ML20206R992
| ML20206R992 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 04/16/1987 |
| From: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| WM-87-0125, WM-87-125, NUDOCS 8704220310 | |
| Download: ML20206R992 (6) | |
Text
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NUCLEAR OPEP.ATING CORPORATION U. S. Nuclear Regulatory Commission April 16, 1987 ATTN: Document Control Desk Washington, D. C.
20555 Letter: WM 87-0125 Re:
Docket No. 50-482 Ref:
Letter dated 3/17/87 from JEGagliardo, NRC, to BDWithers, WCNOC Subj:
Response to Violations 482/8703-01, 02, 03 and 04 Gentlemen:
Attached is response to violations (482/8703-01, 02, 03 and 04) which were documented in the Re ference.
These violations concerned temporary modifications, locked valves, and as built drawings.
If you have any questions concerning this matter, please contact me or Mr. O. L.
Maynard of my staff.
Very truly yours, A
- 1 Bart D. Withers President and Chief Executive Officer BDW:Jad Attachment cc: P0'Connor (2)
RMartin JCummins 8704220310 870416 PDR ADOCK 05000482 O
PDR g
l\\
P.O. Box 411 / Burtngton, KS 66839 / Phone: (316) 364-8831 An Equal Opportunay Emrdoyer M F HCVET
Attichm:nt to WM 87-0125 P;ga 1 of 5 Violation (482/8703-01):
Failure To Perform Activities In Accordance With Established Procedures Finding:
Technical Specifications (TS) 6.8.1 requires that, " Written procedures shall be established, and maintained covering... a.
The applicable procedures recommended in Appendix A of Regulatory Guide (RG) 1.33, Revision 2, February 1978." Section 9.e of Appendix A states,
" General procedures for control of maintenance, repair, replacement, and modification work should be prepared before reactor operation is begun."
TS 6.8.1 also states that
" Major procedures are written to meet the requirements of ANSI N18.7-1976/ANS 3.2.... " Section 5.2.7 of ANSI N18.7 states, " Maintenance or modification of equipment shall be preplanned and performed in accordance with written procedures, documents, instructions, or drawings appropriate to the circumstances...."
Contrary to the above, on February 17, 1987, the NRC inspector observed three plastic shields atttched with aluminum tape, plastic tie wraps, and a pipe clamp at three locations adjacent to the shaft on Centrifugal Charging Pump "B"
(PBG05B)
(High Pressure Injection Pump);
- however, these modifications had not been accomplished in accordance with a licensee procedure.
Reason For Violation:
The three plastic shields attached with aluminum tape, plastic tie wraps, and a pipe clamp adjacent to the shaft on Centrifugal Charging Pump "B"
(PBG05B) were installed by Mechanical Maintenance at the request of Health Physics to control airborne contamination for ALARA considerations.
The mechanic discussed the request with the health physics individual, the duty Shift Supervisor, and his coordinating supervisor. The involved individuals did not feel the installation of the temporary shields altered the design, function, or method of performing the function of the Centrifugal Charging Pump and therefore was not significant enough to have impacted the safety of operations.
Corrective Steps Which Have Been Taken and Results Achieved:
A temporary modification order was initiated, approved and put in place upon discovery by the NRC Resident Reactor Inspector (RRI).
It was also determined that an unreviewed safety or environmental question did not exist.
f
Attach::nt to WM 87-0125 Pcg2 2 of 5 Corrective Steps Which Will Be Taken To Avoid Further Violatioas:
Upon discovery by the NRC RRI a Wolf Creek Event Report (WCER) was generated describing this violation, immediate corrective action
- taken, and recommended corrective actions to prevent recurrence.
The WCER has been placed in required reading for Operations, Maintenance, Health Physics, and Instrument and Controls personnel to ensure their awareness that any modifications to equipment, including temporary shielding must be properly evaluated and approved prior to installation.
Additionally, this event was discussed by the Plant Safety Review Committee at the March 3,1987 meeting.
The Date When Full Compliance Will Be Achieved:
Full compliance has been achieved.
Violation (482/8703-02):
Failure To Lock Valves In Accordance With Procedure Finding:
TS 6.8.1 requires that,
" Written procedures shall be established, and maintained covering.
a.
The applicable procedures recommended in Appendix A of Regulatory Guide (RG) 1.33, Revision 2, February 1978."
Appendix A of RG 1.33 states that, "The following.
safety-related activities should be covered by written procedures.
1.c.
Equipment control (e.g., locking and tagging)."
Checklist (CKL) GL-121, Revision 6,
" Auxiliary Building
- Heating, Ventilating, and Air Conditioning (HVAC) System Valve Lineup," had been established and implemented in accordance with the above TS and required, in part, that the handwheels to Valves GLV132 and GLV138 be locked closed Contrary to the above, on February 12, 1987 the NRC inspector observed Valves GLV132 and GLV138 closed but not locked.
i Reason For Violation i
The reason for valves GLV132 and GLV138 not being locked as specified by system Checklist (CKL) GL-121, Revision 6,
" Auxiliary Building Heating, Ventilating, and Air Conditioning (HVAC) System Valve Lineup," was due to operations personnel not locking the valves when restoring the system.
The root cause for valves GLV132 and GLV138 not being locked as specified by system Checklist (CKL) GL-121, was the result of Shift Supervisor direction.
The Shift Supervisor, after referring to administrative procedure, ADM 02-102, Revision 12,
" Control of Locked Component Status" found no requirement for these valves to be locked, and subsequently ordered them to be placed in the closed position. He did not refer to the checklist requirements recognizing that the required locked valves per the requirements of Regulatory Guide 1 33 are addressed in ADM 02-102.
