ML17290A751
| ML17290A751 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 11/10/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17290A750 | List: |
| References | |
| EA-93-191, NUDOCS 9312030106 | |
| Download: ML17290A751 (10) | |
Text
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY Washington Public Power Supply System Washington Nuclear Project No.
2 (WNP-2)
Docket No.
50-397 License No.
NPF-21 EA 93-191 During NRC inspections conducted on May 3 through August 2, 1993, violations of NRC requirements were identified.
In accordance with the "General State-ment of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C, the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C.
- 2282, and 10 CFR 2.205.
The particular violations and associated civil penalty. are set forth below:
I.
- Violation Assessed a Civil Penalt Section 6.8. 1 of the Technical Specifications
- states, in part., that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Appendix A of Regulatory Guide 1.33, Section 4.e.
recommends procedures for operation of the Shutdown Cooling System.
WNP-2 Operating Procedure PPM 2.4.2, "Residual Heat Removal," Revision 16 (applicable from October 8, 1990, to June 17, 1992), stated in Paragraph 5.22 under the heading "Limitations:"
"During non-emergency conditions, do not align more than one RHR [Residual Heat Removal] loop in the suppression pool cooling mode at a time."
PPM 2.4.2, Revision 17 (applicable from June 18, 1992, to November 1,
1992), stated in Paragraph 4.23 under the heading "Precautions and Limitations:".
"During non-emergency conditions, do not align more than one RHR loop in the Suppression Pool Cooling mode at one time."
Contrary to the above, on September 30,
- 1991, and on July 6 and 11,
- 1992, during non-emergency conditions, operators placed two loops of RHR in the Suppression Pool Cooling Mode.
This is a Severity Level III violation (Supplement I).
Civil Penalty - $75,000.
(01013)
II.
Violations Not Assessed a Civil Penalt A.
Section 6.8. 1 of the Technical Specifications
- states, in part:
"Written procedures shall be established, implemented and maintained covering the activities referenced below:
9312030106 931110 PDR ADOCK 05000397 PDR
~
C.
g.
The applicable procedures recommended in Appeqdix A of Regulatory Guide 1.33, Revision 2, February 1978.
Refuel ing operations.
Fire Protection Program implementation."
Appendix A of Regulatory Guide 1.33 recommends the following procedures:
~
Section 1.c recommends a procedure for equipment control (e.g., locking and tagging).
Section-8.a recommends a procedure to ensure that tools,
- gauges, instruments, and other measuring and testing devices are properly controlled, calibrated, and adjusted at, specified periods to maintain accuracy.
Section B.b.(2)(a) recommends a procedure for containment and penetration leak-rate tests 1.
WNP-2 refueling procedure PPH 6.3.2, "Fuel Shuffling and/or
'ffloading and Reloading",
Revision 7, required:
~
In Step 6. 1, that the Refueling Floor Operator perform the
- steps, in order, listed on the Nuclear Component Transfer List.
~
In Attachment 8.4, "Bridge Manipulations During Refueling," that control rod blade guides be oriented with spacer buttons facing the control rod blades.
~
In Step 6. 1.3, that the Refueling Floor Operator verify the identity of each fuel assembly by orientation and location on the Nuclear Components Transfer List as it is loaded.
Contrary to the above:
a
~
b.
On May 9, 1993, the Refueling Floor Operator did not perform the steps, in order, listed on the Nuclear Component Transfer List, in that Step 250 was performed before Step 249.
As of May 12, 1993, during refueling, several blade guides were not oriented with spacer buttons facing the control rod blades.
c.
As of May 12, 1993, the orientation of a fuel bundle had not been properly verified as it was loaded in that it was found misoriented 90 degrees.
d.
As of May 23, 1993, the orientation of a fuel bundle had not been properly verified as it was loaded in that it was found misoriented 180 degrees.
WNP-2 Administrative Procedure PPM 1.3.10, Revision 12, "Fire Protection Program," in Section
- 6. 1, "Fire Protection System Impairments," states:
-'6. l.l.c. Examples of PLANNED impairments include...
Propping a normally closed fire door in the open position.
A fire protection system impairment permit is not required... provided ALL'of the following conditions can be met:...
The impaired component must be-attended (within line of sight).
