ML20155C941
| ML20155C941 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 06/08/1988 |
| From: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| WM-88-0150, WM-88-150, NUDOCS 8806140396 | |
| Download: ML20155C941 (4) | |
Text
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e W$LF CREEK NUCLEAR OPERATING CORPORATION Bart D. weer Proskient a4 ChLef Executrve Officer June 8,1988 WM 88-0150 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 l,
Re fe re nce : Letter dated May 11, 1988 from L. J. Callan, NRC, to B. D. Withers, WCNOC
Subject:
Docket No. 50-482 :
Response to Violation 482/8813-01 and 02 Gentlemen:
Attached is a detailed response to violation 482/8813-01 and 02 which were documented in the Reference.
Violation 462/8813-01 involved the failure to have an adequate procedure and 482/8813-02 involved a failure to assure that conditions adverse to quality are promptly identified and corrected.
If you have any questions concerning this matter, please contact me or Mr. O. L. Maynard of my staf f.
Very truly yours, Bart D. Withers President and Chief Executive Officer BDW/jad I
Attachment ec:
B. L. Bartlett (NRC), w/a D. D. Chamberlain (NRC), w/a R. D. Martin (NRC), w/a P. W. O'Connor (NRC), w/a (2)
P.O. Box 411/ Burbogton, KS 66839 / Phone: (316) 364-8831 kl 8806140396 880608 PDR ADOCK 05000482
)
O rocJo J
Attachmant to WM 88-0150 Page 1 of 3 Violation (482/8813-01):
Failure to Have an Adeguate Proce_d_ure :
Finding:
Criterion V of Appendix B to 10 CFR Part 50, requires that activities affecting quality be prescribed by documented instructions or procedures of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions o. procedures.
Contrary to the above, Wolf Creek Generating Station Procedure ADM 07-100, Revision 33, "Preparation,
- Review, Approval, and Distribution of WCGS Procedures," was not appropriate to the circumstances in that it did not require temporary procedure changes to be por ted or identified in the body of any procedures, including Emergency Op stating Procedures (EMGs).
The failure to post temporary changes for Proceaure EMG E-0, "Sa fety Injection,"
resulted in a supervising operator missing a CAUTION in two steps during the implementation of this procedure on the Wolf Creek Generating Station (WCGS) simulator.
Reason For Violation:
ADM 07-100, Revision 33, Step 7.2.2.4 required, "When a temporary change is used in the performance of a procedure, reference to the temporary change should be made in the procedure at the applicable step (s),
or the procedure should be marked up per the temporary change and identified to the temporary change." This step was written to require one of the two options stated but was misinterpreted by station personnel to be an option and not a req ui reme n t.
The reason for the violation was failure to provide adequate instructions in the procedure to eliminate confusion.
Corrective Ste,ps_Which Have Been Taken_ and Results Achieved:
Temporary Procedure Change (TPC)
MA 88-245 was issued to replace the existing step 7.2.2.4 with, "A temporary change used in the performance of system operation, surveillance testing, or operations response to plant evolutions shall be referenced at the applicable procedure step prior to procedure usage.
Procedure manuals and file copies not used as described above are only required to have the temporary change filed in front of the procedure after distribution by the Plant Safety Review Committee ( PSRC). "
This change clarifies the requirement that procedures used on an immediate basis, such as alarm response procedures and emergency operating procedures, have the temporary change referenced at the applicable procedure step upon issuance of the temporary change.
Procedures performed for an activity which allows preplanning, such as surveillance procedures, will have any temporary changes referenced at the applicable procedure step prior to useage.
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l Attachment to WM 88-0150 Page 2 ef 3 This change to ADM 07-100 was discussed by the PSRC and members were instructed to ensure this requirement was followed.
The group responsible for Operations Branch procedures in the Emergency Operating Facility, Technical Support
- Center, and Training were informed of the above requirement and have brought the required procedures into compliance.
Corrective Steys Which Will Be Take_n__To Avoid Further Violations:
The procedures discussed above have been brought into compliance with ADM 07-100, revised step 7.2.2.4.
The TPC MA 88-245 to ADM 07-100, Revision 33, has been incorporated into Revision 34 which has been issued.
Da_te When Ful1_Com_gliance Will_B_e_ Achieved:
Full compliance has been achieved.
Violation (482/8813-02):
Failure ~--~ -to Assure That Conditions Adverse to Quality are__P_romgt_ly Ident i fieTand Correc ted :
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Finding:
Criterion XVI of Appendix B to 10 CFR Part 50, requires that measures be established to assure that conditions adverse to quality are promptly identified and corrected.
Contrary to the above, an incorrect transition point was not corrected in WCCS Procedure EMG C-33 "SGTR Without Pressurizer Pressure Control."
Step 7c, response not obtained column, of this procedure transitions the operator to step 18e which does not exist.
During the implementation of Procedure EMG C-33 on the WCGS simulator, the supervising operator transitioned to step 19 when he observed thst there was not a step 18e.
It was d e t e rm ined that the correct transition should have been from step 7c to 7e.
This transition error had apparently been previously identified but not corrected by the
- licensee, as evidenced by light pencil corrections noted in some copies of EMG C-33 located at the simulator.
Re a s on_ Fo,r_ _ V i o l a_t i o n :
The root cause of this violation was a failure to de'ect a typographical error in the procedure.
The validation of the procedure occurred on April 20, 1985 as esidenced by the validation checklist.
The procedure approval date for Levision 1 is May 4, 1985.
In this time period between April 20, 1985 and May 4,
- 1985, Step 7c was added to more speedily direct the operator how to proceed if RVLIS (Reactor Vessel Level Instrumentation System) was unavailable.
This was a plant-specific step added as a
Attachment to WM 88-0150 Page 3 of 3 procedure enhancement.
The Westinghouse Emergency Response Guidelines for this procedure do not have a Step 7c to check RVLIS availability.
When the change was made, the 18e which should have been 7e was missed as a typographical error.
A contributing f actor to the violation was the apparent failure to note the discrepancy on a Program Improvement Form and send it to Operations to make a procedure change once it was discovered on the simulator.
Since this procedure requires multiple failures (e.g.
spray valves,
- heaters, pressurizer PORV's) it is an infrequently done procedure on the simulator.
This may account for why the pencilled in 7e did not receive more attention.
Corrective Ste_ps Which Have Been Taken and Results Achieved:
Temporary Change 88-218 was made to procedure EMG C-33 to show the proper transition to step 7e.
C_orrective Steps Which Will Be Taken To Avoid Further Violations:
A letter has been issued to all operations personnel and the License Operator T ra in i ng Supervisor instructing use of the Fo rma l Program Improvement Form to request changes to Emergency Operating Procedures.
During the proof-reading and verification effort for Revision 2 of the Emergency Procedures, special attention will be paid to the Response Not obtained column to ensure all transition steps are correct.
Date When Full Compli_ance Will Be_ Achieved:
Full compliance is expected by September 30, 1988, when Revision 2 of the Emergency Operating Procedures are issued.
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