The checklist is established for system level lineups and it is within the Shift Supervisor's authority to manipulate / deviate during operation, however, the checklist should have been refered to during restoration review.
These valves (GLV132 and 138) are not required to be physically locked in position to satisfy the programmatic guidelines of Appendix A to Regulatory Guide 1.33.
j
Atte::hrnt to WM 87-0125 Pcgs 3 of 5 l
Corrective Steps Which Have Been Taken and Results Achieved:
Valves GLV132 and GLV138 were locked as specified in the checklist and the checklist was reperformed for the other valves that were listed to be locked in position.
No other discrepancies were found as a result of reperforming the checklist.
Corrective Steps Which Will Be Taken To Avoid Further Violations:
The Shift Supervisor has been counseled as to the need to refer to valve lineup checklists and locked valve requirements when restoring systems to service following any outage activities.
Additionally, the Operations Section has issued a letter to all operations personnel regarding the need to accurately track systems status through properly restoring systems to service.
A copy of this violation has been placed in Operations Required Reading.
l The Date When Full Compliance Will Be Achieved:
l Full compliance has been achieved.
Violation (482/8703-03): Failure To Have Drawings Reflect As-Built Status Finding:
10 CFR Part 50, Appendix B, Criterion V,
- states, in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances.... "
Drawings M-12GG02(Q), Revision 0; M-02GLO1(Q), Revision 14; and M-12GLO2(Q),
Revision 0, had been established and implemented in accordance with 10 CFR Part 50, Appendix B.
l Contrary to the above, during walkdowns conducted on February 11 and 12, 1987, the NRC inspector identified the following selected examples or documentation deficiencies on quality (Q) drawings which did not reflect plant as-built status:
- Valve GLV055 is not shown on Drawing M-12GG02(Q), Revision 0
- Valve GLV070 and associated line are not shown on Drawing H-02GLO1(Q), Revision 14
- Valve GLV078 and associated line are not shown on Drawing H-12GLO2(Q), Revision 0 Reason For Violation:
The items in question are primarily limited to non-process connections l
within the onvelope of the vendor supplied HVAC equipment skids where I
detailed assembly drawings (i.e. shop drawings) were not provided.
Without I
detailed drawings these connections could easily have been overlooked during I
construction and startup with regards to the detailed configaration.
l i
l l
Attrch;;nt to WM 87-0125 Paga 4 of 5 Contributing to the problem was a startup request (SFR 1-GB-18) which requested a design change in the vents and drains from piping to tubing and corresponding valve types for some of the equipment.
The Engineering Disposition approved the request but for a larger scope of equipment and also allowed the change to be implemented using a typical detail prior to revising the design drawings.
Without the issuance of these drawings it appears that both the field during implementation and the design engineer during drawing incorporation misinterpreted the disposition, thus contributing to the problem.
Although the configuration in the field did not match the design documentation, the equipment would have performed their intended design functions as process piping was not affected.
Corrective Steps Which Have Been Taken and Results Achieved:
All of the vendor supplied HVAC skids are in the process of being walked down for the as-built condition and the affected drawings will be subsequently revised as required.
The package will be issued in accordance 1
with the Wolf Creek's Plant Modification Program which will provide for reconciliation with plant operating procedures.
Corrective Steps Which Will Be Taken To Avoid Further Violations:
The program utilized during construction and startup no longer applies.
The current modification process includes identification of all affected drawings prior to issuance of the modification package and a complete review of all drawings during final closeout.
Therefore, no corrective action is required at this time to avoid further violations.
The Date When Full Compliance Will Be Achieved:
l The affected drawings will be as-built by the end of June 1987.
Violation (482/8703-04): Failure To Establish Adequate Procedures j
Finding:
TS 6.8.1 requires that,
" Written procedures shall be established, implemented, and maintained covering.
a.
The applicable procedures recommended in Appendix A of RG 1.33, Revision 2, 1978." Appendix A of RG 1.33 states that "The following... safety-related activities... should i
be covered by written procedures.
1.c.
Equipment control (e.g.,
locking and tagging)."
i Administrative Procedure (ADM)02-101, Revision 16,
" Temporary Modifications," had been established and implemented in accordance with the above TS to control temporary modifications.
Step 5.5 of ADM 02-011 states, "the placement of temporary modifications authorized by approved procedures are excluded from the requirements of this procedure provided the procedure addresses installation and restoration of the modification."
Atttchstnt to WM 87-0125 Paga 5 of 5 Contrary to the above, on February 24, 1987, the NRC inspector observed a temporary chart recorder which had been connected to the containment -normal sump level recorders in accordance with Off Normal Procedure OFN 00-023, Revision 2,
" Loss of BOP Computer," was not required to be removed by this procedure nor was the recorder removed when the procedure was exited.
Reason For Violation:
The reason for this violation was off-normal procedure, OFN 00-023, Revision 2, " Loss of BOP Computer", not adequately requiring double verification for installation and removal of the chart recorder used to monitor containment sump levels.
Corrective Steps Which Have Been Taken and Results Achieved:
The temporary containment sump level recorder was promptly removed upon notification of the discovery by the NRC RRI.
Off-normal procedure OFN 00-023 has been revised to reference a new surveillance procedure, STS LF-001, i
Revision 0, " Containment Normal Sump Inventory and Discharge Determination",
which provides for installation and removal, including double verification, of the containment sump level recorders on loss and restoration of the BOP computer.
Corrective Steps Which Will Be Taken To Avoid Further Violations:
The development of the new surveillance procedure, STS LF-001, provides the tracking mechanism to ensure the temporary chart recorder is removed and double verified following return to service of the BOP computer.
The Date When Full Compliance Will Be Achieved:
Full compliance has been achieved.