ML20244B902
| ML20244B902 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 06/07/1989 |
| From: | Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| References | |
| NUDOCS 8906140028 | |
| Download: ML20244B902 (2) | |
See also: IR 05000482/1989005
Text
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JUN 7W
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In Reply Refer To:
Docket:
STN 50-482/89-05
Wolf Creek Nuclear Operating Corporation
ATTN: Bart D. Withers
President and Chief Executive Officer
P.O. Box 411
Burlington, Kansas 66839
Gentlemen:
Thank you for your letter of May 31, 1989, in response to our letter and
the attached Notice of Violation dated May 1, 1989.
In regard to
Violations 482/8905-01 and -02, we have reviewed your reply and find it
responsive tS the concerns raised in our Notice of Violation. We will review
the implementation of your corrective actions during a future inspection to
determine that full compliance has been achieved and will be maintained.
As a result of our review of your response to Violation 482/8905-03, we find
that additional information is needed. Specifically, your letter states that
you are evaluating several options to enhance drawing control in the control
room. Your letter further states that the selected corrective action will be
completed by August 31, 1989.
Please provide the supplemental infonnation
describing your selected corrective action within 30 days of when your
evaluation is complete or August 31, 1989, whichever is earlier.
Sincerely,
Original Signed By
Ja m e s, L, l?1 b oMt
James L. Milhoan, Director
Division of Reactor Projects
cc:
Wolf-Creek Nuclear Operating Corporation
ATTN: Otto Maynard, Manager
of Licensing
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P.O. Box 411
Burlington, Kansas 66839
Wolf Creek Nuclear Operating Corporation
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ATTN: Gary Boyer, Plant Manager
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P.O. Box 411
Burlington, Kansas 66839
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ATTN: Robert D. Elliott,. Chief Engineer
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Topeka, Kansas 66612-1571
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Kansas Radiation Control Program Director.
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D. V. Pickett, NRR Project Manager.(MS: .13-D-18).
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NUCLEAR OPERATING CORPORADON
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Proendent and
Chief Executive Officer
May 31, 1989
U. S. Nuclear Regulatory Commission
ATTN: Document Control Desk
Mail Station Pl-137
Washington, D. C. 20555
Reference: Letter dated May 01, 1989 from L. J. Callan, NRC,
to B. D. Withers, WCNOC
Subject:
Docket No. 50-482: Response to Violation 482/8905-01,
02, and 03
Gentlemen:
Attached is Wolf Creek Nuclear Operating Corporation's (WCNOC) response to
violations 482/8905-01,
02,
and 03 which were documented in the Reference.
Violation 482/8905-01 involved an inoperable fire barrier,
482/8905-02
involved the failure to lock a valve in accordance with procedure, and
482/8905-03 involved the failure to update a drawing.
If you have any questions concerning this matter, please contact me or Mr.
O. L. Maynard of my staff.
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Very truly yours,
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Bart D. Withers
President and
Chief Executive Officer
BDW/jad
Attachment
cc:
B. L. Bartlett (NRC), w/a
E. J. Holler (NRC), w/a
R, D. Martin (NRC), w/a
D. V. Pickett (NRC), w/a
A 0()Oh 00]Offg>-
PO Box 411/ Burhngton, KS 66839 / Phone: (316) 364 8831
An Equal Opportunity Ernployer M OHCVET
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Attachment to WM 89-0161
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Page 1 of. 4
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Violation (482/8905-01): Inocerable Fire Barrier
Finding:
TS 6.8.1 requires that written procedures be established
implemented, and
maintained for, among other things, the fire protection program.
Procedure
ADM 13-103 ' Revision 5
" Fire Projections.
Impairment Control," implements
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procedures for impaired fire protection equipment ' including' degraded fire
barriers. ADM 13-103
Section 4
requires that fire protection impairment-
control permit. forms'be prepared for all fire protection system impairments-
-and that entries be made in the fire protection impairment control log'for.
the impairments.
