ML20126B279
| 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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'JUil 101985
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.
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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KANSAS GAS AND ELECTRIC COMPANY
THE ELECTAC COMPANY
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December 21, 1984
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Mr. Richard C. DeYoung, Director
DEC 2 41984
Office of Inspection and Enforcement
U.S. Nuclear Regulatory Commission
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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
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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
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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:
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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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