IR 05000482/1998013
| ML20236S393 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 07/20/1998 |
| From: | Johnson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Maynard O WOLF CREEK NUCLEAR OPERATING CORP. |
| References | |
| 50-482-98-13, NUDOCS 9807240304 | |
| Download: ML20236S393 (5) | |
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. e g*.s u% UNITED STATES p .4 NUCLEAR REGULATORY COMMISSION
$ REGION IV l
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/[ 611 RYAN PLAZA DRIVE, SUITE 400 AR LINGTON, T E XAS 76011-8064 JUL 201998 Otto L. Maynard, President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, Kansas 66839 SUBJECT: NRC INSPECTION REPORT 50-482/98-13
Dear Mr. Maynard:
Thank you for your letter of July 7,1998, in response to our June 12,1998, letter and Notice of
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Violation concerning two examples of failure to properly implement your clearance order l
procedure and one instance of failing to perform an unreviewed safety question determination regarding a modification to the postaccident sampling system. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation with regard to the clearance oraer viobtion. We will review the implementation of your corrective actions for this violation during a future inspection to determine that full compliance has been achieved and will be maintained.
l With regard to the second violation, your response of July 7 did not indicate that an unreviewed safety question determination had been performed. On July 16, a telephone conversation was conducted between D. N. Graves of NRC and A. Harris of your staff, during which Mr. Harris stated that an unreviewed safety question determination had not yet been performed due to ongoing discussions with the Office of Nuclear Reactor Regulation regarding the modification to the postacddent sampling system. Mr. Harris also stated that an unreviewed safety question determination would be conducted with a completion date not later than August 28,1998. If your understanding of this commitroent is different from that stated in this letter, please contact us. We will continue to review your proposed corrective actions for this violation.
Sincerely,
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f W. D.LJohnson, Chief Project Branch B Division of Reactor Projects Docket No.: 50-482 License No.: NPF-42 9907240304 990720 F PDR ADOCK 05000482 h G PDR [
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Wolf Creek Nuclear Operating Corporation -2-
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Chief Operating Officer l Wolf Creek Nuclear Operating Corp.
P.O. Box 411 Burlington, Kansas 66839 l Jay Silberg, Esq.
Shaw, Pittman, Potts & Trowbridge 2300 N Street, NW
. Washington, D.C. 20037 l
Supervisor Licensing Wolf Creek Nuclear Operating' Corp.
P.O. Box 411 '
l Burlington, Kansas 66839 Chief Engineer
Utilities Division Kansas Corporation Commission 1500 SW Arrowhead Rd.
Topeka, Kansas 66604-4027 Office of the Governor State of Kansas Topeka, Kansas 66612 l
l Attorney General l' Judicial Center l 301 S.W.10th ll 2nd Floor
. Topeka, Kansas 66612-1597 County Clerk )
, Coffey County Courthouse !
! Burlington, Kansas 66839-1798 I i Vick L. Cooper, Chief I. Radiation Control Program j l; Kansas Department of Health L, and Environment Bureau of Air and Radiation 1 Forbes Field Building 283 Topeka, Kansas 66620 !
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Wolf Creek Nuclear Operating Corporation -3-t l
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Mr. Frank Moussa I
Division of Emergency Preparedness 2800 SW Topeka Blvd Topeka, Kansas 66611-1287 i
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Wolf Creek Nuclear Operating Corporation ~-4-Jlt 201998
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bec to DCD (IE01)
- bec distrib. by RIV: .
Regional Administrator- Resident inspector DRP Director SRI (Callaway, RIV)
Branch Chief (DRP/B) DRS-PSB Project Engincar (DRP/B) MIS System Branch Chief (DRP/TSS) RIV File .
