ML17292B383
| ML17292B383 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 05/14/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17292B380 | List: |
| References | |
| 50-397-98-06, 50-397-98-6, NUDOCS 9805190371 | |
| Download: ML17292B383 (6) | |
Text
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 March 15 through April25, 1998, four 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.
WNP-2 Technical Specification 5.4.1.a requires written procedures to be established,
.implemented, and maintained for activities covered under Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.
Appendix A of Regulatory Guide 1.33 includes the control of plant equipment as an activity requiring written procedures.
Plant Procedure Manual (PPM) 1.3.1, Revision 36, "WNP-2 Operating Policies Programs, and Practices," provides, in part, guidelines to operators for controlling plant equipment t'o ensure operation of the plant within Technical Specification limits.
Section 4.1 of PPM 1.3.1 directs that during activities that cause a system or component to become inoperable per Technical Specifications, the shift manager/control room supervisor shall declare the system or component inoperable and enter it into the tracking log.
1 Contrary to the above, on April 3, 1998, while the plant was operating in Mode 1, the shift manager/control room supervisor approved the start of a maintenance activity that rendered control room air conditioning Subsystem A inoperable, but failed to declare the subsystem inoperable and enter it in the tracking log.
This is a Severity Level IVviolation (Supplement I).
10 CFR 50.59(b)(1) requires licensees to maintain records of changes in the facility and of changes in procedures made pursuant to this section, to the extent that these changes constitute changes in the facility as described in the Final Safety Analysis Report (FSAR) or to the extent that they constitute changes in procedures as described in the FSAR.
These records must include a written safety evaluation which provides the bases for the determination that the change does not involve an unreviewed safety question.
I 10 CFR 50.9(a) requires, in part, that information required by statute or by the Commission's regulations, orders, or license conditions to be maintained by the licensee shall be complete and accurate in all material respects.
WNP-2 Final Safety Analysis Report, Section 5.4.7.1.1, describes the various design modes of operation of the residual heat removal (RHR) system, including Standby.
Section 5.4.7.1.1 states that, in the Standby mode, the system is aligned with the pumps suction from the suppression pool, the minimum flow bypass valves open, and all other 9805i90371 9805i4 PDR ADGCK 05000$ 97 8
PDR RHR system valves aligned so that only the inboard injection valves are required to open and the RHR pumps started for flowto be delivered to the reactor vessel following depress urization.
Contrary to the above, as ofApril 25, 1998, the description of the facility in the FSAR was not co'mplete and accurate in all material respects in that the FSAR did not match the facility and that the required written safety evaluation was not performed.
Specifically, since initial facility licensing in April 1984, the FSAR has been inaccui ate in that the licensee has maintained the minimum flow bypass valves closed when the RHR system is in Standby and a written safety evaluation was not performed to provide the bases for the determination that this defacto change does not involve an unreviewed safety question.
Additionally, the actual RHR system alignment is that the outboard injection valves are closed (requiring opening to deliver flow to the reactor vessel) instead of open as-described in Section 5.4.7.1.1 of the FSAR.
This is a Severity Level IVviolation (Supplement I) 10 CFR Part 50, Appendix B, Criterion III, "Design Control," requires measures be established to assure that applicable regulatory requirements and the design bases are correctly translated into specifications, drawings, procedures, and instructions.
Contrary to the above, as of January 1, 1998, the function of the residual heat removal (RHR) system in performing its low pressure coolant injection (LPCI) function, was not adequately translated into plant procedures and instructions.
Specifically, the licensee's loss-of-coolant-accident analysis assumes that the RHR system willmeet its LPCI functional requirements by providing fullflowto the vessel 66 seconds after initiation of the event.
However, RHR system operating and surveillance procedures allowed for the suppression pool return valve to be full open, which had the potential to delay full LPCI injection flowfor up to an additional 66 seconds.
This is a Severity Level IVviolation (Supplement I).
WNP-2 Technical Specification 5.4.1.a requires written procedures to be established, implemented, and maintained for activities covered under Regulatory Guide 1.33, Revision 2, Appendix A, February 1978; Appendix A of Regulatory Guide 1.33 includes access control to radiation areas, including a radiation work permit system, as an activity requiring written procedures.
PPM 11.2.7.3, Revision 15, "High and Very High Radiation Area Controls," provides the radiological protection requirements for entry into these areas.
Section 5.2 of PPM 11.2.7.3 states that access to high radiation areas, posted at greater than 1000 mrem/hr, shall be controlled by means of a radiation work permit that includes dose rates in the immediate area.
Section 5.2 also requires that any time a door to a high
g radiation area, posted at greater than 1000 mrem/hr, is unlocked, a health physics qualified individual shall provide positive access control of the area while the door is unlocked.
Contrary to the above, on April 3, 1998, during an instrumentation and controls surveillance being performed in a high radiation area, posted at greater than 1000 mrem/hr, the licensee failed to implement the requirements of PPM 11.2.7.3 in that:
(1)
The instrumentation and controls technician performing the surveillance was
'tilizing a radiation work permit that did not allow entry into high radiation areas and did not provide the dose rates in the immediate area, and (2)
While the door to the high radiation area was unlocked, a health physics qualified individual did not maintain positive access control to the area.
This is a Severity Level IVviolation (Supplement III).
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 willbe achieved.
Your response may reference or include previous docketed correspondence, ifthe 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 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 willbe 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 14 day of May 1998