IR 05000397/1993018
| ML17290A749 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 11/10/1993 |
| From: | Faulkenberry B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Counsil W WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| Shared Package | |
| ML17290A750 | List: |
| References | |
| EA-93-191, NUDOCS 9312030100 | |
| Download: ML17290A749 (10) | |
Text
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR: 93I2030100 DOC. DATE: 93/11/10 NOTARIZED:, NO DPCKET ¹ ACIL:50-397 WPPSS Nuclear Pro Jecti Unit 2i Washington Public Pore 05000397 AUTH. NAME AUTHOR AFFILIATION FAULKENBERRYiB.
Region 5 (Post 820201)
RECIP. NAME
.
RECIPIENT AFFILIATION COUNSILi W. C.
Washington Public Poujer Supply System r
SUBJECT:
Discusses insp repts 50-397/93-18'0-397/93-24>
50-397/'93-29 on 930503-0802 5 forwards notice of violation.
DISTRIBUTION CODE:
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TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:
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UNITED STATES NUCLEAR REGULATORYCOMMISSION
REGION V
1450 MARIALANE WALNUTCREEK, CALIFORNIA94596-5368 Docket No.
50-397 License No.
NPF-21 EA 93-191 November 10, 1993 Washington Public Power Supply System Post Office Box 968 Richland, Washington 99352 Attention:
Hr.
W.
C. Counsil Hanaging Director Subject:
NOTICE'OF VIOLATION AND PROPOSED IHPOSITION OF CIVIL PENALTY $75,000 (NRC INSPECTION REPORT NOS.. 50-397/93-18, 50-397/93-24, AND 50-397/93-29)
I This refers to the inspections conducted by Hessrs.
R.
C. Barr, D. L. Proulx, K. E. Johnston, and W. L. Johnson of this office on Hay 3 through August 2, 1993, at the Washington Nuclear Project No.
2 (WNP-2).
The results of these inspections were documented in the referenced
.NRC inspection reports, which were transmitted to you on July 27, August 30, and August 17,. 1993.
These issues were discussed with you during an enforcement conference held in the Region V Office on September 22, 1993.
The enforcement conference was summarized in Heeting Report No. 50-397/93-37, transmitted to you,on October 15, 1993.
The enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) refers to the use of the residual heat removal (RHR) system in the suppression pool cooling (SPC)
mode during power operation, and to several recent procedure violations.
The Washington Public Power Supply System (Supply System) identified the use of the RHR system in the SPC mode as part of 'an engi'neering review begun in late 1992.and documented the finding in Licensee Event Report (LER) 50-397/93-01, Revision 1, dated June ll, 1993.
These SPC,mode concerns were evaluated for potential enforcement action during a special" inspection documented in Inspection Report No. 50-397/93-29, dated August 17, 1993.
On three separate occasions, operators failed to comply with a procedure that prohibited the use of two trains of the RHR system in the SPC mode during power operation.
The procedure requirement was put in place in September 1990 after your staff determined that a train of RHR operating in the SPC mode could partially drain following a loss of offsite power (LOP)
and incur a
severe water hammer if the RHR pump automatically restarted in response to a loss-of-coolant accident (LOCA).
A LOP coincident with a LOCA is a design basis event for WNP-2.
Operators placed two trains of the RHR system in the SPC mode on September 30, 1991, for almost 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />; on July 6, 1992, for over 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; and on July ll, 1992, for over 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
These three instances, 93i2030i00 93iii0 PDR ADOCK 05000397,
Washington Public Power Supply System
identified by your staff, occurred during low power.safety/relief valve (SRV)
testing.
As stated in the LER, your staff initially determined that placing a,train of RHR in the SPC mode rendered it inoperable since calculations showed that it would not be able to perform its design function following a LOCA coincident with a LOP.
However, your review also concluded that these events did not significantly increase the overall core damage frequency (CDF).
This conclusion was based on the limited time that the RHR trains were in the SPC mode and the low probability of a LOCA coincident with a LOP.
In addition, at the enforcement conference you stated, that the initial operability determina-tion is being evaluated further, based on your. belief that the initial operability-determination was too conservative, as evidenced by the position other licensees have taken on this issue.
Nevertheless, we have concluded that the condition in which two trains of RHR were in the SPC mode constitutes
'n instance wherein a system designed to prevent or mitigate a serious safety event was degraded to the extent that a detailed evaluation is required to determine operability.
Additionally, the RHR procedure violations are considered significant in light of WNP-2's history of procedure compliance problems as documented below and later in this letter.
Specifically, several operator requalification failures between February and June 1991 resulted largely from a prevalent operator attitude that plant procedures, including the emergency operating procedures, were issued for guidance and did not require strict compliance.
In addition, the January 1992 Electrical Distribution System Functional Inspection (EDSFI)
identified eleven separate examples of failure to follow procedures, and the July 1992 Testing Team inspection identified eight examples.
An enforcement conference was held with you following the EDSFI; however, these items were subsequently cited as Severity Level IV violations.
Overall, between September 1991 and August 1993, the NRC has identified more than 60 examples of procedure violations, resulting in over thirty Level IV violations.
While the Supply System management team has repeatedly concurred with the NRC's concerns regarding inadequate procedure compliance, and a number of corrective actions have been taken, the NRC continues to.,identify numerous instances of procedure non-adherence.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy),
CFR Part 2, Appendix C, the three procedure violations involving the use of the RHR system in the SPC mode during power operation have been classified as a Severity Level III problem.
To emphasize the importance the NRC attaches to the proper operation of safety systems and the need for procedure compliance, 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 in the amount of $75,000.
The base value'of a civil penalty for a Severity III problem is
$ 50,000.
