ML20246D376
| ML20246D376 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 05/02/1989 |
| From: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| References | |
| GL-83-28, NUDOCS 8905100210 | |
| Download: ML20246D376 (3) | |
See also: IR 05000482/1988200
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MAY - 2 1989
In Reply Refer To: . 'i
- Docket
- STN 50-482/88-200 (
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Wolf Creek Nuclear Operating Corporation
ATTN: Bart D. Withers
President and Chief Executive Officer >
P.O. Box 411 )
Burlington, Kansas 66839 i
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Gentlemen:
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This refers to your letter of November 30, 1988, which was in response to our
letter and Notice of Violation dated October 19, 1988. We have reviewed your
response and have held a telephone conference between your Messrs. O. L. Haynard,
C. E. Parry and others, and our Messrs J. E. Gagliardo and D. R. Hunter on
April 14, 1989. As discussed in the telephone conference, we have reached the
decisions or need additional information regarding your response to the
violations as delineated below:
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Violation A (482/88200-01) Failure to Take Adequate Corrective Actions
Your' corrective actions appear to be acceptable and appropriate to correct
the conditions listed in the violation. We shall review the
implementation of your corrective actions for this violation during a
future inspection in order to determine that full compliance has been
achieved and will be maintained. We continue to believe that the examples
of failure to take corrective action were all valid; however, the scope of
your committed corrective actions makes further discussion of this
point moot.
Violation B (482/88200-03) Inadequate Procedure
We request that you provide additional information regarding the training
and qualifications standards which define " skill of the craft." We
l further request that you provide information on how planners, engineers or
others drafting work instructions are knowledgeable of what is encompassed
in " skill of the craft" for the various maintenance disciplines.
ViolationC(482/88200-04) Failure to Establish Procedure
The violation was written to state that you had failed to obtain three
Service Information Letters (SILs) affecting your Emergency Diesel
Generator (EDG) and that you had f ailed to review or evaluate five other
SILs affecting your EDGs. In your response, you state that your only
commitment is to review vendor information, not to obtain vendor
information. We reject this argument, for the intent of Generic
Letter (GL) 83-2P was to assure that pertinent information related to
RIV:0PS* C:0PS* D:DRS * D:DRPg RA Af
DRHunter/cjg JEGagliardo JLMilhoan LJCallan R ftin
/ /89 / /89 / /89 /v/89 /p/89 pl
- previously concurred i l
8905100210 890502 2
ADOCK 0500
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Wolf Creek Nuclear Operating -2-
Corporation ,
maintaining safety-related equipment operable was identified and used. Your
position indicates that you may not have grasped the safety significance
of GL 83-28. We request that you provide us with a fuller description of
your corrective actions with regard to the review and use of vendor
information for safety-related equipment.
Violation D (482/88200-05) Failure to Provide Inspection
We are in full agreement that WCNOC, as licensee, has the ultimate
responsibility for the installation and operation of Wolf Creek. The
issue in this violation is not what responsibility lies with other
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organizations such as vendors; rather the issue is whether or not the
diesel generators are installed so that they can reasonably be expected to.
remain operable under all design basis conditions.
Violation E (482/88200-06) Failure to Follow Procedures
We have reviewed your response to this item and find it responsive to the
concerns raised in our Notice of Violation. We shall review the
implementation of your corrective actions during a future inspection to
determine that full compliance has been achieved and shall be maintained.
Please provide the information requested above with 30 days of the date of this
letter.
Sincerely.
ORIGINAL SMEDW
ROBERT D. MAgg
-Robert D. Martin
Regional Administrator
cc:
Wolf Creek Nuclear Operating Corporation
ATTN: Otto Maynard, Manager
of Licensing '
P.O. Box 411
Burlington, Kansas 6b839
Wolf Creek Nuclear Operating Corporation
ATTN: Gary Boyer, Plant Manager
P.O. Box 411
Burlington, Kansas 66839
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. Wolf Creek Nuclear' Operating -3- ,
Corporation
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- Kansas, Corporation Commission;
ATTN: Robert D. Elliott, Chief Engineer
Fourth Floor. ' Docking. State 0ffice Building:
Topeka, Kansas ~ 66612-1571
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Kansas Radiation Contro1' Program Director
bectoDMB(IE01)-DRS&DRP
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bcc distrib. by RIV: -
RRI .
R. D. Martin, RA
Section-Chief (DRP/D)' DRP
RPB-DRSS- R. DeFayette, RIII
RIV File SRI, Callaway, RIII
MIS System RSTS Operator
,ProjectEngineer(DRP/D) Lisa'Shea,RM/ALF
L' - DRS
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D. V. Pickett, NRR Project Manager (MS: 13-D-18) ,
D. R. Hunter J. E. Gagliardo
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m i W4#LF CREEKwn: NUCLEAR OPERATING CORPORATIO 1
Bart D. Withers DEC -51988 !
