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EA-98-480 - Washington Nuclear 2 (Washington Public Power Supply System)

January 29, 1999

EA 98-480

Mr. J. V. Parrish (Mail Drop 1023)
Chief Executive Officer
Washington Public Power Supply System
P.O. Box 968
Richland, Washington 99352-0968

Dear Mr. Parrish:

The NRC conducted an augmented inspection on June 19 through July 8, 1998, and a followup inspection on August 24 through September 17, 1998, at your Washington Nuclear Project-2 facility. The purpose of these inspections was to address the fire protection system rupture and internal flooding event which occurred on June 17, 1998. The augmented inspection report (50-397/98-16) was issued on July 16, 1998, and the followup inspection report (50-397/98-20) on October 16, 1998. The circumstances surrounding the event were discussed with you and your staff at various management meetings, public meetings, and phone conferences since the time of the event. NRC letter dated October 16, 1998, described an apparent violation (EA 98-480) of 10 CFR Part 50, Appendix A, General Design Criterion 3, "Fire Protection." The NRC informed you that it was considering escalated enforcement action for this apparent violation. You elected to respond to the apparent violation in writing in lieu of requesting a predecisional enforcement conference.

Based on the results of the inspections, management meetings, public meetings, and the information that you provided in your response letter to the apparent violation, dated December 18, 1998, 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 reports. The violation involves your failure to assure that a rupture of the plant's fire main would not impair equipment important to safety. Specifically, on June 17, 1998, the actuation of the fire protection system induced a water hammer which caused the rupture of a fire main valve in the northeast stairwell of the reactor building. The resulting water from the running fire protection pumps entered a residual heat removal pump room through an open watertight door. The water then spread to the adjacent low pressure core spray pump room via a sump isolation valve that failed to close. The water completely submerged the residual heat removal pump and motor and the Division I keepfill pump. The water rose to just below the motor in the low pressure core spray pump room and completely submerged the Division II keepfill pump.

As described in NRC Inspection Report 50-397/98-16, the flooding event did not pose a risk to the public health and safety and the actual safety consequences were low. However, the potential safety consequences were considered to be more significant. Had the fire protection system actuation been the result of an actual, developed fire, and had it occurred while the plant was operating at power, operators would have been faced with combating two separate events (fire and flooding), while tasked with a plant shutdown in accordance with emergency operating procedures. The event could have been further complicated had it occurred outside normal working hours when personnel resources to combat the event would have been minimal. Therefore, the 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 $55,000 is considered for a Severity Level III violation. Because your facility has been the subject of escalated enforcement actions within the last 2 years,⁽¹⁾ the NRC considered whether credit was warranted for Identification and for Corrective Action in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy. Because the violation was identified as the result of an event, the NRC considered whether identification credit was warranted based on the ease of discovery, whether the event occurred as the result of a self-monitoring effort, the degree of initiative in identifying the problem, and whether prior opportunities existed to identify the problem. The NRC concluded that while you were aware that the system was susceptible to water hammer transient during fire pump starts, the successful operation of the system during the past 14 years did not indicate that a catastrophic failure could occur. The NRC concluded that the detailed analysis of the root causes of the event and the initiative displayed in identifying the problem warranted identification credit.

The NRC then considered whether credit was warranted for corrective action. The NRC concluded that you are implementing thorough short-term and long-term corrective actions. Your interim corrective actions included strengthening the reactor building standpipe isolation valves and continuously running one of the main fire pumps to maintain fire protection system pressure. Your long-term corrective actions include design modifications to provide standpipe vacuum breaker valves and soft-start capability for the motor driven pumps, and resolving the NFPA noncompliances. As described in your letter, these long-term corrective actions are to be completed by June 30, 1999. Based on the corrective actions that you have taken and intend to take, the NRC concluded that credit was warranted for corrective actions.

Therefore, to encourage prompt and comprehensive correction of violations, I have been authorized, after consultation with the Director, Office of Enforcement, 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 the 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 will be achieved is already adequately addressed on the docket in your December 18, 1998, letter. Therefore, you are not required to respond to this letter 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 and its enclosure will be placed in the NRC Public Document Room.

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

Enclosure: Notice of Violation

cc (w/encl):
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. D. W. Coleman (Mail Drop PE20)
Manager, Regulatory Affairs
Washington Public Power Supply System
P.O. Box 968
Richland, Washington 99352-0968

Mr. Albert E. Mouncer (Mail Drop 396)
Chief Counsel
Washington Public Power Supply System
P.O. Box 968
Richland, 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 & Strawn
1400 L Street, N.W.
Washington, D.C. 20005-3502

Enclosure 1
NOTICE OF VIOLATION

During an NRC inspection conducted on June 19 through July 8, and August 24 through September 17, 1998, 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 50.48. (a) states, in part, that each operating nuclear power plant must have a fire protection plan that satisfies Criterion 3 of Appendix A of this part. The plan must also describe specific features necessary to implement the fire protection program... such as....automatic and manually operated fire detection and suppression systems, and the means to limit fire damage to structures, systems, or components important to safety so that the capability to safely shut down the plant is ensured.

10 CFR Part 50, Appendix A, General Design Criterion 3 (Fire Protection), requires, in part, that fire fighting systems of appropriate capacity and capability be provided and designed to minimize the adverse effects of fires on structures, systems, and components important-to-safety. Fire fighting systems shall be designed to assure that their rupture or inadvertent operation does not significantly impair the safety capability of these structures, systems, and components.

Contrary to the above, on June 17, 1998, inadequate fire protection system design resulted in a rupture of the WNP-2 fire protection system significantly impairing the safety capability of components important-to-safety in Residual Heat Removal Pump Room C and the low pressure core spray room due to flooding from a fire protection system rupture. The rupture occurred when excessive hydraulic forces, generated during preaction sprinkler system actuation in response to an actual fire detection system signal, caused a fire main valve to fail. (01013)

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

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 will be achieved is already adequately addressed on the docket in the licensee's letter dated December 18, 1998. 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, DC 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 facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).

If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

If you choose to respond, your response will be placed in the NRC Public Document Room (PDR). Therefore, to the extent possible, the response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal 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. If you 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). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated this 29^th day of January 1999

1.   The NRC issued a Severity Level III violation on June 1, 1998 (EA 97-573).

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