ML20079E280
| ML20079E280 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 12/09/1983 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| KMLNRC-83-162, NUDOCS 8401170213 | |
| Download: ML20079E280 (2) | |
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KANSAS GAS AND ELECTRIC COMPANY THE ELECTAC COMPANY
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- cum December 9, 1983 VR@[RDW1N*
DEC i 2 1983 Mr. J. E. Gagliardo, Acting Chief 4
Reactors Projects Branch U.S. Nuclear Regulatory Commission s #.ggggynggg;j Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 KMLNRC 83-162 Re:
Docket No. STN 50-482 Subj Preoperational Test Procedure Availability
Dear Mr. Gagliardo:
Kansas Gas and Electric C7mpany (KG&E) has a commitment in SNUPPS FSAR Section 14.2.3 to have available for NRC review, approximately 60 days prior to their scheduled implementstion, the approved preoperational testing procedures necessary to satisfy FSAR testing commitments. This commitment is derived from a recommendation in Regulatory Guide 1.68.
We find ourselves now unable to meet this commitment for a certain limited number of preoperational tests.
For varying reasons, the schedule and logic of startup testing at Wolf Creek has been changed several times. Having the preoperational test procedures available for review 60 days before test performance has been made more difficult by this changing of the Wolf Creek testing schedule.
As such, the definition of what is to be tested via any specific test, how testing can proceed and when have been subject to change.
I KG&E's current startup planning has identified that the preoperational test procedures given in the Attachment will not meet the 60 days before scheduled test performance schedule. We are taking considerable efft,rts to minimize the number of test procedures which are late in being prepared and approved.
These efforts include:
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The establishment of the Startup Technical Support Group to provide focus or the preparation and approval of FSAR committed tests.
2.
Increased Startup Engineer staffing in other Startup Groups, thereby augmenting KG&E's procedure writing capability, n
3.
Enhanced procedure preparatior visibility, tracking and
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expediting. These efforts include enhanced draft proce-() h p
dure review and approval techniques.
8401170213 831209 PDR ADOCK 05000482 g
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A PDR 201 N. !'arket -Wichita Kansas - Mad Address: RO. Box 208 i Wchita, Kansas 67201 - Telephone: Area Code (316) 261-6451
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KMLNRC 83-162 JMr. J. E. Gagliardo December 9, 1983
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KG&E believes that the above efforts will limit the late availability for NRC review of preoperational test procedures to those in the Attachment.
A final revision of each test procedure may be necessary, however, just prior to test performance to accomplish test " fine taning" t., account for minor test scope changes, minor. test logic changes, late design changes or other late identified factors. KG&E believes such changes would be minor and would not alter commitments for safety-related tests described in the FSAR.
The attached schedule shows the planned preoperational test sequence. Wolf Creek personnel will keep the Wolf Creek Resident Inspectors informed of startup testing activities and provide to the Resident office in a timely manner the approved preoperational test procedures.
In summary,.KG&E has an FSAR connitment which we presently know that we cannot meet in a few instances (see Attachment). KG&E is taking corrective actions to preclude future occurrences of the sz.me problem. The major important factors c-erning these test procedures is that they be prepared with quality, with o.41stency to other activities, and in full compliance with FSAR commitments. We do feel, in some isolated instances, the regulatory guidance that establishes procedure availability to meet pretest timing criteria may be counterproductive to quality of testing and does not reccgnize the dynamic nature of startup testing activities for near-term operating license plants of today's era.
If you have concerns about the circumstances described above and the situation KG&E presently finds itself in, please contact me.
Very truly yours, GLK:cks Attach cc: WSchum
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