IR 05000397/1997014
| ML17292B275 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 03/11/1998 |
| From: | Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Parrish J WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| References | |
| 50-397-97-14, NUDOCS 9803170048 | |
| Download: ML17292B275 (21) | |
Text
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SUBJECT:
NRC INSPECTION REPORT 50-397/97-14
Dear Mr. Parrish:
Thank you for your letter of October 16, 1997, in response to our September 16, 1997, letter and Notice of Violation. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We willreview the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.
Sincer Docket No.:
50-397 License No.:
/
Thomas P. Gwynn, D ect r Division of Reactor Pr je s
CC:
Chairman
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Energy Facility Site Evaluation Council P.O. Box 43172 Olympia, Washington 98504-3172 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 9803i70048 9803ii PDR ADQCK 05000397
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Washington Public Power Supply System-2-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 Washington Public Power Supply System P.O. Box 968 Richland, Washington 99352-0968 Mr. Albert E. Mouncer (Mail Drop 396)
Chief Counsel Washington Public "Power Supply System P.O. Box 968 Richland, Washington 99352-0968 Mr. Paul Inserra (Mail Drop PE20)
Manager, Licensing Washington Public Power Supply System P.O. Box 968 Richland, Washington 99352-0968 Perry D. Robinson, Esq.
Winston 8 Strawn 1400 L Street, N.W.
Washington, D.C. 20005-3502
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Senior Project Inspector (DRP/E, WCFO)
Branch Chief (DRP/TSS)
WCFO File Resident Inspector DRS-PSB MIS System RIV File DOCUMENT NAME: R:i WN2iWN714AK.HJW To receive copy of document, indicate in box: "C" = Copy without enctosures
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WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968
~ Richland, Washit i@ton 99352-0968 October 16, 1997 G02-97-192 Docket No. 50-397 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C, 20555 Gentlemen:
Subject:
WNP-2, OPERATING LICENSE NPF-21, NRC INSPECTION REPORT 97-14, RESPONSE TO NOTICE OF VIOLATION Reference:
Letter dated September 16, 1997, TP Gwynn (NRC) to JV Parrish (SS), "NRC Inspection Report 50-397/97-14 and Notice of Violation The Supply System's response to the referenced Notice of Violation, pursuant to the provisions of Section 2.201, Title 10, Code ofFederal Regulations, is enclosed as Attachment A.
Should you have any questions or desire additional information regarding this matter, please call Mr. P. J. Inserra at (509) 3774147.
tfully, Vice President, Nuclear Operations Mail Drop PE23 Attachment cc: EW Merschoff - NRC RIV KE Perkins, Jr. - NRC RIV, WCFO TG Colburn - NRR NRC Sr. Resident Inspector - 927N DLWilliams - BPA/399 PD Robinson - Winston &Strawn
NRC INSPECTION REPIN. I'7-14, RESPONSE TO NOTICE (6 VIOLATION Attachment A Page 1 of 8 VI LATI N A Resta ement of Viola i n WNP-2 Technical Specification (TS) 5.4.1.a requires written procedures to be established, implemented and maintained for the activities outlined in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Appendix A to Regulatory Guide 1.33 requires, in part, written procedures for each TS required surveillance test, as described in Section 8.b, and for combating emergencies and other significant events, including mispositioned control rod(s),
as described in Section 6.
Procedure TSP-CRD-C101, Revision 0, "CRD Scram Timing With Autoscramtimer System,"
provides instructions for performing control rod scram timing in accordance with TS requirements.
Step 7.1.13 directs operators to verify the rod to be scrammed is at position 48 or to move the rod to position 48, in accordance with approved rod withdrawal sheets.
Procedure 4.1.1.7A, Revision 3, "Recovery From Mispositioned Control Rods," directs operators, in part, to run a core monitoring program to identify any preconditioning overpower and to inform plant management prior to recovering the control rod(s).
Contrary to the above, on July 11, l,997, while the unit was in Mode 1, operators failed in two instances to follow plant procedures as follows:
l.
Operators withdrew Control Rod 18-55 out of sequence from that defined in the approved rod withdrawal sheets for Procedure TSP-CRD-C101.
2.
