ML17292A769
| ML17292A769 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 03/28/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17292A768 | List: |
| References | |
| 50-397-97-03, 50-397-97-3, NUDOCS 9704030186 | |
| Download: ML17292A769 (6) | |
Text
ENCLOSURE 1 NOTICE OF VIOLATION Washington Public Power Supply System Washington Nuclear Project-2 Docket No.:
License No.:
50-397 NPF-21 During an NRC inspection conducted from January 19 through March 1, 1997, three 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.
TS 6.8.1 states, in part, "Written procedures shall be..
~ implemented... covering the activities referenced below:
a.
The applicable procedures recommended'in Appendix A of Regulatory Guide 1.33, Revision 2, Februaiy 1978.
Appendix A of Regulatory Guide 1.33 requires, in part, procedures for'the control of maintenance that can'affect the performance of safety-related equipment; and equipment control (locking and tagging):
I d.
Surveillance and test activities of safety-related equipment."
Contrary to the above, between January 6 and February 1, 1997, three examples of a TS 6'.8.1 violation were identified in the area of-Operations.
Specifically:
PPM 1.16.6B, "Voluntary Entry into Technical Specification Activities During
.Power Operations,"
Revision 6, requires the production scheduling shift manager (PSSM) to identify TS Action Statements that are required to be entered prior to performing requested work. Additionally, PPM 1.16.6B requires the PSSM to request a probabilistic safety assessment if the TS entry involved risk-significant TS systems
. However, on January 6, 1997, the standby service water Pump A (SSW-A) and Diesel Generator 1 (DG),
both identified as risk-significant systems, were rendered inoperable during, work associated with SSW-A building ventilation fan (Work Order DGZ6), but the PSSM had not previo'usly identified that the DG and SSW TS Action
. Statements required entry and additionally failed to request a probabilistic safety assessment for the work.
~
PPM 7.4.1.3.1.2, "Control Rod Exercise" Revision 15, states, in part:."For ea'ch control rod that has been exercised satisfactorily
~.. initial the appropriate location on core map..."
However, on January 17, 1997, a reactor operator documented that. Control Rod 54-19 was positioned to Position 48 by initialing the location on the core map that corresponded to Control Rod 54-19, but the control,rod was not exercised satisfactorily and was at Position 46.
PPM 1.3.8, "Plant Clearance Orders," Revision 30, Section 3.9, specifies that equipment operators are responsible for positioning components in the 9704030i86 970328 PDR ADOCK 05000397 9
D'AD plant as determined by clearance order.
However, on January 20, 1997, equipment operators failed to close Valve RHR-V-176B in accordance with Clearance Order 96-12-0074.
These are examples of a Severity Level IV violation (Supplement I).
B.
TS 6.8.1 states, in part, "Written procedures shall be... implemented...
covering the activities referenced below:
a 0 The applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
d.
Appendix A of Regulatory Guide 1.33 requires, in part, procedures for the control of radioactivity and maintenance that can affect the operability of safety-related equipment.
Surveillance and test activities of safety-related equipment."
Contrary to the above, between January 13, 1997, and February 1, 1997, three
.examples of a TS 6.8.1 violation were identified in the area of Maintenance.
Examples included:
PPM 7.4.8.1.1.2.12, "High Pressure Core Spray Diesel Generator Monthly Operability Test," Revision 27, including Temporary Change Notice 96-079,
.dated February 29, 1996, Step 17a, states:
"At E-CP-DG/RP3 (Inside Cabinet), place the Droop Switch in the DROOP position."
However, on
'anuary 13, 'I997, during the performance of PPM 7.4.8.1.1.2.12, an equipment operator failed'to place the Droop Switch in the DROOP position.
PPM 1.11.11, "Entry Into,.Conduct in, and Exit from Radiologically Controlled Areas," Revision 11, requires, in part, that "Persons entering a
radiological controlled area shall adhere to all requirements specified by Health Physics Personnel (i.e., radiological work permit requirements, posted instructions, verbal instructions, etc.)."
RWP 9600375.00 required workers, in part, to don a complete set of anticontamination clothing prior to'entering a contamination area.
However, on January 23,.1997, three workers (who were signed onto RWP 96000375 00) entered a contamination area without first donning a complete'set of anticontamination clothing.
PPM 1.3.7G, "Work I'mplementation," Revision 10, prohibits "minor maintenance" on safety-related equipment where the work could affect the operability of the equipment.
However, on February '1, 1997, mechanics performed work on safety-related Damper DMA-AD-22/2, which could affect
the operability of the damper, under the minor maintenance controls of PPM 1.3.7G.
These are examples of a Severity Level IV violation (Supplement I).
C.
TS 6.8.1.f requires, in part, that procedures covering th'e Emergency Plan be implemented.
PPM 13.14.5, "Emergency Response Organization and Training," Revision 18, Step 4.1.5.2 states, "Upon completion of required training, a Letter of Assignment
... will be issued....
The letter of assignment documents an individual's assignment to an ERO position..."
Additionally, PPM 13.14.5, Step 4.2.4.2 states, "The requirements for each emergency position are detailed in the Emergency Position Training Matrix located in the Emergency Preparedness Training Course Catalog."
The'"Emergency Preparedness Training Course Catalog,'" Revision 2, requires health physics technicians, in part, to complete the course entitled "Health Physics Emergency Functions," PDQ Code 82-EOS-P300-LP.
Contrary to the above, as of February 10, 1997, chemistry technicians were assigned the responsibilities of the emergency response organization on-shift health'hyscis technicians but no "letter of assignment" was issued to document the assignments.
Additionally, the chemistry technicians had not completed the course entitled "Health Physics Emergency Functions."
This is a Severity Level IV violation (Supplement Vill).
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 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). This reply should be clearly marked as a "Reply to a Notice of Violatio'n" and should include for each violation: (1)'the reason for the violation, or, if contested, the basis for disputing the violation, (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 will be 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,'esponse time.
Because your response will be placed in the NRC Public Document Room IPDR), 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.
However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not'o be placed in the PDR, and provide the legal basis to support your request for withholding the information from the public.
Dated at Walnut Creek, California, this 28th day of March 1997