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President and
Chief Executive Officer
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November 30, 1988
U. S. Nuclear Regulatory Commission
ATTN: Document Control Desk
Mail Station P1-137
Washington, D. C. 20555
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Reference: Letter dated October 19, 1988 from L. J. Callan, NRC to
B. D. Withers, WCNOC
Subject: Docket No. 50-482: Response to Violations 482/88200-01,
03, 04, 05 and 06
Gentlemen
This letter provides Wolf Creek Nuclear Operating Corporation's (WCNOC)
responce to the five violations documented in the Reference.
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involved failure to take adequate corrective
inadequate procedures (-03), failure to establish procedures (-04), failure
actions
The violations
(482/88200-01)
to provide inspection (-05) and failure to follow procedures (-06). The
Reference provided the NRC's enforcement assessment of the findings from the
Quality Verification Function Inspection (QVFI) conducted in June 1988. The
QVFI findings covered activities that were performed between 1984 and 1988.
It should be noted that some of these findings had been documented in
previous NRC Inspection Reports and corrective actions were taken or
initiated in 1987.
Attachment I provides WCNOC's response to the violations and Attachment II
provides detailed information on the examples associated with the violation j
involving failure to take adequate corrective action (482/88200-01).
Although WCNOC does not agree with all of the violations and examples,
Attachments I and II documents the corrective actions and/or program
enhancements for all of the identified concerns.
On November 18, 1988, in a telephone discussion between Mr. G. L. Constable,
NRC Region IV, and Mr. O. L. Maynard, WCNOC, the submittal response time was
extended until November 30, 1988.
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P.O. Box 411/ Burhngton, KS 66839 / Phone: (316) 364 8831
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] [ A 1 Equal opporturwty Employer MOHCNET '
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Page 2 of 2
November 30, 1988
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
Attachments (2)
cc: B. L. Bartlett (NRC), w/a
D. D. Chamberlain (NRC), w/a
R. D. Martin-(NRC), w/a
D. V. Pickett (NRC), w/a
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[\ Attachment I'to WM 88-0312
Page 1 of 10
Violation (482/88200-01): Failure to Take Adeauate Corrective Actions
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Finding: I
Appendix B, 10 CFR 50 Criterion XVI, requires that conditions adverse to
quality, such as equipment failure and malfunctions, are promptly identified
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and corrected. It alsc states that the causes of significant conditions
E adverse to quality be detenmined and corrective actions taken to preclude
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their repetition. The licensee's Updated Safety Analysis Report, Revision
0, paragraph 17.2.16.1, states in part that corrective action measures have
been established to ensure that conditions adverse to quality are promptly
identified, reported, and corrected to preclude recurrence. Significant
conditions adverse to quality may include a recurring condition for which
past corrective action has been ineffective. Contrary- to these
requirements:
1. The licensee had not taken the corrective actions specified in
engineering evaluation request EER 85-GK-08 (completed November 27,
1985) to resolve -the electrical breaker malfunctions of the heating,
ventilating, and air conditioning- (HVAC) system in the control.
__ building.
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2. The licensee had not fully investigated the underlying causes of the
multiple HVAC damper failures in the control building.
3. The licensee had not promptly taken action to resolve a large number of
actuations in the control room ventilation isolation signal (CRVIS)
system that were attributed to the control room habitability system
chlorine monitor malfunctions that began in 1985.
4. The licensee had not taken actions to correct multiple fire protection
system failures that resulted from the apparent misapplication of valve
microswitches.
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5. The licensee has not aggressively pursued the cause and taken action to i
resolve malfunctions in the emergency diesel engine's jacket water !
pressure sensing system that began in 1986.
Reason for Violation:
Although WCNOC does not agree that all of the examples cited above represent
a violation of Appendix B, 10 CPR 50 Criterion XVI, WCNOC does agree that
.some of the identified problems could have been resolved more ,
expeditiously. The reason that some equipment failures and malfunctions i
. c' s . have not been corrected as promptly as desired is lack of overall
(' programmatic guidance to define and control a root cause evaluation process i
\s for hardware deficiencies.
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Attachment I to WM 88-0312
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Corrective Steps Which Have Been Taken and Results Achieved:
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Specific responses and corrective actions for the examples of this violation
are discussed in Attachment II. Overall corrective actions taken which
address this violation include a restructuring of the daily planning
meetings to focus management attention on problems and corrective actions
rather than on work status. This forum allows work groups to identify
specific problems and get appropriate management attention. In addition,
selected personnel have been trained in root cause analysis. Another step
which has been taken is the addition of a person from Nuclear Plant
Engineering as a member of the on-site Plant Safety Review Committee.
Again, this provides a forum in which various issues can be discussed from
both the Engineering and Operations perspective relative to safety
significance and priorities. These steps have resulted in improvements in
the identification of problem areas and in the cooperation and coordination
among work groups.
