ML17285A907
| ML17285A907 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 12/21/1989 |
| From: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17285A906 | List: |
| References | |
| EA-89-130, NUDOCS 8912260093 | |
| Download: ML17285A907 (5) | |
Text
NOTICE OF VIOLATION AND PROPOSED IMPOSITION QF CIVIL PENALTY Washington Public Power, Supply System
- Richland, Washington Docket No.
50-397 License No.
NPF-21 EA 89-130 During the Nuclear Regulatory Commission (NRC) inspections conducted between March 27 and September 14, 1989, violations of NRC requirements were identified.
In accordance with the "General Statement of, Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (j.989) the following violation was identified:
10.CFR Part 50, Appendix B, Criterion III, "Design Control," requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications,
- drawings, procedures, and instructions.
These measures shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled.
Measures shall a1so be established for the selection and review for suitability of application of materials,
- parts, equipment, and processes that are essential to the safety-related functions of the structures,
- systems, and components.
Contrary to the above, the licensee failed to establish and implement adequate measures to assure that quality standards are specified and included in design documents, and for the selection and review for suitability of application of materials, parts, and equipment that are essential to the safety-related functions of systems and components.
Specifically, the following are examples of items purchased commercial grade that were either installed or.available for installation in safety-related systems for which,an adequate evaluation for suitability of application had not been performed:
l.
Evaluation 668 dedicated a commercial grade Potter-Brumfield MDR type control circuit relay for use in the safety-related emergency diesel generator "Loss of Power" control circuit.
The evaluation did not specify appropriate quality standards nor otherwise assure that the replacement component was selected and reviewed for suitability of application in its safety-related function.
The evaluation was primarily based, upon advertised specifications that the licensee failed to verify either through audits of the manufacturing process or through identification of critical characteristics that must be inspected or tested.
Consequently, the component was installed in a safety-related application on May 17, 1988, without assurance that design seismic requirements were met.
2.
Evaluation 1179 dedicated Anchor-Darling valve parts purchased commercial grade for use in the safety-related high pressure core spray system.
The evaluation did not specify quality standards, such as fabrication under appropriate aspects of the vendor's approved equality Assurance
- Program, or identify the replacement parts critical characteristics that must otherwise be inspected or tested to assure suitability for for application prior to the components'nstallation per Maintenance Work Request dated April ll, 1988.
8912260093 891221 F'DR ADOCK 0 000397 PDC
4 ~
5.
6.
7.
8.
Standard Procurement Policy No. 6, dated June 30, 1987, dedicated commercial grade fuses for installation in safety-related electrical systems.
The policy did not specify appropriate quality standards nor assure that critical characteristics were identified for inspection or testing.
The policy was inadequate in that it was based in part on:
(I) the licensee's understanding of the manufacturing process for which no audits of the manufacturer were performed or required to be performed by the licensee, (2) Underwriters Laboratory (UL) activities which UL advised are not sufficient to derive any statistical inference with regard to product quality, and (3) functional compliance demonstrated by inspection and installation tests that did not cover the expected range of component operating conditions.
A pressure switch was purchased commercial grade under Purchase Order (PO) 89583 and installed on July 20, 1987 in a safety-related application in the control circuitry for the emergency diesel generator starting air compressor.
The licensee failed to either (1) properly audit the vendor's manufacturing process or (2) specify and conduct appropriate inspections or testing to assure that critical characteristics of the components were suitable for their intended safety-related application.
Metallic 0-rings were purchased commercial grade under PO 90163 and were installed in the discharge flange assembly of RHR relief valve RHR-RV-IB, during the 1988 refueling outage (April-June, 1988).
The PO required a
Certified Material Test Report (CMTR) from the vendor to assure appropriate quality standards.
However, the licensee failed to either assure the validity of the CMTR'hrough an audit of the vendor, or specify inspections or tests to verify the critical characteristics=of the O-rings.
Various General Electric relays were purchased under PO 94920 from North Coast Electric as replacement parts for safety-related applications.
