ML20133K902

Responds to NRC Re Violations Noted in Insp Rept 50-482/85-25.Corrective Actions:Plant Mod Request Program Reviewed.Proposed Changes for KGP-1131, Plant Mod Process, Developed & in Concurrent Review & Approval Process

ML20133K902
Person / Time
Site:	Wolf Creek
Issue date:	08/23/1985
From:	Koester G KANSAS GAS & ELECTRIC CO.
To:	Denise R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20133K898	List: IR 05000482/1985025 ML20133K902
References
KMLNRC-85-203, NUDOCS 8510220342
Download: ML20133K902 (4)

Text

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KANSAS GAS AND ELECTRIC COMPANY T>( ELECTHC COWANY G L E Pe N L MOLSTER VnCE P.ES.OEss? nex6Eme August 23, 1985 7C-q ., [

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

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U.S. Ibclear Regulatory Coninission

• Region IV U 611 Ryan Plaza Drive, Suite 1000 j% ,,

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Arlington, Texas 76011 '

KMUGC 85-203 Re: Docket !b. 50-482 Subj: Response to Inspection Report STN 50-482/85-25

Dear Mr. Denise:

This letter is written in response to your letter of July 26, 1985, which transmitted Inspection Report STN 50-482/85-25. As requested, the violation (482/8525-01), 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 conpliance will be achieved.

Violation: Lack of Pecords Control for Plant Modification Packanes Findina:

10 CPR 50, Appendix B, Criterion II, as inplemented by Eb1f Creek Plant Quality Assurance Program, FSAR Section 17.2.3, requires that control be provided over activities affecting the quality of the identified structures systens, and conponents, to an extent consistent with their inportance to safety.

85102203428%382 PDR ADOCK O PDR

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L C-It'ilW 201 N. Market - Wichita, Kansas - Mail Address: PO. Box 208 I Wichite, Kansas 67201 - Telephone: Area Code (316) 261-6451

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Mr. R.P. Denise KMIRRC 85-203 August 23, 1985 Contrary to the above, the Region III inspector identified a lack of control of the Wolf Creek modification process. . Exanples noted during the review of eight nodification packages are as follows:

1. Records or portions of records from three modificaion packages wre missing from the OA records vault and wre not located during this inspection.

2. Two modification padages contained documentation which did not indicate the required signatures.

3. Two modification packages contained conflicts regarding the safety classification of the modifications.

REPonse:

a) % e reason for the violation, if admitted;

1. Records or portions of records from three modification packages were missing from the QA records vault and were not located during this inspection.

Response

Records or portions of records were not located during the inspection due to personnel unfamiliarity with the PMR and h ==nt retention processes. The original PMRs referenced by the Work Requests are maintained in Management Systens Document Control (MSDC). All of the identified PMRs were in MSDC except the original of PMR N084-KE028 which was in the validation and closecut process. %e 10CFR 50.59 evaluation for PMR 384 was performed by the A/E and is included in the PMR padage. In these cases, a seperate 50.59 evaluation by the PSRC is not required. The required PSRC review of the existing 50.59 was performed on February 22, 1985 and is h==nted in the NR91002-85 package.

2. Two nodification packages contained documentation which did not indicate the required signatures.

Response

WR4279-85 was in the review cycle and was not able to be located during the inspection period. A PMR with a status of AP-7 indicates the work is couplete, however the IHR and associated h==nts may still be in the review cycle and not closed out. Se review cycle is now couplete and the work package contains the required signatures. The missing OC signature on WR91206-85 was caused by a failure to properly follow procedures.

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Mr. R.P. Denise August 23,1985 KMI24RC-85-203

3. Two nodification packages contained conflicts regarding the safety classification of the modifications.

Pesponse:

Wrk Request WR 4604-85 was initiated for installation of neutron shield water bags. The initiator inappropriately marked the work request as non-safety related. However, the water bags were subsequently renoved and replaced with water cans, thus this modification no longer exists in the plant. Work Request NR 2986-85 should have been designated safety related. However, the field installation was performed by the vendor on a rework plan, which identified the equipment as "O" and used the vendors quality progran.

b) The corrective steps which have been taken and the results achieved:

As a result of the NRC inspection conducted on May 20, 1985, the overall Plant Modification Request program was reviewed. A Task Force was developed which included menbers from each group who were involved in the PMR inplementation, closeout and verification processes. As a result of the Task Force, proposed changes have been devloped for KGP-ll31, " Plant Modification Process" and are in a concurrent review and aIproval process. The Operations Branch Plant Modification Process program was also coupletely revised and the inplementing procedure ADM 01-042,

" Plant Modification Request Inplementation" was totally rewritten and is in the review and approval process.

The revised program provides:

-PSBC review of Safety Evaluations

-Plant Manager signature for inplementation approval irraceability from Plant Modification Request (PMR) package to all inplementing Work Requests and from each Work Request to the PMR

-Index for package contents

-Instructions to provide for adequate closecut documentation and verification

i Mr. R.P. Denise [

IQUIRC-85-203 August 23, 1985 }

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The following work h==nts discussed above shall be evaluated by Quality Engineering for proper safety classification. If f

t inproper classification is indicated the inpact on the subject  :

installations shall be evaluated and corrective actions shall be }

taken as required.

{

-WR 4604-85 designated as non-safety related

-WR 02986-85 designated as non-safety related ,

-NR 91206-85 lacks Gl Final Review Signature (Block 35) l c) 'the corrective steps which will be taken to avoid further

[

violations- -

1

'Ihe revised PMR inplementation procedures provide stringent I controls for PMR inplementation, closecut, and verification. i Following approval of the implementing procedures and prior to {

inplementation of the revised program, training in the program .

requirements will be given to appropriate personnel involved in i the PMR inplementation, closecut and verification processes.

d) Date when full coppliance will be achieved: l

{ Full coupliance will be achieved by Septenber 30, 1985. i Yours very truly, f

Wfao,J '

/

[ Glenn L. Koester Vice President, Nuclear [

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cc: PO'Connor (2) h I i

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