EA-96-267 - Washington Nuclear 2 (Washington Public Power Supply System)

October 1, 1996

EA 96-267

J. V. Parrish, Chief Executive Officer
Washington Public Power Supply System
3000 George Washington Way
P.O. Box 968, MD 1023
Richland, Washington 99352

SUBJECT: NOTICE OF VIOLATION (NRC Inspection Report No. 50-397/96-15)

Dear Mr. Parrish:

This refers to the inspection conducted from June 24 through July 29, 1996, at the Washington Nuclear Project-2 (WNP-2) reactor facility. The inspection was conducted to review the effluents program, including a review of the problems associated with the primary calibration of the reactor building stack effluent monitor. Your staff determined that these problems represented a loss-of-emergency assessment capability and subsequently notified the NRC on March 6, 1996, in accordance with 10 CFR 50.72(b)(v). Your staff issued a Special Report to the NRC dated March 20, 1996, further describing the problems. A telephonic exit briefing was held on July 29, 1996, to inform WNP-2 personnel of our disposition of the inspection results. The results of our inspection are documented in the subject report. The inspection report was issued on August 9, 1996, and described an apparent violation of requirements for which the NRC was considering escalated enforcement action.

Based on the information developed during the inspection and the information that you provided in your response to the inspection report dated September 9, 1996, the NRC has determined that a violation of NRC requirements occurred. The violation is cited in the enclosed Notice of Violation and the circumstances surrounding it are described in detail in the subject inspection report. The violation involved WNP-2's failure to meet an emergency planning standard involving assessment (10 CFR 50.47(b)). During the Spring of 1993, WNP-2 installed a radioactive monitoring system for post-accident gaseous discharges. An engineer recorded an incorrect reading during the primary calibration of the mid range monitor, and the resulting erroneous values (calibration factors) were used in offsite dose assessment software. The calibration factor was low by a factor of about 4.4 for the mid-range monitor and by a factor of about 8.1 for the high range monitor. As a result of WNP-2's long term self-assessment program, the errors were discovered in March 1996. Your September 9, 1996, letter stated that the violation resulted from an inadequate test procedure and that contributing causes included undetected personnel error, possible effects of excessive overtime, and inadequate management involvement.

The violation is significant because it could have resulted in delays in assessing the significance of the offsite consequences during an actual event, although no such emergency occurred. As a result, WNP-2 was not able to meet one of the emergency planning standards involving assessment (10 CFR 50.47(b)). Therefore, this violation has been categorized in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600 at Severity Level III.

In accordance with the Enforcement Policy, a base civil penalty in the amount of $50,000 is considered for a Severity Level III violation. Because your facility has been the subject of escalated enforcement actions within the last 2 years¹, the NRC considered whether credit was warranted for Identification and Corrective Action in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy. Because WNP-2 personnel identified the violation, the NRC has determined that credit is warranted for the Identification factor. Further, the NRC has determined that credit is warranted for the Corrective Action factor. Your September 9, 1996, response stated that the corrective actions for the violation included promptly declaring the post-accident monitoring system inoperable, taking appropriate compensatory measures, notifying the NRC, changing the offsite dose assessment software to correct the deficiency, comparing setpoint data with vendor data for consistency, reviewing other effluent monitors for similar problems, and counseling the Plant Oversight Committee members regarding schedule pressures and the necessity to perform detailed technical reviews.

Therefore, to encourage prompt identification and comprehensive correction of violations, I have been authorized not to propose a civil penalty in this case. However, significant violations in the future could result in a civil penalty.

The NRC has concluded that information regarding the reason for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence is already adequately addressed on the docket by your March 20, 1996, Special Report to the NRC; NRC Inspection Report No. 50-397/96-15; and your September 9, 1996, response to the apparent violation. Therefore, you are not required to respond to the provisions of 10 CFR 2.201 unless the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response, if you choose to submit one, will be placed in the NRC Public Document Room (PDR).

Sincerely, /s/ L. J. Callan Regional Administrator

Docket No. 50-397
License No. NPF-21

Enclosure: Notice of Violation

cc (w/enclosure):
Frederick S. Adair, Chairman
Energy Facility Site Evaluation Council
P.O. Box 43172
Olympia, Washington 98504-3172

Chairman
Benton County Board of Commissioners
P.O. Box 69
Prosser, Washington 99350-0190

Mr. Paul R. Bemis (Mail Drop PE20)
Vice President, Nuclear Operations
Washington Public Power Supply System
P.O. Box 968
Richland, Washington 99352-0968

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

Mr. Al E. Mouncer (Mail Drop 396)
Chief Counsel
Washington Public Power Supply System
P.O. Box 968
Richland, Washington 99352-0968

Ms. Lourdes C. Fernandez (Mail Drop PE20)
Manager, Licensing
Washington Public Power Supply System
P.O. Box 968
Richland, Washington 99352-0968

Mr. Malcolm H. Phillips, Jr., Esq.
Winston & Strawn
1400 L Street, N.W.
Washington, D.C. 20005-3502

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NOTICE OF VIOLATION

Washington Public Power Supply System Docket No. 50-397 Washington Nuclear Project-2 License No. NPF-21 EA 96-267

During an NRC inspection conducted on June 24 through July 29, 1996, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

10 CFR 50.54(q) states, "A licensee authorized to possess and operate a nuclear power reactor shall follow and maintain in effect emergency plans which meet the standards in 10 CFR 50.47(b)...." 10 CFR 50.47(b) states, "The onsite and....offsite emergency response plans for nuclear power reactors must meet the following standards:....(9) Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use."

Contrary to the above, from July 1993 through March 1996, adequate methods, systems, and equipment for assessing and monitoring potential offsite consequences of a radiological emergency condition were not in use. Specifically, errors were made during the initial calibration of the intermediate range monitor PRM-RE-1B and high range monitor PRM-RE-1C of the reactor building effluent monitoring system resulting in the errors in establishing a correlation between the post-accident monitor indications and radionuclide contents in the elevated release duct.

This is a Severity Level III violation (Supplement III).

The NRC has concluded that information regarding the reason for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence, and the date when full compliance was achieved is already adequately addressed on the docket by your March 20, 1996, Special Report to the NRC; NRC Inspection Report No. 50-397/96-15; and your September 9, 1996, response to the apparent violation. However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a "Reply to a Notice of Violation," and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region IV, ATTN: Enforcement Officer, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).

Dated at Arlington, Texas,
this 1st day of October, 1996

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^1. A Severity Level III violation and a proposed imposition of a $50,000 civil penalty was issued on September 7, 1995, (EA 95-109). The violation was associated with the removal and transfer of spent Reactor Water Cleanup System filters.