ML20128D385
| ML20128D385 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 05/08/1985 |
| From: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Koester G KANSAS GAS & ELECTRIC CO. |
| Shared Package | |
| ML20128D390 | List: |
| References | |
| EA-85-027, EA-85-27, NUDOCS 8505290054 | |
| Download: ML20128D385 (5) | |
See also: IR 05000482/1984057
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JAM 0 815
-Dockets:
STN 50-482/84-57
STN 50-482/85-11
EA 85-27
Kansas Gas and Electric Company
ATTN: -Glenn L. Koester
Vice President - Nuclear
P.' O. Box 208
Wichita, Kansas 67201
Gentiemen:-
This refers to the routine inspections of activities authorized by NRC Construction
Permit No. CPPR-147 conducted by Mr. W. G. Guldemond and other members of the Wolf
Creek Task Force including Messrs. M. Farber and D. Williams of the Region III
office. These two inspections were conducted under the preoperational test
inspection program during the periods of October 1 - December 20, 1984 and
February 1 - 28, 1985 at the Wolf Creek Generating Station. The results of
these inspections were discussed with you and members of your staff at an
Enforcement Conference held at the Wolf Creek site on December 4, 1984, which
was attended by Mr. R. P. Denise and other members of the NRC staff, and with
Mr. C. Mason and other members of your staff at an Exit Meeting on February 28,
1985.
During these inspections, violations of NRC requirements were identified. These
violctions indicated weaknesses in your preoperational test program.
Violation IA-
in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty
involves three examples which your test program failed.to provide verification
of design safety features. Violation IB involves two examples in which your
test program failed to demonstrate component performance during limiting accident
conditions under which the component is expected to operate. Violation IC
involves three examples in which your test program failed to ensure the use of
proper testing methods and proper equipment. Violation ID involves one example
in which your test program failed to verify a design document commitment.
Previous ' Inspection Reports identified similar weaknesses (Inspection Reports
50-482/84-15,50-482/84-20,and50-482-84-30).
Failures to properly execute
procedures and to properly document test discrepancies had been identified
previously.
In addition, during previous inspections we found a number of
completed preoperational test packages that were voided during the final review
stages due to administrative errors. These violations and other concerns
involving your failure to provide adequate acceptance criteria and to adequately
evaluate anomolous test results were discussed with you previously.
Since similar
violations were identified subsequently, it appears that your initial actions were
to resolve these weaknesses on a case-by-case basis rather than in a comprehensive.
manner.
Insufficient management attention was devoted to identifying and correcting
the root causes of these problems. As a result, as documented in-NRC Inspection
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
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Kansas Gas and Electric Company
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Report 50-482/84-57, these violations and concerns indicated.that a breakdown
in the execution of your preoperational test program occurred.
To emphasize the importance the NRC places on the execution of your preoperational
test program to ensure that the program demonstrates the functional capabilities'
of structures, systems, and components, and after-consultation with the Director,
Office of Inspection and Enforcement, I have been authorized to issue the enclosed
Notice of Violation and Proposed Imposition of Civil Penalty in the amount of
Twenty-Five Thousand Dollars ($25,000). This violation has been categorized as
a Severity Level III violation in accordance with the " General Statement of Policy
and Procedure.for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985).
The base value for this type of violation is $50,000. However, the Enforcement
Policy permits the consideration of factors for mitigation or escalation of the
. proposed penalty. The staff reviewed these factors and determined that
mitigation of the base penalty by 50% was warranted. While we recognize
that your initial actions were limited in scope, we also recognize that you
have taken the prompt and extensive corrective actions you described during the
Enforcement Conference on December 4,1984 and in your letters of December 11,
1984 and February 5,1985. These corrective actions have been reviewed and
found to be satisfactory (as documented in paragraph 2 of enclosed Inspection
Report 50-482/85-11).
Three other violations identified in Inspection Report 50-482/85-11 and discussed
in the enclosed Notice are not assessed a civil penalty. Violation IIA involves
three failures to follow plant administrative procedures. Violation IIB involves
a failure to follow a preoperational test procedure, and Violation IIC involves
a failure to operate the plant to procedural requirements. These violations are
categorized as Severity Level V violations.
You are required to respond to the violations and should follow the instructions
in the Notice when preparing your response. Your response to the enclosed Notice
should address these items and provide an updated status on completion of those
items described in your December 11, 1984 letter. Your response should also
address specifically the corrective actions which you discussed with the Region IV
staff and which you have implemented to preclude recurrence of this type of
violation during the power ascension and operation phases at Wolf Creek. You
may reference previous correspondence concerning these violations.
In accordance with Section 2.790 of the -NRC's " Rules of Practice," Part 2,
Titic 10, Code of Federal Regulations, a copy of this letter and its enclosure
will be placed in the NRC Public Document Room.
The response directed by this letter and the accompanying Notice .is'not subject
to the clearance procedures of the Office of Management and Budget as required
by the Paperwork Reduction Act of 1980, PL 96-511.
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Kansas Gas and Electric Company
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~Should you have any questions concerning this inspection, we will be pleased to
discuss them with you.:
Sincerely,
I
Orignal signed BY.
Pauls. Check
Robert D. Martin
Regional Administrator
Enclosures:
1.
Notice of Violation and Proposed
Imposition of Civil Penalty
2.
Appendix A - NRC Inspection Report
50-482/84-57
3.- Appendix B - NRC Inspection Report
50-482/85-11-
-cc:
' Kansas Gas and Electric Company
ATTN: Gene P. Rathbun, Manager
of Licensing
P.~ O. Box 208
Wichita, Kansas 67201
Forrest Rhodes, Plant Superintendent
Wolf Creek Generating Station
P. O. Box 309
Burlington, Kansas
66839
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R. P. Denise,
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J. Harrison, RIII
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