ML20207P253
| ML20207P253 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 12/26/1986 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| KMLNRC-86-245, NUDOCS 8701150309 | |
| Download: ML20207P253 (4) | |
Text
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KANSAS GAS AND ELECTRIC COMPANY THE ELECinC COMPANY C L E % *e L 8t O E S T E ft oc. -...
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December 26, 1986 Mr. E. H. Johnson, Director Division of Reactor Safety and Projects iq q gq l g' - sa M l
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U. S. Nuclear Regulatory Commission
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Region IV 4
E2 9M 611 Ryan Plaza Drive, Suite 1000 l[,
j Arlington, Texas 76011 J ji Jh KMLNRC 86-245 Re:
Docket No. 50-482 Subj:
Response to Inspection Report 50-482/86-24
Dear Mr. Johnoon:
This letter 10 written in reponse to your letter of November 26, 1986, which transmitted Inspection Report STN 50-482/86-24.
As requested, the violations (482/8624-01 and 02) identified in the Inspection Report are being addressed in four parts.
(a) The reason for the violation if admitted; (b) The corrootive oteps which have been taken and the results achieved (o) Corrective steps which will be taken to avoid further violations and (d) The date when full compliance will be achieved.
Violation (482/8624-01):
Pailuro To Control Combuntible Materials In Accordanon With Proceduren Pinding:
Toohnical Spoeification (TS) 6.8.1 requires that,
" Written procodures shall be established, implomontod, and maintained covering.
a.
The applicable procedurea recommended in Appendix A of Regulatory Guide (RG) 1 33, Reviaton 2, February 1978," including activities for the plant fire protection program.
Administrative Procoduro, ADM 13-102, Revision 5,
" Control of Combustible Materials," has boon establinhed to implomont those requiremento.
0701150309 061226 i
l PDR ADOCK 05000402
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201 N. Market ~ Wchts, Kansas - Mail Address: PO. Bow 208 I Nchts, Kansas 67201 - Telsphone Area Code (316) 2616451
s Mr. E. H. Johnson December 26, 1986 KMLNRC 86-245 Page 2 Contrary to these requirements, the NRC inspector observed the following examples of failure to follow ADM 13-102:
1.
Contrary to Step 3 1.2, on October 22,
- 1986, the NRC inspector observed a wooden box (approximately 2.5 ft.X 5 ft.X5 ft.) made out of untreated lumber stored in train "B" engineered safety features (ESP) switohgear room (No. 3301) on the 2000 ft. level of the control building.
2.
Contrary to Step 3 2.1 on October 26,
- 1986, the NRC inspector observed four wooden crates made of untreated lumber stored on the 2047 ft. level of the reactor building. The approximate sizes of the crates were 3 ft.X 3 ft.X 3 ft.
(two orates),
1 ft.X 2 ft.X 2 ft.,
and 1 ft.X 1 ft.X 30ft.
Pour blocks of untreated wood, each approximately 4 in.X 6 in.X 12 in.,
were also observed in the same location.
3 Contrary to Step 531, on October 26,
- 1986, the NRC inspector observed an unattended and unlocked, temporary flammable liquid storage cabinet (containing alcohol and acetone) on the 2051 ft.
level of the reactor building.
Combustible Materials Permit 86-40 which was issued for the storage cabinet stated ".
in looked flammable liquida cabinet."
Reason For Viointion If Admitted:
The untreated wooden box stored in train "B"
engineered safety features (ESP) switohgear room on the 2000 ft level of the Control Building was originally required by the NRC during the startup phase for the protection of breakers removed from the switohgear cabinets for maintenance. Due to an oversight by station personnel it was not recognized to be in non-compliance with station administrative procedures which require the use of non-combustible or fire-retardant material.
The four (4) wooden orates and four (4) blocks of untreated wood observed on the 2047 ft.
level of the reactor building were the protective containers and attendsnt dunnage for various fuel handling tools required for the first refueling outage.
Personnel unloading this equipment failed to obtain a Combustible Materials Permit in nocordance with station administrative procedures.
The unattended and unlooked, temporary flammable liquid storage cabinet on the 2051 ft.
level of the renotor building was a temporary cabinet for support of the first refueling outage.
The Station Pire Protection Coordinator prescribed a looked cabinet on the Combustible Materials Permit in an effort to maintain control over the number of work groups using the cabinet and the amount of flammable materini allowed in the cabinet.