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l DOCUMENT NAME: R:\_WC\WC813AK.JFR To recolve copy of -i-; J ./, indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:PE:DRP/B[L C:DRP/B[ l DNGraves:df" /f]" WDJohnspri 7/ @ 98 7W9F OFFICIAL RECORD COPY
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y Wolf Creek Nuclear Operating Corporation -4-JUL 201998 b%1 bec distrib. by RIV:
Regional Administrator Resident inspector DRP Director SRI (Callaway, RIV)
Branch Chief (DRP/B) DRS-PSB Project Engineer (DRP/B) MIS System -
Branch Chief (DRP/TSS) RIV File
DOCUMENT NAME: R:\_WC\WC813AK.JFR l To receive copy of doqipment, indicate in box:"C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy
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RIV:PE:DRP/B[ // , C:DRP/B( l l ,
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DNGraves;df /77 WDJohnstfb
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7/W/98 7/ W 9 F OFFICIAL RECORD COPY 2400E3 L
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W9L' CREE (
'UCLEAR CPERATING CORPORATION aos ~ s '
Otto Presioent and Chief Executwe Officer JUL 7 1998 WM 9s-0069 U. 5. Duclear Regulatcry Ccamission ATTU: Document Contrcl Desk Mail Station F1-137 sashington, D. C. 20555 keference: .stter u a te ct J;ne 12, 1999, fr:m W. D. 7annson,
- RC, 10 0 -. :!aynard, WCMOC Subject: '
Ocket .3.13-487.: r esponse to Motice of irlations M-t A2 / 4813-01 and :4913-02 (EA *9-273)
Gentlemen:
This letter transmits 101: creek Muclear vperating Cw potat.on'n t.WCMOC )
response to Motice or 1;1ati:nc '.0-492/9913-01 and 9313-4.i i rlat : nn ') A 13-01 identified two examcles of f ailure to follcw the clearar ce :cer p;ocedure.
The second violatica EA 38-273/9813-02) is related to WCNOC's identifying that we have been ;nable to pertorm certain post-accident sample system analysis within the alletted time and as sucn mace a ce acto change to che facility without a safety evaluation.
WCNOC's Jesponse to these c:.c.aticns is proviced in the attachment. MCNOC nas also proviced ccmments On certain issues dis ussed in the report. If you have any questions regarding this response, please contact te at ;316) 164-8831, extension 4000, or Mr. :1chae. J. Angus at extension 4077 Very truly you m
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/ $$ y/f( f Otto L. Maynard 'f GLM/r1r Attachment l cc: W. D. Johnson (NRC), w/a l # E;: W.;Merschoff 1NRC)/ W/a4 l J. F. Ringwald (::RC I , w/a j K. M. Thomas (MRC), w/a l
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P.O. Sex 411/ Burhngton. KS 66839 / Phone: (316) 364-8831 An Eaual Oppcuny Empoyer M F/HCNET M nnnI. I n NW?_Y___T *_ _ _ _ _ _ -]_ - - _ - _ - _ - _ _ _ - - _ - - - - _ _ _ - - . . - - _ - - - - - - _ - _ ------__-__--____-_-----------_-_-----------a
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, Atta5nment to WM 99-0069 Page _ of 9
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Resoonse to Violation 50-482/9813-01 Violation 50-402/9813-01:
"Tecnnical Specification t.5.". 2 recuires, in part, tnat written procedure be established, implemented, anc maintained covering :he applicable procedures recommended in Appendix A cf Pegulatory Guide 1.33, Revision 2, February 1976.
Pegulatory Guide 1.33, :evisicn 2, February 1979, 2ection 1.C,
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recommends, in part, that procedures be estaclisnea for equipment control.
Procedure AP 21E, " Clearance Orders," Revision 7, Section 6.1.2.1.h, prohibits clearance crders from relying :. n other plant activities for establishing system configurations.
Contrary to the above, 1. On March 17, 19 M , electricians removed creaker !JG001 AGF1 while Clearance Order 99-0250-EF relied on Procedure MGE EOOP-11 to establish isolation of the breaker from the bus, and 2. On April 15, 1999, ele ct rici ar.s removed 3reaker NG001ACR2 while Clearance Order M-:317-EJ relied en Procecure MGE ECOP-21 to establish isolation of the creater fr00 the bus.
This is a Severity Level :V nolation (Supplement 1. (50-482/9813-01)"
Description of Event:
On March .17, 1998, Wolf creek !:aclear Operating Corporation ( ActJOC) craft personnel were replacing 480 volt molded case circuit breakr.r NG001AGF1.
While a craft person was terminating a wire, the "3" phoc: line side of the j breaker became energized. The screwdriver that tne craft person was holding went to ground on the breaker cperating mechanism, ausing an arc / flash. The craft person holding the screwdriver received a first degree burn to the tip of his niddle finger of his right hand.
