ML20204H333
| ML20204H333 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 07/31/1986 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| KMLNRC-86-136, NUDOCS 8608080083 | |
| Download: ML20204H333 (5) | |
Text
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KANSAS GAS AND ELECTRIC COMPANY THE ELECTRIC COMPANY GLENN L MOESTER July 31, 1986
= === ~o= = *a Mr. E. H. Johnson, Director
]3 Division of Reactor Safety and Projects
~- -
U.S. Nuclear Regulatory Commission i
M-4%
Region IV 1
611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 d
KMLNRC 86-136 Re:
Docket No. STN 50-482 Subj:
Response to Inspection Report STN 50-482/86-13
Dear Mr. Johnson:
This letter is written in response to your letter of July 2,
- 1986, which transmitted Inspection Report STN 50-482/86-13.
As requested, the violations (482/8613-01, 02,
- 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 compliance will be achieved.
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I Violation (482/8613-01):
Failure to Properly Document a Completed Portion of a Surveillance Test l
Finding:
i Technical Specification (TS) 6.8.1 requires that,
" Written procedures shall l
be established, implemented, and maintained covering.
a.
The I
applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978."
Section 8 of Appendix A to Regulatory Guide 1.33 states that,
" Procedures for control of measuring and test equipment and for surveillance tests, procedures, and calibration," should be covered by written procedures.
8608080083 860731 g
DR ADOCK 05000482 h
g/ 4 g
PDR iC2-?C 201 N. Market ~ Wichita, Kansas - Mail Address: RO. Box 208 i Nchita, Kansas 67201 - Telephone: Area Code (316) 261-6451
Mr. E. H. Johnson July 31, 1986 KMLNRC 86-136 Page 2 Surveillance Procedure, STS EJ-202, Revision 0, "RPR System Inservice Valve Test," has been established and implemented in accordance with the above TS.
Contrary to the above, on May 16, 1986, the NRC inspector reviewed STS EJ-202, Revision 0, "RHR System Inservice Valve Test," after Valve EJ HV-8809B had been tested and obse ved that both the test performer and the second person witness had failed to properly implement this procedure in that they had signed off Steps 5.1.2, 5.1.3, and 5.1.4 (which documents testing of Valve EJ HV-8809A) rather than Steps 5.1.6, 5.1.7, 5.1.8, and 5.1.9 which were designated and required for documenting the testing of Valve EJ HV-88098.
Reason For Violation If Admitted:
The individuals who performed Surveillance Test Procedure STS EJ-202, Revision 0,
"RHR System Inservice Valve Test" for Valve EJ HV-8809B signed off the incorrect steps for the "A" train valve due to lack of attention to detail to documentation.
The individuals were aware of which valve was being tested.
Corrective Steps Which Have Been Taken and Results Achieved:
Upon being informed of the incorrect surveillance test steps being signed off, the correct steps were signed off.
The individuals responsible were counseled on attentiveness to detail and the importance of ensuring proper steps are documented.
Corrective Steps Which Will Be Taken To Avoid Further Violations:
i A copy of the violation and this response will be placed in Operations Required Reading to ensure operations personnel are aware of the importance of properly documenting the completion of the correct procedural steps at i
the time of performance.
The Date When Full Compliance Will Be Achieved:
Full Compliance will be achieved by August 15, 1986.
Violation (482/8613-02):
Data was not Recorded on a Work Request as Required by Procedure Finding:
Data was not Pecorded on a Work Request as Required by Procedure TS 6.8.1 requires that,
" Written procedures shall be established, implemented, and maintained covering.
a.
The applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978."
i
Mr. E. H. Johnson July 31, 1986 KMLNRC 86-136 Page 3 Administrative Procedure, ADM 01-057, Revision 9,
" Work Request," (WR) has been established and implemented in accordance with the above TS.
Section 3.4.5 requires that the workman perform the required work as specified in Block 18 of the WR.
Contrary to the above, on May 16, 1986, the NRC inspector reviewed completed Work Request (WR) 02222-86 after it had been signed as completed by the shift supervisor (SS) and detersined that the work instructions delineated in Block 18 of the WR had not been adequately implemented in that the limitorque serial number had not been documented in Block 39 of the WR as instructed in Block 18.
