ML17292B355
| ML17292B355 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 04/24/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17292B354 | List: |
| References | |
| 50-397-98-05, 50-397-98-5, NUDOCS 9804300228 | |
| Download: ML17292B355 (4) | |
Text
i ENCLOSURE 1 NOTICE OF VIOLATION Washington Public Power Supply System Washington Nuclear Project-2 Docket No.:
50-397 License No.:
NPF-21 During an NRC inspection conducted on March 12-17, 1998, 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:
10 CFR 50.72 Section (b)(1), "Non-Emergency Events," requires that the licensee provide a report (ifnot reported as an emergency class under Section (a)),
to the NRC as soon as practical and within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for occurrences included in paragraphs (b)(1)(l-vi). Paragraph (b)(1)(iv) identifies any event that results or should have resulted in emergency core cooling system discharge into the reactor coolant system as a result of a valid signal.
Contrary to the above, the licensee did not report within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> that the high pressure core spray system had actuated and discharged into the reactor coolant system on March 11, 1998, at 0516 PST, because of a valid low reactor pressure vessel water level signal.
This is a Severity Level IVviolation (Supplement I) (50-397/9805-01).
WNP-2 Technical Specification 5.4.1.a requires written procedures to be established, implemented, and maintained for those activities outlined in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.
Appendix A of Regulatory Guide 1.33 recommends administrative procedures for hot standby to cold shutdown.
Surveillance Procedure OSP-RCS-C102, "RPV Vessel Cooldown Surveillance,"
Revision 0, paragraph 7.11, requires that the control room operator verify the minimum reactor vessel metal temperature/pressure are to the right of the curve provided in.1, "Minimum Vessel Metal Temperature vs Reactor Vessel Pressure (Operational Values)," at least once per 30 minutes and initial Attachment 9.4, "Cooldown Temperature /Pressure Log."
Contrary to the above, during the cooldown on March 11, 1998, with the reactor subcritical, the reactor pressure vessel temperature and upper head pressure indications used to monitor the cooldown were not appropriately veriTied and maintained within the acceptable region of the temperature/pressure curve provided in Attachment 9.1, "Minim'um Vessel Metal Temperature VS Reactor Vessel Pressure."
This is a Severity Level IVviolation (Supplement I) (50-397/9805-02).
9804300228 980424 PDR ADOCK 05000397 8
PDR WNP-2 Technical Specification 5.4.1.a requires written procedures to be established,-
implemented, and maintained for those activities outlined in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.-
Appendix A of Regulatory Guide 1.33 recommends that administrative procedures be developed for, among others, procedure adherence and temporary change control.
Licensee Plant Procedure Manual Procedure SWO-PRO-02, "Preparation, Review, Approval and Distribution of Procedures," Revision 3, Section 3.10.1, states that, "A temporary change shall ~OT alter the intent of the procedure."
Paragraph 5.9 defines intent as the stated purpose or scope of a procedure as defined in the purpose section of the procedure.
Procedure TSP-DG2/LOCA-B0501, "Standby Diesel Generator DG2 LOCATest,"
Section 1.0, "Purpose," states that, "The procedure provides instructions for operating personnel to perform surveillance testing of DG2 during simulated ECCS initiation (LOCA) conditions in accordance with the Technical Specifications Surveillance Requirements."
The identified technical specification surveillance requirements involve logic system functional testing and response time testing.
Contrary to the above, Temporary Change Notice 98-110 dated March 12, 1998, to Procedure TSP-DG2/LOCA-B501,"Standby Diesel Generator DG2 LOCA Test,"
Revision 0, changed this logic system functional test and response time test, as described in the purpose of the procedure, to allow for full-lowpressure coolant injection flow to the reactor vessel from the suppression pool. Specifically, Temporary Change Notice 98-110 modified the previous requirement to close Residual Heat Removal Valves 111B and C, to close Residual Heat Removal Valves 111B and C at the discretion of the control room supervisor or shift manager.
This is a Severity Level IVviolation (Supplement I) (50-397/9805-03).
WNP-2 Technical Specification 5.4.1.a requires written procedures to be established, implemented, and maintained for those activities outlined in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.
Appendix A of Regulatory Guide 1.33 requires, in part, procedures for the startup, operation, and shutdown of safety-related boiling water reactor systems.
Contrary to the above, two procedures were determined to be inadequate for the operation and shutdown of safety-related boiling water reactor systems.
Procedure PPM 2.7.3,"High Pressure Core Spray Diesel," Revision 29, did not provide adequate direction for the shutdown of the high pressure core spray system.
The procedure did not identify the high pressure core spray initiation seal-in on P601 control board.
On March 11, 1998, following the automatic initiation of the high pressure core spray system, the associated diesel generator was stopped before the initiation seal-in logic was reset, resulting in the reinitiation of the high pressure core spray diesel generator.
Secondly, Temporary Change Notice TCN 98-113, made to Procedure TSP-DG2/LOCA-B501, Step 7.1.33, Substep a, to override the opening of the injection valve, was inadequate and resulted in low pressure coolant injection to the reactor vessel during the conduct of the March 12, 1998, logic system functional test.
This is a Severity Level IVviolation (Supplement I) ) (50-397/9805-04).
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 Violation" and should include for each violation: (1) the reason for the violation, or, ifcontested, the basis for disputing the violation or severity level, (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, ifthe correspondence adequately addresses the required response.
Ifan 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 willbe given to extending the response time.
Ifyou contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.
Because your response will be placed in the NRC Public Document Room (PDR), 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.
Ifpersonal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. Ifyou request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). Ifsafeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21..
Dated at Arlington, Texas this 24th day of April 1998
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