ML20141M102
| ML20141M102 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 03/27/1992 |
| From: | Bailey J WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NO-92-0101, NO-92-101, NUDOCS 9204010111 | |
| Download: ML20141M102 (11) | |
Text
_. - _
i LFCREEK W8' NUCLEAR OPERATING John A. Bailey vtco runuuns Operate March 27, 1992 NO 92-0101 U. S. Nuclear Regulatory Connission ATTH:
Document Control Desk Hall Station-pl-137 Washington, D. C.
20555 Reference Letter dated February 26, 1992 from A. B. Beach, NRC to B. D. Withers, WCNOC
-Subjects-Docket No. 50-482: Response to Violations 482/9136-01, 9136-02 and 9136-03 Centlement Attached is Wolf Creek Nuclear Operating Corporation's (WCHOC) response to l
violations 482/9136-01, 9136-02 and 9136-03 which were documented in the Reference.
Violation 482/9136-01 and 02 involve multiple examples of inappropriate procedures or failures to follow procedures.- Thu responses to these riolations. provide the specific causes and' corrective actions
.spp11 cable -to the cited-examples.
In aadition, the response to these violations contain a discusrion of more comprehensive corrective actions which. are being taken or planned to improve-the quality of'/CNOC procedures andito ensure full complionce with these procedures.
Violation 9136-03. Involves inadequate ' cor r ec t.ive actions.
The attached response addresses the actions being taken'in response.to this specific violation..
WCNOC is also pursuing a more comprehensive program to -achieve improvements in the WCNOC corrective action.
These efforts have previously been described in WM 92-0040, reply to Notice of Violation (EA 91-161).
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NO 92-0101-Page 2 If you have any questions concerning this matter, please centact mc or Mr. S. G. Videman of my staff.
Very truly yours.
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John A. Bailey Vice President Operations JAB /jra Attachmet.t-
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=A. T. Howell (NRC).-wfa R. D. Hartin (NRC), w/a G. A.-Pick (NRC). v/a W. D. Reckley (NRC). w/a i
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Attachment to NO 92-0101 Page 1 of 9 REPhY TO A NOTICK OF VIOI.ATION Violation (482/9136 01)
DLdpJe To Have ADDropriate Procedget, Findlnnt Technical Specificati (TS) 6.8.1.a requires that written procedures be established. Implemented, and maintained covering the applicable procedures reconnended in Appendix A of Regulatory Guide (RO) 1.33 Revision 2.
February 1978.
10 CFP. Part 50, Appendix B, Criterion V,
" Instructions, Procedures, and Drawings ' requires, in part, that activities affecting quality shall be prescribed by procedures of a type appropriate to the circumstances.
Three examples of violating this requirement are stated below:
1.
R0 1.33 Appendix A.
Item 2.j, requires general operating procedures for going from HOT STANDBY to C0bD SHUTDOVN, Mode 3 to Mode 5 respectively.
This is accomplished by GEN 00-006, Revision 17,
' Hot Standby to Cold Shutdown.'
Step 4.21.2 of GEN 00-006 requires - the determination of which centrifugal charging pump (CCP) is to remain operable with the plant operating in Mode 4, and requires that the breakers for the remaining CCP and the positive displacement pump be racked out.
Contrary to the above, on January 6, 1992, with the picnt operating in Mode 4 Step 4.2.1.2 was inappropriate to the circumstances because it did not tiplicitly prevent placing a CCP control switch in the pull-to-lock position.
The control switch for CCP A was placed in the pull-to-lock position, which rendered the pump inoperable.
CCP B breaker was racked out, and the positive displacement pump was left in operation.
2.
RG 3.33, Appendix A.
Item 8.b(1)(1),
requires procedures for surveillance tests, inspections, and calibrations of the reactor-protection system.
This is accomplished, in part, by STS10-235,
'Arnlog channel Operational Test Nuclear Instrumentation System Intermediate Range N-35 Protection Set I,'
and STS10-236,
" Analog Channel Operational Test Nuclear instrumentation System Intermediato Range N-36 Protection Set II.'
