ML20215B773
| ML20215B773 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 06/12/1987 |
| From: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| WM-87-0162, WM-87-162, NUDOCS 8706170446 | |
| Download: ML20215B773 (6) | |
Text
W$LF CREEK NUCLEAR OPERATING CORPORATION Bart D. Withers President and CNef Executive Officer.
June 12,1987 1
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U. S. Nuclear' Regulatory Commission ATTN: Document Control Desk-Washington, D. C.
20555' Letter: WM 87-0162 i
Re:
Docket No. 50-482 Ref:
Letter dated 5/15/87 from EHJohnson, NRC, to j
.BDWithers, WCNOC Subj:
Response to. Violations 482/8705-01 and 482/8705-02 l
Gentlemen:
' Attached is a detailed. response to' violations 482/8705-01 and 482/8705-02
.which were documented in the Reference... Violation 482/8705-01 concerns a
. failure'to maintain the Total Plant Setpoint Document up-to-date.. Violation-482/8705-02 concerns a failure to perform activities in-accordance with established procedures.
I f.
you have any questions concerning this matter, please contact me or-Mr. O. L. Maynard of my staff.
Very truly yours, Bart D. Withers President and Chief Executive Officer J
BDW:jad Attachment oc:
P0'Connor (2)
RMartin JCummins i
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PDR ADOCK 05000482 G
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P.O. Box 411/ Burlington, KS 66839 / Phone: (316) 364 8831 l
An Equal Opportunity Employer MF/HC/ VET i
'Attrchmsnt to WM 87-0162 Page 1 of 5-June 12,1987 i
l Violation (482/8705-01): Failure to Maintain Total Setpoint Document (TPSD)
Up-to-Date Finding:
Technical Specification (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, February 1978." Section 8 of Appendix A of RG 1.33 states that, " Specific procedures for.... calibrations should be written (... for each..
calibration listed in the Technical' Specifications)."
The licensee has established and implemented procedure ADM 05-103, Revision 2, "WCGS Total Setpoint Document" in accordance with TS 6.8.1, Section 5.2.1 of ADM 05-103 states "The results engineering group will update and control the.WCGS TPSD."
Contrary to the above, a change request (No. AE 85-03) which had been issued and signed as being completed to update the feedwater flow transmitter calibration test data contained in the WCGS TPSD had not been made.
This resulted in using the incorrect test data to calibrate feedwzter flow transmitters on or before January 14, 1987.
Reason For Violation:
Failure to implement Total Plant Setpoint Document (TPSD) change request (No. AE 85-03),
feedwater flow transmitters calibration test data, was due to failure of the responsible Results Engineer to verify that the change to
-the TPSD was correctly entered by the Results Engineering clerk. Therefore,
when the next revision to the TPSD was issued, change request No.
AE 85-03 was not. incorporated.
On June 25,
- 1985, the change request was implemented by I&C and the
'feedwater flow transmitters were recalibrated. However, since TPSD was not
- revised, I&C changed back to the incorrect data provided in the the TPSD on January 14, 1987 when the next recalibration was done.
This was corrected on February 4, 1987.
Corrective Steps Which Have Been Taken and Results Achieved:
In February 1986, the procedure for processing TPSD Change Requests was revised.
The Change Request is not incorporated into the TPSD until it has been returned from I&C as " implemented" with all necessary field work or recalibration completed. The Results Engineer reviews the TPSD Proof Sheets for the associated changes and verifies that the changes have been properly incorporated into the TPSD.
The Engineer then makes a Log Book Entry indicating that he has " proofed" the Change Request to provide the documentation that the computer data base has been properly updated, i
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Attachmsnt to UM 87-0162 Page 2 of 5 June 12,1987 1
A-review of all TPSD' Change Requests from the initiation of the Change Request program in 1983 through May 1987 has been completed by Results Engineering. The results of this review are:
1.
Numerous editorial errors had been made in entering change request data into the TPSD 'databose.
Misspelled words, incorrect digits in model numbers, and improper spacing were some of the common
. errors that were found.
None of these discrepancies affect calibration -information.
2.
Errors were found involving improper calibration data for four instruments.
I&C calibrated three instruments correctly at the time it was issued for implementation.
