ML17284A805
| ML17284A805 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 11/06/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17284A804 | List: |
| References | |
| 50-397-98-15, NUDOCS 9811160314 | |
| Download: ML17284A805 (6) | |
Text
ENCLOSURE 1 NOTICE OF VIOLATION Washington Public Pow'er Supply System Washington Nuclear Project-2 Docket No.:
50-397 License No.:
'uring an NRC inspection conducted on.July 13-31, 1998, five violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:
A.
10 CFR Part 50, Appendix B, Criterion III, "Design Control," states, in part, "Measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in g 50.2 and as specified in the license application...
are correctly translated into specifications, drawings, procedures, and instructions.
Contrary to the above:
1.
As of January 15, 1996, the design basis to maintain a reserve volume of 135,000 gallons in the condensate storage tank, as addressed in Final Safety Analysis Report, Sections 6.3.2.2.1 and 5.4.6.2.2.1.f, and Technical Specification Bases, Section B 3.5.2, "ECCS - Shutdown," was not correctly translated into the plant design.
As of July 29, 1998, the license basis commitment to derive the technical specification allowable values from the analytic limitcorrected for process and all instrument uncertainties, except drift and calibration, specified in Technical Specification Bases, Section B 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation," was not correctly translated into the technical specifications.
Specifically, the derivation of the allowable value for Reactor Vessel Water Level Low Low Low - Level 1, in Table 3.3.5.1-1, "Emergency Core Cooling System Instrumentation," Items 1.a, 2.a, 4.a, and 5.a did not include a correction for post-accident harsh environment effects.
This is a Severity Level IV violation (Supplement 1) (50-397/9815-01) 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings,"
states, in part,,"Activities affecting quality shall be prescribed by documented instructions, procedures, 'or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions."
Contrary to the above, the following activities affecting quality were either not prescribed by documented instructions or were not accomplished in accordance with instructions.
1.
As of July 29, 1998, control panel marking was not always accomplished in accordance with Human Factors Engineering Standard (HFES) -10, "Demarcation Standard,"
Revision 0, Section 3.1, which required the use of 0.25-inch wide red demarcation lines to identify and enhance the visibilityof Category 1 post-accident monitoring instruments.
In addition, marking 98iiih03i4 98ii06 PDR ADOCK 05000397 6
requirements were not prescribed in documented instructions for Category 2 post-accident monitoring instruments.
Design verifications were not always accomplished as prescribed in Step 3.1.14 of Engineering Instruction El 2.15, "Preparation, Verification and Approval of Calculations," effective July 1 through August 9, 1991, or as prescribed in Step 4.1.15 of Engineering Department Procedure EDP 2.15, "Preparation, Verification and Approval of Calculations," Revision 0, effective August 10, 1991, through March 1996.
Both procedures state that the verifier performs a complete check of the calculation to ensure that it is technically correct, complete and accurate; however, the verifiers did not ensure that three site short-circuit calculations were technically correct in that they included nonconservative temperature assumptions.
Calculation modification record reviews were not always accomplished as required by Procedure EDP 2.15, "Preparation, Verification and Approval of Calculations," Revision 3. Specifically, Step 4.5.5 stated, "The CMR [calculation modification record] shall be prepared against the latest revision of the calculation and all outstanding CMRs against the calculation shall be considered.
The pertinent outstanding CMRs, which could affect the results/conclusions, shall be identified and accounted for in the CMR." However, as of July 29, 1998, the loads in outstanding Calculation Modification Records 92-0453, 92-0489, and 97-0173 related to Calculation E11-02-90-01 were not identified or accounted for in the calculation or in the informal working file that was routinely used by engineering to consider outstanding calculation modification records related to electrical load changes.
This is a Severity Level IVviolation (Supplement 1) (50-397/9815-02).
10 CFR Part 50, Appendix B, Criterion XVI,"Corrective Action," states, in part, that measures shall be established to assure that conditions adverse to quality such as deficiencies are promptly identified and corrected.
Final Safety Analysis Report, Section 8.3.2.1.2.2, "[HPCS (Division 3) 125-Volt DC System] Battery and Charger," states, in part, "The 125 V dc system is designed in accordance with applicable clauses of IEEE Standard 308-1974.
IEEE Standard 308-1974, Section 5.3.1 (6), "[Direct-Current Systems, General) Protective Devices states, in part, that "Protective devices shall be provided to limitthe degradation of the.
Class 1E power systems."
Contrary to the above, in September 1992, the licensee identified but did not promptly correct a design deficiency.
Specifically, the licensee identified that the protective device design for 125 V DC Distribution Panel E-DP-S1/HPCS did not limit degradation of the high pressure core spray Class 1E power system, when a fault occurred at the load side of the branch feeder breakers.
As of July 31, 1998, this condition had not been corrected.
This is a Severity Level IV violation (Supplement 1) (50-397/9815-03).
10 CFR Part 50, Appendix B, Criterion XI, "Test Control" states, in part, that a test program shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service was identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents.
Final Safety Analysis Report, Table 9.2-5, "Standby Service Water Flow Rates and Associated Heat Loads Used in the Ultimate Heat Sink Analysis," indicates a minimum flow to the Division 3 diesel generator of 780 gpm.
Surveillance Procedure OSP-SW-M103, "HPCS Service Water Valve Position Verification," Revision 2, a flow balance test, specifies a minimum acceptable flow to Heat Exchanger DCW-HX-1C of 780 gpm.
Contrary to the above, the thermal performance test program did not demonstrate that Heat Exchanger DCW-HX-1C would perform satisfactorily in service for all allowed high pressure core spray service water flows. Specifically, the fouling factor acceptance criterion, used to evaluate Heat Exchanger DCW-HX-1C thermal performance test results, was based on a minimum flow of 910 gpm and was not conservative for the minimum acceptable flow of 780 gpm.
This is a Severity Level IV violation (Supplement
- 1) (50-397/9815-05).
.i E.
Technical Specification 3.0.2 requires the riext surveillance test to be performed on or before 1.25 times the interval stated in the technical specifications.
On July 14, 1998, Technical Specification Surveillance Requirement 3.8 4.7 specified a 24-month frequency for the battery service test.
Contrary to the above, a battery service test for Division 2, Battery E-B1-2, was not performed on or before 1.25 times the interval stated in Technical Specification Surveillance Requirement 3.8.4.7.
Specifically, as of July 14, 1998, the battery service test for Division 2, Battery E-B1-2, had not been performed since April28, 1995, and had been due since October 28, 1997.
This is a Severity Level IVviolation (Supplement 1) (50-397/9815-06).
Pursuant to the provisions of 10 CFR 2.201, Union Electric is hereby required to submit a written statement or explanation for Violations A and B to the U. S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regiona! 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 each violation:
(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 willbe 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.
With respect to Violations C, D, and E, the NRC has concluded that information regarding the reason for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence, and the date when full compliance was or will be achieved is already adequately addressed on the docket in Inspection Report 50-397/98-15 dated November 6, 1998, and in Licensee Event Report 50-397/98-012-00.
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, 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).
If you contest any of the violations included in 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.
If you 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 6th day of November 1998.
0