Contrary, to the above, on February 25 . 1989,
the NRC inspector identified
an open, unsealed, 3/4-inch conduit located'between Room 1326 (Fire Area A-
14)'and Room 1329 (Fire Area A-33) for which no fire impairment had been.
issued.
Reason For Violation:
Investigation -into the -reason the conduit was not sealed has concluded that
the . original embedded conduit had been thrown out of level
.during.
construction,
leaving it - undesirable 'for use as a raceway.
It was
subsequently
abandoned
and
overlooked
during
sealing
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activities. Probable cause of this oversight was its similarity in r;ize and
approximate location to form tie bolt holes present in the area.
It was
noted through the investigation that this penetration was not previously
g
identified on the Turnover Exception Item List.
Based on the investigation,
the failure to take corrective actions is due to personnel oversight at the
time of construction turnover.
Corrective Steps Which Have Been Taken And Results Achieved:
Corrective Work Request.to seal the unsealed conduit was initiated.
A Fire
Impairment
Control Permit was issued and an hourly fire watch was
established on February 28, 1989. The impairment permit and fire watch were
maintained until grouting of the penetration was completed on March 17,
1989.
Corrective Steps Which Will Be Taken To Avoid Further Violations:
The unsealed conduit is believed to be an isolated case as no other unsealed
penetrations were noted in the area.
Date When Full Compliance Will Be Achieved:
Full compliance has been achieved.
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' Attachment to WM 89-0161
Page 2 of 4
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Violation (482/8905-02): Failure to Lock a Valve in Accordance With
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Procedure
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Finding:
TS 6.8.1 requires that written procedures shall be established including the
applicable procedures recommended in Appendix A of Regulatory Guide (RG)
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1.33,
Revision 2,
dated February 1978.
Appendix A of RG 1.33 states that
equipment control (e.g.,
locking and tagging) should be covered by written
procedures. Checklist A of AL-120. Revision 11 " Auxiliary Feedwater Normal
Lineup," requires,
in part,
that the handwheel to the Turbine Driven
Auxiliary Feedwater (TDAFW) Pump Discharge Isolation Valve AL HV-012 be
lockwired in the neutral position.
Contrary to.the above, on February 08,
1989,
the NRC inspectors observed
that AL HV-012 was not lockwired in the neutral position.
Reason For Violation:
AL HV-012 (TURB DRIVEN AFWP DISCH HDR TO S/G C ISO) was found by the NRC
resident inspector with the locking wire and seal installed but the seal was
not properly crimped.
ADM 02-102 (Control of Locked Component Status) and
CKL-AL-120 (Auxiliary .Feedwater Normal ~ Lineup) requires AL HV-012 to be in
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the locked neutral position. The seal and wire are used as a' locking device
and are meant to serve as an Administrative Control only. Additionally, AL
HV-012 is specifically identified with a blue valve tag with the required
" locked neutral" position engraved on the tag to alert personnel of the
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requirements to treat this valve as a locked component per the . requirements
of ADM 02-102. AL HV-012, es well as other required locked components, were
vergfiedandsecondcheckedon 12/10/88 prior to plant heatup greater than
200 F.
The cause for AL HV-012 not being properly locked appears to have
been the failure of operations personnel to properly crimp the seal when
attaching the locking wire and its ceal.
The seal and wire became
disengaged subsequent to the locked valve verification effort and. went
undetected until noted by the NRC resident inspector.
The locked neutral
valve construction prevents effective utilization of a locking wire and
seal.
The method for locking valves full open or full closed precludes this
type of problem.
Corrective Steps Which Have Been Taken And Results Achieved:
The Shift Supervisor dispatched an operator tu verify ALHV-012 valve
position and properly lockwire the valve in the locked neutral position.
Operations personnel performed a verification of locked neutral valves to
ensure these valves were properly lockwired.
No discrepancies were
identified.
Additionally,
Operations personnel performed a walkdown of
locked open and locked closed valves outside of containment to verify that
these valves were properly lockwired.
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Attachment to WM 89-0161
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Page 3 of 4
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Corrective Stnos Which Will Be Taken To Avoid Further Violations:
Due to previous problems with locked neutral valves, Operations management
implemented a new method for locking valves required to be in a locked
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neutral position.
