ML17279B051

Responds to NRC 880418 Ltr Re Violations Noted in Insp Rept 50-397/88-02.Corrective Actions:Plant Switchgear Inspected, W/Exception of Main Generator Voltage Regulator Panel,No Addl Filters Discovered

ML17279B051
Person / Time
Site:	Columbia
Issue date:	05/18/1988
From:	Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
GO2-88-117, NUDOCS 8805260122
Download: ML17279B051 (8)

Text

AC CELERATED DI@GBUTION DEMONSTI+TION SY'TEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

CESSION NBR:8805260122 DOC.DATE: 88/05/18 NOTARIZED: NO DOCKET ACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397

'AUTH. NAME AUTHOR AFFILIATION .

SORENSEN,G.C. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 880418 50-397/88-02.

ltr re violations noted in Insp Rept DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 PD 1 1 SAMWORTH,R 2 2 INTERNAL: ACRS 2 2 AEOD 1 1 A DEDRO 1 1 NRR MORISSEAU,D 1 1 NRR/DLPQ/PEB 11 1 1 NRR/DLPQ/QAB 10 1 1 NRR/DOEA DIR 11 1 1 NRR/DREP/EPB 10 1 1 NRR/DREP/RPB 10 2 2 NRR/DRIS DIR 9A 1 1 NRR/PMAS/I LRB1 2 1 1 NUDOCS-ABSTRACT 1 1 OE LIEBERMAN,J 1 1 OGC 15-B-18 1 1 1 1 RES/DRPS DEPY 1 1 RGN5 FILE 01 .1 1 ERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 A

TOTAL NUMBER OF COPIES REQUIRED: LTTR 25 ENCL 25

Washington Public Power Supply System 3000 George Washington Way P.O. Box 968 Richland, Washington 99352-0968 (509)372-5000 Mav 18, 1988 G02-88-117 Docket No. 50-397 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Gentlemen:

Subject:

NUCLEAR PLANT NO- 2 LICENSE NO. NPF-21 NRC INSPECTION REPORT 88-02

1) Letter G02-88-025 (Original Response to NOV 87-19),

G. C. Sorensen (SS) to NRC, dated 1/29/88

2) Letter G02-88-086 (Supplemental Response to NOV 87-19),

G. C. Sorensen (SS) to NRC, dated 4/ll/88 The Hashington Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated April 18, 1988. Our reply, pursuant to the provisions of Section 2.201, Title 10, Code of Federal Regulations, consists of this letter and Appendices A and 8 (attached).

O Appendix requested A addresses each violation with an exp'lanation of our position regarding validity, corrective action(s) and date of full compliance. The root cause assessment of the design review inadequacies, corrective actions, including a schedule for completion, and assessment of the quality of modifications that have been previously installed in the Plant will be sent by separate transmittal on May 27, 1988.

Should you have any questions regarding this letter, please contact Mr. P. L. Powell, Manager, HNP-2 Licensing.

Very truly yours, G. C. r ensen, Manager Regulatory Programs lw

'Attachments cc: J. B. Martin - NRC RV N. S. Reynolds - BCPSR R. B. Samworth - NRC D. L. Williams - BPA NRC Site Inspector 901A 8805260122 880518 PDR ADOCK 05000397 9 DCD

Appendix A Page 1 of 4 APPENDIX A During an NRC inspection conducted on January 21, 1988 - March 10, 1988, two violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C ( 1987), the violations are listed below:

A. 10 CFR 50, Appendix B, Criterion XVI states in part, "Measures shall be established to assure that conditions adverse to quality, such as deficiencies . . . and nonconformances are promptly corrected." This requirement is implemented by Section 16,2. 1 of the licensee's Operational ()uality Assurance Program Description (0(}APD).

10 CFR 50.9(a) requires, in part, that information required to be maintained by licensees be complete and accurate in all respects.

Contrary to the above, on February 3, 1988, one of the foam filters

, identified in NRC inspection report 87-19 had not been removed as reported by the licensee, and additional filters were in the electrical exciter cubicle for the High Pr essure Core Spray Diesel Generator.

This is a Severity Level IV violation (Supplement 1).

Validit of Violation The Supply System acknowledges the validity of this violation. As stated in our supplemental response to NOV 87-19 (Reference 2), the scope of the inspection was to identify any 'filters which were installed on the outside of critical switchgear. However, after the original response to NOV 87-19 (Reference 1) was sent to the NRC, it was brought to our attention by the Senior Resident Inspector that additional filters were installed inside SM-7 and HPCS switchgear.

Accordingly, another inspection was performed for the purpose of identifying any other filters which were installed inside critical switchgear. During that inspection, filters were discovered inside HPCS and the load side of RHR pump 2C critical switchgear. The filters were immediately removed. The cause of this violation was the Supply System's for not expanding the inspection to include other potential filter locations.

