ML20059C309

Notice of Violation from Insp on 931024-1204.Violations Noted:Failure to Maintain Cognizance of Control Panels & Permits & Failure to Properly Restore Clearance Orders

ML20059C309
Person / Time
Site:	Wolf Creek
Issue date:	12/29/1993
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20059C302	List: IR 05000482/1993029 ML20059C300 ML20059C309
References
50-482-93-29, NUDOCS 9401050092
Download: ML20059C309 (3)

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APPENDIX A NOTICE OF VIOLATION  !

Wolf Creek Nuclear Operating Corporation Docket: 50-482  ;

e Wolf Creek Generating Station License: NPF-42 l l

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During an NRC inspection conducted from October 24 to December 4, 1993, three violations of NRC requirements were identified. In accordance with the  !

" General Statement of Policy and Procedure for NRC Enforcement Actions'" .

10 CFR Part 2, Appendix C, the violations are listed below:

A. 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, Appendix A,  ;

Item 1.b, specifies that administrative procedures address authorities- ,

and responsibilities for safe operation and shutdown. ,

Procedure ADM 02-040, " Conduct of.On Duty Operations Personnel,"

Revision 9, Step 3.2, specifies personnel must be alert, remain i cognizant of their immediate areas of responsibility until properly i relieved, and be particularly attentive of the instrumentation and  :

controls located within the areas at all times, j Contrary to the above, four instances of inadequate on-duty conduct ,

occurred or were identified by the licensee: 1 (1) On October 30, 1993, a licensed operator determined that the ,

pressurizer spray line temperatures differed by:10oF. Subsequent l investigation determined that the air supply to a pressurizer  ;

spray valve was secured, which made the valve inoperable since ,

May 1993. Testing performed on May 20 and July 30 included +

cycling of the spray valve. Operations personnel failed. to recognize that the valve's status indication did not change.

(2) On November 6, 1993, licensed operators determined that they had initiated a containment purge approximately 1% hours after the '

purge permit expired.

(3) On November 8,1993, licensed operators discovered that Steam Generators A and D upper sample isolation valves were not in the normal, closed position. After investigating, the licensee  ;

determined that operators mispositioned the valves approximately -

3 days earlier after completing a slave relay test. .

1 (4) On November 12, 1993, licensed operators found the essential service water supply isolation valve to Air Compresscr A closed. J 9401050092 931229 PDR ADOCK 05000482 G PDR

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Upon review, personnel determined the valve had closed 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> 1 earlier. -l This is a Severity Level IV violation. (Supplement I) (482/9329-01) j B. Technical Specification 6.8.1.a states that written procedures shall be established, implemented, and maintained covering the applicable i procedures recommended in Appendix A of Regulatory Guide l.33, '

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 28.  ;

Procedure ADM 02-100, Step 7.1.5.2, allows clearance orders to be-  ;

accepted and released by individuals acting in the capacity of an i established supervisor on site. Step 7.1.5.2.1 allows those individuals  !

specifically authorized by name and/or title in an operations special i order to accept or release a clearance as a supervisor on site.  !

Contrary to the above, two examples of clearance orders being -l prematurely restored occurred because the guidance was inappropriate to- -!

the circumstances: j (1) On November 12,_1993, Steps 7.1.5.2 and 7.1.5.2.1 were l inappropriate to the circumstances _because the extent of personnel  !

authorized to restore clearances was too broad. Clearance  !

Order 93-2114-AK was restored inappropriately and resulted in  !

personnel working in the condensate demineralizer without proper  !

protection. .;

(2) On December 2, 1993, Steps 7.1.5.2 and 7.1.5.2.1 were j inappropriate to the circumstances because the extent of personnel  ;

authorized to restore clearances was too broad. Clearance  !

Order 93-2077-HF was inappropriately restored prior to all work '

being completed. The clearance was restored, prior to the manway to a total dissolved solids collector tank being reinstalled, r creating a potential personnel hazard.

This is a Severity Level IV violation. (Supplement I) (482/9329-02)

C. 10 CFR Part 50, Appendix B, Criterion XVI, specifies that measures shall j be established to assure that conditions adverse to quality, such as j deficiencies, deviations, and nonconformances are promptly identified i and corrected.

Procedure KGP-1210, " Performance Improvement Requests," Revision 9, Step 6.3 specifies requirements for processing nonsignificant <

performance improvement requests that include consideration of work . i groups affected. Step 6.3.1 specifies for nonsignificant performance  !

improvement requests that personnel shall review the performanca

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improvement request and determine what corrective actions, if any, should be implemented. The scope and depth of the evaluation should be appropriate to the circumstances.

Contrary to lhe above, corrective actions for Performance Improvement Request 93-0982 relating to inappropriate restoration of a clearance order, were implemented only for electrical maintenance when the corrective actions were applicable to all crafts. Subsequently, on November 12, 1993, mechanical maintenance personnel performed work  :

without a clearance order in place to protect personnel safety.

This is a Severity Level IV violation. (Supplement I) (482/9329-03)  :

A written response to Violation A discussed above is not required. This was based on the actions taken by the licensee to determine the root cause, implement the appropriate immediate corrective actions, and implement initiatives already in place to improve operator performance.

Pursuant to the provision 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 for Violations B and C, ATTN: Document Control Desk, Washington, D.C. 20555, with a copy to the Regional  ;

Administrator, Region IV, 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 t clearly marked as a " Reply to a Notice of Violation" and should include for ,

each violation: (1) the reason for the violation, 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 demand for information may be issued as to 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, i

1 Dated at Arlington, Tex , ,

this e(qh64, day of 1993 l c

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