Section.5.2.4 of STS IC-235-and STS 1C-236 provides for the establishment of-the-intermediate range high. level reactor trip setpoints.
Contrary to the above, on January 11, 1992 Section 5.2.4 of STS IC-235 and S75:10 236 was inappropriate to the circumstances becaune licensee personnel failed to incorporate an approved procedure change into Section 5.2.4.
This resulted in the improper establishment of high
-level reactor trip setpoints for both channels of intermediate range monitors.
~~-
k Attochment to NO 02-0101 i
Page 2 of 9 l
3.
RG 1.33, Appendix A,
Item 8.b.
requires specific impl9menting procedures for each surveillance test.
Inspection, and calibration listed in the Technical Specifications.
This is accomplished, in part,
}
by Procedure STS PE-019E, Revision 6,
'RCS Isolation Check Valve Leak Test.'
i Step 2.16 of STS PE-019E requires that the motor-operated safety i
Injection accumulator isolation valves be manually lifted off of their seat to equalize pressure across the valves, af ter co.npletion of the respective accumulator discharge check valve test.
Contrary to the above, safety injection accumulator isolation valvos could not be lifted off of their closed seats without the potential for
{
motor operator damage because procedure step 2.16 was inappropriate to the circumstances.
Step 2.16 failed to specify that the control switch seal-in circuit be placed in ' norm 61",
rather than the " maintain closed
- position.
-As a result, on January 8, 1992, motor operator damage associated with Safety injection Accumulator Xeolation Valve l
EP HV-8808B occurred when technicians lifted the valve off of its closed seat with its control switch in the ' maintain closed' position.
Reason For Violations l
1.
On January 6,
- 1992, at 0230 hours0.00266 days <br />0.0639 hours <br />3.80291e-4 weeks <br />8.7515e-5 months <br /> with the unit in Hode 4 Hot
- Shutdown, th positive displacement pump (PDP) was started and i
Centrifugal Charging Pump (CCP) A was secured because of low flow cavitation concerns with the CCP.
CCP A was placed in the ' normal.
after-stop* position.
CCP B had been previously removed from service.
At 0359 hours0.00416 days <br />0.0997 hours <br />5.935847e-4 weeks <br />1.365995e-4 months <br /> the unit entered Mode 3. Hot Standby, and the handswitch for CCP B was placed in the ' normal-after-stop' position.
At 0427 hours0.00494 days <br />0.119 hours <br />7.060185e-4 weeks <br />1.624735e-4 months <br />.
CCP B and safety injection pumps A and B were restored to operable status. On January 6, 1992, at approximately 1958 hours0.0227 days <br />0.544 hours <br />0.00324 weeks <br />7.45019e-4 months <br />, the unit commenced a cooldown to Mode 4 to repair a leaking relief valve.
At 2126 hours0.0246 days <br />0.591 hours <br />0.00352 weeks <br />8.08943e-4 months <br /> the unit entered Mode 4.
The CCP B breaker was racked out to comply-.with-procedure GEN 00-006 ' Hot Standby to Cold Shutdown".
On January 7, 1992, at 0749 hours0.00867 days <br />0.208 hours <br />0.00124 weeks <br />2.849945e-4 months <br />, li van discovered that the CCP A handswitch had been. inadvertently placed in the
" pull-to-lock' position at approximately 1958 hours0.0227 days <br />0.544 hours <br />0.00324 weeks <br />7.45019e-4 months <br /> on.!anuary 6, 1992.
CCP A was then started and the PDP secured following the discovery that both CCPs were inoperable shile in Mode 4.
At-the time of discovery, the allowed outage time specified-in the Technical. Specification had not been exceeded, therefore, no violation of the Technical Specification had occurred.
l The operators failed to recognize that a CCP had to be operable as required by the Technical Specifications for operation in Modes 4, 5,
Cold Shutdown, and 6-, Refueling. However, a temporary procedure change was initiated to allow the described condition for Modes 5 and 6 in response.to the low flow cavitation concerns.