In response to the event, the clearance orcer used, 99-0250-EF, was reviewed, l sleng with work package 101433, task 20, and proceaure MGE ECOP-11, "Mo]ded Case Circuit Breaker ana Ground Fault Sensor Te s t i r.g . " Clearance order 98- g 025C-EF tagged the hand switch and breaker for Essential Service Water System l
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valve, EF HV-0023 and taggea the valve in the closea position. The clearance orcar boundary was believea to be adequate to change out the breater. Work package 101433, Task 20, referenced procecure MGE EOOP-11 for the breaker rencval and installation. The wording in the proceaure gave no indication of the close proximity of the bus bar.
Interviews ' determined that the Electrical Maintenance personnel involved in this event were aware of the boundaries set by the clearance. They realized that the load side af creaker was isolated anc that the bus bars were i
energized. They also knew their work instructions would be used to pull the l bucket to its disconnected position, where it would be secured by placing the j screw and pawls mechanism in place to facilitate changing out the breaker.
! This clearance order / work instruction interface was the standard work practice l for 460 volt molded case circuit breaker change outs.
The vendor manual recommends that when work at a molded case circuit breaker requires the cubicle bucket to be moved off the bus, then the breaker and cubicle bucket should be verified in the " lockout position." The " lockout position" was not known by the clearance order personnel, and it was not addressed in the work packages or procedure MGE EOCP-11 used during the March 17, 1998, work activities-. The cubicle " lockout position" is when the hole in
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Atta'chment to . M 90069 Page 2 et 9
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the lower right :orner of the cu c r.e t ceccres alignea with tne hole in the slide rail. The cucket is required to be secured in this position with an approvvi mechanical device. Vendor Instruction Manual for ITE Gould 5600 Series MCC E-018-00190 descrites using the " lockout position" for maintenance l activities, what the " lockout position" is, and how it should be used.
Because the existence of the " lockout position" was unknown, the clearance orcer relied cn maintenance work instructions and procedure MGE E00P-11 to provide safe working ccnditions.
After the Marcn 17, 1998, event, corrective actions were put in place to ensure that the " lockout position" was included in the work instructions.
Additionally, the Clearance Order Summary Sheet was requirs< to be used to inform the electricians of the mechanical device used to secure 480 volt breakers in tne lcckout position. The above actions were met during the April 15, 1998, event; however, at that time the conclusions related to the clearance order process were still under investigation, and the requirement that the isolation boundary be controlled solely by the clearance was not met.
In both examples, the clearance orders did not comply with the requirement of procedure AP 21E-001, " Clearance Orders," step 6.1.2.1.h which states:
" Clearance orders shall not be prepared such that they sclely rely on other plant activities '. s u ch as Local Leak Rate Testing ( LLRT' s ) etc.) for establishing system configurations and/or conoitions." Additionally, step 6.1.2.2 of AP 21E-001, states that a summary sheet should be used to
" communicate technical information or safety concern."
Reason for the Violation:
The personnel perferming the clearance orders were not aware of the vendor information regarding the " lockout position" and due to this lack of knowledge did not have this information in the clearance order.
Contributing Factor:
Personnel relied on past experience with breaker change outs and, due to their lack of knowledge regarding the " lockout pori. tion" and the wording in maintenance procedure MGE E30?-ll, did not recognice the need for a Clearance Order Summary Sheet.
Corrective Actions to Prevent Recurrence A representative cross-section of electrical maintenance procedures were reviewed. The possibility of other weaknesses involving the clearance order / breaker interference was researched and documented in Performance Improvement Request (PIR) 98-1152. This procecure review revealed no additional prcblems er concerns. Therefore, this issue is considered to be unique to 480 volt molded case circuit breakern.
The electrical maintenance procedures describe breaker maintenance activities being accomplished by either removing the breaker from the cubicle to complete the work or placing the treaker in the " lockout position" to work 480 volt molded case circuit breakers. As cf Maren 20, 1998, when work at a molded case circuit breaker required the bucket to be moved off the bus, then the breaker and cubicle must be verified in the " lockout position." Additionally, a Clearance Order Summary Sheet is to be used to inform the electricians of the mechanical device used to secure 480 volt breakers in the " lockout position" during maintenance activities.
