ML20126B279

Ack Receipt of 841221 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-482/84-22

ML20126B279
Person / Time
Site:	Wolf Creek
Issue date:	06/10/1985
From:	Denise R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Koester G KANSAS GAS & ELECTRIC CO.
References
NUDOCS 8506140058
Download: ML20126B279 (2)

See also: IR 05000482/1984022

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In Reply Refer To:

Docket: STN 50-482/84-22

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 December 21, 1984, in response to our letter

and Notide of Violation dated November 21, 1984. We have reviewed the

implementation of your corrective actions and determined that full compliance

has been achieved and will be maintained. Closure of the violation is

documented in NRC Inspection Report 50-482/85-03.

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Sincerely,

Original Signed By:

Richard P. Denise

R. P. Denise, Director

Wolf Creek Task Force

cc:

Kansas Gas and Electric Company

ATTN: Gene P. Rathbun, Manager

of Licensing

F. O. Box 208

Wichita, Kansas 67201

Forrest Rhodes, Plant Superintendent

Wolf Creek Generating Station

P. O. Box 309

Burlington, Kansas 66839

Kansas Radiation Control Program Director

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THE ELECTAC COMPANY

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Mr. Richard C. DeYoung, Director

Office of Inspection and Enforcement DEC 2 41984

U.S. Nuclear Regulatory Commission ,

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Washington, DC 20555

KMLNRC 84-234

Re: Docket No. STN 50-482

Ref: Letter dated 11/21/84 from RDMartin, NRC, to

GLKoester, KG&E

Subj: Enforcement Action 84-107

Dear Mr. DeYoung:

Attached is Kansas Gas and Electric Company's (KG&E) response to Violation II,

as documented in the Reference. Pursuant to 10CFR2.201, the following five

items are addressed for the alleged violation:

1. Admission or denial of the alleged violation;

2. The reasons for the violation, if admitted;

3. The corrective steps that have been taken and the results achieved;

4. The corrective steps that will be taken to avoid further violations;

and

5. The date when full compliance will be achieved.

KG&E's response to Violation I (Violation Assessed Civil Penalty) will be trans-

mitted by separate letter on or before December 31, 1984. This extension was

discussed and agreed to during a December 18, 1984, telephone call between Mr.

Lawrence Martin of the Nuclear Regulatory Commission (Region IV) and Mr. Otto

Maynard of KG&E.

Please contact me or Mr. Otto Maynard of my staff, ..if you have any questions

concerning KG&E's response to the alleged violation.

Very truly yours,

GLK:cks

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201 N. Market -WicNta, Kansas - Mail Address: RO, Box 208 i Wichita. Kansas 67201 - Telephone: Area Code (316) 261-6451

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OATH OF AFFIRMATION

STATE OF KANSAS )

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COUNTY OF SEDGWICK )

I, Glenn L. Koester, of lawful ago, being duly sworn upon oath, do depose,

state and affirm that I am Vice President - Nuclear of Kansas Gas and

Electric Company, Wichita, Kansas, that I have signed the foregoing letter

of transmittal, know the contents thereof, and that all statements contained

therein are true.

KANSAS GAS AND ELECTRIC COMPANY

By pf

Glenn'L. Koester

Vice President - Nuclear

E.D. Prothro, Assistant Secretary

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COUNTY OF SEDGWICK )

BE IT REMEMBERED that on this 21st day of December, 1984 , before

me, Evelyn L. Fry, a Notary, personally appeared Glenn L. Koester, Vice

President - Nuclear of Kansas Gas and Electric Company, Wichita, Kansas,

who is personally known to me and who executed the foregoing instrument,

and he duly acknowledged the execution of the same for and on behalf of

and as the act and deed of said corporation.

IN WITNESS WHEREOF, I have hereunto set my hand _and affixed my seal the

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,o.mi.da,te and year above written.