The new method utilizes stainless steel wire and a
locking tab as' opposed to a lead seal.
Operations personnel installed the
stainless steel wire and locking tab on all locked neutral valves.
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additional verification of locked neutral valves was performed post-
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installation
of
the stainless steel wire and locking tab with no
discrepancies identified.
The Operations department will conduct periodic
inspections and verifications of the locked neutral valves to verify the
effectiveness of the new method for locking neutral valves.
A letter to Operations personnel describing the new method for locking
valves required to be in a locked neutral position has been placed in
Operations Required Reading.
Date When Full Compliance Will Be Achieved:
Full compliance has been achieved.
Violation (482/8905-03):
Failure to Update Drawinz
Findinn:
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Appendix B,
Criterion V states,
in part,
that activities
affecting quality shall be
prescribed
by
documented
instructions,
procedures,
or drawings and shall be accomplished in accordance with these
instruction, procedures, or drawings.
Licensee Administrative Procedure ADM
01-042, Revision 9 " Plant Modification Request implementation," Step 5.4.5,
requires color coding applicable control room drawings
to
indicate
implementation progress,
if a plant modification request (PMR) is partially
implemented.
Contrary to the above,- on February 28,
1989, the NRC inspector determined
that Drawing M-12AL01(Q) was not color coded (" redlined") to reflect field
implementation and partial closeout of PHR 00264 in December 1986.
Reason For Violation:
Drawing M-12ALO1(Q) had been redlined sometime between 9/09/88 and 9/20/88.
This is based on discussions with personnel involved and from auditor's
notes of a Quality Assurance surveillance on the redline program,
then in
progress.
The drawing was excluded from the auditor's problem list in that
time period, indicating it had been properly redlined.
A replacement for this drawing had been requested on 9/15/88,
apparently
because of soiling or damage, after the redlining took place. Mark-ups were
not transferred since the replacement drawing was found unmarked during the
NRC inspection on 2/28/89.
The replacement drawing remained at revision
"0",
confirming that replacement occurred outside the drawing revision
process
(i.e.
the drawing was re-issued upon request from the Control Room
in lieu of being issued due to a revision).
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Attachment to WM 89-0161
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Page 4 of 4
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Corrective Stens Which Have Been Taken And Results Achieved
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Drawing M-12ALO1 (Q),
Rev. O has
been
redlined
to
reflect
field
implementation and partial closeout of PMR 00264.
A letter has been issued
to Shift Supervisors
and
Supervising
Operators
providing
interim
instructions for the replacement of damaged or soiled drawings which have
been redlined.
Corrective Steps Which Will Be Taken To Avoid Further Violations:
A significant effort has been expended to improve the method for updating
drawings in the Control Room. A Quality Assurance surveillance conducted in
Augret of 1988 identified several concerns relative to Control Room
drawings.
A task force was convened to address these concerns and resulted
in various currective actions.
Procedure ADM 01-042,
" Plant Modification
Request Implementation" was revised to provide acceptable methods and
instructions for redlining PMR changes on affected Control Room drawinge. A
review of Control Room drawings that require redlining for PMRs that have
been installed has been completed.
A drafting person has been assigned to
perform the redlining of Control Room drawings to provide consistency and
reduce the number of individuals interfacing with changes to Control Room
drawings.
Document Control personnel provided training to the Control Room
shift clerks on drawings and document control methods.
A verification of corrective action surveillance was performed by Quality
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Assurance during May 1989 and identified based upon a sampling of Control
Room drawings that redlining was being performed in accordance with
procedure ADM 01-042.
WCNOC is evaluating several options to enhance drawing control in the
Control Room along with the replacement of damaged or soiled drawings.
The
evaluation and implementation of appropriate administrative controls to
enhance the drawing control process will be completed by August 31, 1989.
Date When Full Compliance Will Be Achieved:
Full compliance has been achieved and the drawing
control
process
enhancements will be completed by August 31, 1989.
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