ML20153E462

Notice of Violation from Insp on 880711-15.Violation Noted: Fire Impairment Permit Not Issued for Fire Dampers Undergoing post-mod Testing

ML20153E462
Person / Time
Site:	Wolf Creek
Issue date:	09/02/1988
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20153E444	List: IR 05000482/1988021 ML20153E440 ML20153E462
References
50-482-88-21, NUDOCS 8809060327
Download: ML20153E462 (2)

Text

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l APPENDIX A NOTICE OF VIOLATION

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Wolf Creek Nuclear Operating Corporation Docket: 50-482 Wolf Creek Generating Station License No.: NPF-42 ,

During an NRC inspection conducted on July 11-15, 1988, violations of NRC requirements were identified. The violations involved failure to remove an i individual from watchstanding activities, failure to properly establish a fire watch, and failure'to implement adequate corrective action. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," i 10 CFR Part 2, Appendix C (1988), the violations are listed below A. Failure to Implergnt Procedures f Wolf Creek Generating Station Technical Specification 6.8.1 requires that, j "Written procedures shall be established, implemented, and maintained f covering . . . a. The applicable procedures recomended in Appendix A of I Regulatory Guide 1.33, Revision 2, February 1978."

App'endix A to Regulatory Guide 1.33 specifies, in part, that safety-related activities conducted during the operations phase should be covered by written procedures.  !

The following are examples of failure to implement the approprite i procedures: l

1. Fai'ure to Remove an Individual From Watchstanding Activities l Procedure ADM 06-224 Revision 5. "Licensed Operator Requalification (

Training Program " had been established to ensure a proficient '

operating staff. [

Procedure ADM 06-224 Step 6.5.2.5.2, requires that, "An individual l enrolled in an accelerated requalification program shall be removed i from all licensed duties until he has successfully completed the l Accelerated Requalification Program."  !

l Contrary to the above, after having been notified of failing the  !

annual requalification examination on August 11, 1987, a licensed i operator stood six watches during the time period of August 11-16, i 1987. j

2. Failure to Properly Establish a Firewatch l Procedure ACM 13-103, Revision 3. "Fire Protection: Impainnent Control " had been established and implemented in accordance with the  !

above requirements.  !

8809060327 88090' 82 DR ADOCK 0500

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r Procedure ADM 13-103, Step 4.1, requires, "A Fire protection Impairment Control Permit form will be prepared for all Firo Protection System Impsirments, both routine and emergency." j Contrary to the above, during the period April 13, 1987, through j October 13, 1987, a fire impairment permit had not been issued for

fire dampers undergoing post-modification tcsting.

This is a Severity Level !Y violation. (SupplementI)(482/8821-02)

8. Failure to implement Adequate Corrective Action Code of Federal Regulations 10 CFR 50, Appendix B Criterion XVI requires, in part, "Measures shall be established to assure that conditions adverse i

to quality, such as . . . are promptly identified and corrected. In the  !

case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action l taken to preclude repetition." i J

Procedure QAP 16.1, Revision 1, "Corrective Action for QA Program l Broakdowns," provides criteria for determining if a condition constitutes a significant condition adverse to quality, and requires, in part, that ,

corrective action control as established in this procedure shall assure -

, that significant conditions adverse to quality are promptly corrected to preclude recurrence.

Contrary to the above, the corrective action taken to prevent the recurrence of the inadvertent actuation of the Auxiliary Feedwater i

System (AFS), as reported in Licensee Even* Trt (LER) 482/85-019,was i not sufficient to prevent the similar events reported in LER 482/85-008  ;

j and LER 482/87-018

This is a Severity Level IV violation. (SupplementI)(482/8821-04)

i Pursuant to the provisions of 10 CFR 2.201, Wolf Creek Nuclear Operating

Corporation is hereby required to submit to this office, within 30 days of the .

date of the letter transmitting this Notice, a written statement or explanation

in reply, including for each violation: (1) the reason for the violation if  !

{ admitted,(2)thecorrectivestepswhichhavebeentakenandtheresults t achieved. (3) the corrective steps which will be taken to avoid further .

violations,and(4)thedatewhenfullcompliancewillbeachieved. Where good l

cause is shown, consideration will be given to extending the response time.  !

Dated at Arlington, Texas, l this cQg day of p 1988, t

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