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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217K9681999-10-19019 October 1999 Ack Receipt of Transmitting Rev 40 to Physical Security Plan for Washington Nuclear Plant 2.Based on Determination That Changes Do Not Decrease Effectiveness of Plan,No NRC Approval Required ML17284A8981999-10-14014 October 1999 Forwards Rev 0 to WNP-2 Cycle 15,COLR 99-15, IAW Requirements of TS 5.6.5 ML17284A9061999-09-24024 September 1999 Forwards Final Rept for 990812 out-of-sequence Drills for Energy Northwest Washington Nuclear Power Project 2 (Lab, Food Control Point & Milk Sampling).No Deficiences & No Areas Requiring C/A Identified in Three Drills ML17284A8881999-09-24024 September 1999 Informs NRC of Change in Schedule Pertaining to Final Implementation of Reactor Stability long-term Solution for WNP-2 ML17292B7591999-09-24024 September 1999 Forwards Rev 24 to WNP-2 Emergency Plan,Iaw 10CFR50.4(b), 50.54(q) & 10CFR50 App E.Detailed Synopsis of Changes,Encl ML17292B7581999-09-22022 September 1999 Forwards NRC Forms 396 & 398 for Nl Hancock,License SOP-50027-3,AR Herrington,License OP-50013-3,WH Sawyer, License SOP-50023-3 & Dl Strote,License SOP-50031-3,for Renewal of Licenses.Without NRC Forms 396 & 398 ML17284A8811999-09-0909 September 1999 Forwards Response to NRC 990623 RAI to Support Review of Pending Request for Amend to Reactor pressure-temp Limit Curve TS GO2-99-168, Forwards Rev 40 to Physical Security Plan.Rev Withheld,Per 10CFR2.790(a)(3)1999-09-0808 September 1999 Forwards Rev 40 to Physical Security Plan.Rev Withheld,Per 10CFR2.790(a)(3) ML17284A8711999-08-30030 August 1999 Informs Staff of Errors in world-wide-web Database Related to WNP-2 Reactor Vessel Structural integrity.Marked-up Pages Containing Errors or Omissions Will Be Forwarded by 991201 ML17284A8751999-08-30030 August 1999 Provides Correct Page from License NPF-21 Marked to Show Rev Addressed in 990729 Application for Amend,Which Included Page That Was Inadvertently Included as Attachment 4.Replace Attachment 4 with Attached Page & Disregard Attachment 5 ML17284A8721999-08-30030 August 1999 Forwards Proprietary Info to Support Review of Request for Amend to License NPF-21,re Min Critical Power Ratio Safety Limits Tss,As Requested During 990816 Conversation. Proprietary Encl Withheld ML17292B7531999-08-24024 August 1999 Requests That Eleven Individuals Listed Below Take BWR Generic Fundamentals Examination to Be Administered on 991006 ML17292B7511999-08-24024 August 1999 Forwards Fitness for Duty (FFD) Semiannual Performance Data Rept for Jan-June 1999,per 10CFR26.71(d) ML17284A8701999-08-19019 August 1999 Forwards NRC Form 396, Certification of Medical Exam by Facility Licensee & NRC Form 398, Personal Qualification Statement - Licensee, for Jd Prescott (License SOP-50262-1).Without Encls ML17292B7501999-08-19019 August 1999 Informs Staff That Licensee Has Completed Review of NRC SER for B&Wog Util Resolution Guidance Document Addressing ECCS Suction Strainer Blockage ML17284A8681999-08-12012 August 1999 Submits Two ISI Program Plan Relief Requests for NRC Review & Approval,Per 10CFR50.55a(a)(3)(i).Proposed Alternatives Provide Acceptable Level of Quality & Safety ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML17284A8541999-08-0202 August 1999 Forwards Proprietary Addl Info to Support Review of Pending Request for Amend to MCPR Safety Limit Ts.Info Consists of Proprietary