Corrective Steps Which Will Be Taken to Avoid Further Violations:
WCNOC Senior Management continues to stress the need to identify the root
cause as problems arise. To strengthen this approach, WCNOC is developing a
formalized root cause analysis program for hardware deficiencies. This
program will include a detailed methodology for root cause analysis as well
p,$)h as requirements for training, documentation, and program interfaces. WCNOC
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g,,,/ believes that integration of this root cause analysis program with existing
programs will result in a more effective and efficient process for
identifying and correcting conditions adverse to quality.
Date When Full Compliance Will Be Achieved: ,
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The root cause analysis program will be initially implemented in March,
1989. The required training will be complete by the end of 1989.
Violation (482/88200-03): Inadeauate Procedure
Pinding: !
Appendix B, of 10 CFR 50, Criterion V, requires that activities affecting
quality be accomplished in accordance with docunented instructions,
procedures, or drawings of a type appropriate to the circumstances.
Instructions, procedures, or drawings shall include appropriate quantitative
or qualitative acceptance criteria for determining that important activities
have been satisfactorily accomplished.
Contrary to the above, NRC inspectors observed during a component cooling
water pump maintenance activity that the licensee's procedures and
instructions provided to the maintenance personnel did not include
/ appropriate cautions or details for removal of the bearing.
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Attachment I to WM 88-0312 )
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Reason for Violation:
Although WCNOC does not agree that this specific event represents a
violation of Appendix B, 10 CFR 50, Criterion V, WCNOC does agree with the
factual information provided in the Inspection Report and acknowledges that
some work procedures could provide more detail to the crafts. However,
WCNOC craft workers do possess and are expected to utilize certain skills
and judgement in their work activities. This bearing removal activity falls
well within the range of ANSI N18.7, 1976 Section 5.2.7 as skills normally
possessed by qualified maintenance personnel. Procedures can never be
written in such detail that the crafts are relieved from recognizing
potential problem areas not identified in the procedure.
The reason the procedure did not contain the level of detail desired by the
NRC inspector is that WCNOC Maintenance work procedure writers rely on the
skill-of-the-craft in many cases and do not put a high level of detail in
the work procedure.
Corrective Steps Which Have Been Taken And Results Achieved:
Subsequent to concerns voiced by the NRC inspector, work was stopped, the
vendor was contacted, and heating limitations were added to the governing
work request by revision. It should be noted that after the limitations
f'"' were added to this work request and the work resumed, the shaft coupling hub
(' released at approximately 400 degrees F which is well below the 750 degree F
limit identified by the manufacturer. Therefore, for this particular work
activity, the reliance on skill-of-the-craft would have resulted in an
acceptable bearing removal.
WCNOC Maintenance supervision have discussed this event with the maintenance
work instruction writers and craft supervisors. Work instruction writers
have been instructed to not rely too heavily on skill-of-the-craft and use
" cautions" where appropriate. It has also been emphasized to the crafts to
request technical assistance when a work activity is not going as planned.
Corrective Steps Which Will Be Taken To Avoid Further Violations:
WCNOC believes the corrective actions discussed above should prevent
recurrence. It should be noted, however, that the degree of detail needed
in work procedures to comply with Appendix B, 10 CFR 50, Criterion V, is
very subjective and perceived compliance will vary between individuals
assessing specific situations. WCNOC strivos to meet the regulations as we
interpret them and as we get additional guidance.
Date When Full Complianca Will Be Achieved.
Full compliance has been achieved.
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Attachment I to WM 88-0312
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Violation (482/88200-04): Failure to Establish Procedures
Finding:
Appendix B, 10 CPR 50, Criterion V, requires that activities affecting
quality be accomplished in accordance with documented instructions,
procedures, or drawings.
Wolf Creek licensing condition 2.C(13) describes the licensee's vendor
interface program as part of their response to NRC Generic Letter 83-28.
Wolf Creek Nuclear Operating Corporation Procedure, KGP-1311, Revision 1,
specifies the function of the Industry Technical Information Program
(ITIP). Part of the ITIP requires that vendor reports be reviewed to
determine their applicability to Wolf Creek Generating Station (WCGS) and,
if necessary, a detailed evaluation is to be performed to determine the
effects on WCGS.
Contrary to the above, the licensee had not obtained three of the SILs that
were potentially applicable to the EDGs supplied to Wolf Creek. It was
further determined that the five EDG SILs that the licensee had received had
not been formally reviewed or evaluated.
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Reason For Violations
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( ,,/ Although procedure KGP-1311, " Industry Technical Information Program" (ITIP) l
requires vendor reports be reviewed for applicability, it does not require
WCNOC to establish a program for obtaining vendor information. This
procedure is consistent with WCNOC's letter to the NRC dated December 10,
1986 and the March, 1984 Nuclear Utility Task Action Committee response to ,
Generic Letter 83-28, Item 2.2.2. Therefore, the statement in the finding: !
' Contrary to the above, the licensee had not obtained three of the SILs that
were potentially applicable to the EDG's supplied to Wolf Creek', appears to
be inappropriate and WCNOC does not agree that this item is a violation of
Appendix B, 10 CFR 50, Criterion V.
