ML20100A349
| ML20100A349 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 10/25/1984 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Denise R NRC - WOLF CREEK TASK FORCE |
| Shared Package | |
| ML20100A342 | List: |
| References | |
| KMLNRC-84-190, NUDOCS 8503250476 | |
| Download: ML20100A349 (3) | |
Text
I KANSAS GAS AND ELECTRIC COMPANY THE ELECTRC COMPANY SLENN L MOESTER TiCE PRE $1MNT - NUCLEAR October 25, 1984
' Mr. R.P. Denise, Director D]Q]gg%
Wolf Creek Task Force U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 OCT J 01984 Arlington, Texas 76011 N
KMLNRC 84-190 Re:
Docket No. 50-482 Subj: Response to Inspection Report 50-482/84-20
Dear Mr. Denise:
This letter provides the Kansas Gas and Electric Company (KG&E) response to your letter of September 28, 1984, which transmitted Inspection Report STN 50-482/84-20. As requested, the violation identified in the Inspection Report is being addressed in three parts:
a) Corrective steps which have been taken and the results achieved; b) Corrective steps which will be Mken to avoid further violations; and c) The date when full compliance will be achieved.
VIOLATION 482/84-20: FAILURE 10 PROPERLY FOLLOW PROCEDURES Finding:
Criterion V of Appendix B to 10 CFR Part 50 requires, in part,
" Activities affecting quality.
. shall be accomplished in ac-cordance with.
. instructions, procedures, or drawings.
Startup Administrative Procedure Preoperational test program implementation (ADM 14-200) requires in part, that individual procedure steps within these subsections will be performed in the order in which they appear. Reordering of steps requires a
'ICN in accordance with Section 4.2, " Test Procedure Changes."
8503250476 841126 PDR ADOCK 05000482 G
PDR 201 N. Market -WicNta, Kansas - Mail Address: RO. Box 208 I Wichita, Kansas 67201 - Telephone: Area Code (316) 261-6451
f, F
Mr. R.P. Denise
.KMLNRC 84-190 October 25, 1984 Contrary to the above, step 7.2.1 of preoperational test SU3-bJ3 was not properly followed. Test personnel performed steps not stated in step 7.2.1, i.e., measurement of the closed /open stroke time, performing a fail safe test, and recorded data in Appendix F.
It was later realized by the licensee that timed stroke measure-ments were required later in the test procedure under dynamic conditions. The test personnel then lined through all entries, then recorded fail safe test accomplishment incorrectly in test failed
_ data sheet of the test procedure.
ADM 14-200 also requires,'in part, that.
"After all approvals, the 'ICN is sequentially numbered, and entered on the Test Change Notice Iog."
Contrary to the above while performing preoperation test SU3-BG03 test change notice (TCN) 004 was not recorded in the TCN log.
ADM 14-200 also requires, in part, that, ".
. Preoperational test procedures may require modification.
. These modifications may be accomplished in.
. the following way (a) test change notices.
Contrary to the above, a test discrepancy was corrected in pre-operational test SU3-BG03 by inserting a second verifiction/
witness signature without pocessing a test change notice. Further, this discrepancy was not entered in the test chronological log.
Responses a) Corrective steps which have been taken and results achieved:
On October 15,1984, at 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br /> a late entry was made in the Chronological Test Log for SU3-BG03, Revision 2.
This entry describes the sequence of events and documents the actions taken to delete the data taken during static conditions and to record the proper data taken under dynamic conditions.
Test Change Notice 004 to SU3-BG03 was sequentially recorded in the Test Change Notice Iag.
Test Discrepancy No. 009 was issued for step 7.2.13.14 of SU3-BG03 to document the insertion of a second veri-fication/ witness signature. Test Change Notice No. 005 to SU3-BG03 was issued to add the second signature witness line in step 7.2.13.14 resolving Test Discrepancy No. 009. A late entry was entered in the Chronological
~.
G..
Mr. R.P. Denise KMLNRC 84-190 October 25, 1984 Test Iog identifying the issuance of Test Discrepancy No. 009 and resolution of it by Test Change Notice No. 005, b) Corrective Steps which will be taken to avoid further violations:
Training has been provided to all startup personnel covering the requirements of the startup administrative procedures. In addition, startup management has held separate sessions with startup supervisory personnel to stress their increased involvement in ensuring that administrative requirements are adhered to, c) Date when full compliance will be achieved:
Full compliance has been achieved.
If you have any questions concerning this subject, please contact me or Mr. Otto Maynard of my staff.
Yours very truly,
% Glenn L. Koester Vice President - Nuclear GLK bb xc:RCDeYoung PO'Connor (2)
HBundy.
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