Ltr from Abb Combustion Engineering,Inc.Encl Withheld ML17284A8531999-07-30030 July 1999 Forwards Estimate of Number of Licensing Action Requests Planned for Submittal in Future,As Requested in Administrative Ltr 99-02.Twenty-nine Submittals Scheduled for Fy 2000 & Four for Fy 2001 ML17284A8301999-07-22022 July 1999 Clarifies Change of Licensee Name from Wpps to Energy Northwest & Change of Facility Name from Wppss Nuclear Project Number 2 to WNP-2,as Requested in 990719 Telcon with Js Cushing of NRC.Marked-up OL Pages,Encl ML17292B7451999-07-20020 July 1999 Forwards Rev 23 to WNP-2 Emergency Plan,Iaw 10CFR50.4(b) & 50.54(q) & 10CFR50 App E.Rev 23 Provides Updated Description Re Establishment of Separate Emergency Operation Centers for Benton & Franklin Counties ML17292B7391999-07-16016 July 1999 Submits Withdrawal of Request for Amend to Secondary Containment & Standby Gas Treatment Sys Ts.Util Currently Plan to re-submit Amend Request in Entirety by 991112 ML17292B7381999-07-12012 July 1999 Forwards NRC Form 396 & NRC Form 398,for If Sumsion,License OP-50487 & Ga Westergard,License SOP-50415 for Renewal of Operator Licenses.Without Encls ML17292B7171999-07-0606 July 1999 Provides Notification of Early Completion on 990630 of Exception Noted in 990629 Ltr.Equipment within Scope of GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants, Evaluated & Y2K Ready ML17292B7181999-07-0202 July 1999 Responds to 990623 RAI to Support Review of Evaluation of Planar Indication Found on Weld Number 24RRC(2)A-1 During 1998 RO ML17292B7161999-06-30030 June 1999 Forwards Addl Info Requested in 990513 Ltr to Support Review of Pending Response to GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power Operated Gate Valves. ML17292B7131999-06-29029 June 1999 Forwards Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. ML17292B7091999-06-21021 June 1999 Forwards Proprietary Response to NRC 990603 RAI Re Licensee Request for Amend to MCPR Safety Limit Tss.Proprietary Info Withheld IAW Requirements of 10CFR2.790 ML17292B7041999-06-17017 June 1999 Forwards NRC Forms 396 & 398 for Three Individuals Listed Below for Renewal of Operator Licenses.Without Encls ML17292B7031999-06-10010 June 1999 Forwards Response to NRC 990511 RAI Re License Request for Amend to Secondary Containment & SGTS Tss.Results of Addl Benchmark of Gothic Computer Code Performed to Demonstrate Modeling Capability of Drawdown Response,Encl ML17292B6841999-06-0404 June 1999 Forwards Response to NRC 990326 RAI Re WNP-2 GL 96-05 Program for Periodic Verification of design-basis Capability of MOVs ML17292B6851999-06-0101 June 1999 Forwards 1999 Quality Audit of WNP-2 Emergency Preparedness Program, Per NUREG-0654,Section Ii,Criteria P.9.Seven Problem Evaluation Requests & Nine Recommendations for Improvement Were Issued as Result of Audit Activities ML17292B6831999-05-25025 May 1999 Informs That Request for NRC Approval of Changes to Emergency Plan Requesting Reduction in on-shift HP Staffing, Is Retracted.Util Will Resubmit Request with Required Addl Info at Later Date ML17292B6751999-05-25025 May 1999 Forwards Proprietary ABB-CE Ltr Re WNP-2 Cycle 15 SLMCPR & Core Reload Design Rept,Per Util Request for Amend Re MCPR Safety Limits.Proprietary Info Withheld,Per 10CFR2.790 ML20206U4501999-05-19019 May 1999 Ack Receipt of Which Transmitted Rev 39 to Physical Security Plan,Per 10CFR50.54(p).No NRC Approval Is Required,Since Changes Do Not