ML20128Q283
| ML20128Q283 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 05/30/1985 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| EA-85-027, EA-85-27, EA-85-27-142, KMLNRC-85-142, NUDOCS 8506040142 | |
| Download: ML20128Q283 (9) | |
Text
\\
KANSAS GAS AND ELECTRIC COMPANY THE ELECTAC COMPANY SLENN L MOESTER M Epets otNT NvCLtan May 30, 1985 Mr. J.M. Taylor, Director Office of Inspection and Enforcement U.G. Nuclear Regulatory Conmission Ruthington, D.C.
20555 KMLNRC 85-142 Re:
Docket No. STN 50-482 Ref:
- 1) Letter dated 5/8/85 from RDMartin, IRC, to Gmoester, KG&E
- 2) KMLNRC 84-227 dated 12/11/84 from G M oester, KG&E, to RDMartin, NRC
- 3) KMLNRC 84-240 dated 12/31/84 from Gmoester, KG&E, to RDMartin, NRC
- 4) KMLNRC 85-014 dated 1/10/85 from GEoester, KG&E, to RDMartin, NRC
- 5) Letter dated 1/18/85 from RPDenise, NRC, to Gmoester, KG&E
- 6) KMLNRC 85-044 dated 2/5/85 from GMoester, KG&E, to RPDenise, NRC Subj: Enforcement Action 85-27 Dear Mr. Taylors enclosed is Kansas Gas and 6fectric Conpany's (KG&E) response to Item I (Violation IA, IB, IC, and ID) as documented in Reference 1.
Pursuant to 10CPR2.201, the following five itens are addressed for the alleged violation:
1.
Admission or denial of the alleged violation; 2.
The reason for the violation, if admitted; 3
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 conpliance will be achieved.
[
8506040142 850530 I
gDR ADOCK 05000402 I 'l PDR 201 N. Market - Wichita, Kansas - Mail Address: PO. Box 208 I Wichita, Kansas 67201 - Telephone: Area Code (316) 261-6451
Mr. J.M. Taylor May 30, 1985 KMLNHC 85-142 KG&E's response to Item II.C (Violation Not Assessed a Civil Penalty) will be transmitted by separate cover on or before June 7, 1985. The Notice of Reference 1 provides that no response to Items II.A and II.B is required.
Please contact me or Mr. Otto Maynard of my staff if you have any questions concerning KG&E's response to the alleged violation.
Yours very truly, Glenn L. Koester Vice President - Maclear G m: dab Enclosure xc PO'Connor (2)
JCunnins RDMartin
i smTE & KANSAS )
) Ss CITY & WICHITA )
Glenn L. Koester, of lawful age, being first duly sworn upon oath says that he is Vice President - !&aclear and an Officer of Kansas Gas and Electric Conpany; that he has read the foregoing h==rt and knows the content thereof; that he has executed that same for and on behalf of said Conpany with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.
By
+
' Glenn L. Koester Vice President - NL11cear SUBSCR w n and sworn to before me this @ day of %
, 1985.
NmAx3fho-
' @ ary Public i
Expiration Date Il lGIA7 l
i
_ g.# hN.'.Q 0T
! /4
.A&p.
g'-
- =
~ \\Poao#! l G
.T@.;.,,
4-
.m...-.e.-.,
~
,m-
w 4
Enclosure to 1000C 85-142 Page 1 of 6 violation Annannad a Civil Penalty A.. Statement of Alleged Violation I.
Violaticma Annanand a Civil Penalty
,10 CFR Part 50, Appendix B, Criterion XI requires that a
. test program be established to assure that testing required to demonstrate that the structures, systens, and couponents perform satisfactorily in service is l-identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents.
'1he test program is to
- include, as
. appropriate, proof-test prior to installation, preoperational
- tests, and operational tests during nuclear power plant or fuel reprocessing plant operation, of structures, systems, and couponents. Test procedures are to-include ' provisions for assuring that all prerequisites for the given test have been met, that adequate test instrumentation is available and used, and that the test is performed under suitable ' environmental conditions.
Test results are to. be documented and
. evaluated to assure that test requirements have been satisfied.
