GO2-84-047, Responds to NRC Noting Unacceptability of Corrective Action Proposed for Violation a in Insp Rept 50-397/84-09.Containment Entry Will Be Made W/One Air Lock Door Closed at All Times

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Responds to NRC Noting Unacceptability of Corrective Action Proposed for Violation a in Insp Rept 50-397/84-09.Containment Entry Will Be Made W/One Air Lock Door Closed at All Times
ML20096C405
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 08/24/1984
From: Sorensen G
WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To: Bishop T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
GO2-84-0479, GO2-84-479, NUDOCS 8409050271
Download: ML20096C405 (2)


Text

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Washington Public Power Supply System P.O. Box 968 3000 GeorgeWashington Way Ricnland, Washington 99352 (509)372-5000 Docket No. 50-397 3.

August 24, 1984 G02-84-0479 Mr. T. W. Bishop, Director Division of Reactor Safety and Projects U.S. Nuclear Regulatory Commission Region V 3450 Maria Lane, Suite 210 Uf! nut Creek, California 94596 ht,.jact: NUCLEAR PLANT NO. 2 LICENSE NO. NPF-21 NRC INSPECTION 84-09 MAY 29,1984 This is in response to your letter of July 25, 1984, informing us of the non-acceptability of our answer to Violation "A" of NRC Inspection 84-09.. Apparently the unacceptability concerned our " Corrective Steps to be Taken" response. Based on this perception we will readdress NRC Inspection 84-09 Violation "A".

Our interpretation of WNP-2 Technical Specification 3.6.1.3 is as follows:

1) The intent is to provide a boundary for uncontrolled releases to the secondary containment during accident conditions.
2) Personnel access is allowed provided both air lock doors are not opened simultaneously.
3) Al though the surveillance requirements include verification of the door interlock mechanism, neither action statement adequately ad-dresses the follow-up action rer:uired for an inoperative interlock.

Using the above, it is our position that action statement a. most closely defines the action required for this Limiting Condition for Operation (LCO). However, it should be noted that neither air lock door is in-operative. Both doors are capable of providing a pressure boundary and can be verified leak tight by seal leak tests. Therefore, we have con-I f,/; AiMOIN5

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r Mr. T. W. Bishop Page 2 Nuclear Plant No. 2 NRC Inspection 84-09 cluded that the intent of this technical specification allows for reactor operations to continue provided: 1) either air lock door is maintained closed and the interlock is returned to service within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or 2) if the interlock cannot be returned to service within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, then at least one operable air lock door is to be locked closed at all times and verified to .be closed at least once every 31 days. Thus, other condi-tions pemitting, containment entries would be allowed with the above provision that one air lock door remain locked closed at all times.

Locking the air lock doors provides assurance, comparable to the me-chanical interlock, that both doors cannot be open simultaneously.

Very truly yo rs G. C. Sorensen Manager, Regulatory Programs GCS:RLK:mm

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