ML20128Q346
| ML20128Q346 | |
| 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 | |
| EN-85-027, EN-85-27, KMLNRC-85-143, NUDOCS 8506040162 | |
| Download: ML20128Q346 (5) | |
Text
KANSAS GAS AND ELECTRIC COMPANY THE ELECTAIC COMPANY GLENN L MOESTER vctp.EsectMT NucLaa.
May 30, 1985 Mr. J.M. Taylor, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Comission Washington, D.C.
20555 KMLNRC 85-143 Re:
Docket No. SPN 50-482 Ref:
- 1) Ietter dated 5/8/85 from RDMartin, NRC, to GIKoester, KG&E
- 2) KMLNRC 85-142 dated 5/30/85 from GIKoester, KG&E, to JMPaylor, NRC Subj: Enforcement Action 85-27
Dear Mr. Taylor:
Enclosed is Kansas Gas and Electric Conpany's (KG&E) response to Violation II.C (Violation Not Assessed a Civil Penalty) as documented in Reference 1.
Pursuant to 10CFR2.201, the following five items are addressed for the alleged violation:
1.
Admission cr denial of the alleged violation; 2.
The reason 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.
'Ihe date when full empliance will be achieved.
KG&E's response to Item I (Violation IA, IB, IC, and ID) of Enforcement Action 85-27 was transmitted by Reference 2.
g6040162850530 G
ADOCK 05000482 PDR 201 N. Market ~ Wichita, Kansas - Mail Address: Ro. Box 208 l %1chita, Kansas 67201 - Telephone: Area Code (316) 261-6451
Mr. J.M. Taylor-May 30, 1985 KMusC 85-143 Please contact me or Mr. Otto Maynard of my staff, _if you have any glestions concerning KC4E's response to the alleged violation.
Yours very truly, Glenn L. Koester Vice President - NLiclear GE: dab Enclosure xc: PO'Connor (2)
JCununins RDMartin i
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Glenn L. Koester, of lawful age, being first duly sworn upon oath says that he is Vice President - Nuclear and an Officer of Kansas Gas and Electric Conpsny; that he has read the foregoing h ment 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 - Nulcear SUBSCRIBED ami sworn to before me this M day of N 1985.
bt*M mfd a U Notary Public
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Violations Not Assessed a Civil Penalty
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Finding C.
10CFR Part 50, Appendix. B, Criterion XI requires that all testing required: to demonstrate that structures, systems, and couponents will perform satisfactorily in service is identified and -performed in accordance with written test j-procedures which incorporate the requirements and acceptable limits contained in applicable design h==nts.
KGGE. Administrative Procedure ADM 92-101, Revision 11, "Tenporary Modifications", in paragraph 3.1.6 requires that if the procedure authorizing the installation of a modification is suspended for a period of greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the modification must be restored to normal or tagged in accordance with this procedure.
j contrary to the above, at the time of this inspection, test flanges rather than the required blind flanges to Flow Elements EM-924, !!M-925, EM-926, and EM-927 were installed downstream of certain safety injection valves and the test flanges were not tagged as a tenporary modification in
,accordance with ADM 02-101.
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Response
i 1.- Admission or denial of alleged violation:
The. test flanges had been installed in accordance with-surveillance test procedure STS CV-216, " Boron Injection Flow Path Check Valve Test". Following conpletion of the i
. surveillance procedure, the removal of the test flanges, and i:
reinstallation of the permanent blind flanges, was tracked by a Nbrk Request rather than a tenporary modification as required by. administrative procedure ADM 02-101, "Tenporary Modifications".
2.
The reason for the violation, if admitted:
The inplementation requirements of the Tenporary Modification procedure were not clear and therefore, resulted in the described procedural deviation.
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~3.
'Ihe corrective sters that have been taken and the results achieved:
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'Ibe tracking Nbrk Request has been coupleted and the permanent blind flanges have been reinstalled.
'Ihe Plant Manager has issued a letter to all section Superintendents involved in test procedure inplementation reiterating the requirements of administrative procedure ADM.02-101, "Tenporary Modifications",
and
' instructing-each Superintendent to review these requirements and discuss them with the affected personnel.
- 4..'Ihe corrective steps that will be taken to avoid future violations:
In addition to the action described above, a modification to administrative procedure' ADM 02-101 is being prepared to clarify the inplementation requirements.
5.
'Ihe date when full coupliance will be achieved:-
Full coupliance will be achieved by June 15, 1985.
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