ML20247N977
| ML20247N977 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 05/31/1989 |
| From: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| WM-89-0161, WM-89-161, NUDOCS 8906060079 | |
| Download: ML20247N977 (5) | |
Text
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9 W$LF CREEK
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NUCLEAR OPERATING CORPORATION Bart D. Withers President and Chief Executive Otheer -
May 31, 1989 WM 89-0161 U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Mail Station P1-137 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.
Very truly yours.
Bart D. Withers President and Chief Executive Officer 1-BDW/jad 1'
Attachment cca.
B. L. Bartlett (NRC), w/a E. J. Holler (NRC), w/a R. D. Martin (NRC), w/a D. V. Pickett (NRC), w/a
/Qf P.O. Box 411/ Burhngton, KS 66839 / Phone: (316) 364-8831 ifl h
hhhhhdg7 An Equal Opportunity Employer M7/HCNET D
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Attachment to WM 89-0161 Page 1 of 4 I
Violation (482/8905-01):
Inocerable Fire Barrier Findinni TS 6.8.'1 requires that written procedures be established, implemented, and maintained for, among other things, the fire protection program.
Procedure ADH 13-103, Revision 5
" Fire Protection:
Impairment Control," implements procedures for impaired fire protection equipment including degraded fire
' barriers.. ADM 13-103, Section 4 requires that fire protection impairment control permit forms be ptepared 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 issced.
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 penetration sealing activities.
Probable cause of this oversight was its similarity in size and approximate location to form tie bolt holes present in the area.
It was noted through the investigation that this penetration was not previously 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 l
established on February 28, 1989. The impairment permit and fire watch were I
maintained until grouting of the penetration was completed on March 17, 1989.
Corrective Steos 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.
Attachment to WM 89-0161 Page 2 of 4 1
Violation (482/8905-02): Failure to Lock a Valve in Accordance With Procedure Findinn:
TS 6.8.1 requires that written procedures shall be established including the applicable procedures recommended in Appendix A of Regulatory Guide (RG) 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 j
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 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 requirements to treat this valve as a locked component per the requirements of ADM 02-102.
AL HV-012, as well as other required locked components, were verffiedandsecondcheckedon 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 seal.
The seal and wire became disengaged subsequent to the locked valva 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 to 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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1 Attachment to WM 89-0161 Page 3 of 4 Corrective Steps 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 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.
An additional verification of locked neutral valves was performed post-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 Drawing Finding:
10 CFR Part 50, Appendix B, Criterion V states, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawirigs 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-12ALO1(Q) was not color coded (" redlined") to reflect field implementation and partial closecut of PMR 00264 in December 1986.
Reason For Violation:
Drawing H-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, apparer.tly 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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4 Attachment to WM 89-0161 Page 4 of 4 Corrective Steps Which Have Been Taken And Results Achieved:
Drawing M-12ALO1 (Q),
Rev. O has been redlined to reflect field i
implementation and partial closecut 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:
4 A significant effort has been expended to improve the method for updating drawings in the Control Room. 'A Quality Assurance surveillance conducted in August of 1988 identified several concerns relative to Control Room drawings.
A task force.was convened to address these concerns and resulted in various corrective 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 drawings. 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 i
reduce the number of individuals interfacing with changes to Control Room i
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 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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