ML17292A604
| ML17292A604 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 11/26/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17292A602 | List: |
| References | |
| EA-96-327, NUDOCS 9611290236 | |
| Download: ML17292A604 (6) | |
Text
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVILPENALTY Washington Public Power Supply System Washington Nuclear Project-2 Docket No. 50-397 License No. NPF-21 EA 96-327 During an NRC inspection conducted on June 28 through September 4, 1996, violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, 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 particu-
'ar violations and associated civil penalty are set forth below:
A.
Technical Specification 3.0.4 states, in part, that entry into an OPERATIONAL CONDITION or other specified condition shall not be made unless the conditions for the Limiting Conditions for Operation are met without reliance on provisions contained in the ACTION requirements.
Technical Specification 3.7.2 (Limiting Condition for Operation) states, in part, that two independent control room emergency filtration system trains shall be OPERABLE in all OPERATIONALCONDITIONS, and describes actions to be taken if one or more trains are inoperable.
Contrary to the above, on June 2, 1996, reactor operational condition was changed from Operational Condition 5 to Operational Condition 4 with Train A of the control room emergency filtration system inoperable.
The conditions for the Limiting Conditions for Operation contained in Technical Specification 3.7.2 were not met without reliance on the provisions contained in the ACTION requirements. (01013)
Technical Specification 4.0.4 states, in part, that entry into an OPERATIONAL CONDITION or other specified applicable condition shall not be made unless the Surveillance Requirement associated with the Limiting Condition for Operation have been performed within the applicable surveillance interval, or as otherwise specified.
Technical Specification 3.3.1 (Limiting Condition for Operation) states, in part, that as a minimum, the reactor protection system instrumentation channels shown in Table 3.3.1-1 shall be OPERABLE in the OPERATIONAL CONDITION as shown in Table 3.3.1-1.
Technical Specification 4.3.1.1 (Surveillance Requirements) states, in part, that each reactor protection system instrumentation channel shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL FUNCTIONALTEST and CHANNEL CALIBRATIONoperations for the OPERATIONAL CONDITIONS and at the frequencies shown in Table 4.3.1.1-1, Reactor Protection System Instrumentation Surveillance Requirements.
Technical Specification 3.3.6 (Limiting Condition for Operation) states, in part, that the control rod block instrumentation channels shown in Table 3.3.6-1 shall be OPERABLE with their trip setpoints set consistent with the values shown in the Trip Setpoint column of Table 3.3.6-2.
Technical Specification 4.3.6 (Surveillance
~&
Requirements) states, in part, that each of the above required control rod block trip systems and instrumentation channels shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL FUNCTIONALTEST and CHANNEL CALIBRATIONoperations for the operational conditions and at the frequencies shown in Table 4.3.6-1.
Contrary to the above:
On June 20, 1996, reactor OPERATIONAL CONDITION was changed from Operational Condition 2 to Operational Condition 1, and the surveillance requirements associated with Limiting Conditions for Operation of Technical Specification 3.3.1 for-Turbine Throttle Valve - Closure, as shown in Table--
4.3.1.1-1, Functional Unit 9, were not met.
On June 28, 1996, the reactor OPERATIONAL CONDITION was changed from Operational Condition 4 to Operational Condition 2, and the surveillance requirements associated with Limiting Conditions for Operation of Technical Specification 3.3.6 for the upscale, inoperative, and downscale channel checks for the rod block monitor, as shown in Table 4.3.6-1, Trip Functions 1.a, 1.b and 1.c, were not met.
3.
On June 29, 1996, reactor OPERATIONAL CONDITION was changed from Operational Condition 2 to Operational Condition 1, and the following surveillance requirements associated with Limiting Conditions for Operation contained in Technical Specification 3.3.6 for the average power range monitor (APRM) downscale rod block channel functional test, and the APRM fixed neutron flux upscale trips, as shown in Table 4.3.6-1, Trip Functions 2.a and 2.c, were not met.
(01023)
Technical Specification 6.8.1.a states, in part, that written procedures shall be established, implemented, and maintained covering the activities referenced below, including "d. Surveillance and test activities of safety-related equipment."
Technical Specification 6.8.2 states, in part, that each procedure of Specification 6.8.1, and changes thereto, shall be reviewed by the Plant Operations Committee (POC) and shall be approved by the Plant Manager prior to implementation.
Technical Specification 3.6.3 (Limiting Condition for Operation) states, in part, that the primary containment isolation valves shown in Table 3.6.3-1 shall be OPERABLE with isolation times less than or equal to those shown in Table 3.6.3-1 in Operational Conditions 1, 2 and 3.
Technical Specification 4.6.3.1 (Surveillance Requirements) states, in part, that each primary containment isolation valve shown in Table 3.6.3-1 shall be demonstrated OPERABLE prior to returning the valve to service after maintenance, repair, or replacement work is performed on the valve by cycling the valve through at least one complete cycle of full travel and verifying the specified isolation time.
