ML20217H643

Notice of Violation from Insp on 980125-0307.Violation Noted:Operators Failed to Log Entry Into Action Statement for TS 3.1.3.5 Shutdown Rods Inserted Beyond Rod Insertion Limits

ML20217H643
Person / Time
Site:	Wolf Creek
Issue date:	04/01/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20217H636	List: IR 05000482/1998004 ML20217H632 ML20217H643
References
50-482-98-04, 50-482-98-4, NUDOCS 9804060020
Download: ML20217H643 (3)

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EfLCLOSURE 1 NOTICE OF VIOLATION Wolf Creek Nuclear Operating Corporation Docket No.: 50-482 Wolf Creek Generating Station License No.: NPF-42 During an NRC inspection conducted on January 25 through March 7,1998, three violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

A. Technical Specification 6.8.1.a requires, in part, that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Regulatory Guide 1.33, Revision 2, February 1978, Section 2, recommends, in part, that procedures be established for general plant operations.

Technical Specification 3.1.3.5 states that, "All shutdown rods shall be limited in physical insertion as speci'ied in the Core Operating Limits Report"in Modes 1 and 2. The core operating limits report limits shutdown rod insertion to no less than 222 steps. The action statement associated with Technical Specification 3.1.3.5 limits the number of shutdown rods inserted beyond the insertion limit to a maximum of one rod, except for surveillance testing pursuant to Technical Specification 4.1.3.1.2. The action statement requires that rods be restored to within the rod insertion limit within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

Procedure AP 21-001, " Operations Watch Standing Practices," Revision 8, requires that all entries into short-term limiting conditions for operation be logged in and out of the control room log. j l

Contrary to the above, on February 18,1998, operators failed to log entry into the action statement for Technical Specification 3.1.3.5 for shutdown rods inserted beyond the rod insertion limits.

This is a Severity Level IV violation (Supplement 1) (50-482/9804-01). )

8. Technical Specifications 4.7.1.2.1.a and 4.8.1.1.2 require surveillance tests on the auxiliury feedwater pumps and emergency diesel generators be performed on a ,

staggered test basis.

Contrary to the above, between August 1994 and May 1996, the licensee failed to l perform surveillance testing on the auxiliary feedwater pumps and emergency diesel  !

generators on a staggered test basis. l This is a Severity Level IV violation (Supplement l} (50-482/9804-03).

9804060020 980401 PDR ADOCK 05000482 G PDR j

C. Technical Specification 6'.11 requires, in part, that radiation protection technicians and -

workers adhere to procedures for personnel radiation protection consistent with the ,

requirements of 10 CFR Part 20c

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Administrative Procedure AP 258-100, Radiation Worker Guidelines, Revision 5,.

Section 6.3.6, requires individuals to comply with radiation work permit requirements.

Radiation Work Permit 98009, Revision 0, required intermittent health physic 6 coverage and required the radiation worker to avoid all posted hot spot locations.

Contrary to the above, on February 18,1998,

a. A quality control inspector worked within 18 inches of two posted hot spots for approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, and

b. No heath physics coverage of the work was provided during this 3-hour period.

-1 This is a Severity Level IV violation (Supplement IV) (50-482/9804-07).

Pursuant to the provisions of 10 CFR 2.201, for Violations A and C, 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 Violation" and should I include for each violation: (1) the reaton for the violation or, if contested, the basis for disputing the violation or severity level, (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 cor'npliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response.

~ If an adequate reply is not received within the time specified in this Notice, an order or a 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.

. The NRC has concluded that information regarding the reason for Vihlation B, the corrective k actions taken and planned to correct the violation and prevent recurrence and the date when full compliance was achieved is already adequately addressed on the docket in Licensee Event Reports 50-482/96-009-00 and -01. However, you are required to submit a written statement or

. explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a " Reply to a Notice of Violation," and it 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,

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, u 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.

If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001. .

. Because your response will be placed in the NRC Public Document Room (PDR), to the extent

. possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. ~ if personal pdvacy or proprietary information -

is necessary to provide an acceptable response, then please provde a bracketed copy of your -

response that identifies the information that should be protected and a rcdacted copy of your response that deletes such information.- if you request withholding of such material, you must 1 specifically identify.the portions of your response that you seek to have withheld and provide in

- detail the bases for your claim of withholding (e.g., explain why the disclosure of information will

! create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at Arlington, Texas this 1st day of April 1998

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