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Attachment to

84-234

VIOLATION NOT ASSESSED CIVIL PENALTY

FINDING

Criterion V of 10 CFR 50, Appendix B, requires that activities

affecting quality shall be accomplished in accordance with i

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appropriate instructions, procedures, and drawings, and that these

instructions, procedures, and drawings contain appropriate

quantitative acceptance criteria. ]

Bechtel Drawing E-lR8900, Revision 1, " Raceway Notes, Symbols and

Details" states in paragraph 3.36.4 that:

" Minimum separation between different Class lE conduit

systems and minimum separation between Class lE conduit

systems and non lE conduit systems shall be 1". Separation

shall be measured between the outside edges of the conduit".

Bechtel Drawing E-01013 (q) , Revision 11, requires the

following:

1. Paragraph 5.8.1.6 "Within the control boards and other

panels associated with protection systems, circuits and

instruments of different separation groups shall be

independent and physically separated horizontally and

vertically by a distance of 6 inchec".

2. Paragraph 5.8.3 "Non-safety rela ted circuits shall be

separated from Class lE circuits by the same distances

applicable to Class lE circuits of different groups".

Contrary to the above, the following activities affecting quality

were not accomplished in accordance with appropriate drawings:

1. There were neven cascs noted where conduit-to-coneuit

separation was less than one inch.

2. There were five areas in the control panels and cabinets

where electrical cable separation was less than six

inches.

RESPONSE

1. Admission or denial of the alleged violation:

There were cases in which the conduit-to-conduit separation was less

than one inch. In addition, as identified and documented by KG&E

prior to the NRC's inspection, there were control panels and

cabinets in which electrical cable was separated by less than the

specified six inches.

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2. The reason for the violation, if admitted:

One inch separation for flexible conduit is an individual inspection

attribute the inspector must enter on the Quality Checklist. In

addition, the correct installation of the flex is an item that is

looked for on walkdowns during system turnover and again during

room / area turnover. Deviations from the separation criteria

primarily resulted when the installed flexible conduit was slightly

longer than required. This resulted in a slight bowing of the

conduit. Therefore, the one inch separation existed unless two of

the conduits were moved so that they bowed toward each other.

Deviations from the six inch separation criteria in control panels

resulted primarily from the installation of field run cable causing

slight movement of previously installed cables or the introduction

of a cable into an area via a route not allowing the minimum

separation. Again, this condition was identified and documented

prior to the NRC;s inspection.

3. The corrective steps which have been taken and the results

achieved:

In order to document and assure resolution of the deficiency

concerning 1 inch conduit-to-conduit separation, KG&E issued

Corrective Action Request (CAR) 15. All "Q" Buildings were

subsequently walked down to identify deviations from the separation

criteria. These deviations were documented on Monconformance Report

(NCR) 1 SN 20443 E and are currently being corrected by providing

physical restraints such as tie-wraps or reworking the conduits to

maintain separation.

As stated in item 1 above, the concern with 6 inch cable separation

in the main control panels had been identified and documented on a

KG&E Startup Field Report (SFR) prior to the NRC's inspection.

Since the issuance of the SFR, all main control board panels have

now been inspected and deviations of the 6 inch separation criteria

have been documented on Nonconformance Report (NCR) 1 SN 20766 E.

Rework is in progress to either provide the required separation or

provide a physical barrier between the wires.

In addition, the safety significance of both of the separation

deviations has been evaluated for reportability pursuant to

10CFR50.55(e) and determined not to be a significant safety concern

which, if left uncorrected, would have adversely affected safe

operation of the plant.

4. The corrective steps that will be taken to avoid further

violations:

The construction craft, engineering, and inspection personnel will

be retrained on the importance of using good construction practices

to assure proper conduit separation. This training will address the

problems associated with excessively long conduit than can result in

separation deviations if movement occurs.

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Barriers are being added to the control. panels in areas where

maintaining the 6 inch separation is extremely difficult or not

.possible.- In addition, a letter will be issued to site

organizations alerting them to the separation requirements and the

care that'must be taken when routing cable in the control panels.

5. The date when full compliance will be achieved:

The above corrective actions will be completed by December 31,.1984.

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