Section 17.2. of the Wolf Creek Addendum to the SNUPPS l
PSAR, " Quality Assurance During the Operation Phase,"
requires that testing be performed to demonstrate that structures,
- systems, and cu w w.nts
' perform satisfactorily in service.
'1he test program includes preoperational tests, initial startup tests, surveillance those associated with plant maintenance, modification,
^_
procedure changes, failure analysis, and the acceptance of purchased material.
Test-programs are to be established by the Director, Llanclear Operations to assure that testing demonstrates item or system performance.
Testing is to be performed in ~ accordance with written procedures which incorporate or reference the requirements and acceptance limits contained in applicable Technical Specifications,
- drawings,
. instructions, procurement documents, specifications,
- codes, standards, and regulatory requirements.
Test program procedures control when a i
test is required and how it is to be performed.
l 5
j
~
v.-
..,-n-,-
,n,,,--n-.-
-,,,--,..-n,,---,.
,,-.n e~.--,-.-
+r.---,,---n.
--n..,
Page 2 of 6 Test administrative procedures, test procedures, and checklists enployed during tests are to include, as applicable, prerequisite conditions; material and test equipnent requirements; mandatory hold points; testing
. method instructions; limiting conditions and acceptance / rejection criteria; data collection - method; and test result approval requirements. Test results are to be - documented, reviewed, and approved by qualified individuala or groups.
Contrary to the above, at the time of the'NRC inspection, the Kansas Gas and Electric Conpany had not established and executed an adequate preoperational test program which would have demonstrated that structures, systems, and conponents would perform satisfactorily in service.
'Ite following are exanples of failures to adequately establish or inplement the above program:
A.
Verification of design safety features was not performed as Preoperational Test Procedures SU3-AE01,
" Main Feedwater System,"
SU3-AB04,
" Main Steam System," and SU3-NF01, "Imad Shedding and Load Sequencer," did not include provisions to verify that safety system actuation signals would override test signalc for certain conponents, as required by design and as specified in Sections 14.2.12.1.5, 14.2.12.1.3, and 14.2.12.1.63 of the Wolf Creek FSAR.
B.
Test Procedures SU3-W 01, "IDCA Sequencer," and SU3-NF03, " Shutdown Sequencer," failed to demonstrate conpc ent performance under limiting accident cond b ions.
C.-
Neither the use of proper testing equipnent nor the use of proper testing' methods was ensured in that:
l (1) a pressure gauge of inproper range was used to
[
measure the performance of Residual Heat Removal System pmps in test SU3-EJ01, " Residual Heat Removal System", (2) a procedure SU3-NE01, " Diesel Generator Electrical," did not specify adequate conditions for test performance in accordance with FSAR Section B.I.4.3, and (3) the test program did not specify adequate testing of the failure mode of air operated valves.
l i
Page 3 of 6 D..Preoperational. Test Procedure SU3-NC01, "125 VDC Class lE Electrical System," did not incorporate a' connitment from FSAR. Section 8.3.2.2.1 to measure safety-related battery room hydrogen concentration during battery operation.
This is a Severity I4 vel III Violation (Supplement II).
Civil Penalty - $25,000.
B.
Stplg 1.
M=inaion or Denial of A11anad Violation The above quoted violation asserts that Kansas Gas and Electric Company
("KGE"), as of.the time of the inspection, "had not established and executed an adequate preoperational test program which would have demonstrated-that structures, systems, and empients would perform satisfactorily in service".
KGE does not dispute that certain weaknesses existed in the Preoperational Test Program
("the Program")
for Wblf Creek Generating Station, Unit 1.
Those problems are set forth and discussed in Reference 2.
The above quoted violation also asserts that specific deficiencies in the Program were identified in four areas:
failure to provide verification of design safety features f(Violation IA); failure to demonstrate conponent performance during limiting accident conditions (Violation IB); failure to ensure the use of proper testing methods and proper equipnent (Violation IC), and failure to verify a design document connitment (Violation ID).
These specific. instances were first identified in Inspection Report STN 50-482/84-43
("IR 84-43")'
(Reference 5) as, respectively, itens 84-43-09, 84-43-12,
'84-43-11, and 84-43-10.
In its response to IR 84-43 (Reference 6), KGE scknowledged that the identified' deficiencies had occurred.
2.
