IR 05000397/1989030
| ML17285B116 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 03/12/1990 |
| From: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| References | |
| NUDOCS 9003260342 | |
| Download: ML17285B116 (6) | |
Text
'ocket No. 50-397 Washington Public Power Supply System P.
0.
Box 968 3000 George Washington Way Richland, Washington 99352 Attention:
Hr.
G.
C. Sorensen, Manager Regulatory Programs Thank you for your letter of Harch 2, 1990, in response to our Notice of Violation and Inspection Report No. 50-397/89-30, dated February 1, 1990, informing us of the steps you have taken to correct the items which we brought to your attention.
Your corrective actions will be verified during a future inspection.
Your cooperation with us is appreciated.
Sincerely, bcc w/copy of letter dated 3/2/90:
docket file State of Washington A. Johnson G.
Cook B. Faulkenberry J. Hartin Resident Inspector Project Inspector J. Zollicoffer H. Smith D.
F. Kirsch, Chief Reactor, Safety Branch
REGION V
HHiller 3/$ /90 CRamsey 3/W/90 RHu y 3/y /90 DKirshh 3/(~/0 YES /
NO YES /
N
] YES /,
NO YES /
9003260342 900312 PDR ADOCK 05000397 PDC YES /
NO J
VfASHINGTONPUBLIC POKIER SUPPLY SYSTEM!
P.o. Box 965
~
3DDD George 1Vashington 1l'ay
~ Richland, 11'aqhington'9362 March 2, 1990 G02-90-034 Docket No. 50-397 U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Hail Station Pl-137 Washington, D. C.
20555
@/2
/gdE~~
@
ypC4 Gentlemen:
Subject:
NUCLEAR PLANT NO. 2, OPERATING LICENSE NO. NPF-'21 NRC INSPECTiON REPORT 89-30
'ESPONSE'TO LEVEL IV NOTICE OF VIOLATION Reference:
Letter, JB Hartin
{NRC) to DW Hazur {SS),
dated February 1,
1990 The Washington Public Power Supply System hereby repl.ies to the Level IV Notice of Violation contained in your letter dated February 1,
1990.
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, the violation is addressed with an explanation of our position regqrding validity, corrective action and date of full compliance.
As requested in the referenced letter, Appendix A also provides measures we will implement to provide assurance that similar problems do not remain undetected or uncorrected.
The referenced letter also included a Level II Notice of Violation, for which a response was not required.
Me are currently evaluating our position with regard to this issue.
Accordingly, a
30-day extension for this item was requested and granted by the Office of Enforcement.
Very truly yours, G. D. Bouchey, Dire
- or Licensing 5 Assurance JDA/bk Attachments cc:
JB Martin -
NRC RV NS Reynolds
-
BCPKR
.
RB Samworth -
NRC DL Williams - BPA/399 NRC Site Inspector - 901A
APPENDIX A
'1 During NRC inspections conducted during the periods of March 3 - 24, 1986, January 12 - 15, 1987, June 6 - 10, 1988 and October 23 - 27, 1989, violations of NRC requirements were identified.
These violations involved the implementa-tion of the fire protection program.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions",
CFR Part 2, Appendix C (1989), the violations are set forth below:
III.
MNP-2 Technical Specification 6.8.1.g requires that written procedures be
"established, implemented and maintained covering Fire Protection Program implementation.
Contrary to the above, on October 25, 1989, Revision No.
12 of Abnormal Procedure No.
PPM 4.12.1.1, which implements the MNP-2 Control Room Remote Shutdown capability, a required element of the Fire Protection Program, was not appropriate to the circumstances in that:
A.
Step No. A.IO incorrectly required that RHR system valve No.
V-123B, instead of valve No. V-123A, be closed.
S.
Step No. A.27.incorrectly required that cooling fan No. RRA-FN-1 be made operable prior to RHR pump room No.
2B exceeding specified temperature limits, rather than requiring fan No. RRA-FN-3, (which provides cooling to RHR Pump Room No. 2B) to be operable.
C.
Rather than specifying the appropriate cooling equipment, Step No.
A.27 incorrectly required that Equipment No. MN-TI-9, which is only a
temperature indicator, be made operable prior to the Remote Shutdown Panel Room exceeding specified temperature limits.
This is a Severity Level IV Violation (Supplement I).
r."
