GO2-94-157, Responds to NRC Re Violation Noted in Insp Rept 50-397/94-18.Corrective Action:Plan Procedure PPM 1.3.10 Will Be Revised
| ML17291A267 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 07/15/1994 |
| From: | Parrish J WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML17291A266 | List: |
| References | |
| GO2-94-157, NUDOCS 9407280071 | |
| Download: ML17291A267 (6) | |
Text
C WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968
~ 3000 George Washington Way
~ Richland, Washington 99352-0968
~ (509) 372-5000 July 8, 1994 G02-94-157 Docket No. 50-397
~"
Is U. S..Nuclear Regulatory Commission Attn: Document Control Desk Mail Station Pl-37
,Washington, D. C.
20555 Gentlemen:
Subject:
WNP-2, OPERATING LICENSE NO. NPF-21 NRC INSPECTION REPORT 94-18 RESPONSE TO NOTICE OF VIOLATION b
The Washington Public Power Supply System hereby replies to the Notice ofViolation co in your letter dated June 8, 1994.
Our reply, pursuant to the provisions of Section 2.20 10, Code of Federal Regulations, consists of Appendix A (attached) which addres specifics of the Notice of Violation, and this letter which outlines Quality Assurance oi activities of the Inservice Inspection Program.
Prior to the NRC Inspection, Quality Assurance had recognized that the ISI Program been subject to the level of comprehensive assessment efforts appropriate to this are.
Inspection Report accurately reflects our commitment to improve our oversight of tI through current and future assessments'.
Ongoing assessment activity primarily invo'echanical Stress Improvement Process (MSIP), a project conducted during R-9 to stresses on reactor pressure vessel safe-end welds.
The MSIP was chosen for assessment due to its potential safety impact and to assure 3
contractor craft and oversight performance.
The scope of the assessment included:
ai of planning and preparation, observation of work in the field, effectiveness of t independent verification of weld locations and weld treatments, verification of stre.
calculations, and adherence to radiation protection requirements.
During the MSIP assc QA dedicated a total of 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> to observation of activities in the field. This incl 9407280071 940721 PDR ADOCK 05000397 Q
0-
Page 2 NRC INSPECTION MH'ORT 94-18 RESPONSE TO NOTICE OF VIOLATION hours of in-Drywell observation; including performing independent verification of t locations for six of the forty-four nozzles, observation of equipment set up, and the act treatment of eight nozzles.
The extent of these verification activities was chosen in an balance ALARAconsiderations and the amount of observation necessary to assure ~
being conducted properly.
Should you have any questions or desire additional information regarding this matter, pl me or D. A. Swank at (509) 377-4563.
Sincerely,
. V. Parrish (Mail Drop 1023)
Assistant Managing Director, Operations CJF/bk Attachments-CC:
LJ Callan - NRC RIV KE Perkins, Jr. - NRC RIV, Walnut Creek Field Office NS Reynolds - Winston & Strawn JW Clifford-NRC DL Williams - BPA/399 NRC Sr. Resident Inspector - 927N
Appendix A VI LATION During an NRC inspection conducted on May 16 - 20, 1994, one violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:
Technical Specification 6.8.1 requires, in part, that written procedures be established, implemented, and maintained covering the fire protection program implementation.
Administrative Procedure 1.3.10, "Fire Protection Program Implementation," Revision 15 requires that temporary wood/blocking used in the plant shall be treated with a Underwrit<
Laboratory listed pressure impregnated fire retardant process, ifpossible.
As a minimum shall be treated with a painted on, flame retardant.
Contrary to the above, on May 18, 1994, the inspector observed wood stored on elevatioi 501 foot inside the reactor building. This wood was not treated or painted with a flame retardant.
P NET VI LATI N The Supply +stem accepts this violation.
REA NF R VI LA N
The root cause of the violation was failure to enforce existing procedural controls for use wood in plant fire areas.
The event occurred during the annual refueling outage.
Maintenance activities often include use of wood for bracing, use of wooden pallets for moving equipment and supplies, etc.
The existing procedure requires that all wood to b(
brought into the plant be either impregnated with fire retardant or treated externally with flame retardant, and be accompanied by a Transient Combustible Permit. Untreated woo:
may be used only after review by the Fire Marshal, issuance of a Transient Combustible Permit, and arrangement of continuous monitoring of the material until removed.
Howe more structured methods are needed to facilitate compliance with these procedural requirements.
RRE P TKN T
A A walkdown was initiated immediately to determine ifany other untreated wood be found in the plant.
Several pieces of untreated wood were found, and prompt removed from the buildings, or in some cases treated in-situ with fire retardant g
App Page 2.
Labels were affixed to doorways and hatches in the Reactor, Turbine-Genera
- Radwaste, Diesel-Generator, Circulating Water Pumphouse, and Standby Ser Water Pumphouse Buildings to warn personnel that untreated wood must not brought into those plant areas, except as prescribed by procedure PPM 1.3.1 labels state: "Attention! No Untreated Wood Beyond This Point.
(Refer to 1.3. 10 for requirements)
Direct questions to the Plant Fire Marshal".
3.
Training was conducted to emphasize to Supply System and Bechtel mainten project, health physics, and construction personnel that PPM 1.3.10 requires untreated wood generally not be used in the plant.
wood to be used on a temporary basis must either be impregnated wi retardant or painted with an approved flame retardant, and exceptions, ifany, must be specifically reviewed and approved by th Marshal.
RRE TEP T
BE TAKEN Plant procedure PPM 1.3.10 willbe revised by September 15, 1994 to strengthen
'hat untreated wood shall not be permitted to be brought into the plant except unde circumstances, ATE F
L LTA The Supply System was in full compliance on June 6, 1994 when all untreated wo identified during the walkdown referred to above was either removed from the pla areas or treated in-situ with fiame retardant paint.
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