ML17284A789
| ML17284A789 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 10/16/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17284A788 | List: |
| References | |
| 50-397-98-20, NUDOCS 9810220286 | |
| Download: ML17284A789 (3) | |
Text
ENCLOSURE 1 NOTICE OF VIOLATION Washington Public Power Supply System Washington Nuclear Project-2 Docket No.:
50-397 License No.:
NPF-21 During an NRC inspection on August 24 through September 17, 1998, three violations'of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," (Enforcement Policy) NUREG-1600, Revision 1, the violations are listed below:
A.
10 CFR 50.65(a)(1) states, in part, that holders of an operating license shall monitor the performance or condition of structures, systems, and components (SSC), as defined by 10 CFR 50.65(b), against licensee-established goals, in a manner sufficient to provide reasonable assurance that such SSCs are capable of fulfillingtheir intended functions.
When the performance or condition of an SSC does not meet established goals, appropriate corrective action shall be taken.
10 CFR 50.65(a)(2) requires, in part, that monitoring as specified in 10 CFR 50.65(a)(1) is not required where it has been demonstrated that the performance or condition of an SSC is being effectively controlled through the performance of appropriate preventive maintenance, such that the SSC remains capable of performing its intended functions.
Contrary to 10 CFR 50.65(a)(2), as of July 10, 1996, the point in time that the licensee elected to not monitor the performance or condition of reactor building radioactive floor drain sump cross-connect valves (FDR-V-607, -608, and -609) against licensee-established goals pursuant to the requirements of 50.65(a)(1), the licensee'ailed to demonstrate that the performance or condition of the valves was being effectively controlled through the performance of appropriate preventive maintenance, such that they remained capable of performing their intended function (i.e., common mode flooding mitigation). Preventive'mainten.";""e of the cross-connect valves was stopped in 1995 and Valve FDR-V-609, residual heat removal pump Room C and low pressure core spray pump room floor drain cross-connect, failed to perform its intended function during the June 17, 1998, flooding event.
This is a Severity L'evel IVviolation (Supplement I) (50-397/9820-02).
B License Condition 2.C.(14) states, in part, that the licensee shall implement and maintain all provisions of the approved fire protection program as described in Final Safety Analysis Report, Appendix F, Section 9.5.1.
Final Safety Analysis Report, Appendix F, Table R.3-1, Section C.8, states that during operation those portions of the fire protection system that are designated as essential fire protection systems are subject to the applicable portions of the WNP-2 Operational Quality Assurance Program.
98i022028b 98iOib PDR ADQCK 05000397 6
PDR The WNP-2 Operational Quality Assurance Program requires, in part, that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances, be promptly identified, reported, and corrected.
0 Contrary to the above, between February 5 and June 17, 1998, the licensee failed to take prompt corrective actions for a condition adverse to quality. Specifically, on February 5, the licensee had identified personnel knowledge and procedural deficiencies in the control of hot work, which resulted in an inadvertent actuation of fire suppression diesel generator building corridor preaction system (System 66). Although procedural enhancements were defined shortly after the February event, the implementation of the enhancements was not scheduled until as late as August 1998. As a result, maintenance personnel performing similar hot work in the area of preaction System 66 on June 17, did not benefit from the procedural improvements and a second inadvertent actuation of System 66 occurred.
This is a Severity Level IVviolation (Supplement l)(50-397/9820-04).
Technical Specification 5.4.1.d requires that written procedures shall be established, implemented, and maintained covering Fire Protection Program implementation.
Procedure 1.3.10B, "Active Fire System Operability and Impairment Control,"
Revision 1, Section 4.4.5.b.1, requires that, with one or more Essential hose stations inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> provide gated wye(s) on the nearest operable hose station(s).
The wye shall be connected to sufficient hose to provide coverage for the area left unprotected by the inoperable hose station..
Contrary to the above, on June 26, 1998, following the planned impairment of the reactor building northeast stairwell hose stations (designated as Essential hose stations), sufficient hose was not connected to gated wyes on the nearest operable hose stations to provide coverage for the areas left
~ unprotected within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> ~< making the Essential hose stations inoperable.
This is a Severity Level IVviolation (Supplement l)(50-397/9820-06).
Pursuant to the provisions of 10 CFR 2.201, Washington Public Power Supply'System is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011, and a copy to the NRC Resident Inspector at the facilitythat is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for violation A: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.
Your response may reference or include previous docketed correspondence,.if the correspondence adequately addresses the required response.
If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
The NRC has concluded that information regarding the reasons for violations B and C, and the corrective actions taken and planned to correct the violations to prevent recurrence, is already adequately addressed on the docket in the enclosed NRC Inspection Report.
However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position.
In that case, or if you choose to respond, clearly mark your response as a "Reply to a Notice of Violation," and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region IV, and a copy to the NRC Resident Inspector at the facilitythat is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).
Ifyou contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.
Because your response willbe placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction.
If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. Ifyou request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
Dated at Arlington, Texas, this 16th day of 1998