ML20195K186
| ML20195K186 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 11/28/1988 |
| From: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| WM-88-0308, WM-88-308, NUDOCS 8812050153 | |
| Download: ML20195K186 (5) | |
Text
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s WQLF CREEK NUCLEAR OPERATING CORPORATION Sart D. WRhers Pr aws w cw m omew Novertber 28, 1988 WM 88-0308 U. S. Naclear Regulatory Commission ATTH:
Document Cont rol Desk Mail Station PI-137 Washington, D. C. 20555 Re fe renc e Letter dated October 28, 1988 from L. J. Callan, NRC, to B. D. Withers, VCNOC
Subject:
Dock e t No. 50-482:
Response to Violation 482/8824-01 and 02 i
Gentlemen The purpose of this letter is to transmit Wolf Creek Nuclear Operating Co r po r a t ion's response to violations 482/8824-01 and 02 which were documented in the Re ference.
Violation 482/8824-01 involved the failure to implement prompt corrective action and violation 482/8824-02 involved a procedure inappropriate to the circumstances.
If you have any questions concerning this a.stter, please contact me or Mr. O.
L. Maynard of my staf f.
Very truly yours, W
l Bart D. Withers l
President and l
Chief Executive Of ficer l
BDV/jad l
l Attachment l
ect B. L. Bartlett (NRC), w/a l
D. D. Chatsberlain ( NRC), w/ a R. D. Ma r t i n ( N'.C), w/a D. V. Pickett (NRC), w/a i
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1 Attachment to WM 88-0308 Page 1 of 4 i
Violation (482/8824-01):
Failure to Imf ement Progrnt Corrective Action l
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f.I."d,1, ng :
Appendix B to Criterion XVI of 10 CFR Part 50 requires that measures shall be established to assure that conditions adverse to quality are promptly 4
identified and corrected.
Procedure QAP 16.1, Revision 1, "Corrective Action for QA Prograra B r eak d own," req ui re s that conditions adverse to quality are promptly corrected to preclude recurrence.
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Contrary to the above, the NRC inspector identified two examples where the h
licensee failed to promptly identify and correct conditions adverse to f
quality. Thtse examples are t
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l 1.
On June 25,
- 1988, Main Feedwater Isolation Valve AE TV-39 failed to cycle during the initial quarterly surveillance test attempt because a yellow train four-way valve did not operate.
Corrective action was not accorsplished to identify the cause of the four-way valve failure and on j
September 24, 1988, the valve again failed to cycle because a red train L
four-way valve failed to operate.
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2.
In Licensee Event Report 482/87-43 for an event which occurred on September 28,
- 1987, the licensee's stated corrective action was to revise the MODE change checklist for entry to MODE 2.
This corrective l
action had not been completed as of September 16, 1988, even though three entries into MODE 2 had occurred since the previous event.
Reason For Violation
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1.
During performance of STS AE-201 on AE FV-39 on June 25,
- 1988, Correr ve Work Req ue s t ( CWR) 2575-88 was initiated when a four-way j
j valve v.s the inactive side failed to move on signal.
The valve i
L eventually functioned foMowing "agitation of four-ways" as described in 1
CVR 25 7 5-88.
Documentation did identify that solenoid configuration and air binding were not the problen,
- however, Block 37 ( Failure i
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De sc ript ion) and block 38 (Cause of Failure) of CVR 2575-88 were not
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j completed and the CWR remained opened.
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J The reason that some eq uipment failures and malfunctions have not been i
corrected as proraptly as desired is lack of overall programmatic
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guidance to define and control a root cause evaluation process for
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hardware deficiencies.
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Attachment to WM 88-0308 l
Page 2 of 4
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2.
The surveillance group had not revised the Mode change checklist as of f
September 16, 1988.
The reason the Mode change checklist was not promptly updated was because of a conscious decision by the surveillance group supervisor to wait until Refuel III to make the change along with the next major revision of the checklist.
A list of changes that were to be made prict to coming out of Refuel III, for the Hsde 3 to 2 i
check li s t, was being maintained.
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Corrective Steps Which Have Been Taken and Results_ Achieved l
l 1.