Electrical maintenance has completed training on the proper use and installation of the lockout device and the near miss. This training was conducted under T.I.N. IE1331601001, w____-____-___-__ _ _ _ _ _ _ _ _ -
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Atta'enment to WM 99-G69 Fage 3 of 9 Procedure AP 21E-001 was revise 0 to require an applicable local centrol or "Do ;
flot Operate" tag to be attacnea to the mechanical device wnen molded case circuit breaker maintenance is ceing performed ar.a the bucket is required to be secured with an approved mecnsnical device.
Procedure AP 21E-001 was revised to require: 1) a qualified preparer prepare the clearance order down to and including the " prepared by" block, 2) a qualified preparer identify energy sources and determine isolation points, and 3) when positive boundaries are not practical, the clearance not be issued without adding special conditions / precautions to the attached Clearance Order Summary Sheet.
On May 22, 1998, a Clearance Crder Group meeting was held and the proposed changes to precedure AP 21E-001 were discussed. The meeting addressed the tagging of the mechanical device, and the expected use of the Clearance Order Summary Sheet when cceplete isolation by the clearance is not practical.
Date When Full Cornpliance Will Be Achieved:
Full compliance has ceen achieven.
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Attiennent tc WM H-00 0 Page 4 of ?
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Violation 50-482/9813-02:
'10CFR50. 5 9 (b) (1) requ;res, in part that tne licenree maintain records of changes in the facility, pursuant to this section, to the extent that these changes constitute changes in the facility as cescritcc in tne safety analysis report. These recorcs must incluce a written safety evaluation which provided
- the bases for the determination that the cnange did not involve an unreviewed safety question.
'.ipdated Safety Analysis F ecert ^hapter 18.2.3, " Pest Accicent Sampling System (II.B.3)," states, in cart, tnat the licensee shall have the capacility to promptly cotain reactor trolant samples of dissolved gases (e.g., H,) , and the combined time allottec :cr sampling and analysis should ce 3 nours or less from the time a decisicn :s mace to take a sample.
Contrary to the above, :n April 22, 1992, the licensee mace a change in the f acili t'/ as described ir the Upcatec Safety Analysis Report without Commission approval and without perterming a written safety evaluation which provided the bases for the determination rnat the change did not involve an unreviewed safety question. Tpecificaley, r oll owing tne' failure of the reactor coolant dissolved Hydrogen analysis instrument in the postaccident sampling system, the licensee selected an :.Mernate means of onitoring by using the secondary analysis motnod ci per:crming grac samples <nich could not ce performed within tne 3-hour time limit prescrinea in tne Updated Safety Analysis Report.
This is a Severity Leve; :/ nolation (Supplement 1; ( 5 0-4 82 / H13-02 ) ,"
Description of Event:
The Wolf Creek Generating Station (WCGS) Updated Safety Analysis Report (USAR)
Section 13.2.3 states tnat *he NCGS design provides an in-line monitoring system (for post accident monitoring). This system (the Fost-Accident Sampling System, or EASS; incluces provisions for monitorina reactor coolant system _(RCS) Hydrogen 1: accordance with !!UBEG-0737 Section Il.B. 3.
NUREG-0737 Section :1.E.3 speciries eleven criteria whien a post accident sampling system must meet .n ;rcer tc perform its design functicn. The second vi these criteria states:
"The icensee shall estacalsh an onsite radiological anc chemical analysis l rapacility to provice, aithin the 3-nour time frame established above, quantification ct tne :clicwing:
(a) certain racitnuclides in the reactor coolant and containment atmosphere tnat may be indicators of the degree of core damage
(b) Hydrogen levels in tne containment atmosphere; (c) dissolvec gases M.a., H2), chloride (time allotted for analysis subject to discussion celow), ana tcron concentration cf liquids.
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(d) Alternatively, nave in-line monite::ng capabilities to perform all or part of the acove analyses."
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l The WCGS design lacorporated an in-line Hydrogen analyzer for measuring dissolved Hydrogen in tne reacter coolant, as described in USAR Section 18.2.3.2. The in-line monitoring system is normally isolated; hcwever, it could be manually initiated and operated after an accident.
The purpose of using ar in-line monitor is to minimite personnel exposure.
Provisions wcre also included for providing both diluted and undiluted grab
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tta6nment :: '. M h-00C9 Page E f G e
ramples of the reacter :::.r : : nsistent utn NUREG-0737 The grac samples are snielded to minimize tursonnel exposure wnile cotalning grab samples.
