ML17284A576

Responds to NRC 880823 Ltr Re Violations Noted in Insp Rept 50-397/88-27.Corrective Actions:Plant Procedure 4.12.4.5, Design Basis Ash Fallout, Revised to Better Define When & How Filters Should Be Replaced

ML17284A576
Person / Time
Site:	Columbia
Issue date:	10/24/1988
From:	Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
RTR-REGGD-01.033, RTR-REGGD-1.033 GO2-88-220, NUDOCS 8811020281
Download: ML17284A576 (4)

Text

ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

CESSION NBR:8811020281 DOC.DATE: 88/10/24 NOTARIZED: NO DOCKET FACIL: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) l

SUBJECT:

Responds to NRC 880823 50-397/88-27.

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

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES RECIPIENT COPIES RECIPIENT COPIES 8'

ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 PD 1 . 1 SAMWORTH,R 1 1 INTERNAL: ACRS l,l 2 2 AEOD 1 1 DEDRO 1 1 NRR MORISSEAU I D 1 1 NRR/DLPQ/PEB 11 1 1 NRR/DLPQ/QAB 10 1 ~

1 D, NRR/DOEA DIR 11 NRR/DREP/EPB 10 1 1 NRR/DREP/RPB 10 2 2 NRR/DRIS DIR 9A 1 1 NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT 1 1 D

OE L EBERMAN,J 1 1 OGC/HDS2 1 1 F 02 1 1 RES/DSR DEPY 1 1 8 RGN5 FILE 01 1 1 ERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 RESL MARTIN,D 1 1 A

NOXK K) ALL "RIDS" RECIPIENTS'ZEASE HELP US TO REDUCE HASTE! CXÃI'ACZ 'IHE DOCUMENTS CDWZROL DESK BOOM Pl-37 (EXT. 20079) KO %LIMEADE YOUR NAME PMH DISTRIBUTION LISTS PDR DOCUMEMZS YOU DGNPT NEED>

TOTAL NUMBER OF COPIES REQUIRED: LTTR , 25 ENCL 25

WASHINGTON PUBLIC POWER SUPPLY SYSTEM I'.0. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 99352 October 24, 1988 G02-88-220 Docket No. 50-397 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station Pl-137 Washington, D.C. 20555 Gentlemen:

S ubject: NUCLEAR PLANT NO. 2 LICENSE NO. NPF-21 NRC INSPECTION REPORT 88-27 RESPONSE TO NOTICE OF VIOLATION The Washington Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated September 23,. 1988. 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 regarding validity, corrective action and date of full compliance.

Very truly yours, CM~ g4~r G. C. Sorensen, Manager Regulator'y Proyrams JDA/bk Attachments cc: JB Hartin - NRC RV NS Reynolds - BCP8R RB Samworth - NRC DL.Williams - BPA NRC Site Inspector - 901A 88il020281 881024 'F7 PDR ADOCK 05000 9 PDC

APPENDIX A During an NRC inspection conducted on July 8 - August 23, 1988 a 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 (1987), the violation is listed below:

Technical Specification 6.8.1 states in par t: "Hritten procedures shall be established, implemented, and maintained covering the activities...

recommended in 'Appendix A of Regulatory Guide 1.33, Revision 2, February 1978."

Appendix A of Regulato'ry Guide 1.33, Revision 2, February 1978 states, in part, "The following are typical safety related activities that should be covered by written procedures....6.w. Acts of Nature."

Contrary to the above, as of July 19, 1988, procedures had not been esta-blished to provide for the installation and replacement of air intake filters designed to protect the Emergency Diesel Generators in the event of volcanic ash fallout.

This is a Severity Level IY Yiolation (Supplement 1).

Val i di t of Vi ol ati on The Supply System acknowledges the validity of this violation. The reason for the violation was insufficient follow-through on a commitment made in response to NRC Unresolved Item 87-19-09 (Design concerns regarding ash filters for the diesel generators). Although Plant Procedure (PPM) 4.12.4.5, "Design Basis Ash Fallout" (Revision 3), was issued on June 17, 1988, the commitment to determine 1) the manhours required to install the ash fall filters, and 2) the number of replacement filters needed to sustain the Plant for the expected ash fallout period had not been completed.

Corrective Ste s Taken/Results Achieved

1. PPM 4.12.4.5 was revised to better define when and how the filters should be replaced. Major changes include 1) providing storage and staging locations for the filters, and 2) modifying filter changeout requirements.

2. Dedicated filters have been procured and are currently stored on site.

In the event of an ash fallout occurrence, these filters will be moved from the storage area to the staging locations specified in PPM 4.12.4.5.

Corrective Action to be Taken Regarding the reason for the violation (insufficient follow-through on commitments), the Plant Tracking Log (PTL) monitors the processing of external and other commitments by tracking initial entry, document processing and final closeout. A PTL task force has been established to review the accuracy of information in PTL, update the assigned responsibility for each task, and reprioritize. In addition, periodic followup status reviews will be performed to ensure completion of assigned actions.

Date of Full Com liance PPN 4.12 .4 .5 (Revision 4) will be i ssued by October 31, 1988.