Reasons for violation The description of the causal factors or " root causes" of the weaknesses in the Program are described in Reference 2.
The reasons for the specific deficiencies in the Program are described in Reference 6.
Page 4 of 6 3.
Corrective Steos Which Have Been Taken And The Results Achieved The steps which KG&E proposed to take to remedy the weaknesses in the Program consisted of several action items listed in Reference 2.
The inplementation of these action itens is described in References 2, 3, and 4.
An assessment of KG&E's inplementation of these action items by an MC inspection team is contained in Inspection Report STN 50-482/85-11. See Reference 1.
'Ihe NRC team concluded that "[t]he conmitted-to-corrective actions were inplemented as stated with one minor exception which did not conpromise the overall effectiveness of the corrective action program.
The actions inplemented resolved the weaknesses identified and provioed the needed level of assurance relative to the technical adequacy of the preoperational test program."
'Ihe steps which. KG&E has taken to correct the spt.cific deficiencies in the Program, and the results of t'wse corrective actions, are described in Reference 6.
4.
Corrective Steos Which will Be Taken To Avoid Further Violations i
Correci.ive steps which KG&E has taken to prevent recurrence of the identified weaknesses in the Program
-are described'in Reference 2.
The corrective steps taken to prevent recurrence of the specific deficiencies in the Program are described in Reference 6.
5.
Date When Full N anliance Will Be Achieved The corrective steps which KG&E proposed to take to correct the identified weaknesses in the Program and to prevent their recurrence have been fully inplemented.
See References 2, 3, and 4.
The corrective steps which KG&E proposed 'to take to correct the specific deficiencies in the Program, and to prevent thei. ' recurrence, have also been fully inplemented. See Reference 6.
(
..,.n.
e r-..
Page 5 of 6 C. ' Actions Taken to Prevent nrmrrerww of violatirma Durina Power Ascension and Operation During an enforcement conference held.on December 4,1984 between NRC personnel and senior KGEE management personnel, the.lmC noted that adequate assurances would have to be provided that the weaknesses identified during preoperational testing would not reoccur during the power ascension testing program or during routine plant operations.
KGEE has taken a number of. steps to ensure that the problems identified during preoperational testing do not reoccur during power ascension testing the - routine operations.
In addition to the actions outlined in Reference 2, KG&E has established a realistic schedule for power ascension tests.
It has involved management intimately in the scheduled test activities,. and improved connunications at all levels of test personnel and management. KG&E has developed a conprehensive power ascension program and procedures. Other actions taken by KG&E are sunmarized in PEC Inspection Report SIW '
50-482/85-11, p. 17-18.
' An " interim assessment" report on the Power Ascension Test Program was performed by menbers of KG&E's Quality Assurance Organization.
It concluded that the major factors that' led to the weaknesses observed during preoperational testing are not present in the power ascension test program. 'Likewise, the PSC team that conducted the 85-11 inspection concluded that " management is taking action to properly conduct the test program and has integrated the lessons ~from the preoperational test program into the power-ascension program."
Based on the above facts, and other folloMp activities end observations, KGEE has determined that effective actions have been.taken to assure that the power ascension. test program, and routine plant operations, are not subject to tie weaknesses identified during preoperational testing.
Page 6 of 6 D.
References 1.
Ietter dated May 8,1985 from RDMartin (NRC) to GMoester (KG&E) enclosing Notice of Violation and Proposed Inposition of-Civil Penalty and NRC Inspection Report Nos. 50-482/84-57 and 50-482/85-11.
2.
Ietter (KMLNRC 84-227) dated. Decenber 11, 1984 from GMoester (KGEE) to RDMartin (NRC), and enclosures.
3.
Ietter (KMLNRC 84-240) dated Decenber 31, 1984 - from GMoester (KG&E) to PDMartin (NRC), and enclosures.
4.
Ietter (KMLNRC 85-014) dated January 10, 1985 from GMoester (KG&E) to RDMartin (?RC), and enclosures.
5.
Ietter dated Jamlary 18, 1985, from RPDenise (NRC) to GMoester (KG&E),
enclosing Inspection Report STN~
50-482/84-43.
6.
Ietter (KMLNRC 85-044) dated February 5,
1985 from GMoester (KG&E) to RPDenise (NRC), and enclosures.
.