ML20206K023

Responds to NRC Re Violations Noted in Insp Rept 50-482/86-04.Corrective Actions:Temporary Procedure Change Issued to Relax Precaution & Limitation & Will Be Permanently Incorporated Into Procedure

ML20206K023
Person / Time
Site:	Wolf Creek
Issue date:	04/22/1986
From:	Koester G KANSAS GAS & ELECTRIC CO.
To:	Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20206J813	List: IR 05000482/1986004 ML20206K023
References
KMLNRC-86-069, KMLNRC-86-69, NUDOCS 8606270344
Download: ML20206K023 (6)

Text

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KANSAS GAS AND ELECTRIC COMPANY THE ELECTRC COMPANY April 22, 1986 o te n u e n or s, waCE PRE 54 DENT hvCLE Aft I

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Y Mr. E. H. Johnson, Director

., 3 Division of Reactor Safety and Projects yl' U.S. Nuclear Regulatory Commission g-6g Region IV

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611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 KMLNRC 86-069 Re:

Docket No. STN 50-482 Subj:

Response to Inspection Report STN 50-482/86-04

Dear Mr. Johnson:

This letter is written in reponse to your letter of April 1,

1986, which transmitted Inspection Report STN 50-482/85-38.

As requested, the violations (482/8604-01, 02, 03, 04) 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 (482/8604-01):

Failure to Comply With Surveillance Procedure Instructions Finding:

WCGS Technical Specification 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 1.33.

Revision 2, February 1978."

Surveillance Test Procedure STS SF-001, Revision 3.

" Control and Ghutdown Rod Operability Verification,"

has been established and implemented in accordance with this Technical Specification (TS).

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l Of N. Market - Wichota, Kansas - Mail Address: PO. Box 208 I wichita, Kansas 67201 - Telephone: Area Code (316) 261-6451

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Mr. E. H. Johnson KMLNRC 86-069 Page 2 April 22, 1986 Section 2.2 of Surveillance STS SF-001, requires that no change in reactor coolant boron concentration shall be made during the test.

Contrary to the above, on February 3, 1986, operations personnel performed Surveillance STS SF-001 while reactor coolant boron concentration was being changed by dilution.

Reason For Violation If Admitted:

Reactor Coolant System temperature decrease and the Xenon transient which resulted from a power reduction had to be compensated for by dilution at the time surveillance procedure STS SF-001,

" Control and Shutdown Rod Operability Verification" was performed to determine shutdown control rod banks C, D,

and E operability.

The personnel performing the procedure failed to recognize the precautions and limitations which did not allow dilution of the reactor coolant boron concentration during performance of the surveillance test.

Corrective Steps Which Have Been Taken and Results Achieved:

A review of the Technical Specifications and Final Safety Analysis Report (FSAR) was performed and it was determined the precaution and limitation was excessively stringent considering transient conditions.

A temporary change was issued to relax the precaution and limitation on February 3,1986, which will be incorporated into the next permanent revision to STS SF-001.

The l

surveillance procedure was performed again in its entirety for both the control and shutdown rod control banks.

Additionally, a Wolf Creek Event

Report, (Number 86-17) aas issued and assigned as required reading for all l

operations personnel to reappraise them of their responsibility for being cognizant of

" Precautions and Limitations" prior to procedure implementation.

Corrective Steps Which Will Be Taken To Avoid Further Violations:

The temporary procedure change relaxing the requirement to not allow boron dilution during performance of STS SF-001 will be permanently incorporated into the procedure during the next revision.

The Superintendent of Operations will stress the importance of reading,

understanding, and following procedures to each of the Shift Supervisors at subsequent shift supervisor meetings.

The Date When Full Compliance Will Be Achieved:

Full compliance will be achieved by June 1, 1986.

Mr. E. H. Johnson KMLNRC 86-069 Page 3 April 22, 1986 Violation (482/8604-02):

Failure to Maintain Control Room HVAC in Required State Of Operability.

Finding:

WCGS 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 1.33, Revision 2, February 1978."

System Operating Procedure SYS GK-121, Revision 3.

" Control Building HVAC Startup,"

has been established and implemented in accordance with this TS.

Section 3.8 of Procedure SYS GK-121 requires that control building HVAC electrical switches be lined up in accordance with checklist CKL GK-131.

This checklist requires that handswitch GK HS-40/PNL GK199A be in its normal position.

Contrary to the above, on February 20, 1986, when a control room ventilation isolation actuation was manually initiated, the control room air conditioning unit (SGK04B) did not start and two associated dampers did not reposition as required due to Switch GK HS-40/PNL GK199A being in the off position rather than the required normal position.

Reason For Violation If Admitted:

Investigation into the mispositioning of the SGK04B switches revealed that SGK04B had been secured at approximately 0118 CST on February 16,

1986, because of a noise in the compressor and the local switches had been manipulated to pump down the refrigeration unit.

It is believed that they

)

were left in the wrong position at that time, because of a cognitive personnel error.

The use of the switches to pump down the re frigeration unit is not covered in the system operating procedure.

A sign at the switches provides the steps required to pump down, but it does not identify the need to return the switches to the proper position to allow the unit to properly respond to an Engineered Safety Features Actuation signal.

