ML20195K301
| ML20195K301 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 12/01/1988 |
| From: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| WM-88-0310, WM-88-310, NUDOCS 8812050179 | |
| Download: ML20195K301 (4) | |
Text
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WQLF CREEK NUCLEAR OPERATING CORPORATION Bart D. Wsthers Prowswa and ce e tem ome.
Decerrber 1,1988 WM 88-0310 U. S. Nuclear Regulatory Commission
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ATTN!
Doc ura en t Cont rol Desk Mail Station PI-137 Washington, D. C. 20555 l
Reference Letter dated October 31, 1988 from L. J. Callan, j
NRC, to B. D. Withers, WCNOC
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S u' ett Docket No. 50-482 Response to Violation 482/8828-01 i
and NRC concern with the Post Accident Sa'apling System i
Gentlemen:
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The purpose of this letter is to transmit Wolf Creek Nuclear Operating Corporation's ( WCNOC) response to violation 482/8828-01 which was documented in the Re f e rence.
Violation 482/8828-01 involved Chemistry Laboratory 1
Technician analytical performance. Also attached is WCNOC's response to NRC i
j concerns over the numerous probless identified with the Post Accident Sampling System (PASS).
On November 30, 1988, in a telephone discussion between Mr. B. L.
- Bartlett, l
NRC Region IV, and Mr. O. L. Maynard, VCNOC, the submittal response time was extended until December 1,1988.
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If you have any quertions concerning this matter, please contact me or Mr. O. L. Maynard of my staff.
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Very truly yours, I
J I
a N
Bart D. Withers President and a
99a Chief Executive Officer
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B. L. Bartlett (NRC), w/a h
5 D. D. Chamberlain (NRC), w/a j
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F. D. Martin (NRC), w/a k
MO D. V. Pickett ( N RC), w/a
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Page 1 of 3 t
I Violation (482/8828-01): chem i s,t_ry,1. abo r a t o ry Technicla_n_An g tic, Perlormance 7.1"S 38 f
Technical Specification 6.8.1 requires, that, "Written procedures shall be established, implemented, and maintained covering the activities referenced below:
The applicable procedures recomrsended in Appendix A,
of Regulatory Guide 1.33. Revision 2, February 1978."
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The licensee's Administrative Procedure ADM 04-017 "Veri fic at ion of l
Analytical Performance," Revision 7, dated August 7,
- 1987, paragraph 2.2 l
requires that, "for any unacceptable conditions or results identified by
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this procedure, the cause shall be determined and immediate corrective L
action t ak e n and documented on the Corrective Action Record (Figure 4) of l
ADM 04-005."
j Contrary to the above, the NRC inspectors determined on September 21,
- 1988, that nurse rous analytical results for various chemical parameter analyses cross-l performed by chemistry technicians on laboratory analytical accuracy check program standards during the time period July 10,
- 1987, through July 20, 1988, were not within the acceptance range established for satisfactory analytical pe r f o rm a nce.
The cause of these unacceptable results had not been determined and insediate specific corrective action had not been t ak en and documented on the Corrective Action Record for each of the unacceptable analytical results as directed by procedure.
Reason For Violation l
In August, 1988, it was discovered that the chemistry group had not completed a "Corrective Action Record" for several technicians whose i
analyses failed to meet the required acceptance criteria.
At this time it i
was decided to revise ADM 04-017, "Verification of Analytical Performance" to delete the requirement to use the "Corrective Action Record" for determining the cause of analytical perfortsance f ailure.
The procedure was revised to require a technician to reperform an analyses until it can be
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determined that no consistent problem exists.
l The reason for this violation was a cognitive personnel error by a Chenistry supervisor who tailed to determine the cause of the unacceptable results, t ak e losediate corrective actions, and docunen the results on the Corrective Action Record per the requirement of proce lure ADM 04-017 wh ich was in effect at the time of the occurrence.