While performing STS AE-201 on September 24,
- 1988, a four-way valve on the active side failed to move on signal. CWR 4429-88 was initiated and work progressed through a variety of troubleshooting activities l
including change out and bench testing of four-way valves, pressure regulator adjustments and troubleshooting Solenoid valves.
These were I
accomplished and documented in accordance with successive revisions to f
the work instruction contained in CWR 4429-88.
Cause of f ailure was ultimately documented in block 38 of CWR 4429-88 as "insufficient air pressure to activate four-way valve caused by faulty pressure gauge".
Work Request 4455-88 was subsequently initiated to replace air gauge W30345.
These air gauges are being included in the preventative maintenance program for periodic monitoring.
The difference in addressing the two separate four-way valve incidents is indicative of the progress that is being made in thoroughly identifying causes of failure and performing prorapt corrective actions.
2.
The Mode 3 to 2 chucklist was revised following notification of this potential concern.
The surveillance group supervisor has been counseled on the need fer timely changes to Mode change checklists, when required.
Corrective St_eys Which Wi11 Be Taken To Avoid 7urther Violations:
WCNOC is developing a
root cause analysis program for hardware deficiencies.
This program will include a detailed methodology for root cause analysis as well as requirements for training, documentation, and program interfaces.
WCNOC believes that integration of this root cause analysis program with existing progr. sis will result in a more effective and ef ficient process for identifying and correcting conditions adverse to quality.
Date When Full Comp,1(ance Vill Be Achieved:
The root cause analysis program will be fully implemented in March, 1989.
d Attachment to WM 08-0308 Tage 3 of 4 l
Violation (482/8824-02): ? roc ed ure _Inaggrop ria t e to the Circumstances Findingt i
Technical Specification (TE) 6.8.I requires that procedures be established, l
implemented, and maintained covering activities 11sted in Regulatory Guide l
1.33, Revision 2, February 1978.
Regulatory Guide 1.33 includes specific procedures for each s urve lliance test listed in the Technical Specifications.
Contrary to the above, Procedure STS CR-001, Revision 8, "Shift Log for Modes 1, 2,
and 3"
did not implement the per shift channel check surveillance requirements for auxiliary feedwater pump suction pressure-loss because incorrect instrumelts were identified in the procedure.
This resulted in the per sh i t* t surveillance channel check requirements of TS i
Table 4.3-2, Section 6.h. not beir.g accomplished f rom May 2,
- 1985, through August 21, 1988.
_R_e a s on Fo r _V_i_ol a t ion t l
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The reason for this violation was determined to be two separate personnel errors.
The first by procedure writers in changing the ins trument a t ion identified in the surveillance procedure when the revision was made and the I
second, by the individuals involved in the procedure review process who did not identify this error.
A letailed recreation of the circumstances surrounding the revision to the surveillance procedure could not be made i
because some of the personnel are no longer employed at Wolf Creek l
Generating Station.
The re f o re,
the cause of the chanr.el check instrumentation being changed in the surveillance procedure could not be de t e rm ined.
The "reason for change" procedure change form s ta tes,
"Add NRC c omme1t s, update to current f o rm a t, correct ref s (references) and numbers to currsu T/S",
which does not give enough detail to d e t e rm ine why the specified instrumentation was changed.
l Corrective Ste,ps Which Have Been Taken and Results Aehleved t i
Upon discovery of this event, Operations personnel began surveilling the correct instrumentation and initiated a procedure change to correct STS CR-001.
A temporary procedure change was issued to correct the surveillance procedure on August 22, 1988.
This change has been incorporated as a permanent change to the surveillance procedure.
In addition, a review of this surveillance procedure has been conducted to ensure that this surveillance procedure meets the TS require,sents.
Cc,rrec tive _S_teys Which Wi_ll _ Be _Tjk en To Avoid Further Violat ions :
An in-depth review of all TS surveillance requirements to ensure that they are procedurally addressed is being conducted and will be complet1d by December 29, 1989.
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Attachment to WH 88-0308 Page 4 of 4 l
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d Date When Full Comg11ance Will Be Achieved r
The in-depth review of all TS surveillance requirements will be completed by l
December 29, 1989.
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