Reason For Violation If Admitted:
Wolf Creek Administ;'ative Procedure ADM 01-057, Revision 10, requires that the Shift Supervisor sign Block 31 of the Work Request, (System Restored Block), when the required testing is completed and it's acceptable to return the item to service. This signature is not intended to provide a review for concurrence with Block 18, (Work Instruction), but serves the function of documenting the acceptability of the retest instructions specified in Block 29, (Retest Instructions).
Blocks 32 (Section Review) and 34 (Quality Engineering Review) provide the final acceptance of the work performed per the work instructions.
Wolf Creek Generating Station administration controls, in fact, provide for a final review of the work request to ensure all administrative requirements such as: work instructions are followed, all blanks as required, are filled in, QA/QC requirements have been met, and etc.
This review would have identified the missing serial number on Work Request Number 2222-86.
Therefore, KG&E does not feel this violation is warranted.
Corrective Steps Which Have Been Taken And The Results Achieved:
The limitorque operator serial number was added to the Work Request (number 2222-86) subsequent to the shift supervisor signing Block 31 and prior to the final acceptance of the work request in Blocks 32 and 34.
Corrective Steps Which Will Be Taken To Avoid Further Violations:
No additional corrective steps are required as Section Review (Block 32) and Quality Engineering Review (Block 34) should identify any discrepancies in the work request such as the one identified by this violation.
The Date When Full Compliance Will Be Achieved:
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Full compliance has been achieved.
1
July 31, 1986 Mr. E. H. Johnson KMLNRC 86-136 Page 4 Violation (482/8613-03):
Cardboard Containers Stored in the Auxiliary Building Contrary to Procedure Finding:
TS 6.8.1 requires that,
" Written procedures shall be established, implemented, and maintained covering.
a.
The applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978."
Section 1.1 of Appendix A to Regulatory Guide 1.33 states that activities for the plant fire protection program should be covered by written procedures.
Administrative Procedure, ADM 13-102, Revision 4,
" Control of Combustible Materials," has been established and implemented in accordance with the above TS.
Step 3.1.2 of ADM 13-102 states, in part,
" Storage of all types of combustibles in safety-related areas... shall be prohibited."
Contrary to the above, on May 10, 1986, during a routine plant tour the NRC inspector observed approximately 25 empty, heavy cardboard containers stored on the north end of Elevation 2000' of the auxiliary building.
During a tour on May 13, 1986, the NRC inspector observed that the containers were still at the same location.
The NRC inspector informed the supervising operator (S0) and the SS who had the containers removed.
Reason For Violation If Admitted:
On about May 10, 1986 Building Services personnel were asked to remove approximately 25 empty, boric acid containers from a room on the North end of the Auxiliary Building.
These drums were then moved to the North end of the 2000' elevation and left.
They remained at that location until May 13, 1986.
The reason for this violation is attributed to lack of adequate communication between Operations and Building Services personnel.
Corrective Steps Which Have Been Taken And The Results Achieved:
Upon being informed that the containers were still located at the North end, 2000' elevation of the Auxiliary Building, the Shift Supervisor had the containers removed and properly disposed of.
The incident was discussed with the involved individuals to stress upon them the requirements of Station Administrative Procedure, ADM 13-102,
" Control of Combustible Materials".
Mr. E. H. Jshnron July 31, 1986 KMLNRC 86-136 Page 5 Corrective Steps Which Will Be Taken To Avoid Further Violations:
A copy of this violation and response will be placed in Required Reading for the appropriate groups and the Plant Safety Review Committee to ensure personnel are aware of the importance of adhering to Station Procedures.
The Date When Full Compliance Will Be Achieved:
Full compliance will be achieved by August 15, 1986.
If you have any questions concerning this matter, please contact me or Mr.
O. L. Haynard of my staff.
Very truly yours, Glenn L. Koester Vice President - Nuclear GLK:see cc: P0'Connor JCummins JTaylor i
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