Decrease Effectiveness of Security Plan ML17292B6661999-05-0707 May 1999 Requests Exemption to Requirement in 10CFR55.59(a)(2) Re Annual Operating Test requirements.One-time Exemption from Requirement to Period Not to Exceed 15-months from Last Date of Passing Operating Exam for Licensee at Facility ML17292B6531999-05-0303 May 1999 Forwards Response to NRC 990402 RAI Re Licensed Operator Positive Drug Test.Encl Withheld,Per 10CFR2.790 ML17292B6561999-04-29029 April 1999 Forwards Rev 0 to Calculation ME-02-98-04, Fracture Mechanics Evaluation of N1 Safe End & Calculation Mod Record CMR-98-0243, Fracture Mechanics Evaluation of N1A Nozzle Safe End, as Suppl Info to ISI Exam ML17292B6421999-04-19019 April 1999 Responds to NRC 990319 Ltr Re Violations Noted in Insp Rept 50-397/99-01.Corrective Actions:Provisions Are Presently in Place to Maintain Adequate Level of Security GO2-99-073, Forwards Rev 39 to WNP-2 Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Effectiveness of Approved Plan.Encl Withheld IAW 10CFR73.21 & 10CFR2.7901999-04-19019 April 1999 Forwards Rev 39 to WNP-2 Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Effectiveness of Approved Plan.Encl Withheld IAW 10CFR73.21 & 10CFR2.790 ML17292B6401999-04-13013 April 1999 Requests That WNP-2 Operator Requalification Program Be Granted one-time Extension Beyond Requirement in 10CFR55.59(a)(2) for Annual Operating Tests ML17292B6371999-04-12012 April 1999 Forwards Response to NRC 990211 RAI Re Util Request for Amend to Secondary Containment & SBGTS TS ML17292B6281999-04-0606 April 1999 Informs NRC That Insp Interval Ending Date for ISI Program Plan Has Been Extended by One Year to Dec 12,2005 Due to Changes in Plant Refueling Outage Schedule ML20196K6961999-03-30030 March 1999 Ack Receipt of ,Transmitting Rev 38 to Physical Security Plan for Plant.No NRC Approval Is Required,In Accordance with 10CFR50.54(p) GO2-99-060, Submits Rept of Status of WNP-2 Decommissioning Fund as of 981231,IAW 10CFR50.75(f)(1)1999-03-26026 March 1999 Submits Rept of Status of WNP-2 Decommissioning Fund as of 981231,IAW 10CFR50.75(f)(1) ML17292B6131999-03-24024 March 1999 Forwards Rev 0 to Calculation ME-02-98-04, Fracture Mechanics Evaluation of N1 Nozzle Safe End. Info Will Be Used to Assist NRC in Review of WNP-2 ISI Activities Associated with Evaluation of Planar Indication ML20204F0261999-03-19019 March 1999 Forwards Insp Rept 50-397/99-01 on 990201-04 & 0303-05.No Violations Noted.Areas of Physical Security Plan Effectively Implemented with Listed Exceptions ML17292B6001999-03-16016 March 1999 Responds to Weakness Noted in Insp Rept 50-397/98-24. Corrective Actions:Developed Document to Identify Areas Needing Improvement,Assigned Responsibility for Actions & Provided Milestones for Achievement ML17292B5941999-03-16016 March 1999 Forwards NRC Form 396, Certification of Medical Exam by Facility Licensee, & NRC Form 398, Personal Qualification Statement - Licensee, for MD Comstock,Mc Naulty & RR Nelson.Without Encls 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML17284A8981999-10-14014 October 1999 Forwards Rev 0 to WNP-2 Cycle 15,COLR 99-15, IAW Requirements of TS 5.6.5 ML17284A9061999-09-24024 September 1999 Forwards Final Rept for 990812 out-of-sequence Drills for Energy Northwest Washington Nuclear Power Project 2 (Lab, Food Control Point & Milk Sampling).No Deficiences & No Areas Requiring C/A Identified in Three Drills ML17292B7591999-09-24024 