Subsequent to withdrawing Control Rod 18-55 out of sequence, operators failed to recognize the action as a mispositioned control rod and, therefore, failed to implement the requirements of Procedure 4.1.1.7A to run a core monitoring program and inform plant management prior to repositioning the rod.
This is a Severity Level IV violation (Supplement I).
Res nse o Violation A The Supply System accepts the violation.
Reason for Violation A The Supply System agrees with the staff's characterization of this event as given in the Violation and Report Details of the Reference.-
NRC INSPECTION~ I97-14, RESPONSE TO NOTICEg VIOLATION Attachment A Page2of 8 The reason for the control xod mispositioning event was failure of control xoom staff members to self-check their rod manipulation actions against the requirements of the rod pull sheet while performing scram time testing. A contributing factor to this erxor was confusion in the wording of an attachment to the scram time testing procedure which directed withdrawal of the selected rod rather than specifically directing the performers to the rod pull sheet.
Additionally, the contxol room staff did not recognize the event as a mispositioned control xod, and consequently did not meet management's expectation for use of plant pxocedure 4.1.1.7A, Recovery from Mispositioned Contxol Rods, and for recording events of this type in the contxol room log.
Further, it is recognized that the corrective actions taken as a result of a similar event in 1994 did not prevent recurrence.
Corrective Actions Taken and Results Achieved Issued an Operations Night Order directing review of this event and reinforcing the management expectation that plant procedure 4.1.1.7A be used whenever a control rod is positioned to a position other than specified on the rod pull sheet.
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Operations Manager met with the contxol room personnel involved in this event to discuss the expectation that plant procedure 4.1.1.7A be used any time the existing contxol rod'pattern is not in full compliance with the rod pull sheet, and the expectation that events of this kind be recorded in the contml room log.
The Control Room Operator involved has been placed on a personal performance improvement plan.
I'bservation of the involved Shift Technical Advisor's (STA) performance has been conducted and documented in ten subsequent successful xod manipulations. 'Ihe STA has also been coached to reinforce the need for attention to detail and to minimize distractions when, moving contxol rods.
The control rod scram time testing procedure has been changed to direct performers to refer to the rod pull sheet for identification of requixcd rod manipulations.
Corrective St s That WillBe Taken to Avoid Further Violations Format xcquixcments for better human factored rod pull sheets willbe developed.
Plant procedures directing manipulation of control rods will be revised to refer to plant procedure 4.1.1.7A any time a control rod is placed in a position other than that specified on the control md pull sheet.
NRC INSPECTION RE~ I'7-14, RESPONSE TO NOTICE IC VIOLATION Attachment A Page 3 of 8 The definition of mispositioned control rods given in plant procedure 1.3.59, Reactivity Management, will be revised to be the same as the criteria given in plant procedure 4.1.1.7A to eliminate potential confusion.
Date ofFull Com liance The immediate corrective action of returning the control rod to its intended position and verification that the event had no detrimental impact on the core occurred shortly after the event.
However, full compliance was not achieved until three days later, on July, 14, 1997, when management was informed of the control rod mispostioning event per the requirements ot plant procedure 4.1.1.7A.
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R tatemen ofViola i n TS 5.5 requires that the Inservice Testing (IST) program described in TS 5.5.6 be properly implemented.
The WNP-2 IST Program requires that surveillance testing for Valve TIP-V-6 be performed on a refueling outage interval.
Contrary to the above, at the completion of Refueling Outage R12 (July 4, 1997), surveillance testing in accordance with the requirements of the IST program had not been performed on Valve TIP-V-6. This is a repetition of previous violations described in NRC Inspection Report 50-397/96019.
This is a Severity Level IV violation (Supplement I).
Res nse to Violation B The Supply System accepts the violation.
Reason for Violation B The Supply System agrees with the staff's characterization of this event as given in the Violation and Report Details of the Reference.
The Inservice Testing Program Lead Engineer discovered an error in the recently performed IST procedure OSP-TIP/IST-R701.
The procedure is required to be performed each refueling outage and is used to exercise the TIP purge inboard containment isolation check valve, TIP-V-6, as required by 'the WNP-2 IST Program Plan.
