ML20133K788

Responds to NRC Re Violations Noted in Insp Rept 50-482/85-23.Corrective Actions:Tape Removed from Level Indicator Slide Pole & Drain Pipe from Valve & Conduit Relocated

ML20133K788
Person / Time
Site:	Wolf Creek
Issue date:	09/04/1985
From:	Koester G KANSAS GAS & ELECTRIC CO.
To:	Denise R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20133K780	List: ML20133K778 ML20133K788
References
KMLNRC-85-216, NUDOCS 8510220301
Download: ML20133K788 (3)

Text

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• s KANSAS GA: AND ELECTRIC COMPANY T>E ELECTAiC COMP ANY )

GLENN L MOESTER VtCE P.ES*DEset seuCLEa.

Septenber 4, 1985

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~l Mr. R.P. Denise, Director Division of Reactor Safety and Projects

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U.S. Riclear Regulatory Connission - - 1I Region IV 611 Ryan Plaza Drive, Suite 1000 .

Arlington, Texas 76011 KMLlac 85-216 Re: Docket No. 50-482 Subj: Response to Inspx: tion Report SrN 50-402/85-23

Dear Mr. Denise:

This letter is written in response to your letter of August 8, 1985, which transmitted Inspection Report SrN 50-482/85-23. As requested, the violation (482/8523-01), identified in the Inspection Report is being addressed in four parts.

a) The reason for the violation, if admitted; b) The corrective steps which have been taken and the results achieved; c) Corrective steps which will be taken to avoid further violations; and d) The date when full cor:pliance will be achieved.

1. Violation: Failure to Follow Plant Procedures Findina:

10 CPR Part 50, Appendix B, Criterion V states, in part,

" Activities affecting quality . . . shall be acconplished in accordance with these instructions, procedures, or drawings. . ."

8510220301 851015 PDR ADOCK 05000402 O PDR f

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201 N. Market - Wictuta, Kansas - Mad Address: PO. Box 208 I Wichita, Kansas 67201 - Telephone: Area Code (316) 261-6451

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6 Mr. R.P. Denise DILNRC 85-216 2 Septenter 4,1985 The following are excerpts from plant procedures that have been established in accordance with 10 CPR Part 50, Appendix B, Criterion V:

ADM 01-041, " Plant Modification Request," Revision 4, dated February 23, 1985, in Section 2.3 states; "The Wolf Creek Generating Station Plant Manager will appro w all modifications prior to their being inplemented."

- ADM 01-057, " Work Request," Revision 7, dated May 13, 1985, in Section 2.1 states in part: "The work request is intended to document and ccotrol work activities involving safety related, special scope, and . . . "

AEM 02-101, "Tenporary Modification." Revision 12, dated May 16, 1985 which in Section 2.1, states in part; "It is the responsibility of the group leader (or designee) whose personnel are inplementing a tenporary modification to ensure the modification is necessary, correct, and to prepare the 10 CPR 50.59 applicability review for . . . The group leader (or designee) shall approve the modification in advance of the work being performed."

Contrary to the above, on May 24, 1985, the slide pole for containment water level indicator IF-LI-9 was observed to be inoperable due to an unauthorized modification in the form of tape wratped around and obstructing the level indicator slide pole.

Resoonse:

a) The reason for the violation if admitted:

While the specific activity which resulted in this incident could not be determined, the tape obstruction on the slide-pole is believed to have occurred during insulation activity in the general area of the instrument. Adhesive tape was found wrapped around the slide-pole approximately one foot above the containment floor. The-presence of the tape on the slidc-pole would have obstructed the instrument float from rising with conta3nment water level above the elevation of the tape on the slide-pole. Shortly after this condition was identified, the tapa obstruction was removed from the slide-pole and the instrument was returned to service.

This instrument is used for event identification during accident conditions when containment water level could reach. a maxinum of four and one half feet above the contairment floor. Redundant l

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s Mr. R.P. Denise 1 KMIRRC 85-216 3 Septenber 4, 1985 containnent water level instrument IE-LI-10 was in service during this time. Two additional fully qualified (Class IE) containment ,

water level instruments EJ-LI-07 and EJ-LI-08 were also in service.

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Since the duration of the out-of-service condition is believed to be greater than seven days, a violation of Technical Specification Action Statement 3.3.3.6a -is considered to have occurred and was  :

reported in Licensee Event Report 85-034-00.

b. Corrective steps which have been taken and the results achieved:

'Ihe tape was removed upon discovery. As a result of this event, the slide-pole for redundant containment water level instrument LP-LI-10 was inspected for obstructions. While no obstructions affecting operability were found in the accident monitoring range of the instrument (naxinum flood level of four and one half feet above the floor) two obstructions were found at approximately six and seven feet above the floor. The obstructions to the slide-pole float in the extended range of the instrument involved a small drain pipe from a valve and a flexible conduit. They have been relocated to eliminate any possible interference.

c. Corrective steps which will be taken to avoid further violations: i To prevent occurrences of similar situations, a letter has been issued to all organizations which may be called upon to perform work in the plant, instructing them to review this situation with their enployees and to reiterate the requirenents for specific prior approval before making any attachments to pemanent plant equiptent or structures.

d. Date when full conpliance will be achieved.

Full conpliance has been achieved.

Please contact me or Mr. Otto Maynard of my staff if you have any

.Jastions concerning this response.

Yours Very Truly Glenn L. Koester GIK:see xc: PO'Connor (2)

JCunnins