ML20128E292

Forwards Response to SALP Rept 50-482/84-36 for Aug 1983 - Sept 1984 Re Const QA & Emergency Preparedness

ML20128E292
Person / Time
Site:	Wolf Creek
Issue date:	03/19/1985
From:	Koester G KANSAS GAS & ELECTRIC CO.
To:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20128E246	List: IR 05000482/1984036 ML20128E243 ML20128E292
References
KMLNRC-85-078, KMLNRC-85-78, NUDOCS 8505290340
Download: ML20128E292 (4)

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KANSAS GAS AND ELECTRIC COMPANY THE ELECTAC COMPANY

@LENN L N O E S T E st vatt PwastOffe?- NUCLCAN March 19, 1985 Mr. R.D. Martin Regional Administrator ~

U.S. Nuclear Regulatory Commission )

Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 MM 2 5E M

KMLNRC 85-078 Re: Docket No. STN 50-482 Ref: Letter dated 2/19/85 from RDMartin, NRC, to GLKoester, KG&E, SALP Report 482/84-36 Subj: Response to SALP Report

Dear Mr. Martin:

The Referenced letter forwarded the NRC's Systematic Assessment of Licensee Performance (SALP) Board Report of the Wolf Creek Generating Station. As requested by the Reference, this letter provides comments on the report and addresses Kansas Gas and Electric Company's (KG&E) actions taken in two functional areas.

The SALP Report covered the period from August 1,1983 through September 30, 1984 Section V.F of the Report lists an escalated enforcement ' action concerning " Failure to implement QA Procedures involving the turnover from construction of the Refueling Water System - NRC Report 482/84-02".

This violation was issued on March 23, 1983 and the order imposing a civil penalty was dated June 30, 1983. 'Ihis matter was addressed in the previous year's SALP Report and was not" . . . initiated by NRC Region IV during this assessment period." In addition, the reference to Inspection Report 50-482/84-02 is incorrect.

KG&E has reviewed the SALP Report and either has or will give appropriate consideration to all of the recommended licensee actions. Attachment 1 to this letter specifically addresses the actions taken in the area of construction quality assurance. Similarly, Attachment 2 addresses emergency preparedness.

KG&E welcomes independent assessments at Wolf Creek and is striving to attain additional improvements in performance that should be evident during the next SALP Board review.

8505290340 850522 Yours very truly' PDR ADOCK 05000482 0

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201 N. Market -Wictita, Kansas - Mail Address: RO. Box 208 I Wichita, Kansas 67201 - Telephone: Area Code (316) 261-6451

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.' Attachment-to KMLNRC 85-078 Attachment 1 SALP Report Response - Construction Quality Assurance

.The 'SALP Board recommended a review of all nonconfomance and cor-rective action reports to assure that they have not been used as a vehicle.to obviate drawing or specification requirements, and/or commitments to the NRC.

. Construction Nonconformance Reports (NCRs) are reviewed in accor-dance with approved procedures by the KG&E Quality Assurance (QA) organization. These reviews are independent of the KG&E and Daniel International Corporation (DIC) Construction organizations and the results are provided to the KG&E Manager QA (WCGS). This process has not discovered any cases where the NCRs have been used as a means to circumvent requirements and/or commitments to

.the NRC.

Corrective. Action Reports (CARS) were reviewed to assure that there were no progransnatic deficiencies. This review was per-formed coincident with the corrective actions performed in KG&E

CAR Number 19 (Reference KMLNRC 84-238, KG&E CAR _ #19, Management Action. Plan,Section VI.H, Item D, Page 8). Although not origi-nally;the scope of KG&E CAR #19, non-welding related quality programs were reviewed for comparable programmatic deficiencies.

In accomplishing this, KG&E and DIC conducted an extensive pro-gram assessment of the piping, hanger, mechanical, electrical, and civil; disciplines to ascertain the adequacy of the construc-tion and quality programs instituted. This assessment detemined that a satisfactory level of confidence exists'to assure com-pliance with the Design and Construction Quality Assurance Program, ANSI N45.2,'and design and procedural requirements. A review of

-DIC and KG&E CARS was performed to detemine if any QA problems existed similar to those noted in KG&E CAR #19. Aside from CAR #19 and the related DIC CARS, there were no CARS that had significant problems pertaining to the construction inspection and document areas.

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'O~ Attachment to KMLNRC 85-078 Attachment 2 SALP Report Response - Bnergency Preparedness

-Significant' progress has been made in emergency preparedness program implementationsince the September 17-28, 1984 NRC inspection. This has been demonstrated to the NRC during a field exercise conducted on November 7, 1984 and during an NRC appraisal inspection conducted January 7-11, 1985. KG&E letters, KMLNRC 85-008 dated January 4,1985 and KMLNRC 85-043 dated January 30, 1985,.provided detailed status and schedule

-information that responded.to the September 1984 NRC inspection.

An updated schedule has been developed identifying key elements of the 1985 KG&E Bnergency Preparedness Program. The progress schedule will be distributed to cognizant middle and upper KG&E management. . Snergency Preparedness Program status will be dis-cussed during KG&E management staff meetings to address program

. commitments which impact other KG&E departments.

'Ihe SALP Board reported a number of specific areas, within the functional area of emergency preparedness, that had not been completed. Actions taken in these areas are addressed below.

Personnel Assignments and Training The KG&E Bnergency Response Organization (ERO) was finalized as of January, 1985. A document identifying KG&E personnel with ERO assignments was issued by the' Bnergency Planning Coordinator January 16, 1985. Training for primary and first alternate posi-tion holders was completed on January 15, 1985.

The existing KG&E ERO is currently being evaluated and updated to reflect new assignments, personnel transfers, and response posi-tion changes. The revised ERO will be finalized and issued in Nrch 1985.

Preliminary planning for conducting continued ERO training is in progress.. A training program schedule will be developed and implemented to complete retraining of primary and first alternates and. initial training of the remainder of the ERO. Training and

-retraining of primary and first alternates is expected to be com-plete in my 1985. Initial training of the remainder of the ERO is expected to be complete by November, 1985.

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,. - . V-4 J's Attachment to KMLNRC 85-078 Attachment 2 Prompt Public Notification System Procedures describing tone alert radio distribution and siren ,

maintenance have been developed and approved. Sirens are

installed and operational; formal, documented testing will pro-ceed following fuel load. Initial tone alert radio distribution is complete-and maintenance of the distribution is in progress.

-News Media Training News media training was performed on October 24, 1984. News media training for 1985 is scheduled in October.

Bnergency Personnel Call-Out Procedures Bnergency call-out procedures were completed in January,1985.

Training on the existing procedures was also completed in January.

'Ihe call-out procedure series is currently undergoing review and revision. The changes are based on ERO position and staffing changes, additional information available on the Automatic Dial-ing System (ADS) and improvements identified in the manual call-out methodology. A manual call-out drill will be scheduled after fuel load, but prior to exceeding 5% power.

Middle &nagement Awareness of Bnergency Preparedness Program Requirements A preliminary,1985 KG&E Bnergency Preparedness Program schedule has been develope *d. The schedule indicates key program milestones and commitments. The schedule will be distributed to the appro-priate KG&E managers for their information. &nthly progress status reports are developed by the.Onergency Planning Coordinator and distributed to the appropriate KG&E managers. Additionally, Bnergency Preparedness Program issues have been, and will continue to be, discussed during'KG&E management staff meetings.

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