The procedure allows credit to be taken for successful completion of a LLRT to demonstrate the exercise of TIP-V-6.
However, the procedure did not specify that the LLRT had to be performed during the most recent refueling
I NRC INSPECTION REPf I'7-14, RESPONSE TO NOTICEf VIOLATION Attachment A Page 4 of 8 outage to be acceptable.
No LLRT of TIP-V-6 was required to be performed during the 1997 refueling outage.
LLRT-results for this valve from the 1996 refueling outage were used and the procedure was erroneously accepted as complete.
The reason for the violation was a procedure inadequacy in that the IST procedure did not contain direction to specify that the use of LLRT data to verify the exercise of TIP-V-6 was acceptable only ifthe LLRT had been performed during the most recent refueling outage.
As pointed out in the Report Details of the Reference, there were two previous occurrences of the IST Program Lead identifying missed surveillances after the components had been returned to service. In recognition of this continuing problem, corrective actions to improve the quality of review of the performed IST procedures prior to returning the equipment to service have been taken as specified below.
orrective Action Taken and Results Achieved Revised IST procedure to clarify the need for TIP-V-6 exercise if LLRT was not performed within one year prior to performance of the procedure.
Performed a review of IST procedures performed during the most recent refueling outage to verify other IST Program Plan requirements have been met.
rrective S e That WillBe Taken to Avoid F irther Violation Other IST Program Plan procedures mill be reviewed and revised as necessary to clearly specify the IST Program Plan acceptance criteria requirements."
TIP-V-6 will be stroked closed in accordance with the exigent Technical Specification Amendment approved on September 18, 1997.
Preoutage training for control room staff will be completed on IST Program acceptance criteria to enable the control room staff's adequate review of performed IST procedures.
The plant Master Startup Checklist will be revised to add a verification step tor the IST Program.
Lead Engineer to verify that the IST procedures necessary for plant startup have been performed as required.
Date fF ill om liance Full compliance was achieved on September 18, 1997 when the exigent Technical Specitication Amendment for TIP-V-6 was approved.
NRC INSPECTION REPC.T 97-14, RESPONSE TO NOTICEC VIOLATION (
Attachment A Page 5 of 8 L
Re tatemen of Violation TS Limiting Condition for Operation (LCO) 3.6.1.3 requires each primary containment isolation valve to be operable while in Modes 1, 2, and 3.
i TS 3.6.1.3.A.1 (the applicable conditions) requires, in part, with one or more primary containment isolation valves inoperable, isolate the affected penetration flow path by use of at least one closed and deactivated automatic valve within 4-hours.
The penetration may be unisolated intermittently under administrative controls.
TS 5.5.6.c states that the provisions of TS Surveillance Requirement (SR) 3.0.3 are applicable to inservice testing activities.
TS SR 3.0.3 states, in part, "Ifit is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is less... Ifthe Surveillance is not performed within the delay period, the LCO must immediately be declared not met and the applicable condition(s) must be entered..."
Contrary to the above, between July 18 and August 12, 1997, while the unit was in Mode 1 and with Valve TIP-V-6 inoperable, the affected penetration was unisolated continuously and without administrative controls. Valve TIP-V-6 should have been considered inoperable because the IST Surveillance for valve TIP-V-6 was not performed within its specified frequency and the surveillance could not be performed in the current operating mode (as such, TS LCO 3.6.1.3 was required to be declared "not met" and the applicable conditions were required to be entered)
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This is a Severity Level IV violation (Supplement I).
Res nse to Violation C The Supply System accepts the violation.
Reason for Violation The Supply System agrees with the staff's characterization of this event as given'in the Violation and Report Details of the Reference.
The reason for this violation is misinterpretation of guidance contained in NUREG l482 allowing use of Generic Letter (GL) 91-18 for determining operability of TIP-V-6.
This misinterpretation resulted in inappropriate reopening of the TIP purge penetration.
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V NRC INSPECTION REPIC I'7-14, RESPONSE TO NOTICE(f VIOLATION Attachment A Page6of8 Additionally, the Supply System recognizes the similarity of the two previous issues involving misinterpretation of regulations identified in the Report Details of the Reference.
