ML20212J538
| ML20212J538 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 03/02/1987 |
| From: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| WM-87-0057, WM-87-57, NUDOCS 8703090043 | |
| Download: ML20212J538 (5) | |
Text
,
W6LF CREEK NUCLEAR OPERATING CORPORATION March 2,1987 U.S. Nuclear Regulatory Comission ATTN: Document Control Desk Washington, D.C.
20555 Letter: WM 87-0057 Re:
Docket No. 50-482 Subj:
Response to Inspection Report 50-482/86-34 Gentlemen:
This letter is written in reponse to your letter of January 29, 1987, which transmitted Inspection Report STN 50-482/86-34.
As requested, the violations (482/8634-01 and 02) identified in the Inspection Report is being addressed in four parts.
(a) The reason for the violation if admitted; (b) The corrective steps which have been taken arx1 the results achieved; (c) Corrective steps which will be taken to avoid further violations; and (d) The date when full compliance will be achieved.
Violation (482/8634-01): Failure To Have An Adequate Procedure For Draining The Reactor Coolant System Finding:
Technical Specification (TS) 6.8.1 requires that, " Written procedures shall be established, implemented, and maintained covering.
a.
The applicable procedures recomended in Appendix A of Regulatory Guide (RG) 1.33, Revision 2, February 1978," Section 3.a of Appendix A states that draining the reactor coolant system should be covered by written procedures.
These procedures shall be written in accordance with ANSI N18.7-1976/ANS-3.2, Section 5.3 which requires that activities affecting safety at nuclear power plants shall be described by written procedures of a type appropriate to the circumstances.
0703090043 870302 PDR ADOCK 0500 2
Ro. Box 411/ surigon, KS 66839 / Phone: (316) 364 8831 f
An Equal opporturvty Employer M F HCVET l.
c ^
WM 87-0057 March 2, 1987 Page 2 Procedure SYS EC-200, Revision 6,
" Changing Ievel in the Spent Fuel Pool or Refueling Pool, " has been established to iroplement these requirements.
Contrary to the above, SYS E-200 was found to be inadequate to effectively control pool level requirements in that on November 29,
- 1986, during draining.of 'the refueling pool /BCS, the Residual Heat Removal. (RHR) purops became airbound on two separate occasions.
Numerous NRC and Industry notices had previously identified.RHR punp air binding to the licensee.
Reason For Violation If Adnitted:
Following loss of suction to both RHR pumps during _ lowering of the refueling pool / reactor coolant system level on November 29,
- 1986, it was correctly believed the cause was due to lowering the level at too fast a rate.
Both RHR pumps were restored to service. Evaluation of this event concluded that even though visual water level was at or just above the vessel flange when cavitation occurred, the drain down rate was too fast.
To better identify voiding in-the upper part of the Reactor Pressure Vessel', an extra tygon tube was installed for additional level determination and one (1) additional
-operator was placed in containment to view the tubing as well as the actual pool water level.
Both were in direct communication with the Control. Room.
A second pump down was attempted at a slower rate using_ system operating procedure SYS E-200,
" Changing Ievel in the Fuel Pool or Refueling Pool".
4 During the second attempt the tygon tubing indicated a rapid level decrease; in the Reactor Pressure Vessel and the punp down was innediately terminated with one RHR pump losing suction.'
Water level was-increased and the RHR punp returned to service. - Water level was subsequently lowered to half-pipe using a much slower rate with the letdown system.
Subsequently, it was realized that during previous punp downs, when a loss of RHR did not occur, the reactor vessel upper internals and fuel were not installed.
During drain down with fuel in the vessel and the upper internals installed, a loss of RHR was experienced.
Our review 'of the t
numerous NRC and Industry concerns of RHR punp cavitation events did not identify the sudden loss of water in the reactor pressure vessel while a visible water level existed above the vessel flange.
To the best of our knowledge, this phenomenon had not been identified in the past.
'Iherefore, the reason for this violation is attributed to inadequate procedures for punping down the refueling pool / reactor coolant systen with the vessel upper internals installed.
Corrective Steps Which Have Been Taken and Results Achieved:
Following loss of suction to the RHR punp(s), water level was quickly restored and RHR ptmp(s) returned to service.
Water level was subsequently lowered using the letdown system, at approximtely 100 gpm flow.
Tenporary procedure change number MA86-0867 was issued for station procedure FHP 02-001, Revision 5, to limit the reject rate to the RNST during drain down to 1000-1500 gpm while greater than two (2) feet above the vessel flange and to approximately 250 gpm when less than two (2) feet above the flange.
1 NM 87-0057 Page. 3_
March 2, 1987 Corrective Steps Which Will Be Taken To Avoid Further Violations:
Additionally,. system operating procedure, SYS EC-203,.has been revised to incorporate the lessons learned from this incident.