6.1.2.c.
Impairments involving passive fire ponents (i.e., fire doo} s, dampers
... Must be documented by use of a Checklist, unless the requirements met."
protection com-and penetrations):
Fire Impairment of 6.l.l.d are Section 6.3.5.a states:
"... Combustible liquids. must be removed and put into storage at the end of the job or at the end of the shift if the job is not continuous between consecutive shifts."
Section 6.3.8.a states in part:
When removal is not possible, a Transient Combustible Permit is required. if the combustibles are to be left unattended for ~an length of time '(i.e.,
- breaks, lunch)"
Contrary to the above:
a.
On May 27, 1993, the fire door to the Division 1 battery charger room was propped open.
This impairment was unattended, as no licensee personnel were present at the door or within line of sight, and this impairment was not documented by a Fire Impairment Checklist.
b.
On July 19,
- 1993, combustible liquids were present in the Residual Heat Removal A pump room, having been left unattended since July 17,
- 1993, but no Transient Combustible Permit had been obtained.
Notice of Viol ati on
'3.
WNP-2 Administrative Procedure PPH 1.3'.29, Revision 18, "Locked Valve Checklist'," states in section
- 4. 1, "All locked valves greater than or equal to 2 inches shall be fixed in place using a shackle lock and chain."
Contrary to the above, on June 1,
1993, valves RRC-V-51A and RRC-V-51B (2-inch valves) were required by PPH 1;3.29 to be locked closed, but were not fixed in place by a lock and chain in that the handwheels secured by the locking device were not attached to the valves.
4.
WNP-2 Administrative Procedure PPM 1.5.4, Revision 16, "Control of Measuring and Test Equipment. Transfer Standards,"
Step 6.1.5.a, requires that 'personnel using measuring and test equipment (HRTE) ensure that each piece of HKTE is properly
- checked out from the METE Tool Crib.
Contrary to the above, on Hay 8,
- 1993, personnel used an MLTE gauge to perform a pressure test of Diesel Generator No. 2, engine B, cylinder 20, in accordance with Maintenance Work Request AP-1184, Step 2.40, which had not been checked out from the H&TE Tool Crib.
5.
WNP-2 Surveillance Test Procedure PPM 7.4.6. 1.2.4, Revision 7, "Containment Isolation Valve and Penetration Leak Test Program,"
Step 2. 1.6, states the following:
"Containment penetration components undergoing maintenance/repairs which could alter the leakage rate shall require... as-found... testing during the outage period in which the maintenance is performed, unless determined not required by the LLRT [local-leak rate test]
test coordinator."
Contrary to the above, on Hay 3,
- 1993, containment penetration valves RHR-V-16B and RHR-V-17B underwent maintenance.activities which could have altered the leakage rate and no as-found testing was performed nor determination made by the LLRT coordinator that the test was not required.
This is a Severity Level IV violation (Supplement I).
B.
Section 6.8. l.k of the Technical Specifications states that written procedures shall be established, implemented and maintained covering Health Physics/Chemistry Support.
Section
- 6. 12. 1 of the Technical Specifications states in part that "each high radiation area in which the intensity of radiation is greater than 100 mrems/h but less than 1000 mrems/h shall be barricaded and conspicuously posted as a high radiation area."
Notice of Violation Section 3. 1.7.4. 1 of the WNP-2 Health Physics Program Description (HPPD), Revision 34, states, "A'n area shall be posted as a radiation area where there exists radiation at such levels that a major portion of the body could receive in any one hour a dose of 2.5 millirem."
C.
WNP-2 Administrative Procedure PPH 1. 11. 11, Revision 2, "Entry Into, Conduct In and Exit from Radiologically Controlled Areas,"
Paragraph 4.6, states that "Persons entering a radiologically controlled area shall return barriers, altered for access, to their original position after passing."
Contrary to"the'above, 1.
On May 28,
- 1993, an area on the 522-foot elevation of the reactor building contained radiation levels greater than 100 mrem/hour, but was not conspicuously posted at all entrances to the area as a "High Radiation Area."
Specifically, an 18-inch gap behind the instrument rack on the 522-foot elevation provided access to the High Radiation Area; but was not posted.