The escalation and mitigation factors in the Enforcement Policy were considered as described belo Washington Public Power Supply System With respect to identification, the Supply System identified this violation as a'esult of apparently improved rigor in the pursuit of engineering issues, while investigating a problem concerning suppression pool air space
,temperatures.
Accordingly, 50X mitigation for identification is warranted.
The corrective actions proposed in, LER 93-01, which documented this problem, were not aggressive, and appeared indicative of an assessment that this issue was of minor significance.
The LER merely referenced training on procedure compliance which had already been provided to operators, and established the LER as required operator reading.
Only after submittal of the LER and the issuance of Special Inspection Report No. 50-397/93-29 did the Supply System take additional corrective actions to revise operating procedures so.that they more cTearly define the requirements applicable to the SPC mode of operation, and to revise administrative procedures regarding the use of procedure caution statements.
Your staff appears to have focused primary corrective actions on procedure quality improvements, and did not take full advantage of problems such as the RHR procedure violations to effectively emphasize the importance of strict procedure adherence.
Based on these considerations, we have concluded that 50X escalation is warranted for corrective action.
The Supply System's performance in the area of procedure compliance has been of concern for several years and has been so noted in each SALP report since 1988.
These procedure adherence weaknesses have resulted in the numerous violations mentioned above and the weaknesses were discussed in management meetings in February, Hay and October of,1992, and in March 1993.
In part, the problems with procedural adherence have been caused by the Supply System's inconsistency in holding personnel accountable for procedural compliance.
However, the procedure adherence violations at issue here occurred in the Plant Operations area, a functional area which has shown some improvement in the recent past.
This was evidenced in a generally well-managed refueling outage (April - June 1993)
and good plant operational performance since that time.
The Plant Operations area was also awarded a
SALP Category 2 rating earlier this year (improved from a Category 3 the previous SALP period).
Therefore, on balance, we have escalated the proposed civil penalty by 50X rather than by 100X for licensee performance.
The other adjustment factors in the Enforcement Policy were considered, and no further adjustment to the base civil penalty is considered appropriate.
Based on the above, the base civil penalty has been increased by 50X.
One violation originally considered for inclusion in the enclosed Notice concerned the Supply System's failure to take adequate corrective actions in response to industry information regarding the use of the SPC mode of RHR.
Although this deficiency may have contributed to the 1990 instance when both loops of the RHR system were operated in the SPC mode, your staff did ultimately address the problem by making an appropriate procedure revision later in 1990.
Your staff identified this violation, and has taken appropriate corrective actions to address it.
Since the criteria of Section VII.B(2) of 10 CFR Part 2, Appendix C, were met, this violation is not being cite '
Washington Public Power Supply System
The enclosed Notice also includes a number of examples of less significant procedure violations (cited in the Notice as Severity Level IV violations not assessed a civil penalty) that resulted from the apparent violations documented in Inspection Reports 50-397/93-18 and 93-24. While these violations do not directly relate to the RHR issues discussed above, they do demonstrate a continued lack of attention to detail by Supply System workers when performing procedures, a willingness to work around inadequate procedures, and a lack of adequate supervisory review of performance related to procedures.
In this regard, we note that your September 8,
1993, letter discussed the root causes and your planned corrective actions to address these violations.
We strongly encourage your management to take appropriate and effective measures to improve your staff's performance regarding procedure
'dherence...
One other apparent violati'on identified in Inspection Report No. 50-397/93-18 involved the approval of overtime for operators after WNP-2 returned to operation, on other than an individual basis, contrary to the requirements of TS 6.2.e.4.
As documented in that inspection report, your staff committed to take appropriate corrective actions for this violation.
Since the criteri'a of Section VII.B(l) of 10 CFR Part 2, Appendix C, were met, this violation also is not being cited.
You are required to respond to this. letter and should, follow the instructions specified in the enclosed Notice when preparing your response.
In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence.
You may include by reference, where this is applicable, portions of your September 8,.1993 letter which addressed the procedure violations.
After reviewing your response to this Notice,
.including your proposed'orrective 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 subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub.
L. No.96-511.
Sincerely, Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalty cc w/encl:
See Next Page t
.
Fa en r
Regional Admini trato
Washington Public Power-Supply System Hr. J.
V. Parrish, Assistant Managing Director for Ope'rations, WPPSS Hr. J.
C. Gearhart, Director, guality Assurance, WPPSS Mr. J.
H. Swailes, WP-2 Plant Manager G;
E.
C. Doupe, Esq.,
WPPSS Hr. Warren A. Bishop, Chairman, Energy Facility Site Evaluation Council Hr. Alan G. Hosier, Licensing Hanager, WPPSS Chairman, Benton County Board of Commissioners H. H. Philips, Jr.,
Esq.,
Winston h Strawn
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Washington Public Power Supply System DISTRIBUTION:
PDR LPDR SECY.
CA J. Taylor, EDO J. Sniezek, DEDR B. Faulkenberry, RV J.
Lieberman, OE L. Chandler, OGC J. Goldberg, OGC T. Murley, NRR J. Partlow, NRR F.
Ingram, GPA/PA B. Hayes, OI D. Williams, OIG E. Jordan, AEOD RV Docket File.
DCS EA File Enforcement Coordinators RI, RII, RIII, RIV, RV OE OE:DD RV JLuehman JGray BFaulkenberry 11/
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Roe, NRR E. Adensam, NRR T. quay, NRR K. Perkins, RV-S. Richards, RV C. VanDenburgh M. Blume, RV R. Huey, RV L. Miller, RV P. Johnson, RV R. Barr, RV J. Mitchell, OEDO J. Clifford, NRR G. Cook, RV D. Kunihiro, RV K. Johnston, RV Day File OE:0 DEDR JLieberman JSniezek 11/
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