We procedure requires
)
use of the letdown system after the level has been lowered to approximately
- two (2) feet above the vessel flange.
Wis violation and response has been placed in operations required reading program to ensure operations personnel are ' cognizant of the need for adequate evaluations of abnormal or unexplained operations events.
We Date When Full Compliance Will Be Achieved:
Full Cortpliance has been achieved.
Violation (482/8634-02):
Violation. Of Technical Specification. - Fire Suppression System Surveillance Finding:
TS 4.7.10.3.b requires that, "Each of the required halon systems shall be demonstrated operable at least once per 18 months by verifying the systen, including associated ventilation system fire danpers... actuates manually and automatically.... "
- Contrary to the above, as identified in Kansas Gas & Electric (KG&E) Quality Program Violation (OPV) 11/86-180, STS Ifr-032, Revision 4,
" Single-Zone Halon System Checkout;" STS MT-036, Revision 3,
"Two-Zone Halon System Checkout;"
and STS MT-037, Revision 3,
"Six-Zone Halon System Checkout," failed to address the verification of darrper ' actuation.
.These STS's were being relied upon to meet TS surveillance requirements.
This violation is a repeat of Violation 482/8541-01.
Reason For. Violation If..Adnitted:
On November 24, 1986 it was determined that surveillance procedures STS MT-
- 032, STS MT-036 and STS MT-037 failed to address verification of the five darrpers to actuate during Halon System surveillance testing.
Technical Specification Surveillance Requirement 4.7.10.3.b
- requires, in part, demonstration of Halon System operability by verifying that the system, including associated Ventilation System fire dampers and fire door release mechanisms, actuate manually and automatically upon receipt of a simulated actuation signal at least once per eighteen (18) months.
m.;
it 1M 87-0057' lPage-4
. March 2, 1987 m
A previous similar occurrence was discussed in violation 482/8541-01.
As discus' sed in our response to that violation,' a comprehensive review of Fire Protection related Technical. Specifications to ensure procedural conpliance was. completed in early 1986.
This review was performed,.by the NCGS Fire-Protection Coordinator with_ assistance from respective ~ HCGS groups 'having responsibility for Fire Protection related surveillance procedures.
This review did not identify the discrepancies. identified-in this violation, apparently due to personnel not fully understanding the. intent of the surveillance requirements.
Corrective Steps Which Have Been Taken and Results Achieved:
Following discovery of this situation, the affected Halon Systems were declared inoperable and fire watches for.the affected areas were established in accordance with. Action Statement
'a' of Technical. Specification 3.7.10.3.
h.
required verification of fire damper actuation was successfully coupleted and docmented on a Work Request on December 2,
1986.. Following completion of this testing, the Halon Systems were declared operable and the fire watches were terminated.
The surveillance procedures identified in this violation are 18 month
.surveillances related to Fire Protection HVAC systems.
'Iherefore, an independent review of HVAC related, infrequently performed surveillances was initiated by operations results engineering group who did not perform the previous review.
Corrective Steps Which Will be Taken To Avoid Further violations:
The ; independent review of infrequently. performed HVAC surveillance procedures has been coupleted to ensure Technical Specification requirements are fully met by approved surveillance Test Procedures. All re m...aadations resulting-from the review, including Procedural enhancements and human factor considerations will be added to'the procedures prior to the next performance date of the procedure.
Surveillance procedures, STS MT-032, STS MT-036 and STS MT-037 will be
-revised to include a provision for verification of fire damper actuation upon receipt of a simulated actuation signal.
'Ihe Superintendent of Maintenance will hold a group discussion with Fire Protection and the appropriate Maintenance personnel involved in writing and reviewing surveillance procedures to stress the inportance of ensuring all Technical Specification requirements are verified; and specifically reviewing the past procedural inadequacies discussed above.
N Date When Full Conpliance Will Be Acheived:
N STS MT-032, 036 and 037 revision process will be conpleted by March 31, 1987. The group discussions have been congleted.
._ ~. -...-. - -
g: ~.3 WM 87-0957-
- Page 5 March 2, 1987-If you have any questions concerning' this matter, please contact me or Mr.
O. L. Maynard of my staff.
Very truly yours, t
Bart D. Withers President and Chief Executive Officer BDid:jad -
cc: P0'Connor (2)
RMartin JCimmins 4
4 k
s 1
l 1
i t
i 1
1
\\
f i
l l
1 i
4 2
4 a
-,n-
,--we-w-
w-v-,-,,----e,
.m p,,, w w wm m-,---ww-m,,,.-nm,,neme,-wr,,rw,mm-,.r-,--n-< - - ~. - - - - -
---,-.,-e-e-e.----m-,-