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Prior to November 1986, the emergency diesel generator (EDG) Service
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Information Letters (SILs) were being received by an individual employed by
Wolf Creek's architect / engineering firm. Upon leaving the Wolf Creek
project in November, 1986, the individual contacted the vendor and had his
name removed from the list of receivers. It is believed the above
individual assumed other personnel on site were receiving the SILs. This
resulted in no SILs being received by WCGS.
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Attachment I to WM 88-0312
Page 5 of 10
{A)
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This deficiency was discovered in November, 1987, at which time the vendor
was contacted and requested to provide all previous SILs that pertained to
WCGS. The vendor indicated that five SILs pertained to WCGS's model of
diesel engines. Numerous delays were encountered in receiving the SILs and
the vendor was contacted four additional times in an attempt to obtain the
SILs. The vendor indicated they were reluctant to provide the SILs because
the SILs were out of date and were in the process of being revised. After
emphasizing to the vendor WCNOC's strong desire to obtain the SILs due to
the potential safety significance of such information, five SILs were
received in March, 1988, with the understanding from the vendor that up-to-
date revisions would be received in approximately four to six weeks.
Since it was believed that the SILs would soon be revised, the ITIP
Coordinator sent the SILs to the appropriate organizations for an informal
review. The review determined that the SILs had no immediate affect on the
operability of the diesel engines. Therefore, it was determined that the
detailed evaluation required by procedure KGP-1311 could be delayed pending
the receipt of revisions to the SILs.
Corrective Steps Which Have Been Taken and Results Achieved: ,
The five SILs received from the vendor and three additional SILs received
from the NRC inspector were reviewed in accordance with procedure KGP-1311
- on June 16, 1988 after discussions with the NRC inspector. The evaluation of
, the SILs did not identify any substantial safety concerns. However,
(__,/ additional preventative maintenance activities have been incorporated into
the Preventative Maintenance Data Base as a result of the SILs.
A Programmatic Deficiency Report was initiated to determine if additional
EDG SILs applicable to WCGS were not provided by the vendor. The Supplier
Quality organization performed a surveillance at the vendor's offices on
July 21, 1988, and identified two additional SILs which had not been
provided by the vendor. These two SILs were subsequently reviewed and
evaluated in accordance with procedure KGP-1311. Additionally, the
surveillance verified the appropriate contacts were in place on the vendor's
list of receiver's for SILs and that an adequate system exists for
transmittal of future SILs.
Corrective Steps Which Will Be Taken To Avoid Further Violations:
The vendor EDG SIL program will be audited on a regular frequency to verify
that an adequate system exists for transmittal of SILs. Although, as
explained above, WCNOC's vendor interface program is currently in
compliance with commitments associated with NRC Generic Letter 83-26, a
program is currently under development to enhance the vendor interface
process at WCGS. A procedure is being developed to provide a method for
contacting certain hardware suppliers to determine if they have issued
letters or bulletins which could impact components or systems at WCGS. This
fs program will be implemented by July 31, 1989.
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Attachment I to WM 88-0312
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Date When Full Compliance Will Be Achieved:
WCNOC believes that the decision not to perform the detailed evaluation of
the SILs was appropriate based on the informal review and because the vendor
had indicated that these SILs were in the process of being revised. Full
compliance has been achieved.
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Violation (482/88200-05): Failure to Provide Inspection
Finding l
Criterion X of Appendix B to 10 CFR 50 requires that a program for
inspection of activities affecting quality be established and executed by or
for the organization performing the activity to verify conformance with the
documented instructions, procedures, and drawings for accomplishing the
activity.
Contrary to the above, NRC inspectors found that during construction of the
EDGs, the licensee had not verified that the safety-related seismic and
vibration control emergency diesel turbocharger cooling water pipe supports
had been installed as required by the vendor's design drawing.
O Reason For Violation
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\~ # WCNOC recognizes that it has the ultimate responsibility for assuring that
the installed systems are capable of performing its safety function.
Although it is true that Wolf Creek Generating Station (WCGS) had not
verified that the safety-related seismic and vibration control supports were
installed, Wolf Creek Nuclear Operating Corporation (WCNOC) believes that
this is not a violation of 10 CFR 50, Appendix B, Criterion X requirements.
As explained below, the receipt inspection program which was in place when
the Emergency Diesel Generators (EDG) were shipped to WCGS complied with 10
CFR 50 Appendix B, Criterion X requirements and did not require inspection
of these supports. Rather, verification of the installation of the required
components was the responsibility of the vendor. WCNOC believes that it is
not appropriate to cite activities under the control of a vendor's quality
program as a violation of WCNOC's Criterion X requirements unless this
results in a degradation of the ability of the EDG to perform its safety
function. WCNOC believes that the Quality programs in place were adequate
for providing assurance of EDG functionality. The vendor activities
identified in this particular case did not invalidate the EDG's ability to
perform its safety function during the design basis accidents.