Appendix A Page 2 of 4 Corrective Ste s Taken/Results Achieved All other Plant switchgear has subsequently been inspected and, with the exception of the Main Generator Voltage Regulator Panel (non critical switchgear), no additional filters were discovered. The filters installed in the Main Generator Voltage Regulator Panel are by design and are listed on the Bill of Material for the unit.

Corrective Action to be Taken As stated in both References 1 and 2, Plant Procedure (PPN) 1.3. 19, "Housekeeping", will be revised to expand the responsibilities and expectations of the Area/Floor Coordinators. The intent of the revi-sion is to identify degradation and abnormalities of equipment and structur es, and bring such information to the attention of Plant Management. In addition, training will be developed and provided to the coordinators on these responsibilities and expectations. The--

intent of this corrective action is to identify unauthorized Plant'-

modifications of the type identified in this violation.

A criteria list will be developed which defines what constitutes a Plant modification. Training on the modification criteria will be pr ovided to Maintenance, Operations (Equipment Operators) and Plant Technical personnel . The intent of this corrective action is to provi de an addi ti onal l evel of awareness in preventing P 1 ant modifications without utilization of the existing programmatic controls.

Date of Full Com liance The Supply System is currently in full compliance.

The Area/Floor Coordinator training program will be developed by June 30, 1988 and the training will be accomplished by August 31, 1988.

Plant Maintenance, Operations (Equipment Operators), and Technical Staff personnel will be trained on the modification criteria by September 30, 1988.

Appendix A Page 2 of 4 Corrective Ste s Taken/Results Achieved All other Plant switchgear has subsequently been inspected and, with tth e't excep i ception of the Main Generator Voltage Regulator Panel (non al switchgear) no additional filters were discovered. The filters installed in the Main Generator Voltage Regulator Pane are b y 1 design and are listed on the Bill of Material for the unit.

Corrective Action to be Taken A tt d 'n both References 1 and 2, Plant Procedure (PPM) 1.3. 19, "Housekeeping", will be revised to expand the responsibi li i expectations of the Area/Floor Coordinators. The intent of the revi-sion is to identify degradation and abnormalities of equipment and structures, and bri ng such information to the attention f Management. In addition, traini ng will be developed and provided to the coordinators on these responsibilities and expectations. The intent of this corrective action is to identify unauthorized Plant modifications of the type identified in this violation.

A criteria 'ist will be developed which defines what constitutes a Plant modification. Training on the modification criteria will e provi d e d to Maintenance, i Operations (Equipment Operators) and Plant Technical personnel. The intent of this corrective acti'on is to provide an additional level of awareness in preventing Plant modifications without utilization of the existing programmatic contr ol s.

Date of Full Com liance The Supply System is currently in full compliance.

The Area/Floor Coordinator training program will be developed by June 30, 1988 and the training will be accomplished by August 31, 1988.

Plant Maintenance, Operations (Equipment Operators), and Technical Staff personnel will be trained on the modification criteria by September 30, 1988.

0 Appendix A Page 4 of 4

3. A detailed electrical/I8C re-review of the ATWS-ARI design change was conducted in addition to the requirement review described in Item 2 (above). These reviews included complete wiring and physical layout re-checks. Problems identified during this review have been corrected by Field Change Notices or other Design Change Packages.

4. A detailed root cause evaluation of the ATWS modification design errors was performed by the Supply System equality Assurance Directorate. The root causes identified include schedule pressure es, inadequate checking, fr agmented elementary wiring diagrams, failure of management to provide adequate technical guidance/oversight and not following procedures. The conclusions of the root cause evaluation are being factored into the engineering improvement plan.

Corrective Action to be Taken Preparation of an engineering improvement plan with the goal to pr ovide a bottoms-up plan to improve the engineering management process and create an environment that fosters quality in the engineering design control process. The plan addresses planning and scheduling, technical leader ship, training in expectations on design checking and verification as well as other aspects affecting engineering design quality. The engineering improvements will be included in a more comprehensive improvement plan which is being developed. In addition to the engineering improvements, improvement plans will also be developed for plant modification implementation and quality assurance engineering. Supply System management will review the improvement plan with the NRC,, during the management meeting scheduled for June 3, 1988.

Date of Full Com liance o The ATWS-ARI design package is currently in compliance with the design requirements and Supply System commitments.

o The documentation inadequacies identified as a result of the design requirement review, discussed in item 2 above, will be corrected or dispositioned by August 30, 1988. The incomplete items will be tracked to completion and/or completed within the normal process of revising design data base documentation.