As of May 26, 1989, the licensee's evaluation process performed to dedicate these components was inadequate in that the licensee dedicated the components for use in safety-related applications prior to (1) auditing the suppliers of the components and (2) conducting tests to assure that the components would perform in accordance with applicable critical characteristics.
A York (Division of Borg-Warner) chiller shaft was purchased under PO 20173.
As of May 26, 1989, the licensee failed to either perform an audit of the vendor's manufacturing process or evaluate the critical characteristics and specify any inspection or testing necessary to assure the adequacy of the component for its intended safety-related application.
A pump shaft was purchased as commercial grade from Ingersoll-Rand under PO 70808 for use as a spare part for emergency cooling water pumps.
As of May 26, 1989, the licensee failed to either (1) audit the vendor's manufacturing process or (2) specify inspections or tests to assure that the component's critical characteristics were suitable for its intended safety-related application.
Pressure gauges were purchased from Paramount Supply for various safety-related applications under PO 83283 in 1986.
The licensee failed to either conduct or verify that an appropriate audit of the vendor's manufacturing process was conducted until another'utility performed a
February 1989 audit.
This is a Severity Level III Violation (Supplement I).
Civil Penalty - $50,000.
Pursuant to the provisions of 10 CFR 2.201, Washington Public Power Supply System (Licensee) is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of this Notice.
This reply should be clearly marked as a "Reply to a Notice of Violation", and should include for each alleged violation:
(1) Admission or denial of the alleged violation; (2) the reasons for the violation if admitted; (3) the corrective steps that have been taken and the results achieved; (4) the corrective steps that will be taken to avoid further violations; and (5) the date when full compliance will be achieved.
If an adequate reply is.not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked, or why such other action, as may be proper, should not be taken.
Consideration may be given to extending the response time for good cause shown.
Under the authority of Section 182 of the Act, 42 U.S.C.
2232, this response shall be submitted under oath or affirmation.
within the same time as provided for the response required above under 10 CFR 2.201, the licensee may pay the civil penalty by letter to the Director, Dffice of Enforcemeni, U.S.
Nuclear Regulatory Commission, with,a check, draft, or money order payable to the Treasurer of the United Siates in the
'amount of the civil penalty in whole or in part by a written answer addressed io the Director, Dffice of Enforcement, U.S. Nuclear Regulat'ory Commission.
Should ihe licensee elect io file an answer in accordance with 10 CFR 2.205 protesting the civil ~enaliy, in whole or in part, such answer should be clearly marked as
.an
'Answer io a'otice of Violation", and may: (1) Deny the
,violations listed in this Notice in whole or in part; (2) demonstrate extenuating circumstances; (3) show error in this Notice; or'4) show other reasons why ihe penaliy should not be imposed.
In.addition to protesting the civil penalty, such answer may request remission or mitigation of the penalty.
In requesting miiigation of the proposed penaliy, the factors addressed in Section V.B. of 10 CFR Part 2, Appendix C (1988 and 1989) should be addressed.
Any written answer in accordance with 10 CFR 2..205 should be set forth separately from the statement or explanation in reply pursuant io 10 CFR 2.201, bui may incorporate parts of the 10 CFR 2.-201 reply by specific reference (e.g., citing paqe
.and paragraph numbers) to avoid repetition.
The attention of the licensee ss directed to other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty.
Notice of Violation Upon failure to pay any civil penalty due which subsequently has been determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty, unless compromised,'emitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C.
2282c.
The responses to the Director, Office of Enforcement, noted above (Reply to a
Notice of Violation letter with payment of civil penalties, and an answer to a Notice of Violation), should be addressed to: Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.
C.
20555, with a copy to the Regional Administrator, U.S.
Nuclear Regulatory Commission, Region V, 1450 Maria Lane, Suite 210, Walnut Creek, California 94596, and a copy to Mr. C. Bosted, Senior Resident Inspector, at the WNP-2 plant.
FOR THE NUCLEAR REGULATORY COMMISSION
'I j;~%on ar
>n Regional Administra Dated at Walnut Creek, California on this A/ar day of December 1989