ML20237J487

Responds to NRC Re Violations Noted in Insp Rept 50-482/87-15.Corrective Actions:Procedure Governing Hydrostatic Testing Changed to Ensure Correct Pressure Indicated at Location That Repair Made

ML20237J487
Person / Time
Site:	Wolf Creek
Issue date:	08/21/1987
From:	Withers B WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
WM-87-0217, WM-87-217, NUDOCS 8708260193
Download: ML20237J487 (5)

Text

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LF CREEK W6) NUCLEAR OPERATING Bart D. Withers

ggg, August 21,1987 WM 87-0217 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.

20555

Reference:

Letter dated 7/22/87 from JEGagliardo, NRC, to BDWithers, WCNOC

Subject:

Docket No. 50-482:

Response to Violations 482/8715-01' and 482/8715-02 Gentlemen:

Attached is a detailed response to violations 482/8715-01 and 482/8715-02 which were documented in the Reference.

Violation 482/8715-01 concerns a-failure to comply with Technical ' Specification (TS) 4.0.5..

Violation.

482/8715-02 concerns a violation of Technical Specification 4.3.3.11, Containment Purge System Surveillance.

If 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 BDW/jad l-Attachment cc:

P0'Connor (2)

RMartin JCummins 8703260193 070821 PDR ADOCK 0500 l

/,

An F : 41 Opportunity Employer Mf/HC.YET Y

1 1

Page 1'of'4 I

Attachment to WM 87-0217 August : 21, _1987

a Violation (482/8715-01)

Failure to Comply With Technical Specification iT5) 4.0.5 Finding:

Technical Specifications.4.0.5

requires, in part, that,

"... Inservice testing of ASME Code ~ Class 1, 2,

and 3 pumps and valves shall be perfomed in accordance with Section XI of the ASME Boiler and Pressure Yessel Code and applicable' addenda as required by 10 CFR Part 50, Section~ 50.55a(g)...."

Section 50.55a(g)(5)(iii)-of 10 CFR Part 50 requires, "If the licensee has determined that conformance with certain code requirements is impractical for'its facility, the licensee shall notify the Commission...."

Contrary to the above, on June '23, 1987, the NRC inspector,.

through a routine review of work requests and discussions with licensee personnel, became aware that a section of safety-related, ASME Code Class 3,

piping downstream Valve EFV090 had :not been properly pressure tested after a through-wall repair and would not be tested until next refueling outage.

The. licensee had failed to notify the Commission.

Reason ror Violation:

Following the through wall repair of the section of safety-related, ASME Code Class 3, piping downstream of Valve EFV090, a hydrostatic test was perfomed. -

Subsequent to the hydrostatic test, it was discovered that the hydrostatic test equipment configuration was improper. resulting in the pressure test not meeting the required 224 psig hydrostatic test pressure.

The reason for the violation was a failure to recognize the applicability of Technical Specification 4.0.5. to post maintenance testing.

Technical Specification 4.0.5, Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2,

and 3 components, was interpreted to be applicable only to inservice testing and not post maintenance testing.

Corrective Steps Which Have Been Taken and Results Achieved:

On June 23, 1987, Wolf Creek requested and received, by teleconference with the NRC, temporary relief from ASME Section XI in order to delay performing a new pressure test until the next refueling outage.

Additionally, relief was requested and granted for delaying testing of two other sections of safety-related piping which have been repaired but cannot be pressure tested 1

with the unit in Mode 1.

On June 30, 1987, the above verbal relief request along with the technical justification was formally submitted to the NRC.

i

______n i

j Attachm:nt to WM 87-0217 Page 2 of 4 August 21, 1987 Corrective Steps Which Will Be Taken To Avoid Further Violations:

j

'For thi s hydrostatic test, the pressure indicator was located in a spot which did not give a true indication of the pressure at the. location of the through-wall repair.

This resulted in not meeting the hydrostatic test pressure, even though the pressure indicator showed the required pressure was met. To prevent recurrence of the hydrostatic test pressure not meeting the required test pressdre because of an improper test equipment configuration,_ the procedure governing hydrostatic testing has been changed to ensure the correct pressure is indicated at the location that the repair was made.

The Superintendent of Maintenance has instructed the maintenance engineers by a written memo of the requirements of Technical Specification 4.0.5 and i

10 CFR 50.55a(g)(5)(iii).

l Date When Full Compliance Will Be Achieved:

Full compliance has been achieved.

