ML20205N359
| ML20205N359 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 02/21/1986 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20205N348 | List: |
| References | |
| KMLNRC-86-032, KMLNRC-86-32, NUDOCS 8605020102 | |
| Download: ML20205N359 (3) | |
Text
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KANSAS GAS AND ELECTRIC COMPANY THE ELECTFRC COMPANY GLENN L MOEstER WICE ##S S.DE% f - NUCLE AR February 21, 1986 F
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Mr. E. H. Johnson, Director Division of Reactor Safety and Projects
@ 2 ~[ g U.S. Nuclear Regulatory Commission d.,l I -
L Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 KMLNRC 86-032 Re:
Docket No. STN 50-482 Subj :
Response to Notice of Violation 50-482/85-38
Dear Mr. Johnson:
This letter is written in response to your letter of January 29, 1986, which transmitted Inspection Report STN 50-482/85-38. As requested, the violation (482/8538-01) identified in the Inspection Report is being addressed in four parts.
a)
The reason for the violation if admitted b)
Tne corrective steps which have been taken and the results achieved; c)
Corrective steps which will be taken to aovid further violations; and d)
The date when full compliance will be achieved.
1.
Violation:
(482/8538-01) Failure to Establish Procedures For Certain Activities That Could Affect The Performance Of Safety-Related Equipment Technical Specification 6.8.1 requires that, " Written procedures shall a.
The be established, implemented, and maintained covering.
applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978."
Section 9.a, Appendix A of Regulatory Guide 1.33, Revision 2, February 1978 states
- that,
" Maintenance that can affect the performance of safety-related equipmenc should be properly preplanned in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances."
~ A3h 8605020102 860418 b
PDR ADOCK 05000482 O
PDR 201 N. Market -Wictuta, Kansas - Mail Address: PO Box 208 I Wochtta, Kansas 67201 - Tele %ne: Area Code (316) 26 t 6451
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Mr. E. H. Johnson KMLNRC 86-032 Page 2 February 21, 1986 Contrary to the above, the NRC inspectors oberved the following maintenance-related conditions that could have affected the performance of safety-related equipment, but no procedures had been established to cover the situation.
On December 23, 1985, a stepladder (approximately 6' long) was observed that had been abandoned above the control room suspended ceiling.
The ladder could have fallen on operators and/or safety-related components.
On December 12, 1985, an unattended stepladder (approximately 6" long) was observed on a catwalk approximately 30' above emergency diesel generator 'B'.
The ladder could have fallen and damaged components of the emergency diesel generator system.
On December 12, 1985, an extension ladder (approximately 12' long) was observed being supported by safety-related conduit 3J1025.
The conduit is located on the 2000* level in the northeast corner of the auxiliary building.
On December 18,
- 1985, an extension ladder (approximately 12' long) was observed being supported by residual heat removal (RHR) system piping in the RHR heat exchanger room
'A' on the 2000' level of the auxiliary building.
Improperly secured ladders above seismically qualified components presents unanalyzed conditions if a postulated Safe Shutdown Earthquake (SSE) should occur.
Numerous equipment hoists mounted on monorails over the top of safety-related equipment were observed with the lifting hooks hanging in a lowered position where they could possibly strike and damage safety-related equipment (i.e.,
valves, pumps).
On December 12, 1985, the NRC inspectors observed hoist lifting hooks hanging in the lowered position adjacent to the following safety-related equipment:
Main Steam Isolation Valves AB HV-11, AB HV-1/ and AB HV-17 Coolant Charging Pump
'A' Safety Injection Pump
'A' Reason for the Violation If Admitted The procedure that controls the placing of ladders or hoist hooks during and after use was not detailed enough to avoid these problems.
A permanent storage location for ladders had not been ide tified.
.m ot
- Mr. E. H. Johnson KMLNRC 86-032.
Page 3 February 21, 1986 Corrective Steps Which Have Been Taken And The Results Achieved All' ladders identified in the inspection report have been removed Land all hoists have been properly positioned.
The plant has been inspected by management and operations to identify and correct any similar problems. A letter has been sent to all Operators instructing them on what to look for in their housekeeping inspections.
The list includes storage of ladders and hoist hook positioning.
A temporary change has been processed to Administrative procedure ADM 01-034.
" Housekeeping and Cleanliness Control", to control the placement and storage of ladders and hoist hooks.
Corrective Steps Which Will Be Taken To Avoid Further Violation Adainistrative Procedere ADM 01-034,
" Housekeeping and Cleanliness Control",
will be permanently revised to reflect the temporary change.
Permanent storage locations for the ladders will be identified. Permanent storage brackets and signs will be. installed at the designated storage locations.. Plant personnel will be trained on proper placement and storage of ladders and hoist hooks.
Date When Full Coupliance Will Be Achieved Full compliance will be achieved by May 1, 1986.
If you have any questions concerning this matter, please contact me or Mr.
0.L. Maynard of my staff.
Yours very truly, Glenn L. Koester Vice President - Nuclear GLK:see cct P0'Connor (2)
JCummins JTaylor