No recalibration is necessary for these instruments.
- However, one instrument was eslibrated according.to, faulty information in the TPSD.
As it does. not involve critical instrumentation, recalibration is scheduled during the refueling outage.
Corrective' Steps'Which Will Be Taken To Avoid Further Violations:
The program revision described above provides verification of the incorporation of a TPSD revision into the computer database by Results Engineering.
Additionally, the review of all TPSD change requests as described above verified that no other change requests affecting setpoints have been lost in the process of incorporation as was AE 85-03.
Additionally, the setpoint change request form that is used to initiate and track the status of changes to the TPSD has been revised to include a verification. sign-off by the Results Engineer that all computer database changes have been completed.
As a result of. the TPSD Change Request review and the resultant high degree of assurance that-no other significant omission or inaccuracy in setpoint data currently exists in the TPSD, no further corrective steps are believed to be necessary.
The Date When Full Compliance Will Be Achieved:
Full compliance has been achieved.
Comment The change request regarding the feedwater flow transmitter calibration test data (No. AE 85-03) was signed as completed as it had been implemented in the field by I&C, and the flow transmitters recalibrated using the test data on the change request.
Subsequent issue of the next revision of the TPSD without change request No.
AE 85-03 caused I&C at the next recalibration to recalibrate using incorrect data.
I The results of the review performed by Results Engineering on all Change Requests from the initiation of the program in 1983 through May, 1987 i
provides a high degree of assurance that no omissions or inaccuracies in setpoint data currently exists in the TPSD which could cause errant indications on other critical instrumentation.
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Attachm:nt to WM 87-0162 Page 3 of 5 June 12,1987 1
Violation (482/8705-02): Failure to Perform Activities In Accordance with Established Procedures j
Finding:
j a i Technical' Specification (TS) 6.8.1 requires that, " Written procedures shall
~ l be established, implemented, and maintained covering.
a.
The applicable procedures recommended in Appendix A of RG 1 33, Revision 2,
'F.ebruary 1978."' Section 8 of Appendix A of RG '1.33 states that. activities related to surveillance. tests should be covered by written proo dures..
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Administrative Procedure ADM 02-300, Revision 8, " Surveillance Testing,";and Surveillance Test STS RE-011, Revision 1, "RCS Total Flow Rate Measurement" had been established and implemented in accordance with the above TS.
i Section A.3 of ADM 02-300 defined test deficiency as "Any degraded condition associated with a surveillance activity which potentially resulzs in the acceptance criteria. noh being met, premature termination; of. the surveillance, or any STS procedural discrepancies which require;a procedure /..
change."
Section 5.4.1.3 states that each test ' performer is responnible for documenting and reporting all test deficiencies to the shift supervisor, and Section 6.7.1 states:
"Upon determination of a Test Deficiency, the Test Performer shall:
- Notify Shift Supervisor
- Document a brief description of the condition in the Test Deficiency section of. the STRS.
(Section 3, Attachment 1)
- Initial and date in the Test Deficiency section' of the STRS.
(Section 3, Attachment 1)."
Contrary to the above, during the performance of surveillance test STS RE-011,. Revision 1, "RCS Total Flow Rate Measurement," on Janbary 14,
- 1987, even though the total RCS flow rate calculated in accordance with STS RE-011 was below the minimum flow required by the STS and TG 323, the test performer did not,.upon determination of this test deficiency, perform the activities required by Sections 5.4.1 3 and 6.7.1 of Administrative Procedure ADM 02-300, Revision 8, " Surveillance Testing _"
Reason For Violation:
When the results of STS RE-011, RCS Total Flow Rate Measdement, indica ed a reduction in RCS Flow Rate from cycle 1 of 3.6% (below the minimum flow rate required by Technical Specification 3/4.2.3),
the results were not considered to be indicative of actual plant conditions.
This information j
was immediately conveyed to the Plant Manager and the ' Superintendent of 1
5 Operations.
The test was suspended and the following day the data was collected again to check repeatability, at which time th? shift supervisor l
was informed that the results from the previous day were considered to. be l
invalid.
