ML17285A905
| ML17285A905 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 12/21/1989 |
| From: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| Shared Package | |
| ML17285A906 | List: |
| References | |
| EA-89-130, NUDOCS 8912260091 | |
| Download: ML17285A905 (3) | |
Text
~yg RKgy
~C Wp
+
0
)
I oo
+a*++
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION V 1450 MARIALANE,SUITE 210, WALNUTCREEK, CALIFORNIA94596 Docket No.
50-397 License No.
NPF-21 EA 89"130 DFCgg$ 89 Washington Public Power Supply System ATTN:
Mr.
G.
C.
- Sorensen, Manager Regulatory Programs Post Office Box 968 3000 George Washington Way
- Richland, Washington 99352 Gentlemen:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF A CIVIL PENALTY-
$50,000 (NRC INSPECTION REPORT NOS. 50-397/89-21, 50-397/89"22, AND 50-397/89"28)
This refers to the NRC inspection conducted from March 27 - April 7, and May 8-26, 1989, of activities authorized by NRC License No.'PF-21.
The inspection included a review of the procurement program implemented at WNP-2.
The report documenting this inspection was sent to you by letter dated June 23, 1989.
As a result of this inspection, failures to comply with NRC requirements were identified.
The apparent violations, their causes, and your corrective actions were discussed with you during an enforcement conference held in this office on June 28, 1989.
The summary of the enforcement conference was sent to you on July 21, 1989.
A followup inspection to assess the adequacy of your reevaluation for suitability of use of'ommercial grade components installed in safety-related systems was subsequently conducted on September 11-14, 1989.
The inspection report documenting our review of your reevaluations was sent to you by letter dated October 12, 1989.
Further changes to your procurement programs were discussed during a management meeting held on November 20, 1989.
The violation in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) involves a number of failures to adequately assure the quality of installed items purchased
-as commercial grade.
Specifically, on numerous occasions in 1987 and 1988, commercial grade items were purchased and either installed or made available for installation in safety-related systems at WNP-2 without adequately evaluating the suitability of the items for such use.
You failed to either audit the suppliers of these items to ensure that appropriate quality assurance measures consistent with 10 CFR Part 50, Appendix 8, were implemented during the manufacturing process, or identify and require the performance of suitable tests or examinations to verify the adequacy of CERTIFIED MAIL BlllEEVT RE IIESl'EO i226.09 O50OO3$ 7
('1 i 89122i pop ADQCK pDC lg
Mashington Publ'ic Power Supply System QEC 2
~
198S the items for their intended applications.
A fundamental flaw in your procure-ment program appears to be the failure to adequately identify each commercial grade item's critical characteristics that must be inspected or tested to verify its suitability for use in a safety-related application.
This failure conflicts with the requirement to implement ANSI N18.7, specified in your FSAR as the method chosen to comply with 10 CFR Part 50, Appendix B.
After this concern was brought to your attention in the June 28, 1989 Enforcement Conference, our follow-up inspection of items already installed found the items to be acceptable for the function intended;
- however, the underlying programmatic problem of adequately identifying critical characteristics of commercial grade items and properly verifying their adequacy remained unchanged.
Subsequent discussions concerning your long term corrective action regarding commercial grade items available for installation and future procurement practices were held during the November 20, 1989 management meeting.
Though those changes now appear to be -addressing our
- concerns, they have not yet been inspected.
To emphasize the need to properly assure the quality of materials used in safety-related structures, systems and components, I have been authorized, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Nuclear Materials Safety, Safeguards, and Operational
- Support, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of $50,000 for the violations described in the enclosed Notice.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1989 Enforcement Policy), the violations described in the enclosed Notice have been categorized as a Severity Level III problem.
The base value of a civil penalty for a Severity Level III problem is $50,000.
The escalation and mitigation factors of the Enforcement Policy were considered.
The civil penalty was mitigated 50K because of prior overall good performance.
However, despite several meetings and exchanges of correspondence with the NRC concerning procurement, your corrective actions for these violations failed to fully address the need to properly evaluate and specify the critical charac-teristics required for proper dedication of commercial grade items.
Accordingly, the penalty was escalated 50K for inadequate corrective actions.
No other adjustments were considered appropriate.
Therefore, overall, no adjustment to the base penalty appears warranted.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparinq 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 the
.Notice, including your proposed corrective actions and the 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 Section 2.790 of the NRC's "Rules of Practice,"
Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure wi 11 be placed in the NRC Public Document Room.
Mashington Public Power Supply System OEC
~ i f889 The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Action of 1980, Pub.
L.
No.95-511.
Sincerely,
Enclosures:
Notice of Violation and Proposed Imposition of Civil Penalty Pv n
Regional Administr cc w/enclosure:
C.
M. Powers, MNP-2 Plant Manager A.
G. Hosier, WP-2 Licensing Manager G.
D. Bouchey, Director, Assurance 8 Licensing G.
E.
Doupe, Esq.,
MPPSS A.
L. Oxsen, Assistant Managing Director for Operations, MD/1023 N.
S.
- Reynolds, Esq.