ML20215E448
| ML20215E448 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 12/04/1986 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| KMLNRC-86-228, NUDOCS 8612220308 | |
| Download: ML20215E448 (4) | |
Text
C KANSAS GAS AND ELECTRIC COMPANY THE ELECTAC COMPANY
@LENN L MOESTER December 4, 1986 T3@ BOWS T Mr. E. H. Johnson, Director Division of Reactor Safety and Projects i
DECI6 m U. S. Nuclear Regulatory Commission y
Region IV 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 (d) The date when full compliance will be achieved.
Violation (482/8622-01): Technical Specification (TS) Fire Door Blocked Open Finding:
Wolf Creek Generating Station (WCGS) TS 3.7.11
- requires, in part, "All sealing devices in fire-rated assembly penetrations (fire doors,
.)
shall be operable" and "With one or more of the above required fire barrier penetrations inoperable, within one hour establish a continuous fire watch.
or verify the operability of fire detectors.
and establish an hourly fire watch."
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8612220308 861204
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[(y305/flo PDR ADOCK 05000482
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PDR 201 N. Market - WIctuta, Kansas - Mail Address: PO. Box 208 I Wichita, Kansas 67201 - Telephone: Area Code (316) 261-6451
3, Mr. E. H. Johnson December 4, 1986 KMLNRC 86-228 Page 2 Contrary to the above, on September 25, 1986, the NRC inspector observed Fire Door 15031 blocked open without the required continuous or hourly fire watch being established.
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 charcoal in the Auxiliary / Fuel Building Normal Exhaust Filter Adsorber Unit FGLO2.
At approximately 0200 CDT, the hose being used in pumping the 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:
These personnel and their foremen have been reminded of the importance of maintaining fire barriers and of the necessity for promptly contacting the Control Room anytime the function of a fire barrier is jeopardized.
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
.'o r contacting the Control Room prior to blocking open.
The Date When Full Compliance Will Be Achieved:
Full compliance has been achieved.
Violation (482/8622-02): Failure To Control Documents Marked As Safeguards In formation 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."
)
.J Mr. E. H. Johnson December 4, 1986 KMLNRC 86-228 Page 3 Section 1 of Appendix A to RG 1.33 states "a.
Security and visitor controla should be covered by written administrative procedures.
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 "TMO 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:
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 PSRC clerk did not notice the safeguards stamp and added the TM0 safety evaluation to the PSRC Meeting No. 234 agenda as attachment No. 82.
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.
The PSRC clerks have been counseled on the importance of attention to detail regarding the distribution of documents stamped as safeguards. Additionally TM0 86-SE-126 was declassified as it did not contain safeguards information.
o m-Mr. E. H. Johnson December 4, 1986 KMLNRC 86-228 Page 4 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 has been achieved.
If you have any questions concerning this matter, please contact me or Mr.
O. L. Maynard of my staff, il Very truly yours, f
Glenn L. Koester Vice President - Nuclear GLK:see cc: P0'Connor JCummins JTaylor t
l t