Technical Specification 4.6.3.2 states, in part, that each primary containment automatic isolation valve shown in Table 3.6..3-1 shall be demonstrated OPERABLE
during COLD SHUTDOWN or REFUELING at least once per 18 months by verifying that on a containment isolation test signal each automatic isolation valve actuates to its isolation position.
Table 3.6.3-1, Primary Containment Isolation Valves, lists Reactor Core Isolation Cooling Valves RCIC-V-63 and RCIC-V-76 as Automatic Isolation Valves.
Contrary to the above, as of June 12, 1996, procedures utilized during reactor startup were inadequate, in that they failed to ensure, prior to shifting OPERATIONAL CONDITIONS from Operational Condition 4 to Operational Condition 2, that reactor core isolation cooling containment isolation Valves RCIC-V-63 and RCIC-V-76 were stroke-time tested in accordance with established procedures for conducting such surveillances.and which'had'been reviewed by the POC.
. Specifically, the licensee performed post-maintenance testing of the valves which was equivalent to the surveillance test but with a procedure (PPM 10.25.132) that had not been reviewed by the POC. (01033)
D.
Technical Specification 4.4.1.3 (Surveillance Requirements) states that recirculation loop flow mismatch shall be verified to within the limits as least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> while in Operational Conditions 1 and 2.
Contrary to the above, on June 13 and 14, 1996, the plant was in Operational Condition 2, and the daily recirculation loop flow mismatch surveillances were not performed. (01043)
E.
Technical Specification 4.3.1.1 (Surveillance Requirements) and associated Table 4.3.1.1-1, Functional Unit 2.b, requires that the APRM channel check be performed daily in Operational Condition 1.
Contrary to the above, on June 21 and 23, 1996, the plant was in Operational Condition 1 and the daily APRM channel checks were not performed. (01053)
The above violations represent a Severity Level III problem (Supplement I).
Civil Penalty - $ 100,000.
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 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 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.
I
~ Iel Alt
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Within the same time as rovid 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 Re gulatory Commission, with a check, draft money d
electronic transfer a able p y to the Treasurer of the United States in the amount of the civil penalty proposed above, or the cumulative amount of the I
I f
e civi pena ties i more than one ivi pena ty is proposed, or may protest imposition of the civil penalty in whole or in art by a written answer addressed to the Director, Office of E f o,
ice o n orcement, U.S. Nuclear egu atory ommission.
Should the Licensee fail to answer wth'h order imposing the civil penalty will be issued.
Should the Licensee elect to i
r wi in e time specified, an in accordance with 10 CFR 2.20 5 protesting the civil penalty, in whole or in part h
answer should be clearl ma k y
rked as an Answer to a Notice of Violation" and may:
(1) r, suc cir u in pa, emonstrate extenuatin
'umstances, (3) show error in this Notice or (4) h h
deny the violations listed in this Notice, in whole or i rt (2) d 9
s ow ot er reasons why the penalty not e imposed.
In addition to protesting the civil penalty in whole or in part, such answer may request remission or mitigation of the penalty.
In requesting mitigation of the ro os h
p posed penalty, the factors addressed in Section VI.B.2 f t e Enforcement Policy should be addressed.
A 0
CFR 2.2
. 05 should be set forth se ssed.
Any written answer in accordance with 10 pursuant to 10 CFR 2 parately from the statement or explanation n
I CFR 2.201, but may incorporate parts of the 10 CFR 2.201 re I
b i
inrepy specific reference (e.g., citin a
e e
1 reply by attention of the Licen e g page and paragraph numbers) to avoid repetition.
Th
'censee is directed to the other provisions of 10 CFR 2.205 re ar procedure for imposing a civil penalty.
, regarding the 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 collected b civil ac
'nera, an t e enalt unles p
y, s compromised, remitted, or mitigated, may be co ecte y civil action pursuant to Section 234c of the Act, 42 Ll.S.C. 2282c.
The response noted above (Re I
(
p y to Notice of Violation, letter with payment of civil penalty, and Answer to a Notice of Violation) should be addressed to: Jam Director, Office of Enforcement, U.S.
Nuclear Re ear Reg~l~t~~y C~mm~~s~~~
One Wh~t~ Fl or, ockville Pike, Rockville, MD 20852-2738 wit Administrator U S. Nuclear Re viator or, uc ear Regulatory Commission, Region IV, 611 Ryan Plaza Drive uite, Arlington, Texas 76011 an
, and a copy to the NRC Resident Inspector at WNP-2.
I extent Because your response will be placed in the NRC Public Docu t R
'PDR, possible, it should not include any personal rivac r
i ocument oom (PDR), to the information so that it can be lac i
ona privacy, proprietary, or safeguards o
a i can e placed in the PDR without redaction.
However, if ou fin necessary to include such information h
ld that you desire not to be placed in the PDR d
, you s ou c early indicate the s ecific inf request for withholding the information from the public.
in e, an provide the legal basis to su ort our pp y ur Dated at Arlington, Texas, this 26th day of November 1996