This failure to recognize the requirements is attributed to inadequate procedursi guidance which did not provide clear and consistent precautiens or i
limitations to assist in-understanding CCP operability during the discussed evolutions.
A cont.ributing f actor was the inf requent amount 1
of time the unit is operated in Mode 4.
J
Attachment to NO 92 0101 Page 3 of 9 i
i 2.
Review of this event identified neveral factors which contributed to the failure to properly perform the surveillrace test procedures.
As
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allowed by procedure, temporary procedure changes to surveillance test procedures STF 10-23$ and STS 10 236 were not issued as permanent changes to avoid incorporating the newly calculated setpoint values into the permanent revision prccess before the final setpoint values were obtained at 100 percent power.
- Instead, temporary procedure changes were written and approved as valid through January 11, 1992.
On January 11. 1992, at approximately 1715 hours0.0198 days <br />0.476 hours <br />0.00284 weeks <br />6.525575e-4 months <br />.
copies of STS 10 23S and STS 10 236 were issued in anticipation of performing the procedures 1
within twelve hours prior to physics testing as required by T/S surveillance Requirement 4.10.3.2.
The temporary procedure changes were issued with the procedures.
Administrative procedure ADM 07100
' Preparation.
Review. Approval And Distribution of WCGL Procedures.*
requires that temporary changes to be used in the performance of surveillance testing -shall be referenced at the applicable procedure step prior to procedure usage.
-Since it was possible that the surveillance
-test procedures would not be performed prior to expiration of the temporary changes, requiring new temporary procedure changes to be processed, the temporary procedure changes were not referenced at the applicable procedure steps at the time the procedures were issued for use.
- The temporary procedure changes were verified to be valid and attached to the surveillance procedures.
The Surveillance Test Routing Sheets, which are attached to the front of the surveillance test procedures to be performed and _ includes a verification that the procedure is the current revision with all temporary changes attached, wao initialed and dated.
During shift turnover on the night of January 11, it was I
identified thct the temporary procedure changes had not yet been referenced and -incorporated at the applicable procedure steps.
The Instrumentation and Control (1&C) Technician who van to perform the test was assigned responsibility of updating the procedure.
However.
when it came time to perform the test, the IEC Technician var involved in other activities and the surveillance test procedures were assigned to other qualified I&C personnel.
Seeing that the surveillance Test l
Routing Sheet verification had been signed, the I&C test performers assumed that_ the temporary procedure changes had been properly incorporated.
Therefore.
I&C personnel failed to follow procedures when the temporary procedure changes were not referenced at the applicable procedure step prior to procedure usage.
3.
On January 8,
.1992 because of concerns about piping movement during the performance of survellinrice procedure STS PE.019E.
'RCS Isolation Check. Valve Leak Test.' a procedure change was issued to manually crack i
open, and subsequently energize open. Safety Injection (SI) Accumulator Isolation Valves EP HV8808A, B, C,
& D.
Tne procedure was performed that-same day- -by-tha dey shift-for valves EP HV8808C & D without-experiencing any problems.
After shift
- turnover, the engineering personnel responsible for the testing reported to the Control Room and were told to manually crack open valve EP 8808B.
-While turning the-handwheel, a grinding noise was heard.
Investigation into the cause I'
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Attschment to NO 92-0101 l
-Page 4 of 9 revealed that the control switch was not removed from the ' maintained closed
- position to the ' normal' position. After unlocking the valve -
it was declutched and manually placement of switch to ' normal' removed from its seat.
The valve was then energized to its open position without axperiencing any problems.
Upon closing, a grinding noise was sgein heard. After disassembly of the valve actuator. It was determined that the gears had ban damaged by the engaged clutch during i
the initial attempts to operatre the valve.
As a result of the electrical logic while the control switch was in
' maintained closed',
the valve motor operator drove the valve closed while it was being opened manually.
