ML20214N643
| ML20214N643 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 11/05/1986 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| KMLNRC-86-206, NUDOCS 8612030709 | |
| Download: ML20214N643 (5) | |
Text
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KANSAS GAS AND ELECTRIC COMPANY THE ELECTRC COMPANY GLENN L KOESTER November 5, 1986
"'"""~~^a TM@M OWM N h:
Mr. E. H. Johnson, Director n o NOV I 3 SPI Division of Reactor Safety and Projects 1
U. S. Nuclear Regulatory Commission ji -
Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 KMLNRC 86-206 Re Docket No. STN 50-482 Subj:
Response to Inspection Report STN 50-482/86-18
Dear Mr. Johnson:
This letter is written in reponse to your letter of October 6, 1986, which transmitted Inspection Report STN 50-482/86-18.
As requested, the violations (482/8618-01 and 02) identified in the Inspection Report are being addressed in four parts.
(a) The reason for the violation if admitted; (b) The corre::tive 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 (482/8618-01): Pailure To Comply With Licensee's Temporary Modification Procedure Pinding:
Technical Specification (TS) 6.8.1 requires that, " Writ' ten procedures shall be established, implemented, and maintained covering.
a.
The applicable procedures recommended in Appendix A of Regulatory Guide (BG) 1,33, Revision 2, February 1978."
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Mr. E. H. Johnson November 5, 1986 KMLNRC 86-206 Page 2 Appendix A of RG 1.33, Revision 2, February 1978, states that "The following safety-related activities.
should be covered by written procedures.. 1.c.
Equipment control (e.g.,
locking and tagging) and "1.d Procedure Adherence and Temporary Change Method."
Administrative Procedure (ADM)02-101, Revision 15,
" Temporary Modifications," has been established and implemented in accordance with the above TS to control temporary modifications to ensure an accurate control of*
station equipment is maintained and to ensure the return of a system to its permanent configuration.
Section 6.1.1.1 of ADM 02-101, Revision 15, May 27, 1986, states that, "The type of temporary modification shall be indicated in the activity to be performed block.
Information to be recorded in Section D and on each temporary modification tag t sculd be as follows:
Lifted lead-cabinet name/ location, terminal block number and terminal number, wire number, and tag number."
Section 6.1.6.1 of ADM 02-101, Revision 15, May 27,
- 1986, states that, "... After the tag (s) are placed, the installer will sign the tag (s),
initial the appropriate space on the temporary modification order, and sign Section B, installed by."
Section 6.1.6.2 of ADM 02-101, Revision 15, May 27, 1986, states
- that, The person performing the independent verification will sign the tag (s),
initial the appropriate space on the temporary modification order, and sign Section B, independent verification by."
ADM 01-001, Revision 12,
" Introduction To Wolf Creek Generating Procedures," has been established and implemented in accordance with the above TS to establish the administrative controla required of various organizations to carry out their assigned responsibilities.
Section 4.2.4 of ADM 01-001, Revision 12, April 1, 1986, states that, "Those participating in any activity shall be -made aware of, and use, proper and current instructions,-procedures, drawings, and engineering requirements for performing the activity as applicable."
Contrary to the above, on August 5,
- 1986, the NRC inspector reviewed Temporary Modification Orders 86-72KC and 86-81r1 The NRC inspector observed that ADM 02-101 had not been followed in that the required
c Mr. E. H. Johnson November 5, 1986 KMLNRC 86-206 Page 3 information for a lifted lead had not been recorded in Section D of Temporary Modification Order 86-81KC, and that Temporary Modification Tag 86-72-KC-01 had been hung but the appropriate space on the temporary modification order was missing initials for tag installation and verification.
The NRC inspector also observed that ADM 01-001 had not been followed in that Temporary Modification Order 86-72KC, prepared on July 10, 1986, used out-of-date ADM 02-101, Revision 14, versus the then current Procedure ADM 02-101, Revision 15, May 27, 1936.
Reason For Violation If Admitted:
The information for the lifted lead that was not recorded in Section "D" of Temporary Modification Order (TMO) 86-81KC and the TM0 Tag 86-72-KC-01 that was hung with the appropriate space on the TM0 missing initials for tag installation and verification were due to failure to follow procedure by station personnel.
TM0 86-72KC being prepared using an out-of-date ADM 02-001 was due to failure to follow procedure by station personnel.
l Corrective Steps Which Have Been Taken and Results Achieved:
TM0 86-81KC, Section
'D' was corrected to include the required information.
TM0 86-72KC was correc'ted to include the initials for tag installation and verification.
Revision 15 to ADM 02-101 did not create any changes to the TM0 forms.
Therefore the information on the out-of-date Revision 14 form was the same as would have been entered on the Revision 15 form.
Management has stressed the importance of attention to detail to the Supervisory personnel in attendance at several of the daily status / schedule meetings.
Corrective Steps Which Will Be Taken To Avoid Further Violations:
A copy of the violation and this response will be placed in Operations, Maintenance, and Instrument & Control Required Reading to ensure personnel are cognizant of the importance of following procedures'.
The Date When Full Compliance Will Be Achiet ed:
Full compliance will be achieved by November 30, 1986.
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Mr. E. H. Johnson November 5, 1986 KMLNRC 86-206 Page 4 Violation (482/8618-02): Pailure To Lock Valve 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 RG 1.33, Revision 2, February 1978."
Appendix A of. RG 1 33, Revision 2, February 1978, states that, "The following... safety-related activities... should be covered by written procedures... 1.c. equipment control (e.g., looking and tagging)."
Checklist CKL AL-120, Revision 8,
" Auxiliary Peedwater Normal Lineup," has been established and implemented in accordance with the above TS.
Checklist A of CKL AL-120 requires, in part, that the handwheels to Valves AL HV-006, AL HV-008, AL HV-010 and AL HV-012 be lockwired in the neutral positions.
Contrary to the above, on August 20, 1986, the NRC inspectors observed that 3 out of the 4 turbine driven auxiliary feedwater pump (TDAPWP) discharge valve handwheels were in the required neutral position but were not properly lockwired. Valve ALHV-006 had its lockwire broken and twisted back together, ALHV-008 was not lockwired, and ALHV-010 was lockwired so loosely that the valve could be operated.
Reason For Violation If Admitted:
Failure to properly lockwire valves ALHV-006, ALHV-008 and ALHV-010 was due to operations personnel failure to follow procedure.
Corrective Steps Which Have Been Taken and Results Achieved:
Valves ALHV-006, 008 and 010 have been properly lockwired in the neutral position in accordance with Checklist ' A' of CKL AL-120.
Administrative Procedure ADM 02-102, " Control of Locked Component Status" has been revised to provide a distinct blue valve tag for a Locked Neutral Valve.
Surveillance Test procedure, STS AL-103, " Turbine Driven Auxiliary Peedwater Pump Inservice Pump Test" has been modified by Temporary Procedure Change No..MA 86-0434 to open and lockwire the valves in the neutral position.
o
Mr. E. H. Johnson November 5, 1986 KMLNRC 86-206 Page 5
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Corrective' Steps Which Will Be Taken To Avoid Further Violations:
A copy of this violation and response has been placed in Operations Required Reading to ensure operations personnel are aware of the requirement for properly lock-wiring required valves.
s 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.
Very truly yours, Glenn L'.-Koester Vice President - Nuclear GLK:see cc P0'Connor (2)
JCummins JTaylor s
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