'he PASS in-line .iquia ncnitor usea for Hycrcgen analysis of *he reactor
- clant is a non-safet; related in-line cnitor. The Hycrogen analyzer was nesignea to be used during ::ident conaitions cnly, not during normal plant
- cerations. Mcwever, <;CNOC :akes no creait ter the analyzer in cur satety analysis and it is not i.clucea in tur emergency response procedures. NCGS has
'ne am.ity to vent the react r vessel heaa to Containment during an accident.
The Containment atmospnere is monit::ed with safety-relatec Hydrcgen analyzers.
Thereicre, the inability to moniter Hydrcgen in the Reactor Coolant System
'RCS) is of low sa fety si gnificance. Although the RCS Hydrogen ana.lyzer is not functional, anotner meth a 1 *s to take a grab sample ana send it Offsite for analysis. A computer araws ine aamole, whicn la moved from the sampling room to the snipper by a remote ^;ntrol cart. This allows WCNOC to take a sample ina ensure worker safety, :ut Ices not meet NUREC-0737 requirements for t imelir.es s . This meth:a meet: ne "lREG-G 7 3 7 requirements for carr.up sampling apability for in-line ren :: rang qu ipmen t . However, this rackup method has teen relied upon tar an ~xcess;ve period of time.
Nplacina the Hydrcgen e.a.yrer was researched in 1991, ano a plant mocif::stion in ::atea at *nat ::me. However, 'he hign c:st cf replacement, c=oinea with tne _cw 'nety ngnificance 11 the : unction, mace the
~caif :ation a 1:w pricrity croject. Recognizing that ine Hydrogen analyzer
- as not functional, 3 JSAR mance was :nitiated in 1997 The USAR change uscrihed tLe use cf tne c -14; carcie panel as an alternate to the FASS panel
- r ctt aining Hyaragen samples and !
- r analysis of these samples.
In 1996, WCNOC identified tnat there was a neeri te direct our atteution toward literal ccmpliance and full ;naerstanding c: our regulatory commitments. Since that time, WCUCC employees have exhinited an increased sensitivity to the USAR and to literal scmpliance. ^n February 3, 1998, a system engineer reviewing JSAR section 13.2.3 ident ::ea two 2:ncerns with tnis USAR change: 1) expected dose received by tne individuals performing post-accident sampling could be in oxcess -f NUREG-0737 limits, and 2: in the event af a icss of offsite power, mergency power :s not supplieu tc a flow valve in the SJ-143 panel.
Reason for Violation:
'he ;eason the NUREG-0737 equ;rements regarcing the Hydrogen analy:er were not et, vas a minaset that cons cerea level ct importance and safety significance,
- ut talled to tactcr in regulatcry requiremen r 1r aecisicn making. This rindset, coupled with
- 2 failure :: uncerstana literal compliance, led to imprcper pricritization of repair / upgrade work on the Hydrogen analyzer or to consider the need to chance *ne regulatory ccmmitment.
Corrective Steps Taken and Results Achieved:
he issue of mindset ind c.;1ture has been addressed hy :ncreasea omphasis cn upect atiens and literal compliance. The identification of this issue is indicnien that WCMOC personnel understands our regulatory requirements.
The incorrect USAR change request nas been supersecea, with references to the i Hydrogen analyzer removea. USAR Cnange Request 98-044 was approved by the l Plant Zafety Beview Cctmittee on Marcn 6, 1999.
WCMOC has emtarked upon a USAR fidelity review and initiated Design Basis / Licensing Bases projects wnicn are designed to increase tr e awareness of perscnnel to this type ci issue. In addition, to improve the quality of Unreviewed Safety Cuestion Determinations (USQDs), the number of personnel performing USQDs was reduced by half.
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Attabhment to WM 99-0069 Page 6 cf 9
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In letter WO 98-0047, dated May 11, 1998, f rom C. C. Narren, WC110C, to the
!;RC, WC!;OC proposed deletion of the commitment to provide in-line monitoring and grab sample capability for dissolved gasses (e.g., Hydrogen) in liquids (specifically, reacter coolant). l t
To ensure no similar situations exist, System Engineering performed a review of I work packages open greater than two years on non-safety related systems to l
l determine if any commitments were not being net. !:0 items were identified.