Test personnel and operators were j
not fully aware that this would happen with these motor operated valvet.
Therefore, this event is being attributed to an inadequate procedure in that the procedure revision did not specify that the switch should be placed in the
' normal' position prior to manually lifting the valve from its seat.
A contributing cause was the lack of knowledge that certain HOVs will attempt to reclose.
if manually opened, unless the handswitch is placed in ' normal'.
I Corrective Actions That flave Been Taken And ReSuits Achievedt 1.
On January 7,1992, upon discovery tnat the CCP A handsvitch was in the pull-to-lock position, CCP A was immediately started and the PDP secured.
Procedures GEN 00-006 and GEN 00 002,
' Cold Shutdown to Hot Standby',
will be resised to provide better instructional guidance in relation to this event.
2.
Upon notification from 16C personnel. Control Room operators halted the low power physics testing.
16C personnel estimated that the values used in the January 11.-1992, calibration had resulted in the setpoints being set at approximately 36 percent rather--than less than or equal to 25 percent of Reactor Thermal Power (RTP) based on the prestart-up estimates. : Technical Specification 2.2.1, applicable in Mode _2, Start-up, and Mode 1
- Power Operations, below the low setpoint power range neutron flux interlock setpoint, requires the immediate range trip setpoint to be set at less than or equal-to 25 percent with an allowable value of less than or equal to 35.3 percent.
Technical Specification 2.2.1, action statement b, requires that with the Reactor Trip system instrumentation or interlock setpoint less conservative than the allowable value, either adjust the setpoint consistent with the trip setpoint value of less than or equal to 25 percent of RTP and determine within twelve hours that the es-measured value of the setpoint error of the affected channel is less than the total allowance provided-in Table ?.2-1 when the calculation provided in-T/S 2.2.1 is applied, or declare the channel inoperable and apply the applicable action-statement requirement of T/S 3 1.1 until-the --channel is restored to operable _ status with its setpoint adjusted consistent with the trip setpoint value.
Because it was estimated that the setpointu oxceeded the calculated-value for the T/S allowable value of 35.3 percent of RTP.
and more than twelve hours had already lapsed since the plant had entered Mode 2, Control Room operators declared oth Intermediate Range Channels inoperable.
Technical Specification
.3.1 requires two operable Intermediate Range Channels.
The action statement for T/S 3.3.1 states that with the number of the channels
At t at hment to NO 92-0101 Page 5 of 9 operable one less t.
'hv minimum channels operable requirement and with the thermal power level below the intermediate range neutron flux interlock setpoint, rectore the inoperable channel to operable status prior to increasing thermal power above the interlock setpointi or with thermal power above the interlock setpoint but below 10 percent of RTP, testore the inoperable channel to operable status prior to incr easing thermal power above 10 percent of RTP.
Technical Specification 3.3.1 does not provide an action statement for inoperability of more than one channel.
Consequently, Control Room operators entered T/S 3.0.3 on Jcnuary 13. 1992, at 0735 hours0.00851 days <br />0.204 hours <br />0.00122 weeks <br />2.796675e-4 months <br />, and 1&C personnel vere instructed to reperform STS 1C-235 and STS 1C-236.
On January 13,
- 1992, at 0805 hours0.00932 days <br />0.224 hours <br />0.00133 weeks <br />3.063025e-4 months <br />, Control Room operators began to bring Shutdown Bank
- B' to its full-out position, while inserting Coatrol Banks in normal overlap to compensate for the positive reactivity addition.
At 0817 hours0.00946 days <br />0.227 hours <br />0.00135 weeks <br />3.108685e-4 months <br />.
Shutdown Bank "B"
rods were positioned in their full-out position in accordance with T/$ 3.1.3.5 and the action statement was exited.
At 0835 houro.
I&C personnel commenced reperformance of partial surveillance test procedures to properly calibrate the intermediate range trip setpoint as less than or equal to 25 percent of RTP.