Va idit of Violati n The Supply System acknowledges the validity of this violation.
A formal root cause analysis was performed for this violation and, although the reason for the procedural deficiencies could not be specifically determined, contributing factors were identified and are discussed as follows:
RHR-V-1238 - Contributing causes are 1)
ui men De n
e icien-
(RI t f
'1'RR I
I th INR "R" mimic),
and 2)
ui ment Desi n
e cienc Labelin ess Than
~dt (RHR-V-123A power transfer switch labeled as RHR-'-
123).
RRA-FN-1-Contributing cause is ui me t Desi nDeficienc Orawin s
~ (inadequate information on the flow diagram for Reactor Building HVAC).
MMA-TI-9
-
Contributing cause is ersonnel Lac of Atten-
~ti
tt (
Ight t ftl t
gt thi headings).
Appendix A Page 2 of 3 Corrective Ste s Taken Results Achieved 1.
Plant Procedures (PPMs) 4.12.1.1,
"Control Room Fire/Evacuation",
and 4.12.1.2,
"RPV Remote Cooldown", were revised to correct the deficiencies noted.
2.
A procedural training course, developed by a consultant specifically for WNP-2, was planned prior to the receipt of this violation.
The training course, which was completed on January 19, 1990, provided I)
an outline of the fundamental elements of procedures, 2)
appropriate human factors elements specific to'procedures, and 3)
verification and validation techniques.
The course also included exercises to practice and demonstrate the methods presented, with specific focus on the review of existing WNP-2 procedures.
Several members. of the Plant staff (including guality Assurance)
involved in the procedure review and development process participated in this training.
3.
As a part of the root cause efforts, an evaluation of the consequen-ces of these procedural deficiencies was performed.
The results of the evaluatioh are presented as follows:
Ivy a.
b..
RHR-V-123B The current revision of PPM 2.4.2,
"Residual Heat Removal System", administratively mitigated this deficiency.
In the PPM Valve Checklist attachment, both RHR-V-123A and RHR-V-123B are specified "CLOSED". The System Power Supply Checklist attachment directs that electrical breakers for both valves be cautioned tagged open during modes 1, 2 and 3.
Therefore, if a control room fire occurs during a plant condition when an overpressure in the RHR system could occur, the boundary is administratively maintained through lineups specified in PPM 2.4.2.
This administrative control was added to PPM 2.4.2 in May 1986.
RRA-FN-1 Thi s deficiency was mitigated because when the RHR 28 pump is energized,
RRA-FN-3 is automatically started.
Additionally the procedure requires hourly temperature monitoring of the pump room.
If the temperature exceeds 150'F, operators are instr ucted to make the cooling equipment operable.
The highest safe operating temperature for the pump is listed as 200'F.
The following sequence of events would have to occur for the pump room to exceed the safe operating temperature:
The fan would fai 1 to automati cal ly energize.
The temperature would increase to above 150'F.
The operator would energize the incorrect fan RRA-FN-Appendix A Page 3 of 3
~
Assuming the incorrect fan was energized the temperature would continue to increase.
~
During the next hourly reading the operator does not notice an increase in room temperature with the pump room fan not in service, after having energized a
fan previously.
~
Hourly readings continue with no actions by operators in light of situational conflicts (see above) until room temperature exceeds 200'F.
c)
MHA-TI-9 Guidance contained in the body of the procedure provided the correct actions to be taken ifRemote Shutdown Room Temperature increased.
Since no incorrect.information was included, and the. guidance contained the corrective action for the condition,
.the impact of this editorial deficiency was negligible.
Corrective Action to b Take 2.
Plant personnel are currently in the process of making improvements to the Plant Operations Procedure Writer's Guide.-
Plant Operations personnel are in the process of developing an improved Procedural Verification Program.
The current plan is to include checklists in this process, which would significantly increase the opportunity to detect the type errors identified in this violation.
Verification is concerned with written correctness and technical accuracy.
Written correctness ensures information is incorporated as specified by administrative guidance.
Technical accuracy ensures proper incorporation of generic and plant -specific technical information.
ate of Full Com
anc 1.
The revised Plant Operations Procedure Writer's Guide will be issued, by July 1, 1990.
2.
The Procedural Verification Program will be initiated by Duly 1, 1990
l
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