The EDGs were originally furnished by Colt Industries during the
construction phase of WCGS as skid mounted subcomponent systems due to the
size and complexity of the EDGs. Each EDG was manufactured and furnished I
under Colt's Quality Program. This program was reviewed and accepted by l
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three separate organizations, the ASME,
(Bechtel Power Corporation), and Wolf Creek.
the organization procuring the EDGs l
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Page 7 of 10
%sl In addition, Bechtel established and executed a program which encompassed
the review of EDG documents (e.g., drawings, procedures, reports, etc.),
surveillance of manufacturing processes and final shop inspection of the
EDGs including skid mounted subsystems prior to their release for shipment.
These activities were in addition to those performed by the Authorized i
Nuclear Inspection agency engaged by Colt. I
At WCGS, a receipt inspection program, QCP-I-01, " Receipt, Storage, and
Preservation of Quality Related Material and Items' was established and
executed by the constructor acting on behalf of KG&E. Under this program, i
for the material / items which were procured by another organization, such as !
Bechtel, and also had a final ship inspection report (or equivalent release
document) indicating that the procuring organization had performed a final
shop inspection, receipt inspection was restricted to the following
elements:
a) review of documents submitted with the material / items for
completeness, legitability, and the correct number and type of
documents.
b) inspection for evidence of shipping / handling damage.
c) an accountability review for correct material / items and number of
material / items.
\s_/ d) a general configuration review, as appropriate, to verify size,
length, finish', etc.
Inspection to the level of detail necessary to verify each and every
component, subcomponent, and sub subcomponent on a complex piece of vendor
furnished equipment, such as the EDGs, was the responsibility of the vendor
and their ANI as applicable under the vendor's Quality Program.
Corrective Steos Which Have Been Taken and Results Achieved:
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When it was discovered that the seismic and vibration control supports were
missing, WCNOC contacted Colt to determine if the turbocharger cooling pipe j'
could perform its intended function without the supports and whether the
turbocharger cooling pipe would experience cracking or the flange bolts
would loosen as a result of excessive vibration.
Colt refered to Colt Industries' Engineering Report No. M-018-0367-02,
l " Seismic Calculations for Skid Mounted Piping." A tchle in this report
indicated that the support bracket would be required for the turbocharger
cooling piping in a seismic event if the length of the piping was greater
than 60.7 inches.
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Attachment I to WM 88-0312
Page 8 of 10
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The subject piping was measured and found to be 56 inches in length; thus it
was concluded that the turbocharger cooling pipe would perform its intended
function during a seismic event without the support brackets. WCNOC also
performed a confirmatory seismic calculation, which also indicated that the
pipe did not require the support to withstand seismic loading. .
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Even though the available engineering data did not support installation of
the supports for seismic reasons, Colt recommended WCNOC install the four
missing supports to ensure that vibraticns from the operating diesel engine
would not cause degradation of engine components. In additi.on, Colt
recommended that WCNOC visually inspect the pipes for cracking and a loss of
jacket cooling water and perform a torque inspection for all associated pipe
flange bolts.
WCNOC took immediate actions to fabricate and install the four pipe supports
and performed the inspections recommended by Colt. In addition WCNOC
performed nondestructive examinations on all four turbocharger cooling water
pipes and a vibration test and analysis to determine if there were any
additional adverse effects on the cooling pipe caused by operating the EDGs
without the supports. No adverse effects of the missing supports were
revealed.
Following these immediate corrective actions, the investigation focused on
the reasons that the "as installed" configuration was different than the
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with Colt, it has been determined that while the drawings contained in the
instruction manual may show the installation of components such as supports,
the drawings are included for the purpose of identifying parts, and are not
intended as the final as built configuration drawings. Thus the fact that
the parts drawings in Manual M-018-00309 may show the vibration control
supports does not mean that these supports are required in order for the
EDGs to fulfill their design function.
In early September 1988 WCNOC performed a walkdown of tubing and pipe
supports on the Lube 011, Fuel Oil. Injection Cooling and Air Start systems
of both EDGs. This walkdown involved personnel from NFE, Maintenance and
Quality Control utilizing Colt Manual M-018-00309. As a result of the
walkdown, deviations from the vendor manual were discovered on both EDGs.
Appropriate documentation has been issued for evaluation and updating of the
applicable drawings in M-018-00309 to more accurately reflect the existing
configuration of the EDGs. NPE is currently working with Maintenance and
Colt in response to these items. No adverse affects on the proper
functioning of the EDGs has been identified to date.
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Atta'chment I to WM 88-0312
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\ Corrective Steps Which Will Be Taken To Avoid Further Violations:
The actions discussed above should avoid further instances of vendor
nonconformances relative to seismic and vibration control supports on the
EDGs. In addition, actions discussed in response to violation 482/88200-04
relative to the vendor interface program should help reduce further problems
in this area.
Date When Full Compliance Will Be Achieved:
Evaluation of the deviations identified during the September 1988 walkdown
of the EDGs will be complete by 12/31/88.
