ML17284A639
| ML17284A639 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 06/01/1998 |
| From: | Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Parrish J WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| Shared Package | |
| ML17284A640 | List: |
| References | |
| 50-397-97-13, EA-97-138, EA-97-573, NUDOCS 9806040391 | |
| Download: ML17284A639 (7) | |
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. CATEGORY 2 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS) 4)ACCESSION NBR:9806040391 DOC.DATE: 98/06/01 NOTARIZED: NO jj CIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe UTH.NAME AUTHOR AFFILIATION'RSCHOFF,E.W.
Region 4 (Post 820201)
RECIP.NAME RECIPIENT AFFILIATION PARRISH,J.V..
Washington Public Power Supply System DOCKET 05000397
SUBJECT:
Discusses 980310
& 23 ltrs in-response to 980209 insp rept Ec forwards NOV.Xnspection completed 980112.Two apparent violations involved failures to perform adequate SE when
'RCIC sys downgraded
& maintain acceptance criteria for RCIC.
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TITLE: 'General (50 Dkt)-Xnsp Rept/Notice of'Violation Response NOTES:
A RECIPIENT XD CODE/NAME PD4-2 PD INTERNAL: ACRS AEOD XLE CENTE NRR/DRPM/PECB NUDOCS-ABSTRACT OGC/HDS3 AL: LITCO BRYCE,J H NRC PDR COPIES LTTR ENCL "1
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UNITED STATES NUCLEAR REGULATORYCOMMISSION REGION IV 611 RYAN PLAZADRIVE. SUITE 400 ARLINGTON.TEXAS 76011 8064 June 1,
1998 EA 97-573 Mr. J. V. Parrish (Mail Drop 1023)
Chief Executive Officer Washington Public Power Supply System P.O. Box 968 Richland, Washington 99352-0968
SUBJECT:
NOTICE OF VIOLATIONAND EXERCISE OF ENFORCEMENT DISCRETION (NRC INSPECTION REPORT 50-397/97-13)
Dear Mr. Parrish This refers to your letters dated March 10 and 23, 1998, in response to our letter and inspection report dated February 9, 1998. The inspection was completed January 12, 1998, and it identified two apparent violations of NRC requirements related to the reactor core isolation cooling (RCIC) system at the Washington Nuclear Project-2 facility. The apparent violations involved failures to: (1) perform an adequate safety evaluation in accordance with 10 CFR 50.59 when the RCIC System was downgraded from a safety-related system to a nonsafety-related system without NRC approval (we stated that this downgrade apparently constituted an unreviewed safety question), and (2) maintain the acceptance criteria for the opening stroke-time testing of six RCIC System valves and the failure to maintain inservice testing of Valve RCIC-V-45 as required by 10 CFR 50.55a(f). Our February 9 letter indicated that the NRC was considering escalated enforcement action for these apparent violations and requested that the Washington Public Power Supply System (Supply System) respond to the apparent violations in writing, or request a predecisional enforcement conference.
The Supply System opted to submit a written reply.
In its March 10 letter, the Supply System admitted the violations and emphasized that the actual impact to the RCIC System was very small, that the downgrade resulted in minimal impact on system reliability during the downgrade period, and that the risk associated with the downgrade was considered small. The Supply System acknowledged that it misapplied generic technical guidance, and that this resulted in a failure to identify an unreviewed safety question.
In addition, the Supply System stated that although it had informed the NRC of its intent to downgrade RCIC, a license amendment should have been specifically sought for downgradiiIg the system.
The Supply System also agreed with the NRC's view that the inappropriate downgrading of the RCIC System resulted in the failure to maintain the acceptance criteria for the opening stroke-time testing of six RCIC System valves and the failure to maintain inservice testing of Valve RCIC-V-45.
The March 10 letter also described a number of corrective actions related to the RCIC downgrade issues and the more general concern of the inappropriate use of generic guidance related to other safety evaluations.
