IR 05000397/1995020
| ML17291B165 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 12/12/1995 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Parrish J WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| References | |
| NUDOCS 9512190077 | |
| Download: ML17291B165 (6) | |
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T=S i UCLEAR REGULATO CO 1MISSIOM REGION Iv
!I':4'VI'!.AZAORIVE SUITS 460
'R r'VGTON 76XAS 76011 806<
DEC I-2 l995 Washington Public Power Supply System ATTN:
J.
V. Parrish, Vice President Nuclear Operations 3000 George Washington Way P.O.
Box 968, MD 1023 Richland, Washington 99352 SUBJECT:
NRC INSPECTION REPORT 50-397/95-20 Thank you for your letter of September 15, 1995, in response to our letter and Notice of Violation dated August 16, 1995.
In your response you requested that Violation 8 concerning improper performance of a surveillance test which caused a reactor water level transient be reconsidered with regard to severity level in light of the revised Enforcement Policy guidance.
We have summarized your grounds for reconsideration as follows:
(1) Operations responded rapidly and conservatively; (2) the Enforcement Policy guidance regarding violations identified through events states that the NRC may give credit because no prior opportunities existed to identify the problem; (3) the Supply System has recognized the area of human performance as needing improvement and, as such, specific and general corrective actions have been or are being addressed.
With regard to the first comment, we agree that the operators'esponse was appropriate, timely, and avoided a plant trip.
We recognized this in our inspection report.
With regard to your second comment, we note that the Enforcement Policy guidance referenced relates to consideration for mitigation or escalation of a civil penalty when evaluating a Severity Level I, II, or III violation.
The violation under consideration was considered a Severity Level IV and, therefore, the cited Fnforcement Policy guidance is not directly applicable.
Severity Level IV violations may be treated as noncited violations even if identified as the result of an event (VII.B.I(a)).
This violation was cited because not stopping, not self-checking, and not following procedures in this instance are similar to previous violations and opportunities were missed to prevent the transient.
First, if there was confusion in the activity to be performed, the appropriate action would have been to obtain clarification from supervision.
Second, your procedures require each individual to self-check their actions.
Third, the labeling in the panel was adequate, although potentially confusing, and the procedure reference was correct.
The error in the identification of the leads was readily identifiable had the technicians paid the requisite attention to the work activity.
With regard to your third comment, we acknowledge that actions for this problem area have been taken in the past and continue to be developed to deal with human performance issues.
As this violation demonstrates, your efforts 9512i90077 95i2i2 PDR ADOCK 05000397
Washington Public Power Supply System nave not yet been rullp effective.
Additional'. chis error was considered to be more than a minor concern because it resulted in a significant level transient in the reactor coolant system.
In summary, we maintain that the violation is appropriately categorized as a
Severity Level IV violation.
While the violation may have been considered a
noncited violation, it represents an additional example of a personnel error for which your corrective actions have not been fully effective.
We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.
Sincerely, Docket:
50-397 License:
NPF-21 Deputy Reg>onal Administrator CC:
Washington Public Power Supply System ATTN:
J.
H. Swailes, WNP-2 Plant Manager P.O.
Box 968, MD 927M Richland, Washington 99352-0968 Washington Public Power Supply System ATTN:
Chief Counsel 3000 George Washington Way P.O.
Box 968, MD 396 Richland, Washington 99352-0968 Energy Facility Site Evaluation Council ATTN:
Frederick S. Adair, Chairman P.O.
Box 43172 Olympia, Washington 98504-3172 Washington Public Power Supply System ATTN:
D. A. Swank, WNP-2 Licensing Manager P.O.
Box 968 (Mail Drop PE20)
Richland, Washington 99352-0968
Washington Public Power Supply System-3-Washington Public Power Supply System ATTN:
P.
R.
Bemis, Director Regulatory and Industry Affairs P.O.
Box 968 (Mail Drop PE20)
Richland, Washington 99352-0968 Benton County Board of Commissioners ATTN:
Chairman P.O.
Box 190 Prosser, Washington 99350-0190 Winston 8 Strawn ATTN:
M. H. Philips, Esq.
1400 L Street, N.W.
Washington, D.C.
20005-3502
Washington Public Power Supply System DEC I 2 l995 E-Hail report to D. Nelson (DJN)
E-Hail report to NRR Event Tracking System ( IPAS)
bcc to DMB (IEOl)
bcc distrib.
by RIV:
L. J. Callan DRSS-F IPB Branch Chief (DRP/E, WCFO)
Senior Project Inspector (DRP/E, WCFO)
Leah Tremper (OC/LFDCB, HS:
TWFN 9E10)
Resident Inspector MIS System RIV File Branch Chief (DRP/TSS)
H.
Hammond (PAO, WCFO)
DOCUMENT NAME':i WN2iWN520AK.RCB To receive copy of document, indicete in boxt "C" e Copy without enclosure
"E" y w'
enclosures "N" No copy RIV:C:DRPiF*
HJWong 11/6/95 D:WCFO*
KEPerkins 11/6/95 0:DRP JEDyer ll/a3/95 DRA SJCo ins
~/95
- previous y concurre OFFICIAL RECORD COPY
Washington Public Power Supply System DEC I 2 l995 E-Hail report to D. Nelson (DJN)
E-Mail report to NRR Event Tracking System (IPAS)
bcc to DMB ( IE01)
bcc distrib.
by RIV:
L. J. Callan DRSS-FIPB Branch Chief (DRP/E, WCFO)
Senior Project Inspector (DRP/E, WCFO)
Leah Tremper (OC/LFDCB, MS:
TWFN 9E10)
Resident Inspector HIS System RIV File Branch Chief (DRP/TSS)
H.
Hammond (PAO, WCFO)
DOCUMENT NAME:
R:i WN2iWN520AK.RCB To receive copy of document, indicate in box: "C" ~ Copy without enciosure
"E" y w'
enclosures "N" No copy RIV:C'DRP)F*
HJWong 11/6/95 D:WCFO*
KEPerkins 11/6/95 D:DRP JEDyer 11/ag/95 DRA SJCo ins
~/95
- previous y concurre OFFICIAL RECORD COPY