IR 05000397/1996019
| ML17292A601 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 11/26/1996 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Parrish J WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| Shared Package | |
| ML17292A602 | List: |
| References | |
| EA-96-327, NUDOCS 9611290229 | |
| Download: ML17292A601 (10) | |
Text
November 26, 1996
SUBJECT:
NOTICE OF V(OLATIONAND PROPOSED IMPOSITION OF CIVILPENALTY-
$ 100,000 (NRC Inspection Report No. 50-397/96-19)
Dear Mr. Parrish:
This refers to the matters discussed with Washington Public Power Supply System (Supply System) representatives at the predecisional enforcement conference conducted on October 22, 1996, in Arlington, Texas.
As noted in NRC Inspection Report 50-397/96-19, issued September 23, 1996, the conference was conducted to discuss several apparent violations of Technical Specification requirements at the Washington Nuclear Project-2 facility, Richland, Washington.
Based on the information developed during the inspection, and the information that you provided during the conference, the NRC has determined that violations of NRC requirements did occur.
The violations are cited in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice), and the circumstances surrounding them were described in detail in the subject inspection report.
Briefly, the violations involved: 1) shifting plant operational modes with one train of the control room emergency filtration system inoperable; 2) shifting plant operational modes without conducting required equipment surveillances (four examples);
3) not having an adequate procedure to assure that a required stroke-time test of reactor core isolation cooling containment isolation valves was performed prior to a mode change and in accordance with established procedures; and 4) failing to conduct required equipment surveillances during plant operations (two examples).
These violations appear to have been caused by ineffective processes and procedures for verifying completion of required surveillance tests, and, in part, a poor understanding of the involved requirements for completing surveillance tests prior to mode change.
At the conference, the Supply System expressed no disagreement with the apparent violations; described a number of specific and broad corrective actions to address the root causes; noted that the Supply System had identified all but one of the issues; and pointed out the similarity between two of the current violations and previous violations and stated that the corrective actions from the previous violations had been less than fully effective.
Additionally, despite the number of violations, the Supply System stated its perspective that the violations did not indicate a systemic degradation in Nuclear Operations performance.
Finally, the corrective actions described by the Supply System to address
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Washington Public Power Supply System-2-the current violations included the implementation of process and procedural enhancements, establishment of a surveillance and post-maintenance testing team, discussions of the events with operating crews, and lessons-learned training.
Although these violations did not result in actual safety consequences, the NRC considers the regulatory significance of the violations high. Taken collectively, the violations indicate that the Supply System did not maintain an effective program for assuring that required operational checks of equipment were performed at the appropriate times and in-accordance with the Technical Specifications.
The number of violations; and the fact that
. they. occurred over a relatively short period of time, suggest a serious weakness in this very fundamental and important area.
In addition, similar violations were cited in August 1995, as part of a Severity Level III problem that resulted in a $ 50,000 civil penalty being assessed (EA 95-096).
As you acknowledged at the conference, your corrective actions for the previous violations focused on human performance and did not address the process-related weaknesses that were at the root of the current violations.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," (Enforcement Policy), NUREG-1600, these violations are classified in the aggregate as a Severity Level III problem.
In accordance with the Enforcement Policy, a civil penalty with a base value of $ 50,000 is considered for a Severity Level III problem.
Because your facility has been the subject of escalated enforcement actions within the last f
2 years, as noted above, the NRC would normally consider whether credit was warra t d ne or Identification and Corrective Action in determining whether a civil penalty should be assessed, as described in Section VI.B.2 of the Enforcement Policy. As discuss d
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upp y System identified most of the violations and has taken corrective actions which we consider prompt and comprehensive.
We believe it is important to note that the Supply System identified most of the current violations, and important to recognize that this is, in and of itself, a sign of improved performance on the part of the Supply System.
However, the fact that these violations occurred, particularly in light of the NRC having taken escalated enforcement action in 1995 for violations with similar root causes, remains a significant regulatory concern.
The NRC takes escalated enforcement action infrequently and does so, in part, to encourage prompt and comprehensive corrective action to prevent potentially significant violations from recurring.
Thus, notwithstanding the Supply System's efforts in identifying and correcting the current violations, and to emphasize:
1) the significance of taking corrective actions that are effective in precluding similar violations; and 2) the fundamental importance of having an effective program for assuring that surveillances are performed as required, I have been authorized, after consulting with the Director, Office of Enforcement and the Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations and Research, to issue the enclosed Notice proposing a $ 100,000civil penalty in accordance with the discretion described in Section VII.A.1 of the Enforcement Policy.
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.
After reviewing your response to this Notice, including your proposed corrective actions and the
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Washington Public Power Supply System-3-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, its enclosure, and your response will be placed in the NRC Public Document Room (PDR).
To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction.
Sincerely, L
. Callan Regional Administrator Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalty Docket No.: 50-397 License No.:
NPF-21 cc w/Enclosure:
Frederick S. Adair, Chairman Energy Facility Site Evaluation Council P.O. Box 43172 Olympia, Washington 98504-31 72 Chairman Benton County Board of Commissioners P.O. Box 69 Prosser, Washington 99350-0190 Mr. Paul R. Bemis (Mail Drop PE20)
Vice President, Nuclear Operations Washington Public Power Supply System P.O. Box 968 Richland, Washington 99352-0968 Mr. Rodney L. Webring (Mail Drop PE08)
Vice President, Operations Support/PIO Washington Public Power Supply System P.O. Box 968 Richland, Washington 99352-0968
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Washington Public Power Supply System Mr. Greg O. Smith (Mail Drop 927M)
WNP-2 Plant General Manager Washington Public Power Supply System P.O. Box 968 Richland, Washington 99352-0968 Mr. David A. Swank (Mail Drop PE20)
Manager, Regulatory Affairs Washing, on Public Power Supply System P.O. Box 968 Richland, Washington 99352-0968 Mr. AI E. Mouncer (Mail Drop 396)
Chief Counsel Washington Public Power Supply System P.O. Box 968 Richland, Washington 99352-0968 Ms. Lourdes C. Fernandez (Mail Drop PE20)
Manager, Licensing Washington Public Power Supply System P.O. Box 968 Richland, Washington 99352-0968 Mr. Malcolm H. Phillips, Jr., Esq.
Winston 5 Strawn 1400 L Street, N.W.
Washington, D.C. 20005-3502
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