ML20141E207

Responds to NRC Re Violations Noted in Insp Rept 50-482/85-30.Corrective Actions:Plug Replaced in Test Port Located on Discharge of Containment Purge Filter.Adsorber Unit FGT0l & Grab Sample of Containment Atmosphere Taken

ML20141E207
Person / Time
Site:	Wolf Creek
Issue date:	11/08/1985
From:	Koester G KANSAS GAS & ELECTRIC CO.
To:	Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20141E197	List: IR 05000482/1985030 ML20141E207
References
KMLNRC-85-253, NUDOCS 8601070637
Download: ML20141E207 (5)

Text

8 KANSAS GAS AND ELECTRIC COMPANY THE ELECTAsC COP.M'ANY OLENN L K O E S T E .7 WICE PRESsDENT - NWCLEAR Novenber 8, 1985 Mr. E.H. Johnson, Acting Director $ b Division of Reactor Safety and Projects i j

U.S. Nuclear Regulatory Comnission Region IV g, g g g i:

i 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 ~

W KMIlmC 85-253 RE: Docket No. STN 50-482 SUBJ: Response to Inspection Report STN 50-482/85-30

Dear Mr. Johnson:

This letter is written in response to your letter of October 9, 1985, which transmitted Inspection Report _STN 50-482/85-30. As requested, the violations (482/8530-01, 02 and 03), identified in the Inspection Report are being addressed in four parts.

(a) The reason for the violations 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 cwpliance will be achietrad.

1. Violations: (482/8530-01) Test Port Not Reclosed in Accordance With Procedure Findino:

10 CFR Parti 50, Appendix B, Criterion V states, in part,

" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings...and shall be accortplished in accordance with these instructions, procedures, or drawings..."

8601070637 851223 PDR ADOCK 05000482 o PDR s - l /

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

Mr. E.H. Johnson KMLNRC 85-253 Page 2 Novenber 8, 1985

'Ihe following are excerpts from plant procedures that have been established in accordance with 10 CFR Part 50, Appendix B, Criterion V:

. Administrative Procedure (ADM) _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 approve all modifications prior to their being

_ inplemented." 1

. ADM 01-057, " Work Request", Revision 7, dated May 13, 1985, l

in Section 2.1 states in part: "The Work Request is intended '

to document and control work activities involving .

safety-related, special scope items, and ..."

. ADM 02-101, "Tenporary Modification", Revision 12, dated May 16, 1985, which in Section 2.1,~ states in part: "It is the i responsibility of the- group leader (or' designee) whose personnel are inplementing a tenporary modificatiDn to ensure i the modification is n - 2y, correct, and to prepare the 10 CFR 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 August 5, 1985, a test port ~ located on the discharge of containment purge filter Adsorber Unit FGr01 was observed to have its plug removed ~without any procedural i requirements in place.

Reason for Violation if Admitted:

! 'Ihe investigation into this violation failed to -determine the

, reason that the plug.was not reinstalled. The last time the plug was known to be removed was during DOP testing in January, 1985.

Corrective Steos Which Have Been Taken and Results Achieved:

i The plug was replaced. All filter adsorber units in the plant were inspected to ensure the. test ports were plugged. In addition other duct work-' test plugs were randomly inspected to ensure the plugs were installed.

l .

1 Corrective Steos Which Will Be Taken to Avoid Further Violationst

A review of the procedures which renove plugs in HVAC test ports was conducted. Where apprg riate, procedures were revised to include reinstalling plugs in the test ports.

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Mr. E.H. Johnson

i. KMLNRC-85-253 Page 3 Novenber 8, 1985 Date When Full Conoliance Will Be Achieved:

j Full coupliance has been achieved.

i

2. Violationi: (482/8530-02) Inadeauate Procedure Findina:

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

" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances...

Surveillance Technical Specification Procedure STS IC-275B, Revision 2, " Analog Channel Operational Test Containment Purge System Radiation Monitor Gf RE-33", has been established in accordance with 10 CPR Part 50, Appendix B, Criterion V.