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Attachment to VM 88-0310 Page 2 of 3
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Correc tive St_eys Which llave_ Been_ Taken and Results__ AchJ.eved:
The three technicians whose analyses failed to meet the acceptance criteria went through the require ' On the Job Training Qualification Sheets with a
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Cnemis t ry super 9isor and are being tested more frequently on the failed parameter.
The rasponsible supervisor has been counseled by the Site f
Chemist on the importance of following procedures and performing corrective action requirements
(*. a timely manner.
r Corrective St_eps Whleu 6111 Be Taken To Avoid _ Fur _ther Vioja,tions:
Chemistry technicians's analyses, whether passed or failed, are now being
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tracked on a computer with week ly updates to track the technician's
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analyti tal per formance.
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Date Vhen Full Compj,l_ance Will Be Achieved:
FuM complianet has been achieved.
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R_e m nse to Inspection _Refort 8828 Concerns _Over the Nunerous Probleres
'f Identified With the PASS:
The WCNOC Post Accident Sampling System (PASS) is a computer based menu f
driven system for determiaing radionuclides, chemical and contaminant j
concentration.
It has the capability of analyring undiluted and di'.uted j
samples of reactor coolant and containment atmosphere.
The PASS is used routinely two to three tbeea a week to perform various analytical analyses l
l to check system operability and to provide a cross check for chem i s t ry's l
l normal grab sample analyses.
l In the course of using the PASS and in the performance of procedure CitM 01-202, "Maintenance of the PASS",
problens with the system are promptly identified and work req uest s are initiated to correct identified problems.
The priority established for work requests on the PASS are assigned by t ak i ng into account the severity of the corsponent f ailure and the e f fect this failure has on system operability.
Since 1984, there have been 76 f
corrective work requests on the PASS.
Of these 76 work requests. 22 have been written for valves, twelve on the conputer, four on pumps, and 38 on various analysers and controllers.
Ou of the specific concerns discussed in Inspection Report 4$2/8828 was the reliabMity of the PASS oxygen analyzers.
WCNOC shares the NRC concerns with this equipment and had already sent an engine ering evaluation req uest (EER 87-SJ-02) to consider replacing the analysers prior to this NRC inspection.
The engineering study to replace the analyzers is scheduled to j
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Attachment to JM 88-0110 Page 3 of 3 a
be tx,pleted la the first quarter of 1989, with the design to be completed during. the second quarter of 1939.
This uchedule calls for replacement of i
l the oxygen analyzers by the end of.1989.
It should be noted that NUREC-0737 l
did not rea aire measurements of oxygen concentration for the PASS and that WCNOC had installed the oxygen analysers as an enNancement to the sampling capabilities for post accident situations.
Another specific concarn disecasel in Inspection deport 482/8328 was that of leak s in the PASS which cause airborne activity in the PASS area da-ing sampling.
During the inspection, the NRC inspectors were made aware of a leak which occurred due to a failure of pressure relief valve SJ-IPRV3.
A corrective work request was iniciated on September 21,
- 1988, and the vslve was replaced and pressurn tested on September 28, 1988.
It should be noted thst this leak as well as other leaks on the PASS does not af fect the operability of the system. The presence of leaks in the PASS has not Sola a f r eq ue nt problem at WCCS as only five leaks have occurred to date.
WGN0C will continue to strive to maintain the PASS leak free. Hcwever, when leak s do occur, WCNOC will ensure that 11aks are contained to eliminate the potential spread of e.ootamination and will initiate the necessary repairs in a timely uanner to ensure continued operability of the PASS.
The PAS
- is an inportant tool to be used in past accident conditions for le te rmining the degree of core damsge and for monitoring reactor conditions.
Because of the importance of th's system, WCNOC shares the concerns which have been discussed In Insptetion Rep?rt 482/8828 and feels th.t th.' steps which have been taken in response to the probtems identified eith leaks in the PASS and the oxygen analysers lave been responsive.
In order to rcoolve overall concerns with the reliability of the PASS, the Site Chemist has been assigned to monitor the reliability of the PASS ond to ensate that work re19este receive the appropriate attention and that problems are resolved in a timely manner.
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