IR 05000482/1986013

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-482/86-13.NRC Disagrees W/Denial of Violation 482/86-13-02.Addl Info Requested Re Corrective Action Taken

ML20214K359
Person / Time
Site:	Wolf Creek
Issue date:	08/13/1986
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Koester G KANSAS GAS & ELECTRIC CO.
References
NUDOCS 8608210052
Download: ML20214K359 (2)

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In Reply Refer To: ',1/_ " , _.>. . .a %, p# '

. Docket: .STN~S0-482/86-13 r >  ;, ce ry

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Kansas Gas and Electric Company (gi,/ ~; ^ ,.

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.ATTH: Glenn L. Koester .

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Vice President - Nuclear "

P. O. Box 208 .

Wichita, Kansas .67201 ,

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Gentlemen:

Thank you for your letter of July 31, 1986, in response to our letter and Notice of Violation dated July 2, 1986. We have reviewed your reply and find it generally responsive to the concerns raised in our Notice of Violation.

However, we disagree witn your response that Violation 482/8613-02 is not warranted because the undocumented block on Work: Request 02222-86 would have been discovered during the final review process. Whether or not this discrepancy would have been discovered does not alter the fact that Procedure ADM 01-057, Revision 9,.was violated by not 'docuamnting the appropriate information. As a result of our review, we fin. that additional information is needed. Specifically, we need the corrective action to Violation 482/8613-02.

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'Please provide the supplemental information within 30. days of the date of this letter.

Sincerely, Original S!aned By J. E. Gant!ardo 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 Rhcdes, Plant Superintendent Wolf Creek Generating Station B6082100S2 e60a13 P. O. Box 309 PDR ADOCK 0S000482 PDR Burlington, Kansas 66839 G Kansas Radiation Control Program Director bec (see next page)

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KANSAS GAS AND ELECTRIC COMPANY TFE ELECT A*C COMPANY GLENN L KQESTEft a -new wuu.

July 31, 1986 Mr. E. H. Johnson, Director Division of Reactor Safety and Projects p U.S. Nuclear Regulatory Commission ' 9 } -- % "c-

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Region IV s , 'i 611 Ryan Plaza Drive, Suite 1000 ' $- 4 @  !! l Arlington, Texas 76011 .!t:

( d KMLNRC 86-136 Re: Docket No. STN 50-482 Subj:

Response to Inspection Report STN 50-482/86-13

Dear Mr. Johnson:

This letter is written in response to your letter of July 2, transmitted 1986, which Inspection Report STN 50-482/86-13. As requested, the violations (482/8613-01, 02, 03)

being addressed in four parts. identified in the Inspection Report are (a) The reason for the violations 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 (di The date when full compliance will be achieved.

Violation (482/8613-01): Failure to Properly Document a Completed Portion of a Surveillance Test Finding:

Technical be Specification established, (TS) 6.8.1 requires that, " Written procedures shall implemented, and maintained covering . [

applicable procedures recommended . . a. The p Revision 2, February 1978." in Appendix A of Regulatory Guide 1.33, -

Section 8 of Appendix A to Regulatory Guide 1 33 states for control of measuring and that, " Procedures procedures, and calibration," should be covered by written procedures. test 4W& See.

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Mr. E. KMLNRC 86-136 July 31, 1986 Page 2 Surveillance Procedure, STS EJ-202, Revision ?,

Test," has been established and implemented in accordance with e TS.

the abov"RH Contrary to the above, on May 16, 202, Revision 0, 1986, the NRC inspector reviewed STS EJ-had been tested and observed that both the test"RHR System Inservice V person performer and the second i

had signed off Steps 5.1.2,

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witness 5.1.3, had failed to properly implement this pr Valve iLJ HV-8809A) rather than Steps and 5.1.6,5.1.4 (which documents testing of 5.1.7, ,,

were designated and required for documenting the testing 5.1.8, and 5.1.9 which '

88098. of Valve EJ HV-Reason For Violation If Admitted:

The individuals Revision 0, who performed Surveillance . Test Procedure STS EJ-202, off the incorrect steps train for thedue valve "A" to lack of attention"RHR System Ins detail to being tested.

documentation. The to individuals were aware of which valve was

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i Corrective Steps Which Have Been Taken and Results Achieved:

Upon being informed off, the correct steps were signed off.of the incorrect surveillance test steps being sig counseled on The individuals responsible were steps are documented. attentiveness to detail and the importance of ensuring proper Corrective Steps Which Will Be Taken To Avoid Further Violations:

i A copy of the violation and Required Reading to ensure operations personnel are aware of properly documenting of thethis respon importance the time of performance. the completion of the correct procedural steps at t 9 f-The Date When Full Compliance Will B+ Achieved:

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Full Compliance will be achieved by August 15, 1986. '

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Violation (482/8613-02): Data was not Recorded on a Work Request as b:

Required by Procedure {.