Corrective Steps Which Have Been Taken And The Results Achieved:

A sign has been placed at the switches requiring Control Room notification prior to switch manipulation and stating that the switches are Technical Specification related.

Similar signs have been placed at local switches on the other air conditioning units.

In addition the Licensee Event Report (LER 86-006-00) which discussed this violation was made Required Reading for operating personnel to emphasize the necessity of proper switch positioning.

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t Mr. E. H. Johnson KMLNRC 86-069 Page 4 April 22, 1986 1

i Corrective Steps Which Will Be Taken To Avoid Further Violations:

4 i

Control Room notification is now required prior to switch manipulation andsigns have been posted identifying the switches as Technical Specification related.

l The Date When Full Compliance Will Be Achieved:

Full compliance has been achieved.

I t

Violation (482/8604-03):

Fireproofing Removed From Support Beam

}

i Finding:

l WCGS TS 3.7.11 requires "All fire barrier penetrations.

separating safety-related fire areas... 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 1

j fire detectors... and establish an hourly fire watch."

Contrary to the above, on February 12, 1986, the NRC inspector observed fireproofing removed from structural steel on the 1947' elevation of the auxiliary building without the required continuous or hourly fire watch i

j being established.

Reason For Violation If Admitted:

On February 11, 1986, craft personnel removed fireproofing material from i

structural steel in the Auxiliary Building.

A previous engineering I

evaluation had identified the maximum allowable amount of fireproofing material that could be removed without affecting the performance of the fireproofing material.

The craft personnel were aware of the criteria and i

of the necessity to initiate a Fire Protection Impairment Control Permit (utilized to establish fire watch patrols) if the criteria were exceeded.

However, through a cognitive personnel error, - the craft personnel failed to recognize that the fireproofing material removal critera had been exceeded l

in these three areas.

j A contributing factor to this occurrence was the fact that this crew of cra ft personnel was relatively new and may not have fully understood the requir ements.

Cross training of craft personnel on fire protection program l

requirements was in progress, and these personnel had not yet received this training..

Corrective Steps Which Have Been Taken And The Results Achieved:

i Craft personnel have now received training on the fireproofing material removal criteria. A field inspection of the areas in which they had been i

i

i 1

' Mr. E. H. Johnson i

KMLNRC 86-069 Page 5 April 22, 1986 working revealed r.o other instances of noncompliance.

Upon discovery an hourly Fire Watch Patrol was established in accordance with Technical Specification 3.7.11.

Corrective Steps Which Will Be Taken To Avoid Further Violations:

To prevent future occurrences of this nature, a knowledgeable individual has been assigned the responsibility of overseeing the removal and replacement of fireproofing material in all areas by craft personnel.

The Date When Full Compliance Will Be Achieved:

2 Full compliance has been achieved.

Violation (482/8604-04):

Out-of-Date Procedures Finding:

WCGS TS 6.8.1 requires that,

" Written procedures shall be established, implemented, and maintained cc<ering.

a.

The applicable procedures recommended in Appendix

'A' Regulatory Guide 1.33, Revision 2,

February 1978."

i Operations Alarm Procedures ( ALRs) have been established in accordance with j

this TS.

Contrary to the above, on February 26,

1986, 11 ALRs located in Emergency Diesel Generator Room

'B' were audited by the NRC inspector and all were

}

found to be out-of-date.

Reason For Violation If Admitted:

Investigation into the eleven (11) ALRs located in Emergency Diesel Generator Room

'B' found to be out of date-identified the cause as thef were not on the current controlled distribution list.

The distribution list was converted from a Manual list to a computer distribution list, Configuration Status Accounting Records System (CSARS), in August of 1985 During the transfer, and subsequent review, Manual 114, which included the controlled disbribution for the eleven (11) ALRs in the

'B' Emergency Diesel Generator Room was not inputted into the CSARS program.

Corrective Steps Which Have Been Taken And The Results Achieved:

On February 28, 1986 a surveillance was performed of all remote alarm panels which contain ALR procedures and current revision procedures, including any temporary changes, were distributed as required.

-Each area was assigned as a distribution point and entered into CSARS distribution index for future controlled distribution.

Additionally a review was performed to verify all manuals listed on the old manual distribution index are now in CSARS distribution index.

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.o 4 Mr. E. H. Johnson KMLNRC 86-069 Page 6 April 22, 1986 On 3/7/86 and 4/4/86 a surveillance was performed on the remote alarm panels ALR's to verify all assigned procedures were current.

The 3/7/86 surveillance showed an error rate of ~ 0.013% and the 4/4/86 surveillance an error rate of 0.00375.

Corrective Steps Which Will be Taken To Avoid Further Violations:

Each remote alarm panel containing ALR procedures on controlled distribution will have a user file accuracy surveillance performed by the Regulatory,

Quality, and Administrative Services Surveillance Clerk approximately once per six months. This surveillance will ensure the procedures are current.

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.

Yours very truly, Glenn L. Koester Vice President - Nuclear GLK:see cc: P0'Connor (2)

JCummins JTaylor