ML20210C259
| ML20210C259 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 09/16/1986 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Koester G KANSAS GAS & ELECTRIC CO. |
| References | |
| NUDOCS 8609180297 | |
| Download: ML20210C259 (2) | |
See also: IR 05000482/1986008
Text
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SEP 101986
In Reply Refer To:
Docket: STN 50-482/86-08
Kansas Gas and Electric Company
ATTN: Glenn L. Koester
Vice President - Nuclear
P. O. Box 208
Wichita, Kansas 67201
Gentlemen:
Thank you for your letter of July 3,1986, in response to our letter and the
attached Notice of Violation dated July 2, 1986. As a result of our review, we
find that additional infonnation, as discussed with your Mr. O. L. Maynard,
is needed. Specifically, your response regarding Violation 482/8608-02 should
also address the reasons why the inadequate fire barriers were not recognized
by management and corrective' actions taken in a timely menner. Additionally,
your response to Violation 482/8608-03 should include whether current
surveillance procedures, drawings, and inservice inspection programs include
adequate programatic controls to ensure that the analyzed requirements will be
met.
Please provide the supplemental infonnation within 30 days of the date of this
letter.
Sincerely.
Original Signed By
J. E. Gagliardo
J. E. Gagliardo, Chief
Reactor Projects Branch
cc:
Kansas Gas and Electric Company
ATTN: Otto Maynard, Manager
of Licensing
.
P. O. Box 309 (Sharp Road)
Burlington, Kansas 66839
Forrest Rhodes, Plant Superintendent
Wolf Creek Generating Station
8609180297 860?16
P. O. Box 309
ADOCK 05000482
Burlington, Kansas
66839
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KMLNRC S6-137
Re:
Docket No. STN 50-482
Subj:
Response to Inspection Report STN 50-482/86-08
Dear Mr. Johnson:
This letter
is written in reponse to your letter of July 2,
1986, which
transmitted Inspection Report STN 50-482/86-08.
As requested,
the
violations (482/8608-01,
02,
03) identified in the Inspection Report are
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.
.
Violation (482/8608-01):
Failure To Verify Correct Revision of
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a Surveillance Procedure Prior To Use
!
Finding:
Wolf Creek Generating Station (WCGS) 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, Februrary 1978."
Section 8.b.
of Appendix A to Regulatory Guide 1.33 specifies that specific
procedures for surveillance tests,
inspections, and calibrations are to be
provided.
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Mr. E. H. Johnson
July 31, 1986
KMLNRC 86-137
Page:2
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1
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Plant Administrative Procedure (ADM)02-300,
Revision 6
" Surveillance
Testing," has been established and implemented in accordance with these
requirements.
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t
Step
5.4.1.6
states,
" Verifying prior to its use that a procedure is the
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current revision . .
He will document this review on the surveillance
.
.
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test routing sheet (STRS) . . . ."
1
Contrary to the above, on April 8, 1986, operations personnel performed and
the shift supervisor. signed off as complete, STS RE-004, " Shutdown Margin
Determination," without first verifying and documenting that,the procedure
being used was the correct revision and/or that temporary changes were
current.
)
Reason For Violation If Adaitted:
,
The individual who. initiated surveillace procedure STS RE-004,
" Shutdown
Margin Determination" failed to follow the administrative requirements of
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ADM 02-300, Revision 6, " Surveillance Testing."
Corrective Steps Which Have Been Taken and Results Achieved
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Upon notification of the failure to verify and document that the procedure
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being used was the correct revision and that any temporary changes were
current,
the Shift Supervisor performed the required verification and
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documentation. The procedure was verified to be the current revision and no
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other descrepancies were noted.
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The failure to follow this procedure was discussed with the responsible
individuals,
stressing the importance of
following
procedures
and
verification of current revisions and temporary changes,
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Corrective Steps Which Will Be Taken To Avoid Further Violations:
A copy of the violation and this response will be placed in Operations.
Required Reading program to ensure operations personnel are cognizant of the
procedural requirements and importance of verifying a surveillance procedure
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to be the current revision and that any temporary changes are current.
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The Date When Full Compliance Will Be Achieved:
Full compliance will be achieved by August 15, 1986.
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Mr. E. H. Johnson
July 31, 1986
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KMLNRC 86-137
Page 3
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Violation (482/8608-02): Failure To Maintain Auxiliary Buildins
Buttress Penetrations In Accordance With
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Fire Hazards Analysis
Finding:
WCGS TS 3.7.11 requires, in part, that, "All fire barrier penetrations . . .
separating safety-related fire areas . . . shall be operable.'
I
Contrary to the above, on April 7,
1986,
it was determined that the floor
penetration covers on either side of 'C' containment tendon buttress on
Elevations 2047' and 2026' were not 3-hour fire barriera and were outside
the design basis as specified by the fire hazards analysis.
