ML20141D490
| ML20141D490 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 10/18/1985 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Denise R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20141D459 | List: |
| References | |
| KMLNRC-85-235, NUDOCS 8601070286 | |
| Download: ML20141D490 (4) | |
Text
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KANSAS GAS AND ELECTRIC COMPANY TFE ELECTFuC COMPANY SLENN L MOESTER
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OCT 2 41985 October 18, 1985
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>1 dDi Mr. R. P. Denise, Director
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Division of Reactor Safety and Projects U.S. NL1 clear Regulatory Connission Region ET 611 Ryan Plaza Prive, Suite 1000
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Arlington, Texas 76011 KMLNRC 85-235 RE:
Docket No. SIN 50-482 SUBJ: Response to Ingxx: tion Report BrN 50-482/85-26
Dear Mr. Denise:
This letter is written in response to your letter of Septenber 20,
- 1985, which transmitted Inspection Report SIN 50-482/85-26.
As requested, the violations (482/8526-01 and 02), identified in the Inspection Report are 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 coupliance will be achieved.
1.
VIOUiTION (482/8526-01): Failure to Control Measurino and Test Eauirnent in Accordance with Procedure Findina:
10 CFR 50, Appendix B, Criterion V states, in part, " Activities affecting quality... shall be acconplished in accordance with these instructions, procedures, or drawings...."
The following are excerpts from plant procedures that have been established in accordance with 10 CFR Part 50, Appendix B, Criterion V:
8601070286 851223 DR ADOCK 05000482 y M 2C 201 N. Market - Wichita, Kansas - Mail Address: PO. Box 200 l Wichita, Kansas 672C1 - Telephone: Area Code (316) 2616451
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Mr. R. P. Denise
. 18, 1985 10DBC 85-235 Page 2 October Administrative Procedure, ADM 02-101, "Tenporary Modification,"
Revision -12, dated May 16, 1985, in Section 5.4 states, in
- part, "The placement of temporary modifications authorized by approved procedures are excluded from the requirements of this procedure.. If the procedure authorizing the installation of a modification is to be suspended or terminated, the modification imist be restored to normal, or the op> rations shift responsible
.for the suspension / termination nust initiate the tenporary modification order form.."
In Section 2.2, ADM 02-101, states,.in part, "The duty shift supervisor shall approve all tenporary modifications.
A 10 CFR 50.59 applicability review will be conducted for all temporary nodifications."
Contrary to the above, on June 26, 1985, Pressure Gauge E 9967 was
-observed c u nected to flow orifice flange-B H I-968, located in safety
-injection pump room "B" without the use of 'a tenporary modification order, approved procedure, or a 10 CFR 50.59 applicability review.
Responses a)
The reason for the violation, if admitted:
An investigation into the circumstances surrounding the installation of the gauge E9967 has been ecWucted.
The results of this investigation did not reveal the individual (s) responsible for the installation or the date of installation.
The history of gauge E9967 is as follows:
-Novenber 6, 1984: Gauge E 9967 was calibrated by I&C.
-November 27, 1984: Geuge E 9967 was used in Retest 1 to pre-operational. test SU3-l!M02, " Safety Injection Flow Verification".
-Decenber 22, 1984: Gauge E 9967 was used in Retest 2 to pre-operational test SU3-l!M02.
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'Ihe Startup Engineer for SU3-I!M02 recalls having gauge K9967 removed and returned to IEC.
-A Results Engineer investigating a Field Change Notice (FCN 10724),
concerning a modification to the orifice B H I-968 for flow element BN-FE-968, between February 25, 1985 and March 7, 1985 indicated no test gauge was installed at that time.
-I&C records show an assignment of " lost" status on May 24, 1985, when gauge E9967 could not be found for normal recalibration.
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r Mr. R. P. Denise 10Dec 85-235 Page 3 October 18, 1985
-A review of surveillance tests which might have used the orifice, revealed no use of gauge NC9967.
-A review of the Tenporary Modification log revealed no mention of gauge NC9967.
'Ihe last calibration of BN-FE-968 was on Decenber 20, 1984.
There was no indjeation of an installed test gauge at that time.
-Gauge NC9967 was discovered installed in parallel with BN-FE-968 on the Safety Injection Punp "B" recirculation line on Jtine 26, 1985.
b)
Corrective steps which have been taken and the results achieved:
'Ihe gauge was removed upon discovery by Wolf Creek Nbrk Request 8896-85.
c)
Corrective steps which will be taken to avoid further violations:
'Ihe inproper installation of the gauge in parallel with BN-FE-968 was additionally documented as Wolf Creek Event Report 85-91 and was reviewed and discussed by the Plant Safety Review Consnittee.
d)
'Ite date when full conpliance will be achieved:
Full conpliance has been achieved.
2.
VIOIATION (482/8526-02)
Tannnrary M Not Incoroorated in Procedures as Remired Findinar 10 CFR Part 50, Appendix B,
Criterion V states, in part, " Activities affecting quality.
.. shall be acconplished in accordance with these instructions, procedures, or drawings... "
Adminstrative Procedure ADM 02-021, Revision 6,
"Use of Procedures in Operations," has been established in accordance with 10 CFR Part 50, Appendix B, Criterion V.
Step 3.1.1 of Procedure ADM 02-021 requires that, prior to use,'
a procedure will be verified to ensure that it is the current revision.
Contrary to the above, on Jtine 21, 1985, Surveillance Procedure BrS SE-001, Revision 2,
" Power Range Adjustment to Calorimetric," was performed without having applicable tenporary changes incorporated.
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Mr. R. P. Denise 1008C 85-235 Pep 4 October 18, 1985
Response
a)
% e reason for the violation, if admitted:
Failure to follow procedure.
b)
Corrective steps which have been taken and the results achieved:
Imediately upon discovery, STS SE-001 was rerun incorporating the proper procedure change.
Changes to all procedures utilized by operators are posted in the Shift Supervisor's procedures manual inmediately upon aproval.
Operators-are required to verify that the procedures they use are current and include any tenporary changes by checking them against the Shift Supervisor's procedure manual before use.
The individual that failed to follow the procedure in this event was counseled on the inportance of following procedures and use of current tenporary changes.
Additionally, the Superintendent of Operations sent a memo to all Operations personnel enphasizing the requirement.
c)
Corrective steps which will be taken to avoid further violations:
ne cover sheet that is utilized with surveillance procedures has been revised to include verification that all outstanding changes are incorporated in the procedure.
This verification is done by the person performing the surveillance prior to the Shift Supervisor granting approval to conuence the surveillance.
d)
The date when full coupliance will be achieved:
Full conpliance has been achieved.
Please contact me or Mr. Otto Maynard of my staff if you have any questions concerning this response.
Yours Very Truly, S/
Glenn L. Koester Vice President - Nuclear GU(tsee xctPO'Connor (2)
JCunnins JPaylor