We noted that, in its March 19, 1998, letter, the Supply System stated that it had completed on March 16, 1998, a comprehensive review of other safety 980b00039i 980b01 PDR ADOCK 05000397 8
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Washington Public Power Supply System, evaluations and associated changes made to the facility since startup to determine ifthe misapplication of generic guidance resulted in other similar violations.'ased on the information developed during the inspection, and the information provided in the March 10 letter, the NRC has determined that violations of NRC requirements occurred.
A detailed description of the circumstances resulting in these violations was contained in the inspection report, and are cited in the enclosed Notice of Violation (Notice). These violations include failures to: (1) perform a safety evaluation in accordance with 10 CFR 50.59 prior to downgrading the RCIC system from a safety-related system to a nonsafety-related system, a change which constituted an unreviewed safety question, and (2) maintain the acceptance criteria for the opening stroke-time testing of six RCIC System valves and the failure to maintain inservice testing of Valve RCIC-V-45 as required by 10 CFR 50.55a(f).
The NRC agrees with the Supply System's position regarding the safety consequences of these violations, discussed above.
Although the system was nonconforming, it was found to be operable.
The significance of these violations rests in the processing failures that occurred, failures which, ifapplied to other modifications or changes to plant systems and procedures, could adversely affect plant safety.
In addition, the NRC normally considers as significant failures to properly implement 10 CFR 50.59 in situations involving an unreviewed safety question that could have a safety impact. Therefore, these violations are classified in the aggregate at Severity Level III in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600.
In accordance with the Enforcement Policy, normally a civil penalty with a base value of $55,000 is considered for a.Severity Level III problem.
Given prior escalated enforcement action against the Supply System, and the NRC's identification of these violations, a civil penalty would have resulted had we followed the normal civil penalty assessment process described in VI.B.2 of the Enforcement Policy. However, in consideration of the circumstances of this case, and after consultation with the Director, Office of Enforcement, I have been authorized not to assess a civil penalty, in accordance with VII.B.6of the Enforcement Policy. Specifically, the NRC's basis for discretion include: (1) the NRC's determination that the reason for these violations (i.e., the misinterpretation of industry guidance documents) was similar to the reasons for these violations related to response-time testing procedures (EA 97-138) for which the NRC has recently issued enforcement action, (2) the corrective actions for EA 97-138 encompass the corrective actions for this issue, and (3) the fact that the Supply System continued to meet the Technical Specification surveillance requirements even after RCIC was downgraded.
'he NRC notes similarities in the reasons for the occurrences between this issue and another recent issue.
On February 20, 1998, the NRC issued a Notice of Violation and Exercise of Enforcement Discretion involving the Supply System's inappropriate use of generic industry guidance regarding changes made to response-time testing procedures (EA 97-138). The Supply System's corrective actions involving its comprehensive review of other safety evaluations was actually begun as a result of this previous enforcement action, but had not been started at the time this RCIC downgrade issue had been identified.
Washington Public Power Su'pply System The.NRC has concluded that information regarding the reason for the violations, the corrective actions taken and planned to coirect these violations and prevent recurrence, and the date when full compliance was achieved is already adequately addressed on the docket in the Supply System's letters dated March 10 and 23, 1998; and the subject inspection report. Therefore, no further response is required unless the description therein does not accurately reflect your corrective actions or your position.
In that case, or ifyou choose to provide additional information, you should followthe instructions specified in the enclosed Notice.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and any response you choose to submit will be placed in the NRC Public Document Room.
'incerely, QL(~7/bl.
g> Ellis VL Merschoff Regional Administrator Docket No.: 50-397 License No.: NPF-21
Enclosure:
Notice of Violation cc w/
Enclosure:
Chairman 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 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
Washington Public Power Supply System, 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 & Strawn 1400 L Street, N.W.
Washington, D.C. 20005-3502
i Washington Public Power Supply System
- EA 97-573 i
bcc w/
Enclosure:
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DOCUMENT NAME: G:iEA<CASES>WNPRCIC>EA97573.
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