ML17284A585

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Responds to NRC 881006 Ltr Re Violations Noted in Insp Rept 50-397/88-33.Corrective Actions:On 881011,test Performed to Determine Dynamic Flow Control Characteriztics of Sample Rack REA-SR-37.Procedure Modified
ML17284A585
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 11/04/1988
From: Sorensen G
WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
GO2-88-229, NUDOCS 8811100200
Download: ML17284A585 (13)
v • d • e


Text

WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 99352 G02-88-229 November 4, 1988 Docket No. 50-397 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station Pl-137 Mashington, D.C. 20555 Gentlemen:

Subject:

NUCLEAR PLANT NO. 2 LICENSE NO. NPF-21 NRC INSPECTION REPORT 88-33 RESPONSE TO NOTICE OF VIOLATION The Mashington Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated October 6, 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, G. C. S'orensen, Manager Regulatory Programs JDA/bk Attachments cc: JB Martin - NRC RV NS Reynolds - BCP&R RB Samworth - NRC DL Williams - BPA NRC Site Inspector - 901A PDR g

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Page 1 of 2 APPENDIX A During an NRC inspection conducted on September 6-9, 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:

A. Technical Specification 3.3.7. 12 states, in part:

"3.3.7.12 The radioactive gaseous effluent monitoring instrumentation channels shown in Table 3.3.7.12-1 shall be OPERABLE with their alarm/trip setpoints set to ensure that the 'limits of Specification 3.11.2.1 are not exceeded...."

,"b. With less than the minimum number of radioactive gaseous effluent monitoring instrumentation channels OPERABLE, take the ACTION shown in Table 3.3.7.12-1."

Table 3.3.7.12-1 requires ACTION 112 for less than one Main Plant Vent Release Monitor iodine or particulate channel, and ACTION 113 for less than one Sampler Flow Rate Monitor channel. Table 3.3.7.12-1, Table Notations, states in part:

"ACTION 112 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 30 days provided that within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the channel has been declared inoperable samples are continuously collected with auxiliary sampling equipment as required in Table 4.11-2.

ACTION 113 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 30 days provided that the flow rate is estimated at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />."

'ontrary to the above, from 6:19 p.m. PDT on September 7, 1988, to 4:48 a.m. PDT on September 8, 1988, the main plant vent release monitor was not operable and no effluent sampler flow rate estimations were made nor continuous sample collection conducted, although effluent releases con-tinued via the main plant vent.

This is a Severity Level IV Violation (Supplement IV).

1 e

Page 2 of 2 Validit of Violation The Supply System 'acknowledges the validity of the violation in that procedural requirements were not followed when the Reactor Building HVAC System was secured and the Standby Gas Treatment (SGT) System star ted.

The requirements to declare Reactor Building Effluent Control Rack REA-SR-37 inoperable, and enter the associated Technical Specification Action Statement, were not 'performed. Sample Rack REA-SR-37 is the isokinetic air flow control rack for effluent monitoring of the main plant vent.

Corrective Ste s Taken/Results Achieved On October ll, 1988 a test was performed to determine the dynamic flow control characteristics of REA-SR-37 by equalizing the differential pressure across REA-FT-7 (Reactor Exhaust Air Stack Flow Rate Transmitter), simulating decreasing stack flow. The purpose of the test was to collect data to determine if the effluent monitoring system could accurately provide a representative 'ample during low flow conditions (less than 17,000 cfm). Results of the test indicated that the system will track. vent flows to below 2,000 cfm, and maintain isokinetic sampling to below 4,000 cfm.

Accordingly, the sample rack was operable during the event period and representative samples of main plant vent effluents were being obtained.

Corrective Action to be Taken Further data collection is planned during the next refueling outage, when actual Reactor Building flows will be in the range of 2,000 to 4,000 cfm, to provide an expanded data base for verification of system operability.

. The results of the analysis will be used to determine if any additional actions are required. II In the interim, applicable procedures will be modified to notify the Plant Chemistry Department when the Reactor Building HVAC System is secured.

The intent of this corrective action is to have the technicians monitor REA-SR-37 indications every four hours during such conditions to verify sampler flow. In addition, a caution sign will be posted on the control panel for the Reactor Building HVAC System as a reminder to notify Chemistry personnel when the system is secured.

Date of Full Com liance Although the Supply System is currently in full compliance, interim corrective actions (procedural changes and caution sign) will be completed by December 16, 1988.

Further analysis of REA-SR-37 flow control characteristics will be completed by July 1, 1989.

