ML17292B240

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Forwards Insp Rept 50-397/97-13 on 970715-0802 & Notice of Violation.Insp Involved Follow Up of 25 Open Items Including 4 Violations & 8 Unresolved Items.Three Violations Adequately Addressed
ML17292B240
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 02/09/1998
From: Howell A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Parrish J
WASHINGTON PUBLIC POWER SUPPLY SYSTEM
Shared Package
ML17292B241 List:
References
50-397-97-13, EA-97-573, EA-97-612, NUDOCS 9802170045
Download: ML17292B240 (13)


See also: IR 05000397/1997013

Text

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REGULATORY INFORMATION DISTRIBUTION SYSTEM

(RIDS).

ACCESSION NBR:9802170045

DOC.DATE: 98/02/09

NOTARIZED: NO

FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public

Powe

AUTH.NAME

AUTHOR AFFILIATION

HOWELL,A.T.

Region

4 (Post

820201)

RECIP.NAME

RECIPIENT AFFILIATION

PARRISH,J.V.

Washington Public Power Supply System

DOCKET

05000397

SUBJECT:

Forwards insp rept 50-397/97-13

on 970715-0802

& notice of

violation.Insp involved follow up of 25 open items including

4 violations

S

8 unresolved

items. Three violations

adequately

addressed.

DISTRIBUTION CODE: IEOIT

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TITLE: General

(50 Dkt)-Insp Rept/Notice of Vio ation Response

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PD4-2

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NOTE TO ALL "RZDS" RECIPIENTS:

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PLEASE, HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LZS'.

OR REDUCE THE NUMBER OF COPIES RECEZVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTR(

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ON EXTENSION 415-2083

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UNITED STATES

NUCLEAR REGULATORY COMMISSION

<EGION IV

--I I RYAIIPi AZA DRIVE, SUITE F00

ARLIIIGTO"ITEXAS- ~ 60II-a06~

EA 97-573

EA 97-612

February 9, 1998

Mr. J. V. Parrish (Mail Drop 1023)

Chief Executive Officer

Washington Public Power Supply System

P.O. Box 968

Richland, Washington

99352-0968

SUBJECT:

NRC INSPECTION REPORT 50-397/97-13, NOTICE OF VIOLATIONAND

EXERCISE OF ENFORCEMENT DISCRETION

Dear Mr. Parrish:

An NRC inspection was conducted July 15 through August 2, 1997, at your Washington Nuclear

Project-2 reactor facility. Additional inspection was conducted in the NRC Region IVoffice. An

additional exit meeting that provided the final results of this inspection were conducted by

telephone on January 12, 1998, with Mr. P. Bemis and other members of your staff.'he

enclosed report presents the scope and results of that inspection.

This inspection involved follow up of 25 open items including 4 violations and 8 unresolved

items. Your staff had taken adequate corrective actions for 3 of the violations. However, we are

concerned with your corrective actions taken with regard to the violation that involved an

inadequate corrective action. Specifically, your staff did not take adequate corrective action with

respect to assuring that all plant operators completed the required reading regarding a fire

protection issue.

This issue was identified in 1995 and was reviewed by the NRC in 1996. At

that time, a violation was cited for inadequate corrective actions when'it was determined that the

required reading was not completed for all the operators.

In this inspection, it was found that this

condition continued when it was again found that the required reading had not been completed

for all operators.

This continuing problem was identified as a violation as discussed

below.

Two of the unresolved items were determined to be violations of NRC requirements.

The

circumstances

surrounding these violations are described in detail in the enclosed report.

The

first violation identified three examples of inadequate corrective actions.

This included the

example where the corrective actions, involving operator-required

reading, was not completed.

The second violation involved seven examples of a failure to update your licensing basis. as

required by.10 CFR,50.71(e).

This violation would be classified at Severity Level IVand

normally would be cited because

it was identified by the NRC. However, the NRC is exercising

discretion in accordance with Section VII.B.3 of the Enforcement Policy and is not taking formal

enforcement action (EA 97-612).

Specifically, the NRC recognizes that you have a

9802170045

980209

PDR

ADQCK 05000397

8

PDR

iilllllllllllllllllllllllllllllllllllll

Washington Public Power Supply System

-2-

comprehensive

program underway to review and update your Final Safety Analysis Report.

This program was described in Letters G02-97-022 dated February 7, 1997, which provided

information pursuant to 10 CFR 50.54(f) and GO2-97-120 dated June 16, 1997, in response to

the open items identified in NRC Inspection Report 50-397/96-201.

It is the NRC's view, given

the scope and schedule for completing this review, that these Final Safety Analysis Report

discrepancies

likelywould have been identified through your Final Safety Analysis Report review

program.

The first violation is cited in the enclosed Notice of Violation (Notice). Please note that you are

required to respond to the violation and should followthe instructions specified in the enclosed

Notice when preparing your response.

The NRC will use your response,

in part, to determine

whether further enforcement action is necessary to insure compliance with regulatory

requirements.

Based on the results of this inspection, two apparent violations were identified (EA 97-573) and

are being considered for escalated enforcement action in accordance with the "General

Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy),

NUREG-1600. The first apparent violation involved the failure to perform an adequate safety

evaluation in accordance with the requirements of 10 CFR 50.59. The violation involved the

downgrading of the reactor core isolation cooling system from a safety-related system to a non

safety-related system without NRC approval.

This downgrading may have increased the

probability of occurrence of a malfunction of equipment important to safety previously evaluated

in the Final Safety Analysis Report and increased the possibility for a malfunction of a different

type than any evaluated previously in the Final Safety Analysis Report.

