ML20212E815
| ML20212E815 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 12/30/1986 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Koester G KANSAS GAS & ELECTRIC CO. |
| References | |
| NUDOCS 8701050470 | |
| Download: ML20212E815 (2) | |
See also: IR 05000482/1986022
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OE0 3 01986
In Reply Refer To:
Docket: STN 50-482/86-22'
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Kansas Gas and Electric-Company
ATTN: Glenn L. Koester
Vice President - Nuclear
P. O. Box 208
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Wichita, Kansas
67201
Gentlemen:
Thank you for your letter of December 4,1986, in response-to our letter
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and Notice of Violation dated November 4, 1986. We have, reviewed your reply
and find it responsive to the concerns raised in our' Notice of Violation. We
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will review the implementation of your corrective actions during a future
inspection to determine that full compliance has been achieved and wil1 be~
maintained.
Sincerely,
Stned 'by:
'O'
W
N. E. HALL"
[J.E.Gagliardo, Chief
a Reactor Projects Branch
cc:
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Kansas Gas and Electric Company
ATTN: Otto Maynard, Manager
of Licensing
P. O. Box 309 (Sharp Road)
Burlington, Kansas
66839
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Forrest Rhodes, Plant Superintendent
Wolf Creek Generating Station
P. O. Box 309
Burlington, Kansas
66839
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Kansas Radiation Control Program Director
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DISTRIBUTION
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R. D. Martin, RA
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DRSP
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KANSAS GAS AND ELECTRIC COMPANY
4
T>4 ELECTRC COMPANY
eLENN L MOESTER
December 4, 1986
" ' " " * ' ' ' * * " " "
DM@EDW2 %
Mr. E. H. Johnson, Director
Division of Reactor Safety and Projects
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DECl6 m
U. S. Nuclear Regulatory Commission
Region IV
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611 Ryan Plaza Drive, Suite 1000
Arlington, Texas 76011
KMLNRC 86-228
Re:
Docket No. STN 50-482
Subj:
Response to Inspection Report STN 50-482/86-22
Dear Mr. Johnson:
This letter is written in reponse to your letter of November 4, 1986, which
transmitted Inspection Report STN 50-482/86-22.
As requested,
the
violations (482/8622-01 and 02) 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
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(d) The date when full compliance will be achieved.
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Violation (482/8622-01): Technical Specification (TS) Fire Door Blocked
Open
Finding:
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Wolf Creek Generating Station (WCGS) TS 3.7.11
requires,
in part,
"All
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sealing devices in fire-rated assembly penetrations (fire doors,
.)
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shall be operable" and "With or a or more of the above required fire barrier
penetrations inoperable, within one hour establish a continuous fire watch .
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or verify the opersbility of fire detectors .
and establish an
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201 N. Market - Wichtta, Kansas - Maol Address: PO. Bcx 208 i Wichits, Kansas 67201 - Telephone: Area Code (316) 261-6451
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Mr. E. H. Johnson
December 4, 1986
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KMLNRC 36f228
Page 2
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Contrary to the above, on September 25,
1986, the NRC inspector observed
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Fire Door 15031 blocked open without the required continuous or hourly fire
P
waten being established.
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Reason For Violation If Admitted:
It was determined that contractor personnel had opened the door previously
during the night to provide additional ventilation in the Containment Purge
Exhaust and Mechanical Equipment Room.
These personnel were replacing the
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charcoal in the Auxiliary / Fuel Building Normal Exhaust Filter Adsorber Unit
FGLO2.
At approximately 0200 CDT,
the hose being used in pumping the
.
a
charcoal into the unit had separated at a splice location, resulting in a
considerable amount of charcoal dust.
An individual had been holding the
door open for air flow while the area was being cleaned.
It is believed
that these personnel neglected to ensure that the door had properly closed
when they left the area between 0700 and 0730 CDT for a shift turnover,
corrective Steps Which Have Been Taken and Results Achieved:
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These, personnel and their foremen have been reminded of the importance of
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maintaining fire barriers and of the necessity for promptly contacting the
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Control Room anytime the function of a fire barrier is jeopardized.
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Corrective Steps Which Will Be Taken To Avoid Further Violations:
All Technical Specification fire doors in the plant have been specifically
posted as such to assist personnel in determining the necessity for
contacting the Control Room prior to blocking open.
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Be Date When Full Compliance Will Be Achieved:
Full compliance has been achieved.
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Violation (482/8622-02): Failure To Control Documents Marked As Safeguards
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Information
Finding:
Technical Specif'ication (TS) 6.8.1 requires that, " Written procedures shall
be established,
implemented,
and maintained covering .
a.
The
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applicable procedures recommended in Appendix A of Regulatory Guide (RG) 1.33, Revision 2, February 1978."
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Mr. E. H. Johnson
December 4, 1986
KMLNRC 86-228
Page 3
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Section 1 of Appendix A to RG 1.33 states "a.
Security and visitor control"
should be covered by written administrative procedures.
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Wolf Creek Generating Station (WCGS) Administrative Procedure ADM 07-408,
Revision
6,
" Distribution and Control Of Safeguards Information," has been
established and implemented in accordance with the above TS.
Step 5.2.1.5 of ADM 07-408 states,
in part, "Each document containing SI,
that is not an original will have a copy number stamped in red ink on the
front page."
Step 5.3 1 of ADM 07-408 states, "While in use, documents containing SI will
be attended by personnel authorized as per section 4.1."
Step 6.9.1 of ADM 07-408 states,
in part, " Documents originally containing
SI shall be removed from the safeguards information category whenever the
information no longer meets the criteria . . . ."
Contrary to the above, on October 3,
1986, the NRC inspector reviewed the
agenda for Plant Safety Review Committee (PSRC) Meeting No. 234 and observed
that attachment 82 "TM0 86-SE-126" was marked " safeguards information".
Further inspection revealed that the information contained in the 5 pages of
attachment 82 were not actually SI but had been labeled that way in error.
Since the material was classified and labeled as SI the requirements of ADM
07-408, noted above, should have been complied with.
!
Reason For Violation If Admitted:
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Results Engineering sent Temporary Modification
Order
(TMO)
Safety
Evaluation "TM0 86-SE-126" to the Plant Safety Review Committee (PSRC)
clerks for vaulting as a record in the Quality Assurance Records Room.
Normally, as in the past, the PSRC Serial Review sheet and safety evaluation
are not safeguards and are therefore not stamped as such.
The P3RC clerk
did not notice the safeguards stamp and added the TM0 safety evaluation to
the PSRC Meeting No. 234 agenda as attachment No. 82.
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Corrective Steps Which Have Been Taken And Results Achieved:
Immediately upon notification by the NRC Resident Inspector of the error,
the PSRC clerk ensured that all copies of attachment No.
82 containing a
copy of TM0 86-SE-126 were destroyed.
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The PSRC clerks have been counseled on the importance of attention to detail
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regarding the distribution of documents stamped as safeguards. Additionally
TMO 86-SE-126.was declassified as it did not contain safeguards information.
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Mr. E. H. Johnson
December 4,
1986
i3t
KMLNRC 86-228
Page 4
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Corrective Steps Which Will Be Taken To Avoid Further Violations:
There have been no previous or similar known occurrences of this nature by
the PSRC clerks since this occurred.
No further additional corrective steps
are required.
The Date When Full Compliance Will Be Achieved:
Full compliance lhas been achieved.
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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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a
Very truly yours,
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4.
[
Glenn L. Koester
Vice President - Nuclear
GLK:see
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