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Reason For Violation If Admitted:
.
The covers of the openings were installed in accordance with the original
design which was inadequate to maintain the three-hour fire rating.
Gas & Electric Company (KG&E) was notified of the necessity of adding
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fireproofing to the existing covers by the Architect / Engineer in June of
1985.
Shortly after this notification, a Plant Modification Request was
initiated to add the required fireproofing, but during the initial review of
!
this information,
the Fire Hazards Analysis
impact
and
Technical
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Specification
applicability
of
this situation were not recognized.
Consequently, the Plant Modification Request was assigned a relatively low
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priority, and had not yet been implemented.
This occurrence was the result of a deficiency in the original design, and
the failure to install the required fireproofing is attributed to a
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personnel error. A contributing factor may have been that the personnel who
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reviewed the information were not completely familiar with all Technical
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Specification requirements in June of 1985.
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Corrective Steps Which Have Been Taken and Results Achieved:
Upon discovery of the unsatisfactory condition, hourly fire watch patrols
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were established and have been maintained in accordance with Technical
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Specifications.
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Corrective Steps Which Will Be Taken To Avoid Further Violations:
The Plant Modification Request
(PMR)
for installation of the missing
fireproofing has been processed for implementation and the material is on
order. Estimated date of material receipt is August 29, 1986. Upon receipt
of the required fireproofing material, the PMR will be implemented and will
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require one to two weeks to complete.
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Mr. E. H. Johnson
July 31, 1986
KMLNRC 86-137
Page 4
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Since June of 1985,
the PMR process has been substantially revised,
including a provision for appropriate supervisory personnel to assist in the
determination ~ of Technical Specification applicability of proposed design
changes.
In addition, personnel have gained familiarity with Technical
Specification and Final Safety Analysis Report requirements.
The Date When Full Compliance Will Be Achieved:
.
Technical Specification compliance has been achieved
in
that
fire
impairments identify the requirement for an hourly fir'e watch in the
affected areas. These fire watches have been implemented.
Full compliance
to the design specifications will be completed by November 15, 1986 based on
a material receipt date of August 29, 1986.
Violation (482/8608-03): Failure To Adequately Perform TS
Surveillance Requirement
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Findings
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WCGS TS 4.0.5 requires, in part, that, " Inservice inspection of ASME Code
Class 1, 2, and 3 components and inservice testing of ASME Code Class 1,
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and 3 pumps and valves shall be performed in accordance with Section XI
f
,
the ASME Boiler and Pressure Code . . . except where specific written relief
has been granted . . . ."
ASME Section XI, Division 1, 1980 Edition, Subsection IWV, states, in part,
"If a valve . .
exceeds its specified limiting value of full-stroke time
.
by this testing, then corrective action shall be initiated immediately.
If
the condition is not, or cannot be,
corrected within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the valve
shall be declared inoperative."
Contrary to the above, on March 5,
1986, the open limit switches to valves
AL HV-032 and AL HV-033 (essential service water to turbine driven auxiliary
feedwater pump) were adjusted in the closed direction in order to meet the
stroke time requirement of 15 seconds, however, this action reduced the
stroke travel of the valve so that it no longer fulfilled the full-stroke
provisions of ASME Section XI.
Thus, the valve did not meet its full-stroke
time.
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Reason For Violation If Admitted:
Following failure of the valves to meet their required fifteen (15) second
stroke time, a work request was written to investigate and correct the
problem.
The personnel performing the maintenance activity incorrectly
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ahortened the stroke of the valves following technical manual and schematic
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instructions.
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Mr. E. H. Johnson
July 31, 1986
KMLNRC 86-137
Page 5
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Corrective Steps Which Have Been Taken and Results Achieved:
Following an engineering evaluation of the occurrence, the valves were
readjusted to full open, less a slight amount for valve coast.
The
engineering evaluation verified that at no time was flow decreased below
that required to meet the safety analysis.
The valves stroke time was
reevaluated and
increased as the previously established stroke time of
fifteen (15) seconds was very conservative.
s
Corrective Steps Which Will Be Taken To Avoid Further Violations:
A review has been performed for all other valves with stroke times in the
Section XI valve program to identify any that may have had their stroke
limits adjusted. No further instances of limit switch adjustment to satisfy
valve stroke times were identified.
In addition,
personnel performing
maintenance activities in the Section XI valve program will be advised that
stroke lengths cannot be shortened in order to satisfy valve stroke times
without a proper evaluation.
.
The Date When Full Compliance Will Be Achieved:
Full compliance will be schieved by September 1,1986.
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If you have any questions concerning this matter, please contact me or Mr.
O. L. Maynard of my staff.
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Very truly yours,
j
Glenn L. Koester
Vice President - Nuclear
GLK:see
cc P0'Connor (2)
JCummins
JTaylor
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