Therefore, this

downgrade apparently constituted an unreviewed safety question in accordance with the

requirements of 10 CFR 50.59.

The second apparent violation involved the failure to maintain the acceptance

criteria for the

opening stroke-time testing of six reactor core isolation cooling system valves and the failure to

maintain inservice testing of Valve RCIC-V-45 as required by 10 CFR 50.55a(f). These failures

appear to be the result of the reactor core isolation cooling system downgrading activities.

We have reviewed your Letter G02-97-228, dated December 23, 1997, subject; "WNP2,

OPERATING; LICENSE NPF-21, CLARIFICATIONOF RCIC SAFETY SYSTEM

CLASSIFICATION- RESPONSE TO 96-TIA-005 AND AMENDEDRESPONSE TO NRC

INSPECTION REPORT 96-11 STAFF COMMENTON RCIC," and discussed the letter with the

NRC program office. As the result of this review and discussions, we concur with your positions

that the reactor core isolation cooling system was identified as a nonsafety-related

system when

utilized for the loss-of-feedwater event, that the reactor core isolation cooling system was not an

emergency core cooling system, that the automatic depressurization

system is now the single

failure backup to the high pressure core spray system, and that the reactor core isolation cooling

0

Washington Public Power Supply System

-3-

system was not the designated coping system for station'blackout.

However, we also noted that

you concluded that the reactor core isolation cooling system was classified as a safety-related

system to provide a backup to the high pressure core spray system for the control rod drop

design basis event and that approval of the classification downgrade was not docketed by the

NRC. We also acknowledge your actions to restore the reactor core isolation cooling system to

a safety-related classification.

The circumstances surrounding these apparent violations and the significance of the issues

were discussed with members of your staff at the final inspection exit meeting conducted on

January 12, 1998. A Notice of Violation is not presently being issued for these inspection

findings. Before the NRC makes its enforcement decision, we are providing you an opportunity,

within 30 days of the date of this letter, to either (1) respond to the apparent violations addressed

in this inspection report or (2) request a predecisional enforcement conference.

Please contact

Mr. Thomas Stetka at (817) 860-8247 within 7 days of the date of this letter to notify the NRC of

your intended action.

Ifyou decide to respond to the apparent violations, your response should be clearly marked as a

"Response to Apparent Violations in Inspection Report 50-397/97-13," and should include:

(1)

the reason for the apparent violations, or, ifcontested, the basis for disputing the apparent

.

violations, (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 should be submitted under oath or affirmation and

may reference or include previous docketed correspondence,

ifthe correspondence

adequately

addresses

the required response.

Ifan adequate response

is not received within the time

specified or an extension of time has not been granted by the NRC, the NRC will proceed with

its enforcement decision or schedule a predecisional enforcement conference.

In addition, please be advised that the number and characterization of apparent violations

described in the enclosed inspection report may change as a result of further NRC review. You

willbe advised by separate correspondence

of the results of our deliberations on this matter.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, its

enclosure(s), and your response (ifyou choose to provide one) willbe placed in the NRC Public

Document Room (PDR). To the extent possible, your response should not include any personal

privacy, proprietary, or safeguards

information so that it can be placed in the PDR without

redaction.

Washington Public Power Supply System

-4-

Should you have any questions concerning this inspection, we will be pleased to discuss them

with you.

Sincerely,

Docket No.: 50-397

License No.: NPF-21

Arthur T. Howell III, Director

Division of Reactor Safety

Enclosures:

1. Notice of Violation

2. NRC Inspection Report

50-397/97-13

3. Letter G02-97-228, dated December 23, 1997

cc w/enclosures:

Chairman

Energy Facility Site Evaluation Council

P.O. Box 43172

Olympia, Washington

98504-3172

Mr. Rodney L. Webring (Mail Drop PE08)

Vice President, Operations Support/PIO

Washington Public Power Supply System

P.O. Box 968

Richland, Washington

99352-0968

, Mr. Greg O. Smith (Mail Drop 927M)

WNP-2 Plant General Manager

Washington Public Power Supply System

P.O. Box 968

Richland, Washington

99352-0968

Mr. David A. Swank (Mail Drop PE20)

Manager, Regulatory Affairs

Washington Public Power Supply System

P.O. Box 968

Richland, Washington

99352-0968

l

Washington Public Power Supply System

-5-

Mr. Albert E. Mouncer (Mail Drop 396)

Chief Counsel

Washington Public Power Supply System

P.O. Box

968'ichland,Washington

99352-0968

Mr. Paul Inserra (Mail Drop PE20)

Manager, Licensing

Washington Public Power Supply System

P.O. Box 968

Richland, Washington

99352-0968

Perry D. Robinson, Esq.

Winston 8 Strawn

1400 L Street, N.W.

Washington, D.C. 20005-3502

I

1

Washington Public Power Supply System

-6-

E-Mail report to T. Frye (TJF)

E-Mail report to D. Lange (DJL)

E-Mail report to NRR Event Tracking System (IPAS)

E-Mail report to Document Control Desk (DOCDESK)

bcc to DCD (IE01)

bcc distrib. by RIV:

Regional Administrator

DRP Director

Branch Chief (DRP/E, WCFO)

Senior Project Inspector (DRP/E, WCFO)

Branch Chief (DRP/TSS)

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Resident Inspector

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MIS System

RIV File

M. Hammond (PAO, WCFO)

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Washington Public Power Supply System

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