ML20155B991

Responds to NRC Re Violations Noted in Insp Rept 50-482/88-21.Corrective Action:Verbatim Compliance W/All Procedural Requirements Has Been Stressed by Mgt & Will Continue to Be Stressed & Monitored by Mgt

ML20155B991
Person / Time
Site:	Wolf Creek
Issue date:	09/30/1988
From:	Bailey J WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
ET-88-0130, ET-88-130, NUDOCS 8810070198
Download: ML20155B991 (4)

Text

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. W6,M.F CREEK NUCLEAR OPERATING CORPORATION John A. Badey ve. pre e m w v.u m w s. w September 30,1968 ET 88-0130 U. S. Nuclear Regulatory Commission ATTN Document Control Desk Mail Station P1-137 Vaahington, D. C. 20555

Reference:

Letter datei September 2,1988, from L. J. Callan, NRC, to B. D. Withers, WCN00

Subject:

Dookot No. 50-482: Response to NRO Violations 482/8'J21-02 ani 04 Gentlemen:

Attached is the response to NRC Violations 432/6321-02 and 04 which were documented in the Reference. Violation 482/8821-02 invelved a failure to implement the appropriate proceiuree. Violation 482/8821-04 involvel e failurc to implement adequate corrective action.

If you have any questions concerning this mstter, plesse contact ne or Mr. O. L. Maynard of my staff.

Very truly yours, g h Ar %

John A. hile/

Yice President f Engineering & Techniogl Services JAB /jad Attachment oos B. L. Eartlett (NRC), w/a D. D. Chamberlain (NRC), w/a R. D. Ksetin (NRC), w/a P. V. O'Connor (NRC), w/a (2)

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Attachment to ST 88-0130 Page 1 of 3

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Violation (482/8821-02): Pailure_ _to Impleja,nf. Procedures Pir.dingt Volf Creek Generating Station Technical Specification 6.8.1 requires thst, and maintainei "Vrttter. procedures shall be established, implemented, coverind . . . a. The appliosble procalures esocmmended in Appendix A of Regulatory Guide 1 33, Revision 2, February 1978."

Appendix A to Regulatory Guide 133 specifies, in ; ort, that estety-related .

activities coniuoted during the operatione phase should be oeverei by written procedures.

The following are examples of failure to implement the appropriat* l p;toelures I

1. Psilure to Remove an Individual From Vatchstan-ling Activities Procedure ADM 06-224, Revision 5, "Licensed operator hequalification Training Program," had been established to ensure a proficiaat operating t staff.

i Procedure ADM 06-224, Step 6.5.2.5.2, requires thst, "An individual r i

enrolled in an acceleratei requalifiestion program shall be removoi from [

! all licensed duties until he has successfully completed the Accelerated Requalification Program."

i Contrary to the abuve, after having been notified of failing ths annual requalification examination on August 11, 1987, a licenset operator i stood six watches <1uring the time period of August 11-16, 1957.

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2. Failure to Properly Establish a Pirewatch ,

I l Procedure ADM 13-103, Revision 3, "Pire Protection: Impaiement i

! Control," had been established and implement +1 in accordance with th9 i

above requirements. f i

, Procedure ADM 13 103, Step 4.1, requires, " A Fire Protection Impairment .

4 Control Permit form will be prepared for all Pire Proteotien Syste:s  !

j Impstements, both routine and emergency." l Contrary to the above, during the period April 13, 1987, through October  !

, 13, 1987, a fire impairment permit hsd not been issued for fire dampers

] undergoing post-modification testing.  ;

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Attschment to ET 88-0130  ;

Page 2 of 3 l e

Reason Por Violations i The failure to remove an individual from watchstanding activities for a

, period of six watches following notification of failing the annual l J

requalification examination was due to not implementing the procedural  :

requirements in a timely manner. Because 10 CPR 55.59 does not specify a  ;

time frame for twmoving an individual frors all licensed duties, procedure l ADM 06-224, Revision 5, did not specify any time frame. Therefore, the j individual was allowed to complete his assigned shift.

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! The failur9 to issue a fire impairment permit for the fire dampers undergoing post modification testing was a conscious decision by management as the entire power block was under fire watches due to fire barrier penetation rework. Thus it was felt that individual impairments were not [

required. i i Corrective Staps Vhich Have Been Taken and Results Achieved ,

i ADM 06-224, Revision 5 was revisol by Temporary Procedure Change No. MA 87-252 on 8/18/87, to require "Upon formal notification of any failure . . .

the affected individual shall be placed in an Accelerated Requalification  !

Program, and removed from Licensed Duties within two (2) working days, until )

auch time . . ... " Revision 7 to AIN 06-224 has been subsetuently revised l a by Temporary Procedure Change to require," . . . . upon notifiention of any l l failure . . . the affected individual shall be removed from Licensed j Duties. If the individual is standing wsteh at the time of notifiention, ha will be allowed to complete that watch . . . .".  !

j Corrective Step Vhich Vill Be Taken To Avoid Purther Violations:

i 1 Yerbatim compliance with all procedural raquirements has been stressei by

management and will continue to be stressed and monitored by management.

Date When Full Compliance Vill Be Achieved, l

Full compliance has been achieved. t

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j Violation (482/8821-04): Failure to Implement Adequate Corrective Action i Finlings i

Code of Federal Regulations 10 CPR 50, Appendix B, Criterion XVI requires, t i ir. part, "Measures shall be establirh+1 to assure that coniitions adverse to i

quality, such as ... are pronptly identified and corrected. In the case l j of significant conditions adverse to quality, the measures shall assur9 that i the osuse of the condition is determinel and corrective action taken to j preclude re;4tition." ,

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Attachment to ET 83-0130 Page 3 of 3 Procedure QAP 16.1, Revision 1, "Corrective Action fo r QA Program Breskdowns," provides criteria for determining if a condition constitutes a significant condition adverse to quality, and requires, in ; 't, that corrective action control as established in this procedure shsll assure that aignifiosnt coniitions adverse to quality are promptly corrected to preolude recurrence.

Contrary to the above, the corrective action taken to prevent the recurrence of the insdvertent notustion of the Auxiliary Peedwater System ( APS), as reported in Licensee Event Report (LER) 482/85-019, wss not sufficient to prevent the similar events reported in LER 482/86-003 and LER 482/87-018.

Ronson Por Violation Corrective actions taken following each of the insdvertant notcations of Auxiliary Peedwater System ( APS) as reportoi in Licensee Event Reports (LERs) 482/85-019 and 482/86-008 wss considerei at the time to be sufficient to prevent recurrence. Upon the third nuch occurence it was acknowledged thst the previous actions were insdeluste to prevent recurrence.

Corrective Steps Which Hsve Been Taken ani Results Achieved:

As identified in LER 87-018-00, the control procedure was revised to require the operator speettically verify that the M?P reset push button has been reset. A double verifiestion was also addel to the procedure to ensure that two operators make this reset verifiestion, prior to pinoing the APAS block switch in the "PERMIT" position. To date there hsve been no recurrences resulting in insdvertent notcation of the APS.

Corrective Steps Vhich Vill Be Taken To Avoid Perther Violationo Volf Creek Generating Station management has stressel improve 1 in depth root cause anslysis so thst aleluate corrective action (s) enn be identified ani implemented in a timely nanner to ensure that significant ooniitions adverse to quality are promptly corrected to preolude recurrence.

Date When Pull Compliance Vill Bo Achieved:

Full compliance hsa been schievel.