y Finding:

Data was not Recorded on a Work Request as Required by Procedure '

TS 6.8.1 requires that, implemented, and maintained covering " Written

. procedures shall be established, recommended in

. . a. The applicable procedures

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1978." Appendix A of Regulatory Guide 1.33, Revision 2, February

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i Mr. E. KMLNRC 86-136

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July 31,-1986 Page 3

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Administrative Procedure, ADM 01-057, Revision 9, " Work Request,"~(WR) has been established and implemented in accordance with the above TS. Section 3.4.5 requires that ..the workman perform the required work as specified in Block 18 of the WR.-

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Contrary to the above, on May 16, 1986, the NRC inspector' reviewed completed

Work Request--(WR) 02222-86 after it had been signed as completed by the shift supervisor (SS) and determined that the work instructions delineated

in Block 18 of- the WR had not been adequately implemented in that the

' limitorque serial number'had not been documented in Block- 39 of the WR as instructed in Block 18.

Reason For Violation If Admitted:

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Wolf Creek Administrative Procedure ADM 01-057, Revision 10, ~ requires that the Shift Supervisor sign Block 31 of the Work Request, (System Restored Block), when the required testing is completed and it's acceptable to return the item to service. This signature is not intended to provide a review for

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concurrence with Block 18, (Work Instruction), but serves the function of

documenting - the acceptability of the retest instructions specified in Block 29, (Retest Instructions).

Blocks 32 (Section Review) and 34 (Quality Engineering iieview) provide the final acceptance of the work performed per the work instructions.

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Wolf Creek Generating Station administration controls, in fact, provide for a final review of the work request to ensure all administrative requirements such as: work instructions are followed, all blanks as required, are filled

in, QA/QC requirements have been met, and etc. This review would have

' identified the missing serial number on Work Request Number 2222-86.

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Therefore, KG&E does not feel this violation is warranted.

t Corrective Steps Which Have Been Taken And The Results Achieved:

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The limitorque operator serial number was added to the. Work Request (number 2222-86) subsequent to the shift supervisor signing Block 31 and prior to '

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the final acceptance of the work request in Blocks 32 and 34.

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Corrective Steps Which Will Be Taken To Avoid Further Violations:

No additional corrective steps are required as Section Review (Block 32) and L'

Quality Engineering Review (Block 34) should identify any discrepancies in D the work request such as the one identified by this violation.

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The Date When Full Compliance Will Be Achieved:

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Full compliance has been achieved.

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. Mr. E. July 31, 1986 KMLNRC 86-136 Page 4

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Violation (482/8613-03): Cardboard Containers Stored in the Auxiliary

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Building Contrary to Procedure Finding:

TS 6.8.1 requires that, " Written procedures shall be established, implemented, and maintained covering . . . a. The applicable procedures recoreended in Appendix A of Regulatory Guide 133, Revision 2, February 1978."

Section 1.1 of Appendix A to Regulatory Guide 1.33 states that activities-for _ the plant fire protection program should be covered by; written procedures.

Administrative Procedure, ADM 13-102, Revision 4 '" Control of Combustible Materials," has been established and implemented in accordance with the above TS.

Step 3.1.2 of ADM 13-102 sta'. e s , in part, " Storage of all types of combustibles in safety-related areas . . . shall be prohibited."

Contrary to the above, on May 10, 1986, during a routine plant tour the NRC inspector observed approximately 25 empty, heavy cardboard containers stored on the north end of Elevation 2000' of the auxiliary building. During a ,

tour on May 13, 1986, the NRC inspector observed that the containers were still at the same location. The NRC inspector informed the supervising operator (S0) and the SS who had the containers removed.

i Reason For Violation If Admitted:

On about May 10, 1986 Building Services personnel were asked to remove approximately 25 empty, boric acid containers from a room on the North end of the Auxiliary Building. These drums were then moved to the North end of the 2000' elevation and left. They remained at that location until May 13, 1986. The reason for this violation is attributed to lack of adequate communication between Operations and Building Services personnel,

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i Corrective Steps Which Have Been Taken And The Results Achieved:

Upon being informed that the containers were still located at the North end, l 2000' elevation of the Auxiliary Building, the Shift Supervisor had the 's Tbn incident was discussed

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containers removed and properly disposed of.

with the involved individuals to stress upon them the requirements of '

i Station Administrative Procedure, ADM 13-102, " Control of Combustible

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Materials".

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Mr. E. KMLNRC 86-136 July 31, 1986 Page 5 Corrective Steps Which Will Be Taken To Avoid

_Further Violations:

A copy the of this violation appropriate groups and and response the Plant will be placed in Required Reading for personnel are aware of the importance of adhering to Station ProceduresSafety

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The Date When Full Compliance Will Be Achieved:

Full ccapliance will be achieved by August 15, 1986 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 GLK:see Vice President - Nuclear cc: P0'Connor JCummins JTaylor

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