As indicated above, WCNCC is currently performing a USAR Fidelity Review (SEL 97-044). The purpose ci .m review is to establish a general conclusiot.
regarding the accuracy and completeness of the USAR.
Date When Full Compliance Will Be Achieved:
The appropriate actions will be taken to either revise the USAR cr to pursue plant modifications based on the NRC's response to WCNOC's proposed commitment change. A schecule to acnieve full cc:r.pliance will be generated once NRC input is received on letter WO 99-0047
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Additional Information Quality Evaluation Audits
~he executive currary en Fage I :f ::ispecticn Report 98-312 rtate:
"Two audit reports ::ntaimea xecutive surrary ccnclusicns that generally agreed with tne asseserent cascribec in tne audit report, but also contained notable deficiencies. Ihe repcrts aid cct clearly and consistently present all audit activities and ::nclusicnr. One executive surmary conclusion could not te supported by the assessment and one report described two weaknesses without describing adequate corrective actions."
WCNOC's Response:
NCNOC has received pos,tive comments in other Inspecticn Reports regarding our audit activi ies, and .e are taking actions to ensure that the two reports uiscussed above are isciatec c:2ses. Quality Evaluation (OE) initiated PIR 98-1508 to document this c:ncern %nd assess the depth of the issue. To evaluate the scope of the issue, previously qualified Lead Auaitors, who are no longer cart of the OE group, ave ceen askea tc assess cne or two CE reports for the
- cllowing:
1) Do comments made .:.n the report have supporting cojective evidence?
2) Are statements in tne e::e c u t ive summary supported by the documentation in the bocy of .e report?
3) Are areas of concern aiscussed in repcrt acequately documented as to the need for a PIR cr justification is provided explaining why no action is required as a result of the review?
4) Are conclusions reached that can not be drawn trem the auditors work?
5) Dces information provide an adequate basis for making management judgments?
6) Is the information presented in a clear, consistent, anc logical manner The PIR review of auait reports is scheauled to be ccmcleted cy August 30, 1998. As an irrediate action, ;E management discussed the finaings in IR 98-13 with auditors and reiteratea expectations for attenticn to detail and the requirement that conclusions De supported and well documented in the body of
- ne report. E management will aetermine if further actions are needed based
- n the resultc ct the r=71ew.
As an enhancement to *neir performance indicators, OE is in the process of establishing an independent :cmmittee to review certain reports ( a udit.s ,
curveillances anc plant observations). The committee will grace these reports using criteria proviced by OE anc provice a score in the following areas:
- Criticality
- Use of Perfctmance Easec : etnodology
- Writing Skills OE intends to use this review and the performance indicator to provide feed-back to the individuals and the OE group in order to improve the quality of the reports.
Maintenance Management Oversight for Repair / Rework on Main Steam Isolation valve ABHV11 The executive summary and Page 7 of Inspection Report 96-013 states:
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" Maintenance department ana ement and supervisory oversight for -he removal and replacement cf the air ::1 pump on Main Steam Isolation Valve AS HV0011 was not effective f:r work 7 a safety-relate ccmponent that inv: <.eo a short auration Technical Scecifirsti:n a.:tien statement."
WCNOC Response:
Ocmpletion of a four nour 1;miting Ccndition cf Cperation (LCO) f:ur minutes before it expires dces n:t meet tne expectations of WCMOC plant management, ner la it an example of cur typical performance. Our critique cf the jcb revealed come specific aspects ahien contributed to the work delays.
Supervisory oversight was .t at tne expected levels er the level normally exhibited by maintenance supervisors. The supervisor was in the field at the start of the clearance craer hanging evolution, but then left as he felt this was a straight-ferward soluti:n. Maintenance expectations have been reintorced with the indivinaai :.nvolved utilizing the Management Associated Results Company (MARC) process.
"he supervisor did nat have 3 clear understanding of the LCO time limits for this job and, therefore, nd ". t ccnvey tnis information to the craft cerconnel. Criticality cf re-sensitive pbs is normally part at the pre-job criefing activities. 't a 51so expectec that supervisors monitcr schedule acherence during *he work evoluticn. This particular job is simple in nature and normally coes not requ;re the rull fcur hours to complete. Additionally, tne craft perscnnel involvea were knowledgeable and capable in tne performance of maintenance activities .e general, and a master mechanic was assigned to the task to ensure success cf the activity.
