervisor Had Test Flanges Removed from RHR Sys Valves

ML20151Q848
Person / Time
Site:	Wolf Creek
Issue date:	04/18/1988
From:	Withers B WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
WM-88-0101, WM-88-101, NUDOCS 8804270151
Download: ML20151Q848 (3)

Text

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WQLF CREEK NUCLEAR OPERATING CORPORATION Bart D. Withers President and CNef Executrve Omcor April 18,1988 WM 88-0101 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 205S5

Reference:

Letter dated March 18, 1988 from L. J. Callan, NRC, to B. D. Withers, WCNOC

Subject:

Docket No.30-482 : Response to Violation 482/8801-01 Gentlemen:

Attached is a detailed response to violation 482/8801-01 which was documented in the Re ference.

Violation 482/8801-01 concerns a failure to comply with the station temporary modification procedure.

If you have any questions concerning this matter, please contact me or Mr. O. L. Maynard of my staf f.

Very truly yours, 2-Bart D. Withers President and Chiaf Executive Officer BDW/jad Attachment cc:

B. L. Bare,lett (NRC), w/a R. D. Martin (NRC), w/a P. W. O'Connor (NRC), 2 w/a Oh hko 02 0

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RO. Box 411/ Budngion, KS 66839 / Phone: (316) 364-8831 An Equ4 Opportsuty Employer MF HGYET

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April' 18, 1988 Violation.(482 /8801-01) :

Failure to Comply with Plant Change Proce,duret Finding:

Criterion V of' Appendix B to 10 CFR Part 50 requires that activities affecting quality shall be

. pre sc ribed by documented inr: ructions,,

procedures, ;or drawings and shall be accomplished in accordance with these instructions, procedures,' or drawings.

Administrative Procedure ( ADM)01-022, Revision 13, "Authorization of Changes, Tests, and Experiments," requires that plant changes be reviewed reduction in.the margin of safety and that this review be documented li

' by completing the "Wolf Creek Nuclear Safety Evaluation Checklist".

for a

- Contrary to the above, on February 1,

1988, it was discovered that a plant chahge had besn made which affected residual heat removal (RHR) system piping and no review had been conducted to determine if a reduction in the margin of safety had been created.

The change identified involved steel test flanges hanging by electrical cable tie wraps 'irom RHR system Valves EJ

"-172 174, 175 and 178.

The RHR piping involved is Seismic Category I and no evaluation of the additional seismic loading wi.s performed.

Reason For Violation:

The attachment of the test flanges to RHR system Valves E.1 V-172,

174, 175 and 178 by operations personnel was not recognized as or intended to be a change to a plant system and therefore was not perforeud in acccrdance with ADM 01-022, "Authorization of Changes, Tests and Experiments".

Corrective _ Steps Which Have Been Taken and Results Achieved:

Upon notification by the Resident Reactor Inspector, the duty shift supervisor had the test flanges removed from the RH't system valves.

Operations personnel verified that no other such flanges were tied to any i

safety related equipment oc supports.

Wolf Creek Event Report 88-05 was written to alert menagement and the Plant Safety Revie w Committee of the event.

An Engineering Evaluation Request, (EER), was submitted to Nuclear Plant Engineering to evaluate the noncon forming condition.

2ER 88-XX-12 disposition stated thct, "the identified nonconformance does not prevent the piping system from performing its intended design function, including during a design basis seismic event".

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Attachment"to WM 88-0101:

-April-18, 1988-Corrective Steps Which Will Be Taken To_ Avoid Further,ylolationst m

Operations. personnel have bt'n i nstrucced to properlycatore the test flanges' in a tool box'.

Wolf Creek ' Event Report. 88-05 has been placed -in operations i

required' reading. to ' ensure operations personnel-are. aware that items attached., to

's ys t em s or s'upports constitute. a temporary-modification.

Additionally,'the-requirement to follow ADM 01-022, and this example will be

~dded. to the-requalification programs -for~ Operations and Maintenance a

personnel.

Date When Full Compilance'_Will Be Achieved:

Full compliance will be achieved by June 1, 1988.

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