Contrary to the above, SPS IC-275B, was inappropriate to the circunstances in that during the performance of STS IC-275B, on ally 26, 1985, Danpers GT HZ-4,5,6,7,8,9,11, and 12 were opened or checked open in accordance with Step 5.1.8, and for 40 minutes there was air flow from Containment leaking past closed exhaust . fan discharge danpers, up the stack and to tiwt,outside aluusphere. Technical Specification surveillance requirement No. 4.11.2.1.2 was not' met in that a grab sanple was not _

performed prior to the release. This procedure was inappropriate to the circumstances in that at least one set of isolation danpers should have remained closed and/or a grab sanple should have been performed. Your response to this violation should include the steps you have taken to ensure

similar situations do not occur during the performance of other i

plant procedures.

Reason for Violation if Mmitted

Procedure SfS IC-275 did not provide for obtaining a grab sanple and/or assuring that one set of isolation valves remained closed during the test.

These surveillance procedures were performed during the preoperational test phase, however due to plant conditions the identified problem did not surface. I Corrective Steos Nhich Have h n Taken and Baanlts Achieved:

This event was discovered by the Control' Room personnel. Upon

Mr. E.H. Johnson KMI m C 85-253 Page 4 Novenber 8, 1985 discovery, a grab sample of the Containnent atmosphere was obtained. The sanple results verified that the containment alm 0 sphere u s well below the release limits of Table 4.11-2 of the Technical Specifications.

Additionally, radiation monitor Gr EU-22 was in service throughout the release. The setpoint of this monitor is set in accordance , with the Offsite Dose -Calculation Manual. Had it reached its setpoint, it would have initiated a Containment Purge isolation which would have closed all of the subject dangers.

, Corrective Steos Which Will Be Taken to Avoid Further l Violations:

A review of all procedures which appear to affect conta.inment pirge danpers has been conducted. Where required, obtaining a release permit has been added to these procedures. One result of this review is the elimination of danger movement from Srs IC-275B.

Date Nhen Full Cr=mliance Will Be Achieved:

l

Full Conpliance has been achieved.

j l'

3. Yiolation: (482/8530-03) Flow Orifice Installed Raekwards EiDilina:

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..'."

Drawing 556-32170, Revision ~ 4, ." Outline Drawing Concentric Orifice Plates", shows that orifice plates should be installed i

so the flow enters the orifice plate on the side of the orifice plate stanped " Inlet".

I Contrary to the above, on July 26, 1985, the NRC inspectors observed that Orifice Plates EG FE-83, " Centrifugal Charging Pung 'A' Oil Cooler", and EG FE-89, " Residual Heat Removal Pung Seal Coolers", were installed with the side stanped " Inlet" on the flow outlet side of the orifice plate.

Reason for Violation if Admitted:

een the flow orifice plates were installed at the coupletion of the system flush during the preoperational program, the instructions that were provided did not specify orifice plate orientation and good work practices were not followed.

Mr. E.H. Johnson KMIRRC 85-253 Page 5 Novenber 7, 1985 Corrective Steps Which Have Been Taken and Results Achieved:

All safety related orifice plates were inspected to verify orientation. One additional orifice (EG FE-64) 'was found with I inproper orientation. Orifice plates EG FE-83 and EG FE-89 were reversed on August 7, 1985.

The affect of having the orifices reversed upon the validity of the preoperational flow balance tests was analyzed and determined to be within the allowable tolerences. No retesting is required.

Orifice plate EG FE-64 is a knife edge design which will show~a negligible change on reversal.

Corrective Steos Nhich Will Be Taken to Avoid Further Violations:

Maintenance personnel .have been trained on the proper orientation of crifice plates when they are installed.

Maintenance Engineers that write the work instructions have been trained to specify proper orientation whenever orifice plates are installed.

Quality Engineering (@) personnel who write the work instructions for Quality Control Inspectors for all safety related maintenance work activities have been instructed to verify that work instructions provide adequate detail for proper installation.

Date When Full Conoliance Will Be Achieved:

Reversal of orifice plate EG FE-64. requires the isolation of one train of conponent Cooling Water. This is scheduled for the first refueling outage.

Except for reversing EG FE-64, full coupliance has been achieved.

Please contace me or Mr. Otto Maynard of my staff if you have any questions concerning this response.

Yours Very Truly, 10 M Glenn L. Koester Vice President - Nuclear GIK:see cc: PO'Connor JCunwrdns

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