'I I

AC CELERATZD DISTRIBUTION DEMONSTRATION SYSTEM R EGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

CCESSION NBR:8811100200 DOC.DATE: 88/11/04 NOTARIZED: NO DOCKET N 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)

SUBJECT:

Responds to NRC 881006 50-397/88-33.

ltr re violations noted in Insp'Rept R

DISTRIBUTION CODE: IE06D COPIES RECEXVED:LTR ENCL SIZE: I TITLE: Environ 6 Radiological (50 DKT)-Insp Rept/Notice of Violation Respons D

NOTES:

RECIPIENT COPIES RECIPIENT COPIES S ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 LA 1 0 PD5 PD 1 1 SAMWORTH, R 1 1 A

INTERNAL: ACRS 2 2 AEOD/DSP 1 1 NMSS/LLOB 5E4 1 1 NMSS/SGOB 4E4 1" i 1 D NRR/DLPQ/PEB 11 1 1 NRR/DOEA/EAB 11 1 1 NRR/DREP/EPB 10 1 1 NRR/DREP/RPB 10 2 2 D

NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS2 1 1 RKHEh 02 1 1 RES 1 1 RGN5 FILE 01 1 1 RGN2/DRSS/EPRPB 1 1. RGN4 MURRAY,B 1 1 TERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 RESL MARTIN,D 1 1 R

I 8

A NOSE 'ZO ALL RIDS" RZCZPI/MS:

PLEASE HELP US TO REDUCE HASTE.'GKELCT 'IHE DOCUMWZ CONTROL DESK, ROCN P1-37 (EZZ. 20079) TO EZZMZHATE YOUR SAME HKH DISTRIBUTION LISTS MR DOCUMEMXS KRJ DGNiT NEED)

TOTAL NUMBER OF COPIES REQUIRED: LTTR 25 ENCL 24

Cl ti WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 99352 G02-88-229 November 4, 1988 Docket No. 50-397 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station Pl-137 Washington, D.C. 20555 Gentlemen:

Subject:

NUCLEAR PLANT NO. 2 LICENSE NO. NPF-21 NRC INSPECTION REPORT 88-33 RESPONSE TO NOTICE'OF VIOLATION The Washington Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated October 6, 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, G. C. orensen, Manager Regulatory Programs JDA/bk Attachments cc: JB Martin - NRC RV NS Reynolds - BCP8R RB Samworth - NRC DL Williams BPA NRC Site Inspector 901A PD R

~~00200 S~~L04 ADOCK 0500035'7 QoC PDC Iii

0 Page 1 of 2 APPENDIX A During an NRC inspection conducted on September 6-9, 1988, a violation of NRC requirements was identified. In accordance with the "Gener al Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, (1987), the violation is listed below:

A. Technical Specification 3.3.7. 12 states, in part:

"3.3.7.12 The radioactive gaseous effluent monitoring instrumentation channels shown in Table 3.3.7. 12-1 shall be OPERABLE with their alarm/trip setpoints set to ensure that the limits of Specification 3.11.2.1 are not exceeded...."

"b. With less than the minimum number of radioactive gaseous effluent monitoring instrumentation channels OPERABLE, take the ACTION shown in Table 3.3.7.12-1."

Table 3.3.7.12-1 requires ACTION 112 for less than one Main Plant Vent Release Monitor iodine or particulate channel, and ACTION 113 for less than one Sampler Flow Rate Monitor channel. Table 3.3.7.12-1, Table Notations, states in part:

"ACTION 112 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 30 days provided that within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the channel has been declared inoperable samples are continuously collected with auxiliary sampling equipment as required in Table 4.11-2.

ACTION 113 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 30 days provided that the flow rate is estimated at least once per 4 hours."

Contrary to the above, from 6:19 p.m. PDT on September 7, 1988, to 4:48 a.m. PDT on September 8, 1988, the main plant vent release monitor was not operable and no effluent sampler flow rate estimations were made nor continuous sample collection conducted, although effluent releases con-tinued via the main plant vent.

This is a Severity Level IV Violation (Supplement IV).

Page 2 of 2 Validit of Violation The Supply System acknowledges the validity of the violation in that procedural requirements were not followed when the Reactor Building HVAC System was secured and the Standby Gas Treatment (SGT) System started.

The requirements to declare Reactor Building Effluent Control Rack REA-SR-37 inoperable, and enter the associated Technical Specification Action Statement, were not performed. Sample Rack REA-SR-37 is the isokinetic air flow control rack for effluent monitoring of the main plant vent.

Corrective Ste s Taken/Results Achieved On October 11, 1988 a test was performed to. determine the dynamic flow control characteristics of REA-SR-37 by equalizing the differential pressure across REA-FT-7 (Reactor Exhaust Air Stack Flow Rate Transmitter), simulating decreasing stack flow. The purpose of the test was to collect data to determine if the effluent monitoring system could acc'urately provide a representative sample during low flow conditions (less than 17,000 cfm). Results of the test indicated that the system wil,l track vent flows to below 2,000 cfm, and maintain isokinetic sampling to below 4,000 cfm.

Accordingly, the sample rack was operable during the event period and representative samples of main plant vent effluents were being obtained.

Corrective Action to be Taken Further data collection is planned during the next refueling outage, when actual Reactor Building flows will be in the range of 2,000 to 4,000 cfm, to provide an expanded data base for verification of system operability.

The results of the analysis will be used to determine if any additional actions are required.

In the interim, applicable procedures will be modified to notify the Plant Chemistry Department when the Reactor Building HVAC System is secured.

The intent of this corrective action is to have the technicians'onitor REA-SR-37 indications every four hours during such conditions to verify sampler flow. In addition, a caution sign will be posted on the control panel for the Reactor Building HVAC System as a reminder to notify Chemistry personnel when the system is secured.

Date of Full Com liance Although the Supply System is currently in full compliance, interim corrective actions (procedural changes and caution sign) will be completed by December 16,'988.

Further analysis of REA-SR-37 flow control characteristics will be completed by July 1, 1989.

"

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