IR 05000397/1993019

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-397/93-19 .Disagrees That Violations Represent Egregious Failure of Foreign Matl Controls in Refueling Area

ML17290A701
Person / Time
Site:	Columbia
Issue date:	10/18/1993
From:	Perkins K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Parrish J WASHINGTON PUBLIC POWER SUPPLY SYSTEM
References
NUDOCS 9310260285
Download: ML17290A701 (7)

Text

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9310260285 DOC.DATE: 93/10/18 NOTARIZED:

NO DOCKET

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ACXL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH.NAME AUTHOR AFFILIATION PERKXN,K.E.

Region 5 (Post 820201)

RECIP.PAME RECIPIENT 'AFFILIATION PARRISH,J.V.

Washington Public Power Supply System SUBJECT:

Ack receipt of 930726 ltr informing NRC of steps taken to correct violations noted in insp rept 50-397/93-19 dtd 930625.Disagrees that violations represent egregious failure of foreign matl controls in refueling area.

DISTRIBUTION CODE:

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TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:

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LINITEDSTATES NUCLEAR REGULATORY COMMISSION

REGION V

1450 MARIALANE WALNUTCREEK, CAUFORNIA94596-5368 tow f ] g

$9'Q Docket No. 50-397 Washington Public Power Supply System P. 0.

Box 968 Richland, Washington 99352 Attention:

Hr. J.

V. Parrish Assistant Managing Director, Operations Thank you for your letter (G02-93-189) of July 26, 1993, in response to our Notice of Violation and Inspection Report No. 50-397/93-19, dated June 25, 1993.

.Your response to our Notice of Violation dated June 25, 1993 (concerning foreign material exclusion from the refueling area)

did not accept our finding that a refueling camera was not properly controlled.

In that inspection, the inspectors identified that your personnel failed to follow your procedure for forei gn material control around the reactor during the refueling outage.

Specifically, the inspectors found an uncontrolled, unattended, partially disassembled camera within the foreign material exclusion zone you had established.

Your response states that this condition was not a violation.

Also, in that inspection, the inspectors identified that some commonly used tools, such as knives and pliers, were not uniquely identified as required by your procedure.

In your response you attribute this violation to an unclear procedure.

Finally, you state that the violation is not a repetition of the violation we identified in 1992 where the inspectors identified that several items were either not logged or captured with a lanyard within the foreign material exclusion zone.

We do not consider the violations to represent an egregious failure of foreign material controls in the refueling area.

They were significant only because they were examples of continuing foreign material exclusion controls weaknesses, and because we found two different instances of a failure to follow your foreign material control procedure during the inspection.

9310260285 934018 PDR ADOCK 05000397

PDR

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1n the enclosure to this letter we provide additional discussion which may be useful to you in understanding our perspective'.

We consider violation 93-19-01 to be valid, and to be a repeat violation of ".iolation 92-14-03.

Your actions in response to this violation, particularly the effectiveness of your corrective action, will be reviewed in a subsequent inspection.

Enclosure:

As Stated Pyh-K. E. Perkins, Jr., Director Division of Reactor 'Safety and Projects CC:

Mr. J.

H. Swailes, WNP-2 Plant Manager G. E.

C. Doupe, Esq.,

WPPSS Nr. Warren A. Bishop, Chairman, Energy Facility Site Evaluation Council

• Hr. Alan G. HosIer, Licensing Manager, WPPSS Nr. D.

W. Coleman, Acting Hanager, Regulatory Programs, WPPSS Chairman, Benton County Board of Commissioners H. H. Philips, Jr., Esq.,

Minston 8 Strawn

Enclosure 1.,

In your denial of the first example of Violation 93-019-01, you stated that:

(1) the contractor working on the underwater camera knew of the procedural requi rements to disassemble items outside the Exclusion Boundary when possible, (2) however, it was judged to not be possible due to general contamination concerns expressed by,Health Physics, and (3)

therefore, although the Supply System recognized that a better place to disassemble the camera was possible, considering the contractor's judgement and the concerns expressed by the Health Physi cist, the Supply System believed this example did not violate Plant Procedure 1.3. 18.

Our review of your denial of the first example of Violation 93-019-01 has determined the following:

(1)

The size of the underwater camera was less than eighteen inches by eighteen inches.

The contamination levels on this camera should not have been any greater than those found on other equipment removed from the Exclusion Boundary during the same time period.

Me conclude that removal of the camera was possible and reasonable.

(2)

Me were informed during the inspection that there were no Health Physics log entries documenting an evaluation of contamination concerns for removal of the camera from the Exclusion Boundary for contractor disassembly and inspection work.

Also, we were informed that there were no log entries in the associated Refueling Floor Foreign Haterial Control Accountability Log Sheets documenting the contractor camera inspection or repair activities.

(3)

Plant Procedure 1.3. 18, Section 6.2.1.d required that an item be moved out of the Exclusion Boundary prior to any required disassembly when possible.

Therefore, we conclude that the procedure's requirements were not complied with.

2.

, In your response, you stated that Mashington Public Power Supply System did not consider that this incident was a repeat violation because:

(1)

extensive corrective action was taken in response to.the initial violation (92-014-03)

issued June 30, 1992, and (2) the Supply System had extensively revised Plant Procedure 1.3. 18, "Foreign Naterial Control Around the Spent Fuel Pool, Reactor Cavity, and Dryer-Separator Pit," to enhance the controls for establishing and maintaining foreign material exclusion areas during refueling and nonrefueling periods.

I Me reviewed the June 1992 violation again.

Both violations are related to control of foreign material in the refueling area, and in that sense, we consider the 1993 violation to be a repeat of the 1992 violatio l

L ILL R la IS 9$

RICHARDS PERKINS lg C

61/ le/93 W/IS/93 i 0/is REQUEST COPY YES NO 0 REQUEST COPY YES NO 0 REQUEST COPY YES NO 0 SEND TO DCS YES NO 0 SEND TO PDR YES NO 0