ML20126C036
| ML20126C036 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 01/14/1985 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Denise R NRC - WOLF CREEK TASK FORCE |
| Shared Package | |
| ML20126B995 | List: |
| References | |
| KMLNRC-85-029, KMLNRC-85-29, NUDOCS 8506140288 | |
| Download: ML20126C036 (2) | |
Text
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JAN 2 l 1985 1
January,14, 1985 c6a 6.oaivea
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Mr. R.P. Denise, Director Wolf Creek Task Force U.S. Nuclear Regulatory Commission Region IV Arlington, Texas 76011 KMLNRC 85-029 Ret Docket No. 50-482 Subjt Response to Inspection Report 50-482/84-46 Dear Mr. Denise This letter provides the Kansas Cas and Electric Company (KG&E) response to your letter of December 20, 1984, which transmitted Inspection Report STN 50-482/84-46. 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 taken to avoid further violations; and c) The date when full compliance will be achieved.
VIOLATION 8446-02: FAILURE TO PROPERLY FOLl4W PROCEDURES Findingt criterion V of Appendix B to 10 CFR Part 50 requires, in part, " activities affecting quality... shall be accomplished in accordance with instructions, procedures, or drawings...."
Preoperational Test Program Implementation Procedure ADM 14-200, paragraph 4.4.1 requires, in part, "When pre-op test activity... not expected to continue..
48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />... a test suspension shall be declared...."
cI Contrary to the above, Preoperational Test Procedure SU3-NE01 was stopped on three occasionst 0850, August 5, 1984, until 1335, August 12, 1984 8
1500, August 31, 1984, until 1300, September 5, 1984 1820, September 5,1984, until 1030, September 8,1984 Test suspension require'd actions were not followed during these periods.
O ADM 14-200, Attachment 2, Step 6, requires " Enter a detailed description of the discrepancy."
Contrary to the above, during performance of SU3-NE01, Test Discrepancy 7 was entered in the discrepancy log without a detailed description.
201 N. Market -Wochite, Kansas - Mail Address: PO. Bot 206 I Wichots, Kansas 67201 - Telephone Area Code (316) 26 t 6451
Mro R.P. D',nica P g] 2 ADM 14-405, " Temporary Hodification Control," paragraph 4.3.4.2, requires that log entries by accomplished in the temporary modificationcontrol log when temporary modifications controlled by preoperational or acceptance tests that have not been restored at the time of test suspension.
1 Contrary to the above, temperature testing equipment was connected to component coolfng water pump C in support to Test SU6-Mr01, July 6, 1984.
A temporary modification tag was placed on component cooling water pump C and was not recorded in the temporary modification log. This test was completed August 1,1984, and the test equipment remained installed November 8,1984.
Response:e a) Corrective steps which have been taken and results achieved:
t Test Discrepancy 17 was written to document the three uuspensions of SU3-NE01. An evaluation of the testing activities during the time periods involved was performed and it was determined that this administrative error had no adverse affect on test resulta validity. This will be reconfirmed during the test results review process. Prior to recommencing the test following each suopension, appropriate reverifications of valve / breaker
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lineups were performed and documented in the Chrononlogial Test Log.
A clarifying entry has been added to the Discrepancy Log (Page 4) to explain Test Discrepancy #7.
In addition, the detailed Cnrononlogical Test Log entry describing the test discrepancy (8/28/84, 1630 hours0.0189 days <br />0.453 hours <br />0.0027 weeks <br />6.20215e-4 months <br /> on Page 13) has been referenced at TD#7 on the Discrepancy Log (Page 1). The test discrepancy has been resolved by Test Change Notice (TCN) #20, and the affected steps have been re-performed satisfatorily.
The temporary temperature indicator and the temporary modification tag were removed f rom Component Cooling Water Pump C (PEG OIC) immediately upon motification of its installation.
b) Corrective steps which will be taken to avoid further violations:
System Startup Engineers have been required to satisfactorily pass a written closed-book examination. Individuals failing to pass the test were either required to perform self training or required to attend retraining on applicabic administrative procedures.
In all cases they were retested.
Additionally, daily independent reviews of on going pre-operational test activities are being performed.
c) Date when full compliance will be achieved:
Full compliance has been achieved.
Yours very truly, 4HD di Glenn L. Kocater Vice President - Nucicar GLKidab xc P0'Connor L
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