ML20058E277
| ML20058E277 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 11/19/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20058E276 | List: |
| References | |
| 50-482-93-27, NUDOCS 9312060234 | |
| Download: ML20058E277 (4) | |
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APPENDIX A i
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Wolf Creek Nuclear Operating Corporation Docket:
50-482 Wolf Creek Generating Station License: NPF-42 During an NRC inspection conducted on September 12 through October 23, 1993, five violations of NRC requirements were identified.
In accordance with the i
" General Statement of Policy and Procedure for NRC Enforcement Actions,"
l 10 CFR Part 2, Appendix C, the violations are listed below:
A.
Inadeauate Clearance Order Implementation j
i Technical Specification 6.8.1.a states that written procedures shall be l
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established, implemented, and maintained covering the applicable j
procedures recommended in Appendix A of Regulatory Guide 1.33, j
Revision 2, dated February 1978. Regulatory Guide 1.33, Appendix A, Item 1.c, requires administrative procedures for equipment control (e.g., locking and tagging). This is accomplished, in part, by i
Procedure ADM 02-100, " Clearance Order Procedure," Revision 27.
i Procedure ADM 02-100, Step 6.14, specified that the valve should be checked to ensure that the reach rod reflects the actual valve position.
Contrary to the above, on September 21, 1993, the licensee determined f
that personnel failed to position and verify that the actual valve positions for boric acid filter inlet'and outlet valves reflected the required reach rod position.
j This is a Severity Level IV violation.
(Supplement I) (482/9327-01) j 1
B.
Inadeauate Control of Temporary Ecuipment j
Technical Specification 6.8.1.a states that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, dated February 1978. Regulatory Guide 1.33, Section 1, requires administrative procedures.
10 CFR Part 50,-Appendix B, i
Criterion V, " Instructions, Procedures, and Drawings," requires that activities affecting quality shall be prescribed by procedures of a type j
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appropriate to the circumstances.
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Procedure ADM 01-201, " Control of Temporary Equipment," Revision 5, i
3 Step 4.3.3, specifies that equipment having rollers or wheels capable of moving during a seismic condition shall be immobilized to restrict / limit movement.
Contrary to the above, on September 26, 1993, during a plant-tour the inspector identified several carts with rollers located in the auxiliary building that were not immobilized.
This is a Severity level IV violation.
(Supplement I) (482/9327-02) 9312060234 931119 2
j-PDR ADOCK 05000482 3
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Improper Scaffold Construction l
Technical Specification 6.8.1.a states that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of-Regulatory Guide 1.33, j
Revision 2, dated February 1978.
Regulatory Guide 1.33, Appendix A, l
Item 9.a, requires procedures for maintenance that can affect the performance of safety-related equipment.
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Procedure ADM 01-113, " Scaffold Construction," Revision 5, Section 5.2.d, required that scaffolding shall not be in contact with or i'
secured to any safety-related or special scope structure / equipment unless allowed by the evaluation.
j Contrary to the above, two examples of scaffolding which did not meet f
the requirements of Procedure ADM 01-113 were identified:
(1)
On October 5, 1993, the inspector identified that scaffolding constructed over a safety-related heat exchanger contacted Valve EG-V205, Component Cooling Water Heat Exchanger A i
temperature bypass upstream isolation, and was secured _to l
safety-related room cooler and piping supports.
Scaffold Request 93-S0836 evaluation did.not allow this scaffold to be in contact with the valve or secured to the supports.
(2)
On October 21, 1993, the inspector identified that scaffold
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constructed near the Spent Fuel Pool Cooling Heat Exchanger B was secured to a support for special scope equipment. Scaffold Request 93-S0850 evaluation did not allow this scaffold to be secured to this support.
l This is a Severity Level IV violation.
(Supplement I) (482/9327-03) i I
D.
Failure to Obtain Permission to Start Work i
I Technical Specification 6.8.1.a states that written procedures shall be-l established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, dated February 1978. Regulatory Guide 1.33, Appendix A, t
Item 9.a, requires procedures for maintenance that can affect the performance of safety-related equipment, j
Procedure ADM 01-057, " Work Request," Revision 27, Section 7.24, required that the shift supervisor, " Sign and date to give permission to l
START work."
In addition, Procedure ADM 01-057, Figure 6, " Work Request i
Flow Chart," requires a worker to obtain the shift supervisor's permission prior to starting work.
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Contrary to the above, on October 12, 1993, the inspector observed a machinist perform work under Work Request 02815-93 without first obtaining the shift supervisor's permission.
This is a Severity level IV violation.
(Supplement I) (482/9327-04)
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E.
Inadeouate Corrective Actions 10 CFR Part 50, Appendix B, Criterion XVI, specifies, in part, that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected.
specifies that the contents of a licensee event report will include a-i description of any corrective actions planned as a result of the event-including those to reduce the probability of similar events occurring in j
the future.
l Licensee Event Report 482/93-003 identified that personnel created a
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direct path out of containment while draining the essential service water system. The licensee determined that procedure steps failed to i
ensure personnel understood that performance of the steps violated containment integrity. As corrective action Licensee Event-l Report 482/93-003 specified that a review of SYS procedures utilized to drain systems which penetrate containment would be conducted to' ensure that potential similar situations could not occur or do not exist.
Procedure SYS EG-401, " Component Cooling Water System Drain Procedure,"
Revision 0, provided guidance for draining the component cooling water l
system.
Contrary to the above, on October 7, 1993, the inspector found that the licensee failed to correct weaknesses contained in Procedure SYS EG-401.
in order to reduce the probability of a similar event occurring in the future.
I This is a Severity Level IV violation.
(Supplement I) (482/9327-05)
Pursuant to the provisions of 10 CFR 2.201, Wolf Creek Nuclear Operating Corporation is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011,. and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly. marked as a " Reply to a Notice of l
Violation" and should include for each violation:
(1) the reason for the l
violation, or, if contested, the basis for disputing the violation,-(2) the corrective steps that have been taken and the results achieved,-(3) the corrective steps that will be taken to avoid.further violations, and (4) the date when full compliance will be achieved.
If an adequate. reply is not received within the time ~specified.in this Notice, an Order or.a Demand for
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_4 information may be issued to show cause why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
Dated at Arlington, Tex s, this jtj.fL dayofLj'p,u,,,,./ 1993 i
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