ML20024E095
| ML20024E095 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 05/27/1983 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20024E090 | List: |
| References | |
| KMLNRC-83-061, KMLNRC-83-61, NUDOCS 8308090178 | |
| Download: ML20024E095 (3) | |
Text
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,o KANSAS GAS AND ELECTRIC COMPANY TFE ELECTAC COMPANY QLENN L MOESTEN bKt PatsvotNT NucLtan May 27, 1983 Mr. W.C. Seidle, Chief 1
1 I-hh Reactor Projects Branch 2 U.S. Nuclear Regulatory Commission k]
Region IV I
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KMLNRC 83-061 Re:
Docket No. STN 50-482 Ref: 1) Letter STN 50-482/82-22, dated 2/23/83, from WCSeidle, NRC, to GLKoester, KG&E Ref: 2) Letter KMLNRC 83-035 dated 3/25/83, from GLKoester, KG&E, to WCSeidle, NRC Ref: 3) Letter STN 50-482/82-22, dated 4/27/83, from WCSeidle, NRC, to GLKoester, KG&E Subj: Supplemental Response to Inspection Report STN 50-482/82-22
Dear Mr. Seidle:
Reference 1) transmitted Inspection Report STN 50-482/82-22, to which a Notice of Violation (NOV) was attached. Kansas Gas and Electric Company's (KG&E) response to the NOV was provided in Reference 2). Reference 3) requested a supplemental response to provide additional information con-cerning KG&E's corrective action. This letter provides the additional information requested by Reference 3).
Violation 1.
Failure to Properly Follow Procedures Region IV Comment:
Our finding was that the receiving and maintenance instructions (RMIs) for the pressurizer and the steam generators were not followed. Your response stated that the requirements which had not been followed have been deleted. Your supplemental response should address actions to ensure compliance with all RMIs for safety-related equipment in order to avoi i further violations.
KG&E Supplemental Response:
Special Receiving, Storage and Maintenance Instruction and Inspection Requirements (RMIs) W120 and W130 were not clear 8308090178 830729
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PDR ADOCK 05000472 O
PDR 201 N. Market -Wichita, Kansas - Man Address: RO. Box 208 i Wichita, Kansas 67201 - Telephone: Area Code (316) 261-6451 e..
Mr. W.C. Seidle KMLNRC 83-061 May 27, 1983 as to whether or not paint touch-up was required once the equipment was moved inside. The Constructor's inter-pretation was the paint touch-up requirement was only intended to apply during outdoor storage. This inter-pretation was confirt.ed by a memo from Westinghouse on December 8, 1981.. However, the RMIs were not revised at that time to reflect this clarification. Therefore,-the Constructor was in compliance with the RMI as clarified by the December 1981 memo. The primary concern for this -
issue is that the RMI was not clear, and when clarification was obtained, the 'RMI was not revised to reflect the clarification. Corrective actions for adequacy and clari-fication of RMI requirements were provided in Reference 2, Page 4, under " Response".
In order to ensure compliance with all RMIs for safety-related equipment, KG&E will first verify that the corrective actions stated in Reference 2) are accomplished. KG&E will then conduct a surveillance after full compliance is achieved to ensure RMIs are being complied with.
Violation 2.
Inadequate Quality Records Region IV Comment:
Our finding was that the Equipment Maintenance Log for the pressurizer was not completed and signed as required by your procedures. Your supplemental response should address action to ensure that documentation requirements for maintenance on safety-related equipment are fulfilled.
KG&E Supplemental Response:
All maintenance records will be raviewed as part of the turnover documentation review. If safety-related equipment ~
without proper maintenance documentation is found, it will i
not be turned over until the equipment is inspected, the l
inspection findings are resolved, and the inspection record l-edded to'the maintenance records.
Violation 3.
Inadequate Corrective Action Region IV Comment:
Our finding was that the corrective action taken in response to Corrective Action Report-1G00ll was inadequate. Your
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'N, response included discussion of maintenance record reviews (and a planned review of RMIs by,an organization other-thani
& Daniel International.
_We' agree that these reviews.are-ap-propriate,:but we are concerned that your response :did not 3
Q 'if address actions'to improve the quality and timeliness of~
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~ actions ~taken to resolve and correct conditions adverse to 1
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-qualityLwhich are identified by the Kansas Gas and Electric c
Company'and its contractors 7 Improvements in this' area will 7
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likely be necessary to avoid future violations.
y r..,q, KG&E Supplemental Response:
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- l. Daniel Construction Procedure AP.-VI-12, " Corrective Action",
'was ' revised - (Rev. 2) on December 1,11982 as a result of INPO y
Sele-Initiated Construction Evaluation findings. zThis revision includes measuresto -assure more effective and. timely
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,~Y corrective actions in response to Corrective Action Reports
'W (CAR). Among.these improvements are:
a) - Requirements for the affected manager to provide N
a tentative corrective action plan and timetable
'to-the-Quality Manager!for evaluation within'four s
,5 (4) working days 'of the CAR initiation. This is
. reviewed by Quality Engineering for ' effectiveness and timeliness.
b) /I'he -Project Quality Engineer performs a monthly s -
j, investigation of all'open CAR'sj to monitor progress
'against the corrective action commitments. The:
results of.this investigation are reported to the Project Manager-and' Project Quality Manager.' If y either the effectiveness or timeliness of the actions rt during the month are-inadequate, the Project Managers r
W ill take; additional appropriate actions.
- 2. KG&ElQA will perform an audit of the Daniel Corrective Action Program during ' the, fourth quarter of CY1983. This' audit will evaluate the ~ effectiveness of these Daniel program enhancements.
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s Yours very truly, 2
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Glenn L.Koester c c. ~
Vice President - Nuclear
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