ML20205N382

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Responds to NRC Re Violations Noted in Insp Rept 50-482/86-01.Corrective Actions:Wire Used to Tie Off Flexible Conduit Removed.Future Work Packages Will Be Reviewed to Verify Temporary Restraint Removal
ML20205N382
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 03/14/1986
From: Koester G
KANSAS GAS & ELECTRIC CO.
To: Johnson E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20205N372 List:
References
KMLNRC-86-046, KMLNRC-86-46, NUDOCS 8605020109
Download: ML20205N382 (2)


Text

{{#Wiki_filter:- KANSAS GAS AND ELECTRIC COMPANY THE ELECTFHC COMPANY March 14, 1986 GLENN L MOESTER vaca passiorser- n actga. i h) Mr. E. H. Johnson, Director j Division of Reactor Safety and Projects g7 U.S. Nuclear Regulatory Commission Region IV t y 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 KMLNRC 86-046 Re: Docket No. STN 50-482 Subj : Response to Notice of Violation 50-482/86-01

Dear Mr. Johnson:

This letter is written in response to your letter of February 12, 1986, which transmitted Inspection Report STN 50-482/86-01. As requested, the violation (482/8601-01) identified in the Inspection Report is 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 compliance will be achieved.

1. Violation: (482/8601-01) Failure To Comply With Licensee's Temporary Modification Procedure Technical Specification 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."

Administrative Procedure (ADM) 02-101, Revision 13 " Temporary Modifications," has been established anel implemented in accordance with the above Technical Specifiction to control temporary modificatione which will alter, modify, bypass, or otherwise change design of av portion of a piping system. Contrary to the above, on January 23, 1986, the NRC inspector observed safety-related Flexible Conduit IJ1EID tied with wire to Essential Service Water System Pipe Hanger 1-EF02-R009/134Q which altered the h- 0-{ g 8605020109 860418 2 DR ADOCK 0500 20e .. . .<am -mcnsta, Kansas -Mail Address: PO. Box 208 I W1chsta, Kansas 67201 - Telephone: Area Code (316) 261-6451

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Mr. E. H. Johnson KMLNRC 86-046 Page 2 March 14, 1986 installation design of both components; however, the controls specified in ADM 02-101, Revision 13, had not been implemented. Reason For Violation If Admitted: The investigation into this violation failed to identify why this flexible conduit was tied of f or the reason the temporary modification procedure was not used. Corrective Steps Which Have Been Taken And Results Achieved: The wire used to tie off the flexible conduit has been removed. A field inspection for occurances similar to this violation has revealed twelve other instances of safety related flexible conduit being tied off. Eight of them had previously been documented and were required to provide separation for fire protection purposes. Two have been documented and resolved. Two items are documented and are being evaluated. Plant operators have been instructed to be alert for equipment being tied off to safety related equipment. Quality Engineering will review future vork packages to identify those activities where a potential exists for conduit, hoses, etc. to be temporarily restrained to facilitate the work effort. Where appropriate, Quality Control will be directed to verify temporary restraint removal upon completion of work. The requirements of the Temporary Modification Procedure were discussed with plant supervisory personnel. Corrective Steps Which Will Be Taken To Avoid Further Violations The corrective steps discussed above will help avoid further violations. In addition, the requirements of the Temporary Modification Procedure will be discussed with plant personnel. Date When Full Compliance Will Be Achieved: Full compliance will be achieved by April 30, 1986. If you have any questions concerning this matter please contact me or Mr. 0,L. Maynard of my staff. Very truly yours, , Glenn L. Koes er Vice President - Nuclear GLK:see cc: P0'Connors (2) JCummings

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