Violation (482/88200-06): Failure to Follow Procedures
Finding:
Technical Specification 6.8.1 requires that written procedures be
established, implemented, and maintained for the fire protection program.
Procedure ADM 13-103, Revision 5 " Fire Protection: Impairment Control,"
implements procedures for impaired fire protection equipment. ;
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Wolf Creek Updated Safety Analysis Report, Section 9.5, Table 9.5.1-3 (sheet l
/ s 4), requires that all fire barriers and their penetrations separating '
( , ) safety-related areas from those that are not safety-related or separating
portions of redundant systems important to safe shutdown shall be operable
at all times. Should one or more be found to be inoperable, within one hour l
a continuous fire watch must be established on one side of the affected
barrier or an hourly fire watch patrol must be established.
Contrary to the above, the licensee failed to establish the required fire
watch for penetration OP 142S1099 after an engineering disposition, did not
establish that the penetration would meet fire protection requirements. The !
engineering disposition was completed on May 3, 1988; the licensee posted
the fire watch on June 14, 1988.
Reason for Violation:
The engineering disposition for Corrective Work Request (CWR) 00688-88 was
approved on May 16, 1988. The disposition could not establish that
penetration OP 142S1099 would meet the fire qualification testing
requirements. Procedure KPN E-314 " Disposition of Field Change Documents",
requires notification of Operations when the disposition of special-scope
nonconformances result in an inability to accept an unconditional "USE-AS-
IS" request. For those nonconformances where the impact should not be
allowed to exist without compensatory provisions, verbal notification to the
Control Room Shift Supervisor is made. The engineering personnel involved
,__ did not recognize that compensatory measures were required based upon the
/
) results of the disposition, therefore no priority was placed on
( _,/ dissemination of the disposition.
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Attachment I to UM 88-0312 ]
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Page 10 of 10 ]
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Similarly, procedure ADM 13-103 " Fire Projections impairment Control", )
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Section 4.3 requires the reporting of emergency impairments (equipment '
degradation or failure) to the Fire Protection Coordinator as soon as
possible after discovery. When the disposition was received by Maintenance
personnel, it was not recognized that a fire impairment was required.
Therefore the Fire Protection Coordinator was not noti fied and the work
request was not handled in an expeditious manner.
Corrective Steps Which Have Been Taken And Results Achieved:
On June 14, 1988 Fire Protection Impairment Control Permit No.88-244 was
issued and an hourly firewatch patrol established. The existing type RB-9
penetration closure material (Radflex) was replaced with an M-9 penetration
closure material (RTV foam) on June 17, 1988.
Corrective Steos Which Will Be Taken To Avoid Further Violations:
This violation will be discussed with the Nuclear Plant Engineering l
personnel involved and placed in Maintenance required reading.
Additionally, strict adherence to procedures will be stressed to Nuclear
Plant Engineering and Maintenance personnel.
Date When Full Compliance Will Be Achieved:
Full compliance will be achieved by December 30, 1988.
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Attachment II to WM 88-0312
Page 1 of 6
N
[G Responses to Examples Cited In Violation 482/88200-01
Example:
1. The licensee had not taken the corrective actions specified in
engineering evaluation request EER 85-GK-08 (completed November 27,
1985) to resolve the electrical breaker malfunctions of the heating,
ventilating, and air conditioning (HVAC) system in the control
building.
Responses
A review of maintenance history for the circuit breakers for control room
air conditioning unit SGK05B identified that nuisance tripping of the
breakers was occurring between December 31, 1984 and February 10, 1985.
This review identified that this same problem was not occurring on the
opposite train, SGK05A. During this time frame, WCGS was in pre-licensing
start-ups and system testing. As part of the system testing phase,
adjustments were made to the operation of the HVAC system such that the'
nuisance tripping of the breakers was no longer occurring.
Engineering ? valuation Request (EER) 85-GK-08 was initiated on July 22,
j -~ 1985, as a precautionary measure in the event the adjustments had not
i
corrected the problem and nuisance tripping reoccurred. The engineering
, \s disposition to the EER,- was issued on December 3, 1985 recommending the
installation of new breakers with higher instantaneous trip
characteristics. Subsequently, Plant Modification Request (PMR) 1441 was
initiated to replace the breakers if needed. During the period of February
10, 1985 to December 3, 1985, no problems were experienced with the breaker
for SGK05B tripping. Additionally, maintenance history indicates no further
problema with nuisance tripping of the breaker. Therefore, the actions
teken during plant start-up and system testing had resolved the problem and
implementation of the PMR was not appropriate.
WCNOC has initiated the actions necessary to cancel the PMR. Additionally,
l WCNOC will evaluate existing engineering evaluation request tracking system
l relative to this issue.
Example:
2. The licensee had not fully investigated the underlying causes of the
multiple HVAC damper failures in the control building.
