ML20080P513

Responds to NRC Re Violations & Deviation Noted in IE Insp Rept 50-482/83-38.Corrective Actions:Startup Technical Support Group Established to Provide Focus on Preparation & Approval of FSAR Committed Tests

ML20080P513
Person / Time
Site:	Wolf Creek
Issue date:	01/27/1984
From:	Koester G KANSAS GAS & ELECTRIC CO.
To:	Denise R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20080P496	List: ML20080P513
References
KMLNRC-84-009, KMLNRC-84-9, NUDOCS 8402220568
Download: ML20080P513 (6)

Text

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KANSAS GAS AND ELECTRIC COMPANY THE ELECTRC COMPANY OLENN L R 3 L S T C ft wet pers,ormt ms (tan January 27, 1984

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Mr. Richard P. Denise, Director );' l.I ,

Division of Resident, Reactor Project ,lAN 3 019M *- l and Engineering Programs '. '-

,)i U.S. Nuclear FerJula tory Commission [.(_._ - - -- -

Region IV

_ ____ a 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 M4LNRC 84-009 Re: Docket No. STN 50-482 Ref: Letter KMLNRC 83-162 dated 12/9/83 from GLKoester, KG&U, to JEGagliardo, NRC Subj: Resporse to Inspection Report STN 50-482/83-38

Dear Mr. Denise:

This letter is written in response '.o Mr. Gagliardo's letter of December 29, 1983, which transmitted Inspectun Report STN 50-482/83-38. As requested, the deviation and twa viole.tions identified in the Inspection Report are being addressed in three parts:

a) The corrective steps which have been taken and the results achieved; b) Corrective steps which wi]1 be taken to avoid further deviation (violations) ; and c) The date when full compliance will be achieved.

DEVIATION 482/8338-01: Preoparational Test Procedures Finding:

The Final Safety Analysis Report (FSAR) for the Wolf Creek Generating Station (WCGS) , Chapter 14, Revision 10, paragraph 14.2.3.2, " Test Procedures" states, in part: "The initial test program is conducted in accordance with detailed preoperational and initial startup test procedurcs. The SNUPPS Utilities maintain the overall responsibility for test procedure preparation, 8402220568 S40207 PDR ADOCK 05000482 G PDR 201 N. Market -Wichita, Kansa - Mail Addrets: RO. Box 208 I Wichita, Kansas 67201 - Telephone: Area Code (316) 261-6451

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Mr. Richard P. Denise KMLNRC 84-009 January 27, 1984 Finding (continueM : ,

review, end approval during the preoperational stages. Each utility is responsible for fina] procedure revision, review and approval. These activities should be completed in a timely fashion to ensure that the approved procedures for satisfying FSAR testing equipment commitments are available for review approximately 60 days prior to scheduled implementation or fuel load for preoperational and initial startup tests, respectively."

In deviation from the above, the following preoperational test procedures were not available for review the required tirte prior to scheduled performance:

• SU3-KE06 - Refueling Machine Indexing SU3-BB01 - Rewtoi- Coolant Pump Initial Operation SU3-BBll - Reactor Coolant System Hydrostatic Test SU3-BG01 - Chemical and Volume Control System Major Component Test

Response

a) Corrective steps which have been taken and results achieved:

As .'.dentified in the P.oference, the iollowing actions havn been taken:

1. The establishment of the Startup Technical Support Group to provide focus on the preparation and approval of FSAR committed tests.

2. Increased Startup Engineer ntaffing in other Startup Groups, thereby augrrenting KG&E's procedure writing capability.

3. Enhanced procedure preparation visibility, tracking and expediting. These efforts include enhanced draf t procedure review and appruval techniques.

These efforts have resulted in test procedures being available for review approximately 60 days prior to scheduled implementation of the test.

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Mr. Richard P. Denise KMLNRC 84-009 January 27, 1984 Response (continued):

b) Corrective steps which will be taken to avoid further deviations:

Increased KG&E Management attention to the area of pre-operational test procedures will be continued to assure that corrective steps which have been taken continue to be effective. This includes:

1. Assuring high visibility of the test procedure preparation schedule;

2. Reviewing actual progress against scheduled progress;

3. Assuring procedure preparation is aggressively pursued, tracked and expedited; and

4. Assuring procedure quality is maintained at a high level.

c) Date when full compliance will be achieved:

The required Preoperational Test procedures are now being nade available for review approximately 60 days prior to scheduled ireplementation of the test.