The onbinet was inadvertently left unlocked by one of the work groups who failed to follow the requirements of the Combustible Materials Permit.
- Mr. E. H. J:hn:on December 26, 1986 KMLNRC 86-245 Page 3 Corrective Steps Which Have Been Taken And Results Achieved:
The box was immediately removed from the ESP Switchgear room and will be replaced with a cover constructed of non-combustible or appropriately treated fire retardant material.
The four (4) wooden orates and four (4) blocks observed on the 2047 ft.
level of the reactor building near the equipment hatch were immediately removed.
The unlocked storage cabinet was immediatlely looked and the responsible group reminded of the Combustible Material Permit requirement to look the cabinet.
Additionally management has stressed to the supervisors of all work groups in numerous daily meetings the importance of adhering to the station's administrative controls, minimizing the amount of combustibles taken into the controlled access area, and each work group's responsibility to remove
- packing, containers, etc.,
to appropriate disposal areas prior to leaving the area.
Corrective Steps Which Will Be Taken To Avoid Purther Violations:
Existing administrative procedures are adequate to provide the necessary level of control over combustible materials.
Compliance with the administrative controls will be maintained by increased inspections by the station fire protection specialist.
Additionally, the General Employee Training (GET) segment on Fire Protection will be re-evaluated and any improvements regarding combustible material control will be incorporated, as appropriate.
The Date When Pull Compliance Will Be Achieved:
Pull compliance with the station administrative controle has been achieved.
The GET segment on combustible material control will be re-evaluated and any improvements incorporated by July 1, 1987.
Violation (482/8624-02):
Pailure To look Valves In Accordance With Procedure Pinding:
TS 6.8.1 requires that,
" Written procedures shall be established, and a.
The applicable procedures recommended in maintained covering.
appendix A of RG 1 33, Revision 2, Pobruary 1978," and includes procedures for equipment control (e.g., looking and tagging)".
ADM 02-101, Revision 12,
" Control of Looked Component Status," has been established to imploment those requirements and Section 2.4 of ADM 02-102 i
defines "Looking Device" as any device that prevents a valve, breaker, or componente position from being changed without the devloe first being manipulated (e.g., key operated looks or seals).
Contrary to the above, on October 22, 1986, the NRC inspector observed that the looking devices on Valves KJ-V767A and KJ-V768A required by Checklist A
Mr. E. H. Johnson December 26, 1986 KMLNRC 86-245 Page 4 of CKL KJ-121 were inadequate in that the looking wire on Valve KJ-V767A had slipped off the operating handle and the looking wire for Valve KJ-V768A was so loosely installed that it could be slipped off and on the valve operating handle without disturbing the looking seal.
Reason Por Violation If Admitted:
The wire on the look wire for valve KJ-V767A had parted at the point where the ends were twisted. This was obscured by a piece of electrical tape over the valve hand wheel.
Valve KJ-V768A could only be opened approximately one-quarter (1/4) turn with the look wire in place. This would have alerted an individual that the valve was subject to adminstrative looking controls and that proper authorization is required to reposition the valve.
Corrective Steps Which Have Been Taken And Results Achieved:
Operations personnel verified valves KJ-V767A and KJ-V768A to be in the required (olosed) position.
Administrative procedure ADM 02-102,
" Locked Component Status" provides administrative controls of looked components.
ADM 02-102 was revised by Temporary Procedure Change MI 86-281 to clarify the requirements for independent verification of the looking device to ensure it is adequately attached and to provide the proper control per the definition of a 'looking device' in ADM 02-102.
In addition, Temporary Procedure Change MI 86-246 to ADM 02-102 was made, which requires the looked valve, breaker and component lists to be verified by a physical verification performed independently by two operators prior to plant heatup above 200 Degrees Fahrenheit, when the plant has been in Mode 5 or 6 for an extended period of time.
Corrective Steps Which Will Be Taken To Avoid Purther Violations:
No further corrective steps in addition to those identified above which have been taken are required.
The Date When Pull Compliance Will Be Achieved Pull compliance has been achieved.
TP you have any questions concerning this matter, please contact me or Mr.
O. L. Maynard of my staff.
Yours very truly, Y
/
4
'L, Glenn L.
cester Vice President - N clear GLK:see con P0'Connor (2)
JCummins JTaylor
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