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Attachment II to WM 88-0312
Page 2 of 6
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Response:
1
During November 1987, a Safety Systems Outage Modifications Inspection j
(SSOMI) identified that appropriate corrective action in preventing repeated
damper failures was not taken when five CRVIS damper failures were
experienced during the period of June 25 to November 3, 1987. As a result i
of the SSOMI finding, a review of the maintenance work requests for
dampers / actuators OK-D-085/GK-HZ-29A, GK-D-081/GK-HZ-029B. GK-D-084/GK-HZ-
40A, GK-D-085/GK-HZ-40B was conducted. This review identified that the
actuators were reworked during 1984 with some machining being conducted on
the couplings. In 1985, GK-HZ-40A and B were replaced due to the actuators
being jonned. In 1987, failures of GK-HZ-29A, 40A and 40B, occurred which
required replacement of the actuators. During the previous refueling
outage, the vendor was brought on site to assist in identifying the cause of
the failures. Discussions with the vendor indicated that these failures,
could be attributed to a udsalignment of the coupling and the saddle because
of previous maintenance and the method of clamping the dampers when blocking
them open or closed. It was then determined that WCGS did not have the
appropriate vendor shop drawings identifying strict coupling tolerances and
clearances.
The appropriate tolerances and coupling clearances were obtained from the
vendor and an alignment jig was fabricated to assist in alignment of the
f ~sg saddle and the coupling. The vendor shop drawings were obtained and issued
( ) as controlled drawings. Three of the above dampers were realigned. The
\s_/ fourth damper was inspected and determined to be within the tolerances
provided.
Example:
3. The licensee had not promptly taken action to resolve a large number of
actuations in the control room ventilation isolation signal (CRVIS)
system that were attributed to the control room habitability system '
chlorine monitor malfunctions that began in 1985.
Response
While WCNOC agrees that resolution of the chlorine monitor malfunctions has
taken longer than desired, the actions that have been taken have been
extensive and thorough. The root cause of the monitor malfunctions has been
determined to be poor design of the monitors. The poor design has caused
tape breakage, bunching, and spurious spikes, which has resulted in high
maintenance required to keep the monitors operational.
As a result of the frequent actuations of CRVISs due to apparent chlorine
monitor malfunctions, plant staff personnel surveyed the equipment on a
daily shift basis for indications of possible malfunctions. Plant
Modification Request (PMR) 1207 was issued on June 12, 1985 to confirm that
~g the monitors were the source of the erroneous CRVISs.
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Attachment II to WM 88-0312
Page 3 of 6
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In January,1986 a study was undertaken to add additional chlorine monitors
in order to implement a 2 out of 3 CRVIS logic. In March, 1986, a letter
was sent to MDA Scientific, manufacturer of the monitors, which pointed out
the various problems WCGS was having and requested them to evaluate the
situation and respond. Approximately one week later, MDA did respond with
the steps they were going to undertake.
On May 21, 1986, a second letter was sent to MDA requesting additional
actions. MDA again responded with suggested improvements. During this time
frame, Requests for Quotation were sent to MDA, Consolidated Controls
Corporation (CCC), and Anacon to support a study being performed by
engineering to either add additional MDA monitors to allow a 2/3 logic or
replace the monitors with Anacon or CCC monitors. The study, which was
submitted on December 9, 1986 recommended replacing the MDA monitors with
Anacon monitors.
During the latter part of 1986, WCNOC began investigating the change from
our present chlorination system (liquid) to a solid sedium hypochloride
system, thereby eliminating the accident scenario which necessitated having
chlorine monitors. Since the results of this study could eliminate the need
for chlorine monitors, the replacement study was directly impacted and
subsequently placed on hold.
f'~'s By late 1987, the sodium hypochloride proposal had been rejected and the
( monitor replacement study had been reinitiated. Monitors with a 2/2 logic
'-- configuration manufactured by Anacon were chosen to replace the MDA
monitors.
In the meantime, a representative of the WCGS Supplier Quality organization
visited MDA and an HDA representative in turn came to Wolf Creek and
inspected the existing chlorine monitors. The MDA representative made
several recommendations which have been carried out as an interim measure
until new monitors can be installed.
Unfortunately, the very week that Anacon was being recommended, they went
out of business (May 2, 1988). As a result, Sensidyne chlorine monitors
were selected pending investigation on their suitability. This selection
was based partially on conversations other utilities. In conjunction with
the Sensidyne investigation, WCNOC also began the task of looking at other
available monitors. This review identified Delta as another possible
supplier.
WCNOC decided that due to the importance of resolving the chlorine monitor
issue, monitors from both Delta and Sensidyne would be purchased and
processed through a program which included seismic and environmental
qualifications.
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Attachment II to WM 88-0312 1
Page 4 of 6
.I
On October 10, 1988, NPE issued PMR 2068 to replace the existing MDA 1
monitors with qualified monitors. WCNOC is implementing PMR 2068 during the l
current refueling outage. !
While WCNOC agrees that resolution of the chlorine monitor malfunction took
longer than desired. WCNOC feels that resolution of the chlorine monitor
issue was pursued with perseverance and in a manner which reflected sound
engineering and management judgement. It became increasingly apparent to
Wolf Creek during 1985 as a result of 15 LERs associated with CRVIS that the
chlorine monitor issue required not only the attention of plant operating
groups but also that of plant support groups and management.
