ML20198J100
| ML20198J100 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 12/20/1985 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20198J004 | List: |
| References | |
| KMLNRC-85-277, NUDOCS 8601310200 | |
| Download: ML20198J100 (4) | |
Text
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KANSAS GAS ANI) ELECTRIC COMPANY TM EL.ECT WC CLPA*ANY I
OLENN L EOESTER m m...w.,
Decerabe r 20, 1985 Mr. C.II. Johnson, Acting Director l
Division of Reactor Safety and Projects
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U.S. Nuclear Regulatory Commission Region IV l
j 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 KMLNRC 85-277 REF:
Docket No. STN 50-482 SUBJ Response to inspection Report STN 50-482/85-41
Dear Sir:
Thin letter is written in reponse to your letter of November 29, 1985, which trannmitted Inspection Report STN 50-482/85-41. As requested, the violations (482/8541-01 and 02) identified in the Inspection Report are being addressed in four parts.
(a) The reason for tne violations if admitted; (b) The corrective steps which have been taken and the results achieved; (c) Corrective steps wtich will be taken to avoid further violations; and (d) The date when full complian:e will t'c achieved.
1.
Violation:
(482/854_t-01) Vi-lation of Technical Specification -
Fire Suppression System Surveillanco Finding:
Technical Specification (TS) 4.7.10.2.a requires that the water spray fire supprension system for ESP transformers XNB01 and XNB02 be demonstrated operabic at 1 cast once per 31 days by verifying that each valve in the flow path is in its correct position.
Contrary to the nbove, Surveillance Test Procednre STS FP-005, Revision 0,
" Monthly Sprays / Sprinkler Valvo t'osition Ve rifica1 ton,"
does not require an incpection of thene two ESF transformer water spray systeins. Thus, the required TS monthly surveillances have not been performed.
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'Mr. E.M. Johnson KMLNRC 85-277 Page 2 December 20, 1985 Reason for Violation if Admitted:
STS FF-005 was draf ted by using a preliminary copy of the Technical f
Specifications and approved on October 11, 1984.
The preliminary copy that was being used did not include the ESF transformers under T.S.
3.7.10 2.c, The ESF transformers were not designed as Safety Related components because the Class IE busses they feed are protected by the Standby Diesel Generators.
When the ESF transformera were added to T.S.
3.7.IO.2.c in Deccaber,
Corrective Steps Which Have Been Taken and Results Achieved; i
l The valves associated with the water spray fire suppression system for the ESF transformers were added to STS FP-005 by Temporary Change 85-1753 on October 24, 1985.
During the preparation of this temporary change, the valves were checked by the Shif t Supervisor on l
October 23, 1985, and found to be in their proper position.
They i
were checked by the revised procedure on October 27, 1985.
l On November 19, 1985 a Quality Assurance audit determined that two i
valves in the flow path from the yard firo main to the ESF l
transformer deluge system valves were not being checked at least once j
every 31 days as is required by Technical Specification 4.7.10.1.1.c.
This event is discussed in Licensee Event Report 85-l l
080-00.
One of these two valves has been added to STS FP-005 by l
Temporary Change 85-1753. The other valve was added to STS FP-001 by Temporary Change 85-1839 on November 27, 1985.
The ESF transformer deluge system is electrically supervised such
[
l that any valve misposition would cause a trouble alarm in the Control t
l Room.
No portion of this flow path has been isolated since receipt of the Operating License. There is no reason to believe any of these valves have been out of their required position.
I Corrective Steps Which Will Be Taken to Avoid Further Violationus internal Operations Program Deficiency (10PD)' Number 85-11 was generated to review the Fire Protection Program commitments to ensure i
they are all met by our administrative program.
If the results of our investigation pursuant to 10PD 85-11 identifies any additional discrepancies, they will be corrected and evaluated for reportability.
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Mr. E.H. Johnson KMLNRC 85-277 Page 3 December 20, 1985 l
Permanent changes will be prepared for STS FP-001 and STS FP-005 to l
incorporate the above temporary changes.
Date When Full Comp 1.iance Will Be Achieved:
IOPD 85-11 is scheduled for completion on March 27, 1986.
Fu1L compliance will be achieved by April 30, 1986.
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2.
Viointion:
(842/8541-02) Failure to Follow Surveillance Test l
Procedure for Electric Motor Driven Fire Pump IFP01FA l
10 CFR Part 50, Appendix B, Criterion V, states, in part, " Activities i
affecting quality shall be prescribed by docamented ins t ruction, i
procedures, or drawings... and shall be accomplished in accordance l
with these instruccions, procedures, or drawings... "
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STS PP-602, Revision 3,
" Electric Motor Driven Fire Pump 1FP01PA Monthly Ope ration," requires in Sections 5.2 and 5.3 that the fire pump be started using the switch on the local panel during the monthly tests for January,
- March, May, July, September, and November.
During the alternate months the procedure requires that the pump be started from the control room panel.
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Contrary to the above, the electric motor-driven fire pump was tested i
by starting it from the control panel for May 1985 and from the local panel for June 1985.
Reason for Violation if Admitted:
The STS FP-602 test performer misinterpreted the requirement in May and June, 1985.
The same person was the test performer on both i
dates. May, 1985, was the first time he had been assigned to STS FP-602.
Corrective Steps Which Have Been Taken and Results Achievedt Temporary Change 85-1861 to STS FP-602 was prepared on December 9,
- 1985, to require the Supervising Ope rator or Shift Supervisor i
determine which switch is to be utilized each month to start the i
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Mr. E.H. Johnson KMLNRC 85-277 Page 4 December 20, 1985 Fire pump. This should eliminate the potential for misinterpretation by personnel who have not previously been the test performer for STS FP-602.
Corrective Steps Which Wili Be Taken to Avoid Further Violations:
A permanent revision to STS FP-602 will be prepared to incorporate Temporary Change 85-1861.
Date When Full Compliance Will Be Achieved:
Full compliance will be achieved by January 31, 1986.
If you have any questions concerning this matter, please contact me or Mr.
0.L. Maynard of my staff.
Yours very truly, yh th Al Glenn L. Koester Vice President - Nuclear GLK:see xc: P0' Conner (2)
JCummins JTaylor l
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