At 0919 hours0.0106 days <br />0.255 hours <br />0.00152 weeks <br />3.496795e-4 months <br />, I&C notified Control Room operatorn that the partial surveillance test STS IC-235 had been successfully completed, thuo restoring Channel N-35 to operable status and T/S 3.0.3 was exited and the appropriate action statement for T/S 3.3.1 was entered.
At 0936 hours0.0108 days <br />0.26 hours <br />0.00155 weeks <br />3.56148e-4 months <br />, the partial surveillance test STS IC-236 was successfully completed.
thus restoring Channel H-36 to operable status and the action statement for T/S 3.3.1 was exited.
Using actual intermediate range current data taken during the performance of STS RE.011,
'RCS Total Flow Rate Measurement.' on January 24,
- 1992, an evaluation of the January 11, 1992 setpoints concluded that these setpoints did not exceed the actual values for the T/S allowable values.
Therefore, the Intermediate Range Channels,ere operable.
3.
Following observance of the noise, the breaker for the valve vas racked out with the valve in its normal position.
A work request was issued to troubleshoot and/or repair valve EP HV880BB.
Some actuator components were discovered to be damaged.
The valve was
- repaired, tested, and returned to service.
Corrective Action ihnt Will Be Taken To Avoid Further Violationsi 1.
All CEN and SYS procedures will be reviewed by December 31, 1992 to ensure appropriate precautione/limitatione are clearly incorporated.
2.
To prevent recurrence of this event, a step wes added to RXE 01-002,
'Relood Low Power Physics Testing,' tnat requires Reactor Engineering personnel to verify that the surveillance test procedures used to adjust and test the Intermediate and Power Range Channels within twelve hours of physics testing use the setpoint values based on the ccrrection factors determined for the current core lond.
Because this verification will be performed by persons not involved in the testing of the Intermediate and Power Range Channels, this independent verification should prevent this event's recurrence, Additionally, the
Attochment to NO 02-0101 Page 6 of 9 details of this event were issued as required reading for applicable IEC personnel to emphasiae the-importance of ensuring that all aspects of proper procedure performance have been completed prior to procedure performance and during the post-test review.
-3.
To prevent recurrence of this event, STS PE-019E has been revised to require placing the handswitches to valves EP HV8808A, B, C, E D in the
' normal' position prior to manually opening the valve.
Also, a list of all motor operated valvos with a similar logic has been prepared and provided to the Operations, Maintenance and Modifications,_
Instrumentation and controls, and Training groaps.
Comprehensivg Corrective Actionsi Volf Creek Nuclear O'perating Corporation is aggressively addressing performance and program improvement issues based upon a review of Quality Assurance Audits and Surve111ances Licensee Event Reports, NRC Inspection Reports, and INP0' Assessnents.
'These issues formed the initial basis for the Management Action Plan (MAP) which was discussed in the Reply to Notice of Violation EA 91-161 (letter VM 92 0040 dated March 20. 1992).
In addition to the iten.s discussed in WM 92-0040, the MAP -also specifically addresses improvements in procedural guidance.
The. objective of this effort is, in part, to enhance procedure usability.and ensure compliance.
WCNOC has scheduled a meeting on April 17,
- 1992, to provide the Nuclear Regulatory Commission a more comprehensive description of this program.
Date When Full Compliance Will Be Achieved:
Full compliance will be achieved on D#cember~31, 1992, upon completion of the review of GEN and SYS procedures Violation (482/9136-02): railure To Follow Proc;dures
~
Findinus TS 6.8.1.s requires that written procedures _ shall -be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of RG 1.33, Revision 2 February 2978.
Two examplos of violating _this requirement arm stated below 1.
RG 1.33 Appendix A.
Item _8.b(1)(k),
requires specific procedures for surveillance tests on control rod operability end scram time tests; This is accomplished by Surveillanet Procedure STS RE-007, Revision 5
" Rod Drop Time Measurement.'
Step 5.4.22.10 of STS -RE-007 : requires--personnel-to reconnect all-control rod drive mechanism lift coils in the bank being tested using the lift; coil disconnect switches.