VIOLATION 482/8338-02: Failure to Properly Control Procedure Revisions Finding:

20CFR Part 50, Appendix B, Criterion V, requires, in part, that

" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances..."

Contrary to the above, Kansas Gas and Electric Company (KG&E) failed to provide a procedure to adequately control issuance of revisions to procedures. Specifically, Administrative Procedure (ADed) ADM 01-004, " Superintendent of Operations, Responsibilities and Duties", Revision 1 was issued as Revision 1 twice; once dated August 24, 1983 and again on October 20, 1983.

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Mr. Richard P. Denise KMLNRC 84-009 January 27, 1984 Responses a) Corracti te steps which have been taken and results achieved:

The Plant Safety Review Committee (PSRC) Clerk for Kansas Gas and Electric Company discovered the duplicate Revision 1 to Ad;inistrative Procedure, ADM 01-004, " Superintendent of Operations, Responsibilities and Duties", shortly after the second Revision 1 was issued for dis'_ribution.

After the PSRC Clerk discovered this error, she iminediately sent a transmittal to the previous distribution with instructione to (.estroy the procedure revision dated October 20, 1983.

All of thesc. transmittai returns have been accounted for by the PSRC Clerk.

b) Corrective steps which will be taken to avoid further violation:

A revision to ADM 07-100," Preparation, Review Approval e and Distribution of WCGS Procedures" has been initiated to reflect that all change forms will be routed or given to the PSRC Clerk for tracking or Word Proces. ing. Thi.3 tracking should prevent any duplicate revisions being issued on plant procedures.

Additionally, an Independent Quality Review of procedures prior to their issuance has been implemented. This Independent Quality Review is performed by checking the procedure to bo issued against several quality attributes.

If any problems are noted during this review, the problem must be resolved prior to issuance by the PSRC Clerk. No procedure may be issued without this Independent Quality Review.

c) Date when full cozppliance will be achieved:

Full compliance will be achieved by January 31, 1984.

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Mr. Richard P. Denise KMLNRC.84-009 January 27, 1984 VIOLATION 482/8338-03: Failure to Follow Procedures Finding:

10CFR Part 50, Appendix B, Criterion V, states, in part, that

" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with those instructions, procedures, or drawings."

Wolf Creek Generating Station (WCGS) Procedure ADM 14-202, Revision 3, " Joint Test Group (JTG) ," requires that an alternate chairnan be designated in writing and that the designated alternate will attend meetings when the principal is not available.

Contrary to the above, on November 23,-1983, the JTG was convened without the proper chairman or his designated alternate.

Response

a) Corrective steps which have been taken and results achieved:

The Test Change Notice #002 to Preoperational Test Procedure SU4-CG01, Revision 0, " Condenser Air Removal System", which was reviewed and approved at the Joint Test Group (JTG) Meeting, November 22, 1983, was reviewed and approved by the JTG on December 5, 1983 with proper membership and chairmanship in attendance.

b) Corrective steps which will be taken to avoid further violation:

Wolf Creek Generating Station Administrative Procedure ADM 01-002, " Plant Safety Review Committee" has been revised to include Attachment 002-1, " Joint Test Group".

This attachment provides the charter for the JTG since it is a subcommittee of the Plant Safety Review Committee.

In addition, this revision provides provisions for con-vening a JTG Meeting in the absence of the Chairman or his designated alternate, without the chairman issuing a letter changing his alternate. This revision permits the permanent Chairman of the PSRC to call and conduct a JTG Meeting in the absence of the JTG Chairman and Alternate Chairman, providing the required quorum require-ments are ret. If the JTG quorum requirements cannot be

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Ec . Richard P. Denise KMLNRC 84-009 January 27, 1984 met, a PSRC Meeting may be called to handle JTG business by the permanent PSRC Chairman, or assigned

-alternate in his absence.

This revision to ADM 01-002 has been t i: viewed and approved by the PSRC and is now consistent with PSRC subcommittee requirements. This should resolve un-resolved item 482/8338-04. ADM 14-202 was deleted upon approval and issuance of ADM 01-002.

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c) Date when full compliance will be achieved:

Full compliance has been achieved.

Please contact me or Mr. Otto Maynard of my staff if you have any questions concerning these responses.

Yours very truly,

, $$/ Y Glenn L. Koester Vice President - Nuclear GLK:bb cc: WSchum

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