IR 05000397/1985036

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-397/85-36

ML20140C068
Person / Time
Site:	Columbia
Issue date:	03/19/1986
From:	Chaffee A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
References
NUDOCS 8603250127
Download: ML20140C068 (1)

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MAR 191986 Docket N [

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Washington Public, Power . Supply System P. O. Box 968 ,

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Attention: Mr. G.,C. Sorensen'

Manager. of Regulatory Programs , .

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Gentlemen: '"

e Thank you for your letter d' ated December 19, 1985, informing us of the steps you have taken to correct the items which we brought to your attention in our letter dated November 27, 1985. Your corrective actions will be' verified during a future inspectio ,

Your cooperation with us is appr'eciate

Sincerely,

/s/ '

A. E. Chaffee,' Chief Reactor Projects Branch State of WA bec: RSB/ Document Control Desk (RIDS)

J. Martin, RV B. Faulkenberry, RV G._ Cook, RV Resident and Project Inspector

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Washington Public Power Supply System

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December 19, 1985 Mr. J.B. Martin, Regional Administrator <

U.S. Nuclear Regulatory Commission

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Regio Maria Lane, Suite 210 Walnut Creek, California 94596 Subject: NUCLEAR PLANT NO. 2  :

LICENSE NO. NPF-21 NRC INSPECTION REPORT 85-36 The Washington Public Power Supply System hereby replies to the Notice 'of Violation contained in your letter dated November 27, 1985. Our reply pursuant to- the provisions of Section 2.201, Title 10, Code of Federal .

Regulations, consists of this letter and Appendix A (attached). .

In Appendix A, an explanation of our position 'regarding the validity of the violation, is provided. Should you have any questions concerning our ,

response, please do~ not hesitate to contact m A

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.i G.C. Sorensen

~ Manager, Regulatory Programs

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Appendix A APPENDIX A Page 1 of 2 During an NRC inspection conducted on September 28 - November 1,1985, a violation of NRC requirements was identified. The following has been excerpted from the Notice of Violation:

Appendix B of 10CFR50, Criterion V requires, in_ part, that

" Activities affecting quality shall be prescribed by documented instructions, procedures, ... (which) shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."

The WNP-2 Technical Specifications Section 6.8.1.a requires that procedures -

be established, implemented and maintained covering activities listed in Appendix A of Regulatory Guide 1.33 Revision 2, which includes procedures for -

performing maintenance and surveillance testing. -

Contrary to the above requirements, it was determined on October 24, 1985, that WNP-2 plant surveillance procedures did not include instructions or criteria for determining that important activities are properly accomplished;.

i.e., that terminal box and junction box covers on environmentally qualified equipment are replaced or secured following maintenance or surveillance testing. As a consequence, environmentally qualified instruments were not maintained consistent with the program described in Section 3.11 of the FSAR  ;

and Section 4.2.7 of the "WNP-2 Environmental Qualification Report for Safety- i Related Equipmen VALIDITY OF VIOLATION

The Supply System acknowledges the validity of the violation. 'As noted in '

your inspection report, due to our prompt corrective action, we will not

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respond to the specific finding. It is sufficient to note that prompt interim and final corrective action is the goal of the Supply Syste ,

Per your request, this reply will address:

1) evaluation as to why our staff failed to identify and. correct this deficient condition over an extended period of time; and 2) corrective actions necesstry to improve plant staff response to such matters in the futur As you are aware, Equipment Qualification issues and jargon have bee principally dealt with at the engineering / design level. As such, detailed information concerning all the eguipment qualification requirements are not common knowledge of the " typical plant worker. The Supply Systpm, as have  !

the nuclear industry, recognized the need to increase the awareness of plant -

i stafftothisimgortantissue. This is not to say that our equipment qualifi-cations " experts should not have identified and corrected these situation Rather, as design requirements are specified for a station, or the industry, we must do a better job in evaluating and communicating the requirements to the typical plant worke '

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Appendix A APPENDIX A Page 2 of 2

CORRECTIVE ACTIONS TAKEN/RESULTS ACHIEVED 1) The plant has been inspected with any deficient conditions correcte ) The Plant Manager has directed his staff to conduct more frequent plant tours and to look for and correct deficient condition ) Weekly meetings between the plant staff and the design engineering community are taking place. One of the purposes of these meetings is to

) ensure total integration of the equipment qualification requirements into our normal work proces ) The Equipment Qualification Design Engineering Group has presented a -

program to Plant Management. This program dealt with the history, basic requirements and future issues in equipment qualificatio CORRECTIVE ACTIONS TO BE TAKEN 1) A training video tape on equipment qualification is being prepared. This is intended to educate principal plant workers on these requirement ) The Maintenance Shop Practices Manuals will be evaluated as to the need to provide specific direction concerning preservation of equipment

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qualification integrit ) A training bulletin will be isr+td by our Nuclear Safety Assurance Group. This will describe this event and our corrective actio DATE OF FULL COMPLIANCE 1) The target date to complete the video tape and begin training is February 1,198 ) The evaluation of the Maintenance Shop Pratices Manual will be complete by February 1, 1986.

, 3) The training bulletin will be issued to Maintenance, Operations and Plant Engineering personnel by February 1,198 '

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