Contrary to the above, on January ^10, 1992, the lift coil disconnect switches for seven rods in Control Bank B were not reconnected.
This resulted in a rod control urgent failure alarm during rod withdrawal on January 12. 1992.
Attachment to NO 92-0101
+
Page 7 of 9
+
'2.
RG 1.33, Appendix A,
Item 8.b91)(1),
requires procedures for surveillance tests, inspections, and calibrations of the reactor protection syst em.
This is accomplished, in part, by STS IC-507A, Revision 5, ' Calibration Steam Line Pressure Transmitteru.'
Step 5.10.4 of STS IC-507A requires the isolation of Main Steam Pressure Transmitter AB PT-526.
Contrary to the above, on January 18, 1992, instrumentation and control technicians isolated AB PT-525 instead of AB PT-526.
This resulted in a steam generator level transient.
Reason For The Vio)ation:
1.
On January 12,
- 1992, while manually withdrawing control banks in overlap for the approach to criticality, a rod control urgent failure alarm was received in the Control Room when withdrawal.ommenced in control bank B.
Investigation identified that all rods oe control bank B,
with the exception of Rod K-14, were found to heve their lif t coil disconnect switches in the disconnect position.
It was determined that T
these switches were not returned to the connected position during performance of surveillance procedure STS RE-007,
' Rod Drop Time Measurement,' as required by step 5.4.22.10.
This event is attributed to failing to follow procedures resulting from ineffective communications.
The ineffective communications resulted from the failure of test personnel on one end of a communication link to confirm the completion of certain steps by test personnel on the other end of the link.
2.
On January 18,
- 1992, while performing STS IC-507A, Revision 5
' Calibration Steam Line Presrure Transmitters,"
en Instrumentation &
Control (ILC) technician mistakenly isolated Main Steam Pressure Transmi*.ter AB PT-525 rather than AB PT-526.
This resulted in a loss of pressure compensation of the Steam Flow Channel for Feedwater Control Valve AE FCV520 which caused it to throttle down and decrease the level in Steam Generator (S/G)
'B'.
t Aw in the first example.
this communication was also taking place through a communication link. An interview with the personnel involved revealed that the field technicians were not conmunicating with each other in a fashion conducive to stimulate and enhance self checking attributes.
Review of the procedure determined that when followed, the procedure is accurate, clear, and concise.
Therefore, this event is being attributed to a failure to follow proceduces which resulted from ineffective communication.
Corrective Actions That Hava Been Taken An-1 Resu138 Achievedj, 1.
Control Room operators inserted the control rods in bank A to 113 steps to ensure proper overlap when withdrawal recommenced.
The lift coil disconnect switches for bank B were reconnected and the rod control urgent failure alarm was reset.
Rod withdrawal was recommenced.
s The individual responsible for failing tc follow the procedure was counseled on the need to follow procedures and to receive confirmation of completed steps when instructions are given over a communication link.
b Attachment tc No 92-0101 Page 6 of 9 2.
Upon receipt of the S/G
'B' flow mismatch alarm, the operators seiceted manual on the feedwater control valve and opened it to return feed flow above steam flow.
All test signals and isolated instruments were returned to normal.
Spurective Actions That_V111 Be Taken To avoid Purther Viointiones 1.
To preclude recurrence of this event, survt
'nce procedure STS RE-007 vna revised t; incorporate a final verJficat st step 0.7 that the lift coil disconnect switches for all contro ad drive mechanisms are in the connected position.
2.
1&C technicians have been counseled on the nectasity and benefit of proper communication and its telation to *self-checking'.
A shop policy - hse been developed which addresses proper communication techniques when communication links are used for fie)d activities that are controlled by a remote authority, e,r., the control Roo.n.
Contrehensive corrective Actions Volf Creek thtclear Operating Corporation is aggreosively addressing performance and program improvement issues based upon a review of Quality Assurance Audits and Surveillances, hicenseo Event Reports, liRC
-Inspection Reports, and INPO Assessments.