Wolf Creek pursued resolution of the chlorine monitor issue in a logical
sequence, first working with MDA, manufacturer of the monitors, to determine
the root cause of the monitor malfunctions and a resolution, and second, the
effort undertaken to determine the feasibility of using an alternate method
of chlorination and thereby eliminating the need for chlorine monitors, and
finally, supplementing or replacing the existing chlorine monitoring system
through a program which included seismic and environmental qualification of
needed equipment.
In retrospect, while this approach may have been somewhat time consuming, it
does represent what Wolf Creek feels was the best approach based on
['~' available data, suitable equipment capable of meeting the stringent
environmental and seismic qualification requirements. The inability of MDA
(_
to provide a satisfactory resolution and CRVIS related LERs is being
experienced by the industry on whole.
A primary strength identified during the investigation of this issue was the
fact that the plant staff, engineering, and management worked together to
resolve this issue. No single Wolf Creek organization or group acted
independently, but each performed independent functions to support one
another. Function group meetings were held as a part of the decision
process and key decisions were made based on input from the responsible
groups.
Example:
4. The licensee had not taken actions to correct multiple fire protection
system failures that resulted from the apparent misapplication of valve
microswitches.
Response:
Wolf Creek has experienced a high instance of alarms activating as a result
of the malfunction of a specific type of microswitch used in the 11re
protection system. These micropwitches are installed on various outdoor
valves that are located above and below grade level. FER 87-FP-06 was
[ 'h issued on May 8, 1987, which stated that the present microswitches, Type
( ,/ PIVS-B, are routinely found corroded and appear being used in applications
,
for which they were not designed.
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- ' Attachment II to WM 88-0312
Page 5 of 6
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Nuclear Plant Engineering (NPE) reviewed vendor catalog information but was
unable to find an Underwriters Laboratory (UL) listed and Factory Mutual
(FM) approved replacement limit switch. The vender, Fotter Electric Signal
Company, was contacted to find out if there was a replacement switch for the
UL listed and FM approved PIVS-B limit switch presently in use. The vendor
indicated that the only waterproof supervisory switch they carried was a
" Plug Magnetic Switch" which can be used on a valve with a hand wheel;
however, this switch would not work on the valves installed at WCGS.
Another vendor, Federal Signal, was contacted to see if they offered a
waterproof limit switch. However, they also used Potter for limit switch
applications. They indicated that they had some success in delaying
moisture problems by treating the switches with a coating.
Maintenance and NPE representatives met to resolve the limit switch
problem. The mutually agreeable solution was to seal the switch openings
with a clear flexible silicon sealer which is commonly available, such as
G.E. clear silicon sealer. The purpose of the sealer is to prevent moisture
from reaching the microswitch inside the limit switch housing. This in turn
would prevent false alarm indication.
The prioritization for responding to EER's is based on the following
categories: mandatory, life / safety, ALARA, or discretionary. This EER was
designated as discretionary during meetings between NPE and Maintenance
y personnel. Based upon the discretionary prioritization, the evaluation and
( i subsequent disposition was not completed until July 29, 1988. As a result
'x _- of the EER disposition, Plant Modification Request (PMR) 2650 will be issued
by December 30, 1988 to identify the locations on the limit switch where the
clear silicon sealer should be applied and to indirste which switches should
be repaired. The information provided in PMR 2659 will allow for the
sealing of existing switches as well as th'e sealing of new switches to
eliminate moisture within the switch housing.
Example:
5. The licensee has not aggressively pursued the cause and taken action to
resolve m'lfunctions
a in the emergency diesel engine's jacket water
pressure sensing system that began in 1986.
Response:
The malfunctions in question deal with problems with the proper functioning
of the pressure transmitters due to pulsations in process pressure. As a
result of Engineering Evaluation Request (EER) 87-KJ-01 which described the
pulsation problem, Plant Modification Request (PMR) 2183 was issued on
6/9/87 to install snubbers in the process sensing lines to reduce pressure
transmitter pulsations due to pulsations in the process pressure. WCNOC has
determined that the cause of the pulsations is integral to system design and
equipment characteristics. Pulsations to some extent are a natural
phenomenon associated with pumps in general. The magnitude to which
(y- g) pulsations occur is dependent on the pump (size and type), its use, and the
's ' configuration of overall system associated with the pump.
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- Attachment II to WM 88-0312
Page 6 of 6
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The required parts were then ordered and the PMR was scheduled for
installation during the current refueling outage. However, all the parts
could not be shipped in time for installation during the outage. It was
determined that the pressure transmitter pulsation problems did not affect
the ability of the EDG to fulfill its safety function, therefore PHR 2183
will be implemented after'the parts arrive and at the next available EDG
outage of sufficient duration to accomplish the process line snubber j
installation, but in any case no later than the end of the next refueling j
cutage. l
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