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- Att2ch'm nt>tofWM. 87-0162L
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1 Psge'4 of.5' 1 June 12,1987J
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' Plant Procedure:.ADMf'02-300 defines, test deficiency as. "any. degraded I
condition-' associated with~a,i being. met, surveillance activity which potentially resulta j
in' the ' acceptance criteria ucs premature termination of the-surveillance,- f or. any. STS procedural discrepancies which' require 'a procedure change." LAt:the time of the inciddnt,. the test performer did not interpret q
the situation as constituting a testLdeficiency for the following reasons:
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1.: Engineering judgement was that there"was'not a 3.6% reduction l
in ~ flow rate from end of cycle 1lto beginning of cycle 2-and!
j there were other plant indications to support this, therefore,.
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the results were%contctdered as invalid.
Had.the results
' indicated t a-3.f4 increase in JRCS' flow rate-with.all~other
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plant indicatiotic the same, the results'would still have been considered as' invalid.
At.the time, the' test ' performer did a
not considir invalidtdata. as a basis,for. considering the potential: ol not meeting the acceptance driteria to exist.
2.
The test was not terminated; It was' suspended.for investigation, t
c3.
Therewerenoobservedproceduraidiscrepancies.
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s Corrective St'eps Which Have Been~ Taken' and Results Achieved:-
.ADM 02-300,. " Surveillance Testing", has been revised to.further delineate -
i requiredLaction in the event'of a test deficiency.
'The test performer and' 1
. associated: group' have been advised -that if a surveillance test result' does j
not meetzthe' acceptance criteria, it shall.be handled as.a test deficiency b
regardless of the circumstances; b
Corrective Steps Which Will' Be Taken To Avoid Further Violations:
.ADM 02-300, " surveillance Testing" has been revised to require that whenL a j
surveillance test is suspended through shift turnover due to a test i
deficiency, the NRC RRI also be notified in addition to. the shift i
supervisor.
Additionally, all groups performing surveillance procedures l
affecting. operability have received. instruction of the requirement. and importance of ' notifying the shift supervisor of any test descrepancy or suspension.
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~The Date When Full Compliance Will Be Achieved:
Full compliance has been achieved.
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' Additional Comment Comments on the management decision to take the plant to an indicated power of 100% on January.19 and 20, 1987:
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- Attachm2nt 'tci WM 87-0162
.Page 5.of 5
' June 112, 1987c n
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- It' was.the intent of Reactor Engineering to perform STS RE-011 at full
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' power.. Instrument calibrations were being performed at 100% Reactor Thermal-
- Power?(RTP) L for-performance of.the surveillance when a plant trip occurred.
Due to-the~ calibration window-of seven : days as required by Technical I
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y Specification.Sorveillance Requirement 4.2.3.5, it was decided to ; perform qJ '
.the. test during power ascension'at.76% RTP rather than repeat the entire' L
calibration of associated instruments which had been completed. Step-2.1 of STS:'RE-011 states,.
"This' test should be conducted with the power level greater than or equal.to 75% power to minimize instrument inaccuracies." It was= known-prior.to performing' the test at 76% power that inaccuracies were' being introduced that would' not be present at 100% RTP.
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The' test result indicated a -3.65 decrease in RCS flow rate which was:
' determined to be inaccurate.
Reactor power is directly proportional to the RCS-flow rate,; yet there 'were no indications of a similar drop. in electrical output.. Also, prior. to increasing power to 1005 RTP, calibration results of
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applicable 1nstrumentation were checked..The RCS flow rate measured at.100%
RTP. on January 19, 11987 was' above the minimum required flow rate but still indicated a reduction'from cycle 1.
At this point there was cause to J
suspect.the calibration procedures of applicable instrumentation and power was maintained'below 985 RTP.pending the. investigation and subsequent recalibration of feedwater flow instrumentation.
LA' review of other instrumentation necessary :for the RCS Flow and.
Calorimetric' determinations has been completed. STN-IC-417E " Calibration of 1
Steam: & Feedwater Flow Transmitters,".STS-IC-504A " Reactor Coolant Flow -
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L Full Flow Calibration" and STS-IC-504B " Reactor Coolant' Flow - Transmitter 1
F Calibration" have1 been revised as necessary.
No other instrumentation or procedures required revision.
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