IR 05000397/1996011
| ML17292A594 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 11/14/1996 |
| From: | Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Parrish J WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| References | |
| NUDOCS 9611200039 | |
| Download: ML17292A594 (8) | |
Text
CW'L'aCVH.Y 2 REGULATORY INFORMATION DISTRIBUTION SYST8M (RIL"-;
ACCESSION NBR:9611200039 DOC.DATE: 96/11/14 NOTARIZED: NO
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FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe AUTH.NAME AUTHOR AFFILIATION GWYNN,T.P.
Region 4 (Post 820201)
RECIP.NAME RECIPIENT AFFILIATION PARRISH,J.V.
Washington Public Power Supply System SUBJECT:
Ack receipt of 961015 ltr informing NRC of steps taken to correct violations noted in insp rept 50-397/96-11.
DISTRIBUTION CODE:
IEOID COPIES RECEIVED:LTR g ENCL Q-SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:
DOCKET 05000397 C
RECIPIENT ID CODE/NAME PD4-2 PD INTERNAL: ACRS AEOD/T
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~NR~O HHFB NRR/DRPM/PERB OE DIR RGN4 FILE
ERNAL: LITCO BRYCE,J H
NRC PDR COPIES LTTR ENCL RECIPIENT ID CODE/NAME COLBURN,T AEOD/SPD/RAB DEDRO NRR/DISP/PIPB NRR/DRPM/PECB NUDOCS-ABSTRACT OGC/HDS3 NOAC LTTR E
CL COPIES E
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N NOTE TO ALL "RZDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)
ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED:
SUBJECT:
NRC INSPECTION REPORT 50-397/96-11
Dear Mr. Parrish:
Thank you for your letter of October 15, 1996, in response to our letter and Notice of Violation dated September 12, 1996.
We have reviewed your reply and your specific comments, and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.
As the result of the subsequent telephone discussion between Messrs. Kenneth Brockman and Tom Stetka, and Mr. John Swailes of your staff, on September 18, 1996, we realized that our statement that, "The permanent plant modification program was not effectively implemented...."
could be misinterpreted.
This letter will clarify our position that our statement was based on our inspection findings that isolated instances of improper implementation of the permanent plant modification program had occurred.
While these findings did not indicate a programmatic breakdown, it was indicative of program implementation problems.
With respect to your response to Violations A-1 and A-2, we noted your position that these issues did not involve a lack of adherence to procedures.
We also noted, however, your acknowledgement of the existence of procedure weaknesses.
We consider your acknowledgement that procedure weaknesses existed to be the root cause of these procedure adherence problems.
Nonetheless, we consider your corrective actions to clarify the intent of the procedures to be appropriate toward preventing a recurrence.
With regard to Violation Example C-2, we noted your denial that this example was not the result of inadequate corrective action.
This denial was based upon your discovery, subsequent to the inspection, that Safety Evaluation 95-095 was reviewed by the Corporate Nuclear Safety Review Board and that Attachment 5 of the Corporate Nuclear Safety Review Board minutes listed an incorrect safety evaluation number due to a 96ii200039 96iii4 PDR ADOCK 050003II7
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Washington Public Power Supply System-2-typographical error.
Had this status been identified during the inspection, this violation example would not have been cited.
Based upon this new information, we withdraw Example 2 of Violation C.
We also noted your positions regarding adherence to 10 CFR 50.59 requirements.
While we acknowledge your position that imp/ementation of an activity that involves a Technical Specification change or an unreviewed safety question prior to approval is a business risk decision and, therefore, outside of the requirements of 10 CFR 50.59, our concern pertains to the potential that such a practice could result in activities being conducted at the plant without the performance of appropriate reviews.
Specifically, such practices need to ensure that the operability of other structures, systems, and components have not been compromised a's the result of these preinstallation activities.
With regard to the second example, which involved whether an accident is a new or different type than any previously evaluated, you are correct in stating that the NRC has not endorsed NSAC-125 guidance.
The issues of "slight increases in probability" and "margin of safety" are currently one of the subjects being considered by the NRC as part of an ongoing review of the 10 CFR 50.59 review process.
However, our current position is that utilizing the guidance of NSAC-125 in this instance is inconsistent with 10 CFR 50.59 requirements.
If you have further questions or need clarification regarding these matters, please contact Mr. Chris VanDenburgh of my staff at (817) 860-8161.
Sincerely, L
~~Cg Thomas P. Gwynn, Director Division of Reactor Safety Docket No.: 50-397 License No.:
NPF-21 CC:
Frederick S. Adair, Chairman Energy Facility Site Evaluation Council P.O. Box 43172 Olympia, Washington 98504-3172 Chairman Benton County Board of Commissioners P.O. Box 69 Prosser, Washington 99350-0190
Washington Public Power Supply System Mr. Paul R. Bemis (Mail Drop PE20)
Vice President, Nuclear Operations Washington Public Power Supply System P.O. Box 968 Richland, Washington 99352-0968 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. David A. Swank (Mail Drop PE20)
Manager, Regulatory Affairs Washington Public Power Supply System P.O. Box 968 Richland, Washington 99352-0968 Mr. Al E. Mouncer (Mail Drop 396)
Chief Counsel Washington Public Power Supply System P.O. Box 968 Richland, Washington 99352-0968 Ms. Lourdes C. Fernandez (Mail Drop PE20)
Manager, Licensing Washington Public Power Supply System P.O. Box 968 Richland, Washington 99352-0968 Mr. Malcolm H. Phillips, Jr., Esq.
Winston 5 Strawn 1400 L Street, N.W.
Washing ton, D.C. 20'005-3502
Washington Public Power Supply System E-Mail report to D. Nelson (DJN)
E-Mail report to NRR Event Tracking System (IPAS)
bcc to DMB (IE01)
bcc distrib. by RIV:
L. J. Callan DRP Director Branch Chief (DRP/E, WCFO)
Senior Project Inspector (DRP/E, WCFO)
Branch Chief (DRP/TSS)
Leah Tremper (OC/LFDCB, MS: TWFN 9E1 sident Inspector RS-PSB MIS System IV File M. Hammond (PAO, WCFO)
)
DRS AI 96-G-01 1 3 DOCUMENT NAME: R:tREPORTSiWN611AK.TFS To receive copy of document, indicate in box: "C" = Copy without clos
"E" = Copy with enclosures
"N" = No copy RIV:SRI:EB TFStetka/Imb 10@$ 96 C:EB D:Q.RS D:DRP CAVanDenburg 1 //96 JEDye 1 //9 1 +/96 FFICIAL RECOR COPY
Washington Public Power Supply System 4-E-Mail report to D. Nelson (DJN)
E-Mail report to NRR Event Tracking System (IPAS)
bcc to DMB (IE01)
bcc distrib. by RIV:
L. J. Callan DRP Director Branch Chief (DRP/E, WCFO)
Senior Project Inspector (DRP/E, WCFO)
Branch Chief (DRP/TSS)
Leah Tremper (OC/LFDCB, MS: TWFN 9E1 sident Inspector RS-PS 8 MIS System IV File M. Hammond (PAO, WCFO)
)
DRS AI 96-G-0113 DOCUMENT NAME: R:tREPORTS'tWN611AK.TFS To receive copy of document, indicate in box: "C" = Copy without clos
"E" = Copy with enclosures "N" = No copy RIV:SRI:EB TFStetka/Imb 10@$ 96 D:MRS D:DRP JEDye
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C:EB CAVanDenburg 1 //9
/ /96 1 5496.i.~
FFICIAL RECOR COPY