IR 05000397/1991044
| ML17289A349 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 02/06/1992 |
| From: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Mazur D WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| Shared Package | |
| ML17289A350 | List: |
| References | |
| EA-91-183, NUDOCS 9203030049 | |
| Download: ML17289A349 (7) | |
Text
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Docket No.
50;397 License No.
NPF-21 EA 91-183 UNITED STATES NUCLEAR REGULATORYCOMMISSION
REGION V
1450 MARIALANE WALNUTCREEK, CAUFORNIA94596-5368 F~EB
1992 Washington Public Power Supply System ATTN:
Mr. D.
W. Mazur ManagS.ng Director Post Office Box 968 RS.chland, Washington 99352 Gentlemen:
Subject:
NOTICE OF VIOLATION AND PROPOSED ZMPOSITZON OF CIVIL PENALTY-
$25,000 (NRC INSPECTION REPORT NO. 50-397/91-44)
This refers to the speci.al inspection conducted by Messrs.
R.
C. Sorensen and D. L Proulx of this office on November 4 - December 8,
1991.
The results of this inspection were documented in the referenced NRC inspection report, which was transmitted to you on December 13, 1991.
This report addressed four apparent violations of NRC requirements concerning the contaS.nment atmospheric control (CAC) system.
These issues were discussed with you during an enforce-ment conference held in the Region V Office on December 20, 1991.
Our discussions during, the enforcement conference were summarized in Meeting Report No. 50>>397/91-48, transmitted to you on January 22, 1992.
The four apparent violations in our inspection report have been addressed as three violations, as shown in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice).
The first of these vS.olations involves (1) inoperability of both traSns of the CAC system since initial plant startup due to the inability of flow controllers to control recycle flow in the automatic mode and (2) S.noperability of Train "A" of the CAC system for more than three months during plant operation because lubricating oil had drained out of the associated blower.
You identified these conditions, reported them to the NRC, and have taken or initiated appropriate corrective actions.
The other two violations were identified by the NRC and involve (1) improper assembly of seismic supports for the CAC system and (2) the inordinate amount of time (almost three months)
you took to evaluate and report the inoperable flow controllers to the NRC.
Collectively, these violations reflect S.nsufficient attention by your management and staff to the CAC system; a system your Technical Specifications requS.re to be operable to mitigate the possS.ble con'sequences of an accS.dent.
The violations also indicate a need for additional commitment by your staff to engineering, technical, and maintenance activities, associated with this safety related system.
A more questioning attitude and thorough review on the part of your engineering and maintenance personnel would likely have resulted in your staff's identifying these violations ea'rlier.
Had your staff properly followed up on the flow controller deficiency when it was identified prior to 920303004'V
'720206 PDR ADOCK 05000397 A
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Washington Public Power Supply System ppQ g aaL initial plant startup the violation for that condition would have been avoided.
You are encouraged to consider how the lessons learned from these occurrences relate to your staff's attention to other safety'ystems.
Zn accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy),
CFR Part 2, Appendix C (1991)
g the violation'nvolving inoperability of the CAC system (Violation A in the enclosed Notice) has been classified as a Severity Level ZII violation.
The other two violations have been classified at. Severity Level IV.
However, in the case of both of those violations the NRC staff had some additional concerns.
With regard to the support deficiencies, your staff follow-up was not initially aggressive though eventually they did perform a 100% walkdown of the system.
Regarding the reporting violation, given the length of time it took for the report to be made to the NRC, serious consideration was given to assessing the reporting violation at Severity Level IIZ.
However, given that a report was ultimately made Severity Level IV was considered the appropriate classification.
To emphasize the importance the NRC attaches to properly maintaining and controlling the operability and configuration of safety-related systems, I have been authorized, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations, and Research, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) in the amount of $25,000.
The base value of a civil penalty for a Severity Level ZZZ problem is
$50,000.
The escalation and'itigation factors in the Enforcement Policy were considered as discussed below.
Your response to Violation A was aggressive.
Management has been objective and self-critical in investigating the events, and corrective actions were prompt and thorough, including procedure revisions and captivation of oil plugs.
In addition, you initiated a Safety System Functional Inspection and a number of other longer-term corrective actions.
We have therefore concluded that 50 percent mitigation is appropriate for corrective actions.
As previously noted, you identified and reported the two conditions cited in Violation A.
Had both conditions been reported in a timely manner, mitigation of up to 50% for identification and reporting would have been possible.
On balance, however, in view of the late reporting of one of those conditions (addressed as Violation B.2)
and the fact that the loss of lubricating oil was a self-disclosing event, we have concluded neither escalation nor mitigation is appropriate for identification and reporting.
The'other adjustment factors in the Enforcement Policy were considered, and no further adjustment to the base civil penalty was considered appropriate.
Therefore, based on the above, the base civil penalty has been decreased by 50%.
You also advised us on January 24, 1992 that the Train "B" CAC blower was found to have been inoperable from December 17, 1991 until the condition was discovered by your staff on January 22, 1992 (6 days beyond the out-of<<service time permitted by the associated Action statement in the Technical Specification).
.This condition occurred on December 17 as a result of an
Washington Public Power Supply System FEB
IBsz unusual system configuration during special testing conducted as part of your corrective action program.
You noted that Train "A" of the CAC system was operable during this period.
This matter does not appear to impact our assessment of <he previous CAC system problems and will be addressed in a separate inspection report after completion of NRC review.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response.
Zn your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence.
After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice,"
a copy of this letter and its enclosure will be placed in the NRC Public Document Room.
The responses directed by this letter and the Enclosed Notice are not sub)ect to the clearance procedure of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.
Sincerely, I
pqu'. Martin Regional Administr r
Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalty cc:
A. L. Oxsen, Deputy Managing Director L. L. Grumme, Acting Director, Licensing and Assurance J.
W. Baker, WNP-2 Plant Manager A. G. Hosier, WNP-2 Licensing Manager G. E. Doupe, Esq.
Winston
& Strawn State of Washington
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'Richards, RV BBoger, NRR MVirgilio, NRR SShankman, OEDO Tguay, NRR PEng, NRR GCook, RV PJohnson, RV CSorensen, RV KJohnston, RV RV Docket File I I (~
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