2.,
On May 19, 1993, in an area of the 548-foot elevation of the reactor building where a major portion of the body could receive in any.one hour a dose of 2.5 millirem, radiation.
levels were greater than 5 mrem/hour, but the area was not conspicuously posted as a radiation area.
3.
On May 27,
- 1993, personnel who entered a radiation area at the entrance to the offgas preheater room on the 441-foot elevation of the turbine building altered a barrier for access to a radiologically controlled area, but they did not return the barrier to its original position when exiting.
This is a Severity Level IV violation (Supplement IV).
10 CFR Part 50, Appendix B, Criterion V, requires activities affecting quality to be prescribed by appropriate procedures and accomplished in accordance with those procedures.
1.
WNP-2 Administrative Procedure PPH 1.3.9, "Temporary Modifications," states in Paragraph 6.3, "Restoration of a TH
[temporary modification] via THR,"
"6.3.6 C.
Upon authorization from the Shift Manager, the Work Supervisor, or designee shall:...
Account for all THR tags.
Return all the THR tags to the Control Room.
Tags that cannot be returned because they are lost or contaminated shall be noted in the THR form COMMENTS section.
Notice of Viol ati on d.
Ensure the individuals performing the removal sign the Restoration Per'formed by and Verified by steps on the original THR form.
e.
Inform the Shift Hanager... the TH restoration is complete..."
"6.3.7
'a ~
C.
d.
The Shift Hanager shall:
Review the original THR form to ensure all the THR tags are accounted for, returned tags are discarded, and all the required steps are signed....
I Ensure any restoration testing specified, on the THR is complete.
Ensure documents changed and/or special instructions issued....are corrected and operating personnel on his shift have been briefed.
e.
Sign the Restoration Complete and note any unexpected, or unusual events in the Comments section...
f.
File the TNR in the Completed section of the TNR log.
g.
Nake the appropriate date entry in the THR Log Index under Restored Date."
Contrary to the above, on June 20, 1993, the hardware associated with temporary modification request THR-93-017 was removed but the THR tags were not returned to the control room or accounted for; the signatures for restoration by the craft or Shift,Hanager were not obtained; the Shift Nanager was not notified; Operations personnel were not briefed on the restoration; the THR log index was not updated; and THR-93-.017 was left in the Active section of the THR log.
2.
WNP-2 Administrative Procedure PPM 1. 17.2, Revision 1,
"Procurement Engineering Reviews," required in Paragraph 7.4 that substitute items that are not identical to the original
Notice of Violation item have substitution evaluations performed to determine their su'itability for use in safety-related applications.
Contrary to the above, as of June 9, 1993, the licensee had replaced safety-related carbon steel hydraulic control unit accumulators with new stainless steel accumulators of a different size, weight, and pressure and temperature rating without performing a substitution evaluation to ensure the suitability of the new design.
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2;201, the Washington Public Power Supply System (the 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 of Violation and Proposed Imposition of Civil Penalty (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, and if denied, the reasons why, (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 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.
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 addressed to the Director, Office -of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, money order, or electronic transfer payable to the Treasurer.
of the United States in the amount of the civil penalty proposed
- above, or may protest imposition of the civil penalty, in whole'r in part, by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission.
Should the Licensee fail to answer within the time specified, an order imposing the civil penalty will be issued.
Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, in whole or in part, such answer should be clearly marked as an "Answer to a Notice of Violation" and may:
(1) deny the violation 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 the penalty should not be imposed.
In addition to protesting the civil
- penalty, in whole or in part, such answer may request remission or mitigation of the penalty.
Notice of Violation In requesting mitigation of the proposed
- penalty, the factors addressed in Section VI.B.2 of 10 CFR Part',
Appendix C 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 to 10 CFR 2.201, but may incorpo-rate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition.
The attention of the Licensee is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty.:
t 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
'atter may be referred to the Attorney General, and the penalty, unless compromised,
- remitted, or mitigated, may be collected by civil action pursuant to Section 234(c) of the Act, 42 U.S.C. 2282(c).
The response noted above (Reply to Notice of Violation, letter with payment of civil penalty, and 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, and a copy to the NRC Resident Inspector at WNP-2.
Dated at Walnut Creek, California This 10'" day of November, 1993