ML20214P042
| ML20214P042 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 11/25/1986 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Koester G KANSAS GAS & ELECTRIC CO. |
| References | |
| NUDOCS 8612040059 | |
| Download: ML20214P042 (1) | |
See also: IR 05000482/1986018
Text
_
s; . ..
NOV 2 61986
cIn Reply Refer To:
Docket: STN 50-482/86-18
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 November 5,1986, in response to our letter and
- Notice of Violation dated October 6,1986. 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.
Sincerely,
N *.nal Egned by)
n. E. HALL"
J. E. Gagliardo, Chief
Reactor Projects Branch
cc:
Kansas Gas and Electric Company
ATTN: Otto Maynard, Manager
of Licensing
P. 0.' Box 309 (Sharp Road)
Burlington, Kansas
66839
Forrest Rhodes, Plant Superintendent
Wolf Creek Generating Station
P. O. Box 309
Burlington, Kansas
66839-
Kansas Radiation Control Program Director
8612040059 861125
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KANSAS GAS AND ELECTRIC COMPANY
THE ELECTRC COMPANr
GLENN L KOESTER
November 5, 1986
" " " " * ~ ' " " " "
TM@MDUC
Mr. E. H. Johnson, Director
Division of Reactor Safety and Projects
U. S. Nuclear Regulatory Commission
Region IV
-
l
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 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 (482/8618-01): Failure To Comply With
Licensee's
Temporary
Modification Procedure
Finding:
Technical Specification (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 (RG) 1.33, Revision 2, February 1978."
amt n 1
0-
-
201 N. Market - Wichta, Kansas - Mail Address: PO. Box 208 I Wictuta, Kansas 67201 - Telephone: Area Code (316) 261-6451
.
.
s .
.
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 should 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 modificatien 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 controls required
of
various
organizations
to
carry
out
their
assigned
responsibilities.
Section 4.2.4 of ADM 01-001,
Revisio1 12,
April 1,
1986, states
that,
"Those participating in any activity shall be made aware of,
and use, proper and current instructions, proc 9dures, 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 86-81KC.
The NRC inappctor
observed that ADM 02-101 had not been followed in that the required
_
O
_
, . .
- - - -
o
,
. $ .
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 27,1986.
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.
Corrective Steps Which Have Been Taken and Results Achieved:
TMO 86-81KC,
Section
'D' was corrected to include the required information.
TM0 86-72KC was corrected to include the initials for tag installation and
verification.
Revision 15 to ADM 02-101 did not create any changes to the TM0 fo rms.
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 de tail 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 Achieved:
Full compliance will be achieved by November 30, 1986.
.__ x
. _ _ _
-.
_ _ _ _ _
.
.
>.a
e
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:
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., locking and. tagging)."
Checklist CKL AL-120, Revision 8,
" Auxiliary Peedwater Normal Lineup," has
been established and implemented in accordance with-the above TS.
Checklich
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:
Pailure 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 Precedure Change
No. MA 86-0434 to open and lockwire the valves in the neutral position.
.
.
u
.s
.
Mr. E. H. Johnson
November 5, 1986
KMLNRC 86-206
Page 5
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.
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
ocs P0'Connor (2)
JCummins
JTaylor
.