ML20153F056

Responds to NRC Re Violations Noted in Insp Rept 50-482/85-33.Corrective Actions:Procedure KP-1032 Revised & Emergency Plan Procedure 02-1.1 Revised to Ensure Compliance w/10CFR50.54(q) for Future Procedure Revs

ML20153F056
Person / Time
Site:	Wolf Creek
Issue date:	12/13/1985
From:	Koester G KANSAS GAS & ELECTRIC CO.
To:	Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20153F050	List: IR 05000482/1985033 ML20153F056
References
KMLNRC-85-271, NUDOCS 8602250291
Download: ML20153F056 (3)

Text

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KANSAS GAS AND ELECTRIC COMPANY THE ELECTRC Cf1MPANY GLENN L MOESTER

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December 13, 1985

%2@2._DNP,$q t lU Mr. E. H. Johnson, Acting Director l(i Division of Reactor Safety and Projects DEC 2 31985 U.S. Nuclear Regulatory Comission .

h Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 KMI2EC 85-271 RE: Docket No. SIN 50-482 SUBJ: Response to Inspection Report SIN 50-482/85-33

Dear Mr. Johnson:

This 1ctter is written in response to you letter of ?bvenber 14, 1985, which transmitted Inspection Report SIN 50-482/85-33. As requested, the violation (482/8533-01) identified in the Inspecton Report is I

i being addressed in four parts.

(a) The reason for the violations if admitted:

(b) The corrective steps which have been taken and the results '

achieved:

l l (c) Corrective steps which will be taken to avoid further violations: and (d) The date when full conpliance will be achieved, l ., Yiolation (482/85-33-01) Failure to Follow Procedures Findina:

Technical Specification 6.8, " Procedures and Programs" states that written procedures shall be established, inplemented, and maintained covering the activities related to the emergency plan inplementation.

a. Distribution Control System Procedure Procedure KP-1032, Section 7.3.5-7.3.7 states that if an acknowledgement has not been received within 30 days of the transmittal date of the emergency plan or emergency plan 8602250291 060219 ~

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7 Mr. E.H. Johnson KMLMC 85-271 Page 2 Decenber 13, 1985 i

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! inplementation procedures (EPP), a reminder notice shall be sent to the recipient, to files, and a copy placed in the transmittal file.

Contrary to the above, letters had not been sent to recipients of the emergency plan and EPPS that failed to I return the acknowledgment form.

. b. Rn=roency Precaredriana Proaram Maintenance Procedure EPP 02-1.1, Revision 1, Section 4.3.2, states "An

! evaluation shall be conducted of proposed changes to assure

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conpliance with the requirements of 10 CFR 50.54 (q) ."

Section 4.3.2.1 states "Such an evaluation shall be conducted by the originator of the proposed change and h==nted."

Contrary to the above, there were no evaluation records for the i evaluation performed on EPP changes submitted to the NRC on May 15, 1985, and June 27, 1985.

Reason for Violation if M=dtted:

a. The investigation into this portion of the violation revealed that reminder notices were not sent to recipients because Management Systems personnel were not fulfilling the requirements of this pcttion of procedure KP-1032.

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b. Part b of this violation occurred because, contrary to Sections 4.3.2 and 4.3.2.1 of procedure EPP 02-1.1, Rev.1, records of the evaluation performed on EPP changes submitted to the NRC on May 15, 1985 and June 27, 1985 were not.kept.

s Corrective Steos Nhich Have Been Taken and Raanits Achieved: i i a. Procedure KP-1032 has been revised to reflect the following:

i 1. The requirement to discontinoe distribution to recipients who j fail to acknowledge transmittal was deleted. This requirement.

was inappropriate for Emergency Plan procedure distribution.

2. Reponsibility for corrective action on delinquent acknowlariga==nts from non-nuclear department and non-KGEE' recipients has been transferred to the Man & , a System Manager to allow more diligent followup.

In addition, the Emergency Plan Procedure distribution matrix has been added to the Project Document Control distribution matrix and -an outstanding acknowl+f,- -As have been verified for receipt.

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'Mr. E.H. Johnson  :

i KMDEC 85-271 Page 3 Decenber 13, 1985 1

b. EPP 02-1.1 has been. revised to incorporate sufficient' direction to ensure that 10 CFR 50.54(q) is couplied with for future Emergency Plan Procedure (EPP) revisions.

Section 7.4 of EPP 02-1.1,~ Revision 2, assigns responsibility for I the review of each revision request pursuant to 10 CFR 50.54(q) j to the Emergency Planning Coordinator (EPC). Attachment 2 of this procedure includes a checklist for corpletion of this review by the EPC. This attachment aWcales any EPP revisions through the review and approval cycle.

Revision 2 of EPP 02-1.1 has been used for all revision to EPP's since its release date of 9/19/85.

Corrective Steos Which Will Be Taken to Avoid Further Violations:

l a. The acknowl=1gawmt tracking responsibility will be transferred to a group designed specifically for.the task of transmittal tracking.

An r.utomated tracking system has been inplemented to provide a monitoring mechanism of transmittal adtnowlswigas=rit. Document

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control distribution personnel are being ' trained. on the new procedure and the new automated system. Recipients are also being trained on the new procedure.

b. No further action is required.

Date When Full Conoliance Will Be Achieved:

a. The revised system has already been inplemented. However, full coupliance will be achieved by January 1, 1986 to allow for training of all hn=rit control personnel.

b. Full corpliance has been achieved.

Please contact me or Mr. Otto Maynard of my staff if 'you have any questions concerning this response.

i Yours very truly, i Glenn L. Koester Vice President - Raclear GE:see oc: PO'Connor (2)

JCununins Jraylor i

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