ML19347E974

Responds to NRC 810226 Ltr Re Violations Noted in IE Insp Rept 50-482/81-01.Corrective Actions:Improved Document Suspense File Followup Sys Imposed & Document Control Technician Assigned full-time

ML19347E974
Person / Time
Site:	Wolf Creek
Issue date:	03/19/1981
From:	Koester G KANSAS GAS & ELECTRIC CO.
To:	Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML19347E973	List: ML19347E974
References
KMLNRC-81-065, KMLNRC-81-65, NUDOCS 8105140444
Download: ML19347E974 (3)

Text

l KANSAS GAS AND ELECTRIC COMPANY

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March 19, 1981 Mr. W.C. Seidle, Chief Engineering Inspection Branch U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011 KMLNRC 31-065 Re f: NRC Docket No. STN 50-482/?pt. 81-01

Dear Mr. Seidle:

This letter is written in response to your letter of February 26, 1981, which transmitted Inspection Report STN 50-482/81-01. As requested, the violation is being addressed in three parts:

a) Corrective steps which have been taken and the results achieved 1 b) Corrective steps which have been or will be taken to avoid further violations 1 and c) The date when full compliance will be achieved.

Finding A superseded drawing was not accounted for and returned to the Document Centrol Section as required by Daniel International Administrative Procedura AP-IX-03. *he ReTident Reactor Inspector (RRI) checked three drawings and observed that Hanger Location Drawing No. M-05BN01(q) , Revision 7 was avail-able at a working location in the Auxiliary Building on January 26, 1981.

Pavision 8 of that drawing had been issued en November 25, 1980. However, the Revision 7 version had neither been replaced by Revision 3 nor returned to the Document Control Section as required by procedure.

Response

a) Daniel was in the process of completing corrective action to a Daniel internal audit of document control in the field when the E10514 O Wf 201 N Market -Wechita, Kansas -Mad Address: PO Box 2C8 i Nicnita Kansas 67201 - Tereanone: Area Code (316) 2616451

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fV' Mr. W.C. Seidle KMLMRC 81-065 March 19, 1981 RRI discovered the superseded drawing. That corrective action included a 100% checle of documents issued to the construction forces. Although statistics were not generated during the cor-rective action check, the percentage of superseded documents ,

found available to construction personnel was low.

Subsequent to the RRI's discover /, KG&E Quality Assurance personnel conducted a surveillance of Daniel document control. The surveil-lance was conducted on Februari 17-19, 1981 and revealed that about 21 of the drawings available as of that date to construction forces were out-of-date by 2 to 23 working days.

The Daniel corrective action was not completed until March 1, 1981.

The subject superseded drawing was retrieved and replaced by the appropriate revision on January 26, 1981. This superseded drawing had no impact on the quality of Wolf Creek construction in that the drawing revision released and revised a portion of the drawing which was on hold.

The Daniel and KO&E audit / surveillance activities revealad that the population of superseded drawings was not indicative of a programmatic breakdown of document control at Wolf Creek. The NPC's classification of this deviation as a Severity Level IV violation was not warranted based on the limited sample taken by the NRC. At Wolf Creek there are nearly one million prints of about 65,000 different drawings. When dealing with any limited sample of such a large number of drawings, it is possible to generate misleading statistics that seem indicative of program-matic problems.

Other checks are in place which would discover that a drawing was revised and not forwarded to the proper construction personnel.

These include:

1) The Constructor's engineering forces review of revised drawings for construction impacts

2) Checks of document control procedures such as were underway when the NRC made the finding; and/or

3) The final walkdown procedure required :.s a result of IE Bulletin '/9-14 to verify the as-built condition of the plant As in compliance with the design specificatj.2ns.

The violation 'ound was not an indication of a programmatic deficiency and KG&E feels that the violation should be reclassified at a lower Severity Level due to its minor safety significance

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Mr. W.C. Seidle '

KMLNRCL81-065 March 19, 1981 and the fact that other programs are in effect which would have corrected the deficiency.

b) The following actions are being carried out and will be incorporated into Procedure AP-IX-03 to achieve even greater control over field issued documents:

1) An improved document suspense file folicw-up system has been imposed. Document Control Supervisors in the field areas now maintain a document suspense file which highlights retrieval due dates of revised documents. If the superseded material is not returned to Document Control within eight working days, Senior Daniel management personnel are notified of the tardiness for management action.

2) A Document Control Technician is assigned full time duty by Daniel as a drawing, specification and procedure monitor. The technician provides a continuous check of applicable documents and takes immediate corrective action if an error is discovered.

c) All corrective actions are now complete except for the revision to AP-IX-03 indicated in (b) above. This procedure revision will be issued by April 30, 1981.

Please confirm your reclassification of the Severity Level of this violation and advise if you need additional information.

Yours very truly,

<jggi / i lY GLK:bb cc: TVandel (NRC Site Inspector)

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March 30, 1981 Mr. W.C. Seidle, Chief Engineering Inspec* ion 3 ranch U.S. Nuclear Regulatory Commission Pagion IV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011 K CIRC 81-066 Subj: Docket No. Sni 50-482/ Ppt. 31-01 Re f: ICCIRC B1-065, CLKoester letter, KG&E ,

dated 3/19/81 to WCSeidle, NRC

Dear fir. Seidle:

Attached is the Affidavit which was inadvertently left off of my letter to you, ICCIRC 81-065 (referenced above) , dated March 19, 1981. The Faferenced letter was in response to

!!RC Inspection Report 31-01, which was conducted at the Wolf Creek Generating Station during January,1981.

Please advise if you need additional information.

Yours very truly, y

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GLK:bb Attach l

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PE : Docket No. STN 50-482 IN 'IEE MATTER OF KANSAS GAS AND ELECTRIC COMPANY (WOLF CREEK)

AFFIDAVIT STATE OF KANSAS COUNTY CF SEDGWICK)

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I, Glenn L. Koester, of lawful age, being duly sworn, hereby depose and state that I am Vice President - Nuclear of Kansas Gas and Electric Company, that I am duly authorized to sign and file with the Nuclear Regulatory Commission the attached Response to the Notice of Violation identified in NkC Inspection Report No. 81-01 that I am familiar with the . contents thereof; and that the matters set forth therein are true and correct to the best of my information, knowledge and belief.

KANSAS CAS AND ELECTRIC COMPANY By. [.nyl f) (d !,, (/

Glenn L. KCester Vice President - Nuclear STATE CF KANSAS )

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COUNTY CF SEDGWICK )

BE IT PEMEMBEPID that on this 30th day of March, 1981 ,

be fo re me , Paul D. Winterbum .a Notary, personally appeared Glenn L. Koester, Vice President - Nuclear of Kansas Gas and Electric Company, Wichita, Kansas, who is personally known te me and who executed the fore-going instrument, and he duly acknowledged the execution of the same for and on behal of and as the act and deed of said corporation.

. SI- - IN WITNESS WHEREOF, I have hereunto set my hand and affixed ny seal thi's l' Y ' Y date and year above written.

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' . . . . .T. r My Commission expires on L-Aucust 2I. 1993 .

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