In all three cases, interpretations of TS, or generic correspondence relating to TS compliance, were made by plant Licensing personnel that, upon further review by the NRC staff, were determined to be incorrect.
In all three cases, other guidance (non-Tech Spec)
was used to interpret the requirements of Technical Specifications.
Correc ive Actions Taken and Results Achieved After receiving clarification from the NRC staff concerning the proper interpretation of NVREG 1482; the TIP-V-6 penetration was reclosed, isolating the TIP purge penetration to primary containment.
A Problem Evaluation Request initiated.
rrec ive Ste That Will Be T ken to Avoid Further Vi lation Plant Licensing staff will complete training regarding compliance with the current enforcement standards applied by the NRC staff.
The training will specifically address the requirement that plant Technical Specifications are to be interpreted in a verbatim manner and the requirements therein are not modified by guidance contained in other documents.,
Date of Full Com liance After receiving clarification from the NRC staff concerning the proper interpretation of NVREG 1482, full compliance was achieved when the TIP-V-6 penetration was reclosed on August l'2, 1997, isolating the TIP purge penetration to primary containment.
VI LATION8 Restatement of Violation TS 5.4.1.a requires written procedures to be established, implemented, and maintained tor the activities outlined in Regulatory Guide 1.33, Revision 2, Appendix A, February l978. Appendix A to Regulatory Guide 1.33 requires, in part, written procedures tor implementation of the As Low As Reasonably Achievable (ALARA)program, as described in Section 7.e.
Procedure 11.2.2.5, Revision 6, "ALARAJob Planning and Reviews," requires both Level I and Level II ALARAreview to be performed and approved for radiation work permits associated with work in areas where the general area dose rates exceed 100 mrem/hr deep dose equivalent.
NRC INSPECTION RES.T 97-1iI, RESPONSE TO NOTICE O'IOLATION ((
Attachment A Page 7 of 8 Contrary to the above, on August 6, 1997, while the unit was in Mode 1, work was performed in a reactor water cleanup pump room, with general area dose rates that exceeded 100 mrem/hr deep dose equivalent, under a radiation work permit that did not have completed and approved Level
and Level IIALARAreviews.
This is a Severity Level IV violation (Supplement IV).
Res nse to Violation D The Supply System accepts the violation.
Reason for Violation D The Supply System agrees with the staff's characterization of this event as given in the Violation and Report Details of the Reference.
The failure to perform Level I & II AI.ARA reviews for the subject work was due to the oversight oftwo individuals in the radiation work permit (RWP) planning and approval process.
First, the ALARAplanner failed to include Level I 8. II reviews in the subject ALARATask prior to routing the RWP for further review and approval.
Second, the HP supervisor failed to note the missing Level I Ec II reviews as part of the RWP approval process because of his estimation of low importance for review of a recurring "generic" RWP, and because of unclear procedural guidance directing the review.
Further, it is recognized that the corrective actions taken as a result of an earlier similar event in 1997 did not adequately address the generic impact of the event and did not prevent recurrence.
Corrective Actions Taken and Results Achieved The involved personnel have been counseled concerning the importance of attention to detail and following existing procedural guidance.
A review of ALARATasks attached to currently active RWPs has been completed to ensure the required Level I &, II reviews have been completed.
t orrective Ste That Will Be Taken to Avoid Further Viola ion The appropriate procedures willbe revised to provide an action step in the RWP approval process to review the Level I 8. IIALARAreviews when required.
Procedural guidance willbe developed to ensure appropriate use ofgeneric ALARATasks in high radiation areas.
NRC INSPECTION RE
. I'97-14, RESPONSE TO NOTICE
. VIOLATION Attachment A Page 8 of 8 Eliminate the procedural requirement to perform Level I 8: II ALARA reviews on recurring generic ALARATasks, and substitute pre-job briefings to provide current task information to the users ofgeneric RWPs.
Develop computer-based search reports to verify completion of required Level I 8. II ALARA reviews on RWPs.
Rewrite the Level I 2 II ALARAreview questions to better focus the review on the specific ALARAtask being planned.
Da eof Full Com liance Level I and IIALARAreviews were completed for the subject work on 12 August, 1997.
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