ML20101J761
| ML20101J761 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 12/21/1984 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| EA-84-107, KMLNRC-84-234, NUDOCS 8412310121 | |
| Download: ML20101J761 (5) | |
Text
kS ei KANSAS GAS AND ELECTRIC COMPANY THE ELECTEMC COMPANY otsuu e noustaa December 21, 1984 WsCE PEES
- DENT huCLEAR Mr. Richard C. DeYoung, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555 KMLNRC 84-234 Re Docket No. STN 50-482 Ref:
Letter dated 11/21/84 from RDMartin, NRC, to GLKoester, KG&E Subj : Enforcement Action 84-107
Dear Mr. DeYoung:
Attached is Kansas Gas and Electric Company's (KG&E) response to Violation II, as documented in the Reference. Pursuant to 10CFR2.201, the following five items are addressed for the alleged violation:
1.
Admission or denial of the alleged violation; 2.
The reasons for the violation, if admitted; 3., The corrective steps that have been taken and the results achieved; 4.
The corrective steps that will be taken to avoid further violations; and 5.
The date when full compliance will be achieved.
KG&E's response to Violation I (Violation Assessed Civil Penalty) will be trans-mitted by separate letter on or before December 31, 1984. This extension was discussed and agreed to during a December 18, 1984, telephone call between Mr.
Lawrence Martin of the Nuclear Regulatory Commission (Region IV) and Mr. Otto Maynard of KG&E.
Please contact me or Mr. Otto Maynard of my staff, if you have any questions concerning KG&E's response to the alleged violation.
Very truly yours, GLK:cks Attach xc-RDMartin I\\
EDenise 8412310121 841221 I g,
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I' PO'Connor PDR ADOCK 05000482 G
PDR IIBundy 201 N. Market - Wichits, Kansas - Mad Address: PO. Box 208 l Wichita, Kansas 67201 - Telephone: Area Code (316) 2616451
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OATH OF AFFIRMATION STATE OF KANSAS
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COUNTY OF SEDGWICK )
I, Glenn L. Koester, of lawful age, being duly sworn upon oath, do depose, state and affirm that I am Vice President - Nuclear of Kansas Gas and Electric Company, Wichita, Kansas, that I have signed the foregoing letter of transmittal, know the contents thereof, and that all statements contained therein are true.
KANSAS GAS AND ELECTRIC COMPANY By_
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Glenn L. Koester Vice President - Nuclear E.D. Prothro, Assistant Secretary STATE OF KANSAS
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COUNTY OF SEDGWICK )
BE IT REMEMBERED that on this 21st day of December, 1984
, before me, Evelyn L. Fry, a Notary, personally appeared Glenn L. Koester, Vice President - Nuclear of Kansas Gas and Electric Company, Wichita, Kansas, who is personally known to me and who executed the foregoing instrument, and he duly acknowledged the execution of the same for and on behalf of and as the act and deed of said corporation.
IN WITNESS WHEREOF, I have hereunto set my hand and affixed my seal the
.....n. da,te and year above written.
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- i EyElyn L.
rE, Notary
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's.e;.A' U C C ?',! -
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' !,.*g My. Conmission expires on August 15, 1985.'
f Attachment to 84-234 VIOLATION NOT ASSESSED CIVIL PENALTY FINDING Criterion V of 10 CFR 50, Appendix B, requires that activities affecting quality shall be accomplished in accordance with appropriate instructions, procedures, and drawings,_and that these instructions, procedures, and drawings contain appropriate quantitative acceptance criteria.
Bechtel Drawing E-lR8900, Revision 1, " Raceway Notes, Symbols and Details" states in paragraph 3.36.4 that:
" Minimum separation between different Class lE conduit systems and minimum separation between Class lE conduit systems and non IE conduit systems shall be 1".
Separation shall be measured between the outside edges of the' conduit".
Bechtel Drawing E-01013 (q), Revision 11, requires the following:
1.
Paragraph 5.8.1.6 "Within the control boards and other panels associated with protection systems, circuits and instruments of different separation groups shall.be independent and physically-separated horizontally and vertically by a distance of 6 inches".
2.
Paragraph 5.8.3 "Non-safety relatt.d circuits shall be 4_
separated from Class lE circuits by the same distances l
applicable to Class lE circuits of different groups".
Contrary to the above, the following activities affecting quality were not accomplished in accordance with appropriate drawings:
1.
There were seven cases noted where conduit-to-concuit separation was less than one inch.
2.
There were five areas in the control panels and cabinets where electrical cable separation was less than six inches.
RESPONSE
l.
Admission or denial of the alleged violation:
There were cases in which the conduit-to-conduit separation was less than one inch.
In addition, as identified and documented by KG&E prior to the NRC's inspection, there were control panels and cabinets in which electrical cable was separated by less than the specified six inches.
l
i 2.
The reason for the violation, if admitted:
One inch separation.for flexible conduit is.an individual inspection attribute the inspector must enter on the Quality Checklist..In i
addition, the correct installation of the flex is an item that is looked for on walkdowns'during system turnover and again during room / area turnover.
Deviations from the separation criteria b
primarily resulted when the installed flexible conduit was slightly longer than required.
This resulted in a slight bowing of.the conduit...Therefore, the one inch separation existed unless.two of j
the conduits were moved so that they bowed-toward each other.
Deviations from the six inch separation criteria.in control panels-resulted primarily from the installation of field run cable causing slight movement of previously installed cables or the introduction j
of a cable into an area via a route not allowing the minimum separation.
Agnin, this condition was identified and documented prior to the WRC;s inspection.
3.
The corrective steps which have been taken and the results l
achieved:
In order to document and assure resolution of the deficiency concerning 1 inch conduit-to-conduit separation, KG&E issued Corrective Action Request (CAR) 15.
All "Q" Buildings were 1
subsequently walked down to identify deviations from the separation i
criteria.
These deviations were documented on Nonconformance Report (NCR) 1 SN 20443 E and are currently being corrected by providing physical restraints such as tie-wraps or reworking the conduits to i
maintain separation.
As stated in item 1 above, the concern with 6 inch cable separation in the main control panels had been identified and documented on a i
KG&E Startup Field Report (SFR) prior to the NRC's inspection.
Since the issuance of the SFR, all main control board panels have now been inspected and deviations of the 6 inch separation criteria 3
have been documented on Nonconformance Report (NCR) 1 SN 20766 E.
Rework is in progress to either provide the required separation or i
provide a physical barrier between the wires, t
In addition, the safety significance of both of the separation deviations has been evaluated for reportability pursuant to k
10CFR50.55(e) and determined not to be a significant safety concern which, if left uncorrected, would have adversely affected safe operation of the plant.
4.
The corrective steps that will be taken to avoid further violations:
The construction craft, engineering, and inspection personnel will be retrained on the importance of using good construction practices to assure proper conduit separation.
This training will address the problems associated with excessively long conduit than can result in separation deviations if movement occurs.
Barriers are being added to the control panels in areas where maintaining the t inch separation is extremely difficult or not possible.
In addition, a letter will be issued to site organizations alerting them to the separation requirements and the care that must be taken when routing cable in the control panels.
5.
The date when full ~ compliance will be achieved:
The above corrective actions will be completed by December 31, 1984.
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