ML20212K049

Ack Receipt of Re Notice of Violation . Implementation of Corrective Actions Will Be Reviewed During Future Insps

ML20212K049
Person / Time
Site:	Wolf Creek
Issue date:	01/16/1987
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Withers B WOLF CREEK NUCLEAR OPERATING CORP.
References
NUDOCS 8701280452
Download: ML20212K049 (2)

Text

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JAN 101987 In Reply Refer To:

Docket: STN 50-482/86-24 Wolf Creek Nuclear Operating Corporation ATTN: Bart D. Withers President and Chief Executive Officer P. O. Box 411 q Burlington, Kansas 66839  ;

Gentlemen:

Thank you for your letter of December 26, 1986, in response to our letter and Notice of Violation dated November 26, 1986. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.

l Sincerely, i crtk.i Ctmed Cy J. E. Gar l.!ardo J. E. Gagliardo, Chief f

, Reactor Projects Branch

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l Wolf Creek Nuclear Operating Corporation i ATTN: Otto Maynard, Manager i

of Licensing P. O. Box 411 Burlington, Kansas 66839 Gary Boyer, Plant Manager Wolf Creek Nuclear Operating Corporation P. O. Box 411 Burlington, Kansas 66839 Forrest Rhodes, Vice President, Nuclear Operations Wolf Creek Nuclear Operating Corporation P. O. Box 411 Burlington, Kansas 66839 Kansas Radiation Control Program Director bec: (seenextpage)

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December 26, 1986 Mr. E. H. Johnson, Director [ i ' .

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Division of Reactor Safety and Projects 'ii',,b ' ' w f l-l1/ g; U. S. Nuclear Regulatory Commission e' Region IV 611 Ryan Plaza Drive, Suite 1000 g g g g ;. q Arlington, Texas 76011 ,

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. , , _ . . . _ . , d'h KMLNBC 86-245 - - -

Re Docket No. 50-482 Subj: Response to Inspection Report 50-482/86-24

Dear Mr. Johnson:

This letter is 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 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 (482/8624-01): Pailure To Control Combustible Materiale In Accordance With Procedures Pinding:

Technical Specification (TS) 6.8.1 requires that, " Written procedures shall be established, implemented, and maintained covering . . . a. The applicable procedures recommended in Appendir A of Regulatory Guide (RG) 1 33, Revision 2, February 1978," including activities for the plant fire protection program.

Administrative Procedure, ADM 13-102, Revision 5, " Control of combustible Materials," has been established to implement those requirements.

I J g, 201 N Mathet - Wctuta, Kansas - Mad Address: PO Bos 200 i Wchots, Kansas 67209 - Telephone: Area Code (316) 2616431

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• 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) switchgear 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 orates 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 1 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 cabinot stated ". . . in looked

{ flammable liquids cabinet."

Reason For Violation 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 switchgear 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-i 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 attendant dunnage for various fuel handling tools required for the first refueling outage. Personnel unloading this equipment failed to obtain a Combustible Materials Permit in accordance with station administrative procedures.

The unattended and unlooked, temporary flammable liquid storage cabinet on the 2051 ft. level of the reactor building was a temporary cabinet for l support of the first refueling outage. The Station Fire Protection Coordinator prescribed a looked cabinet on the Comkustible Materials Permit in an effort to maintain control over the number of work groups using the cabinet and the amount of flammable material allowed in the cabinet. The cabinet was inadvertently lef t unlooked by one of the work groups who failed 1

to follow the requirements of the Combustible Materials Permit.

an ..

Mr. E. H. Johnson D:crtber 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-combus tible 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 locked 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 (CET) 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:

Full compliance with the station administrative controls has been achieved.

The OET segment on combustible material control will be re-evaluated and any improvements incorporated by July 1,1987.

Violation (482/8624-02): Pailure To Lock Valves In Accordance With Procedure Pinding:

TS 6.8.1 requires that, " Written procedures shall be established, and maintained covering . . . a. The applicable procedures recommended in appendix A of R01 33, Revision 2, February 1978," and includes procedures for equipment control (e.g., looking and tagging)".

ADM 02-101, Revision 12, " Control of Looked Component Status," han been established to implement these requiromonto and Section 2.4 of ADM 02-102

defines "Looking Device" ao any device that prevento a valvo, breaker, or componente position from being changed without the device first being i manipulated (e.g., key operated looks or nealo).

Contrary to the above, on October 22, 1986, the NRC inspector observed that the looking devioen on Valveo KJ-V767A and KJ-V768A required by Checklist A

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Mr. E. H. Johnson December 26, 1986 KMLNRC 86-245 Page 4 1 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 locking seal.

Reason For Violation If Admitted:

The wire on the lock wire for valve KJ-V767A had parted at the point where the ends were twisted. %is 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 lock wire in place. This would have alerted an individual that the valve was sub, ject to adminstrative locking controls and that proper authorization is required te 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 (closed) position. Administrative procedure ADM 02-102, " Locked Component Status" provides administrative controls of locked components.

ADM 02-102 was revised by Temporary Procedure Change MI 86-281 to clarify the requiroments for independent verification of the looking device to ensure it is adequately attached and to provide the proper control per the definition of a ' locking device' in ADM 02-102. In addition, Temporary Procedure Change MI 86-246 to ADM 02-102 was made, which requires the locked 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 Further Violations:

No further corrective steps in addition to those identified above which have been taken are required.

The Date When Full Compliance Will Be Achieved:

Full compliance has been achieved.

If you have any questions concerning this matter, please contact me or Mr.

O. L. Maynard of my staff.

Yours very truly, Glenn L. ester i Vice President - N clear GLK see cc P0'Connor (2) ,

JCummins JTaylor

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