Violation (482/8715-02):

Violations of Technical Specifications-Containment Purge System Surveillance Finding:

TS Surveillance 4.3.3.11 requires that, "Each radioactive gaseous effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION, and ANALOG CHANNEL OPERATIONAL TEST at the frequencies shown in Table 4.3-9."

Step 3.a of Table 4.3-9 requires that, quarterly, the Analog Channel Operational Test ( ACOT) be performed for the containment purge system noble gas activity monitor (GT-RE33) providing alarm and automatic termination of release,

and that the ACOT shall also demonstrate that automatic isolation i

of the containment purge pathway occurs when the instrument indicates l

measured levels above the Alarm-Trip Setpoint.

Contrary to the above, on July 1, 1987, the licensee determined that TS Surveillance 4.3.3.11 was not adequately performed between October 1985 and October 1986 and between December 1986 and June 1987, in that, the surveillance procedure for performing this surveill ance, STS IC2758, Rerision 4,

" Anal og Channel Operational Test Containment Purge System Radiation Monitor GT RE33," failed to demonstrate that automatic isolation of the containment purge pathway occurred when radiation monitor (GT RE33) indicated measured levels above the Alarm-Trip Setpoint.

This violation is a repeat of Violations 482/8541-01 and 482/8634-02.

p' Attachmtnt to WM B7-0217 Page 3 of 4.

t August 21,.1987 Reason For Violation:

On July 1,

1987, during review and revision o f. the Analog Channel L

Operational Test ( ACOT) procedures for the Containment Purge Radiation Monitors. GT -RE22 and GT RE33, Instrumentation and Control pe sonnel discovered that Technical Specification 4.3.3.11 Surveillance Requit ments were -not being completely satisfied.

This occurrence was reported to the.

NRC as a Technical Specification violation in LER 87-029-00 on July 31, 1987.

Technical Specification 4.3.3.11

requires, in part,. demonstration of automatic pathway isolation and control room alarm annunciation, when the Containment Purge Radiation Monitors indicate measured levels above the Alarm-Trip Setpoint value, on a quarterly basis. During review and revision of the ACOT procedures for GT RE22 and GT RE33, Instrumentation and Control personnel discovered that these procedures did not' address verification of automatic pathway. isolation.

It was then verified that this surveillance requirement was not being satisfied quarterly via any other surveillance

'i procedure.

Investigations into this occurrence determined that this surveillance requirement had previously been included in the ACOT procedures.

In July of

1985, difficulties were encountered in the perfonnance of these procedures because of the system lineup specified in the procedures.

Consequently, during.a subsequent procedure revision in October of 1985, this requirement was deleted from the ACOT procedures.

The reason for the violation was an inadequate review of the procedure revision.

Corrective Steps Which Have Been Taken and P,esults Achieved:

Control Room personnel were notified of this discrepancy and declared GT RE22-and GT RE33 inop"erable at approximately 1555 CDT. An entry was made into Action Statement b"

of Technical Specification 3.3.3.11, which requires suspension of effluents via the affected pathway. On July 2,1987, portions of surveillance procedure STS GP-001,

" Containment Penetration Integrity Verification",

were utilized to initiate a manual Containment Purge Isolation Signal and test the circuitry not covered by the existing ACOT procedures.

Upon satisfactory completion of this testing at approximately 1336 CDT on July 2, GT RE22 and GT RE33 were declared operable and Action Statement 3.3.3.11 "b" was exited.

A new procedure is being developed to satisfy the surveillance requirement of verifying proper pathway isolation on a quarterly basis.

In order to prevent recurrence of this event, an enhancement has been made to the procedure change review process. This enhancement programmatically requires the individual proposing to change a surveillance procedure document that the proposed change, when incorporated, will continue to meet the requirements of the surveillance program.

Attachment to WM 87-0217 Page 4 of 4 August 21, 1987 Corrective Steps Which Will Be Taken To Avoid Further Violations:

The requirement that the individual proposing to change a surveillance procedure, document that the proposed change, when incorporated, will continue to meet the Technical Specification surveillance requirements should avoid further violations of this type.

Date When Full Compliance Will Be Achieved:

.The enhancement has been made to the procedure change review process.

The procedure under development which will satisfy the surveillance requirement of veri fying proper pathway isolation will be issued prior to the next quarterly performance date which is scheduled to be completed on October 2,

1987.

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