Although inacequate overn gnt may have contributed to job performance, the excessive cycling of tne ;ewly installed pump was an unforeseen event which also ' contributed tc the increasec job duration. The pump nad ceen tested approximately 3 weeks prior to the performance of the replacement in order to minimice the potential for :perational prcelems. Had the pump performed as required, the LCO time acu.a not nave been nearly as close as it was.
The engineering evaluation :f *he air lean in the newly installea air oil pump eas performed ana -he surveillance test for operability successfully
- mpleted. Engineering ana Operations underctecc that the air ci. pump would te removed immediately, recause of ccncerns regarding the pump's service life with the air leak. Due :: their knowleogo of the plannec corrective work, engineering did not quantify or bounc the operability of the air oil pump in the operability evaluation. Based on the aonormal situation and increased level of involvement wit" ne cb, it is expected that ccme delay in ccmpletion time would occur.
C;ncerning the issue of the root cause analysis discussed on page 7 of the inepection report, the acting Mechanical Maintenance Superintendent (normally the assistant Superintencert) was not aware of the desire to do a root cause 2 determination on the pump. However, the responsible supervisor and the normal Mect.anical Maintenance Superintendent were aware of the cesire to perform the analysis. A quarantine of the pump was not specifically requested as the i superintendent did not expect anycne to be working on the pump or affect the
' a s- f ound' condition or the pump.
In summary, WCNOC acknowledges that management involvement in this evolution did not meet our expectation. However, even with additional involvement, the issues encountered during :nis evolution would still have resulted in the LCO time frame being challenged.
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e Ata'en ent to WM 99-0069
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Fage 9 of 9
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Bill of Materials The executive summary menticrs a work package planning "
vulnerability and, page 7 of Inspection Feport 99-013 states, in part: .the inspectors noted that tne bill of materials .ist Contained parts applicable to more than cn'e style of moldec case breaker. As a result, the maintenance program relied on the electricians skill of tne ; raft to ensure that the proper materials were selected...While this was an acceptacle method of providing for safety-related parts, the inspector noted t .at this increased the 7 vulnerability for human error."
WCNOC Response WCNOC agrees that this was an acceptable method of providing for safety-related parts. In this particular case, WCNOC chose to change the bill of material.
In general, we find cur current practice acceptable and do not plan en changing our normal process. The oill of material is used by trained personnel that are qualified to perform their * asks. WCNOC does not consider this task beyond their level of ability.
Packing Leak on valve GKVO767 Page 5 cf Inspection Report 99-013 states:
"The inspectors noted that the status of packing leakage en valve GKV0767 had increased from 6 drops per minutes when identified on February 16, 1998, in Action Request 27487, to a steady stream on May 19, 1998 The notch cut in the plexiglass spray guard over the packing area was acting as a weir to the flow from the packing leakage, causing water to back up in the valve packing area.
The inspectors determined that the valve is scheduled for repaiz during the week of August 17-23, 1998."
WCNOC Response WCNOC does not consicer the above statement to be either a negative or a positive comment, but a statenent of fact. In accordance with WCNOCs programs and procedures for scheduling work, the packing leak was identified and scheduled for the next available work window based on the significance to the plant. The Control Su11 ding HVAC ;GK) system is scheduled for work on a 26 aeek rolling scheoule. Since the initial leak was identified, it has been scheduled for repair during the GK system cutage in August 1998.
The increased leakage was evaluated for impact on the GK system. Valve GKV0767 is the flow control valve for the water flowing through the condenser. The valve is located on the downstream side of the condenter, and the valve packing is located an the downstream side of the valve's shutoff disc. With this configuration, the ability to control the flow through the condenser is not impacted. Since the valve is en the downstream side of the condenser, the flow going tnrough the valve and packing leak passes through the condenser. The packing is located en the back side of the shutoff disc and the ability to shut off flow through the condenser is not impacted. Thus the valve's ability to pass tull design flow and/or shut off the flow is not affected. The condenser's heat removal capability is not affected as a result cf the packing leak. Therefore, it was concluded that the leak had no impact to system operability, and that no change in schedule was necessary.
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