These issues forned the initial basis for the Management Action Plan (MAP) discusued in WI 92-0040, Reply to Noti;e of Violation (EA 91-161).
In addition to the itema discussed in W192 0040, the MAP also specifically addresses irnprovements in procedural guidance and connunications.
The oujective of this ef*, ort is, in part, to enhance procedure usability and ensure compliance.
VCh00 has scheduled a meeting on April 17,
- 1992, to provide the Nuclear Regulatory Consnis sion a more comprehensive description of this program.
Da U,Ehen Full,Q.2EpJ1pnce Vill Be Achieved:-
Full compilance has been achieved.
Violation (482/9136-03):
Inadeauate Cctrective Actionn Findinpa Title 10 CFR, Part 50 Appendix B,' Criterion B, Criterion XVI,
- Corrective Action," requires, in part, that measures shall be established to assure that conditions adverse to-quality, such as failures, malfunctions, deficiencies, deviations, defective matorial and equipment, and
- nonconformances'are prnmptly_ identified and corrected.
Contrary to the above, in November _1988, a water hammer event that occurred in the ossential service water system piping that supplies the contairunent coolers vas-identified but not corrected.
Engineering Evaluation Request 88-EF-08 was initiated,_
but the significance of the event was not determined, nor were any corrective actions taken.
The water hanuner event recurrad during the 1991-1992 refueling outage.
l
Attachment to NO 92-0101 5
Page 9 of 9 i
f
]
Jt,ggyp For The Violat f oni t
the water hammer evert was identified as occurring when Essential Service Water (ESV) Pump
'A' was stopped then restarted to verify EDG load rejection capability during performance of surveillance procedure STS KJ-001A, 3
- 1ntegrated D/G and Safeduards Actuation Test - Train A".
The water henner 7
wan caused by draining of the ESW piping to the containment coolers through the common header to components on lower elevations and out to the lake.
Draining stopped when vapor pressure equaled the water col;unn height crop.
Upon pump restact, the surge of wator flow through the drained piping caused the abrupt pressure trensinnt and resulting water hanner.
r After the 1989 cccurrence, Nuclear Plant Engineering (NPE) personnel made an incorrect a s suroption during the initial review of the document shich j
resulted in a low priority assir,nraent.
This aesumption was that only an enhancement was needed and that all other associated actions were corrected l
by others.
A second review noted that additional information was required in order to properly addrets the document.
Tha document was then returned for more information in July 1991.
i This event is being attributed to an inadequate review resulting from an incorrect assumption.
This assumption was based on conflicting definitions in NPE of Engineering Evaluation Requests (EER) 4 the subject dacument procedures and Ami 01-053,
' Engineering Evaluation Requests.'
NPE procedures denote EERs as being used as a request for information only.
This lu contrary to administrative procedure ADH 01 053 which denetes EERo as addressing technical concerns.
Corrretive Actionn That H.Je Been Taken And Results Achievedt Corrective action has been taken to eliminate the water hammer during t
performance of surveillance procedure STS KJ-001A &
B.
An initial evaluation of the effects the water hammer had on the Essential Service Vater System (ESW) piping did not identify any damage.
A thorough design review of the water hammer event has been initiated to confirm that a eignificant condition adverse to safety does not exist.
Completion of-this review will occur by June 30, 1992.
Corrective Action That Will-Be-Taken To ALold Further Violationg,1 To ensure that a similar condition does not exist at the Vcif Creek Generating Station, a review of all open EERs within NPE responsibility will be completed by June 30, 1992.
The review will also prioritize these EERs.
- Additionally, the discrepancy between the NPE procedures and ADM 01-053 vill also be resolved by June 30, 1992.
Date When Full Cgyp11ance Vill Be Achievedt Full compliance will be achieved by June 30, 1992, upon completion of the
_ thorough design review of the water hammer event, the review of open EER6 within NPE's responsibility, and resolution of the procedure discrepancy.
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