September 1999 Forwards Rev 24 to WNP-2 Emergency Plan,Iaw 10CFR50.4(b), 50.54(q) & 10CFR50 App E.Detailed Synopsis of Changes,Encl ML17284A8881999-09-24024 September 1999 Informs NRC of Change in Schedule Pertaining to Final Implementation of Reactor Stability long-term Solution for WNP-2 ML17292B7581999-09-22022 September 1999 Forwards NRC Forms 396 & 398 for Nl Hancock,License SOP-50027-3,AR Herrington,License OP-50013-3,WH Sawyer, License SOP-50023-3 & Dl Strote,License SOP-50031-3,for Renewal of Licenses.Without NRC Forms 396 & 398 ML17284A8811999-09-0909 September 1999 Forwards Response to NRC 990623 RAI to Support Review of Pending Request for Amend to Reactor pressure-temp Limit Curve TS GO2-99-168, Forwards Rev 40 to Physical Security Plan.Rev Withheld,Per 10CFR2.790(a)(3)1999-09-0808 September 1999 Forwards Rev 40 to Physical Security Plan.Rev Withheld,Per 10CFR2.790(a)(3) ML17284A8751999-08-30030 August 1999 Provides Correct Page from License NPF-21 Marked to Show Rev Addressed in 990729 Application for Amend,Which Included Page That Was Inadvertently Included as Attachment 4.Replace Attachment 4 with Attached Page & Disregard Attachment 5 ML17284A8721999-08-30030 August 1999 Forwards Proprietary Info to Support Review of Request for Amend to License NPF-21,re Min Critical Power Ratio Safety Limits Tss,As Requested During 990816 Conversation. Proprietary Encl Withheld ML17284A8711999-08-30030 August 1999 Informs Staff of Errors in world-wide-web Database Related to WNP-2 Reactor Vessel Structural integrity.Marked-up Pages Containing Errors or Omissions Will Be Forwarded by 991201 ML17292B7531999-08-24024 August 1999 Requests That Eleven Individuals Listed Below Take BWR Generic Fundamentals Examination to Be Administered on 991006 ML17292B7511999-08-24024 August 1999 Forwards Fitness for Duty (FFD) Semiannual Performance Data Rept for Jan-June 1999,per 10CFR26.71(d) ML17284A8701999-08-19019 August 1999 Forwards NRC Form 396, Certification of Medical Exam by Facility Licensee & NRC Form 398, Personal Qualification Statement - Licensee, for Jd Prescott (License SOP-50262-1).Without Encls ML17292B7501999-08-19019 August 1999 Informs Staff That Licensee Has Completed Review of NRC SER for B&Wog Util Resolution Guidance Document Addressing ECCS Suction Strainer Blockage ML17284A8681999-08-12012 August 1999 Submits Two ISI Program Plan Relief Requests for NRC Review & Approval,Per 10CFR50.55a(a)(3)(i).Proposed Alternatives Provide Acceptable Level of Quality & Safety ML17284A8541999-08-0202 August 1999 Forwards Proprietary Addl Info to Support Review of Pending Request for Amend to MCPR Safety Limit Ts.Info Consists of Proprietary Ltr from Abb Combustion Engineering,Inc.Encl Withheld ML17284A8531999-07-30030 July 1999 Forwards Estimate of Number of Licensing Action Requests Planned for Submittal in Future,As Requested in Administrative Ltr 99-02.Twenty-nine Submittals Scheduled for Fy 2000 & Four for Fy 2001 ML17284A8301999-07-22022 July 1999 Clarifies Change of Licensee Name from Wpps to Energy Northwest & Change of Facility Name from Wppss Nuclear Project Number 2 to WNP-2,as Requested in 990719 Telcon with Js Cushing of NRC.Marked-up OL Pages,Encl ML17292B7451999-07-20020 July 1999 Forwards Rev 23 to WNP-2 Emergency Plan,Iaw 10CFR50.4(b) & 50.54(q) & 10CFR50 App E.Rev 23 Provides Updated Description Re Establishment of Separate Emergency Operation Centers for Benton & Franklin Counties ML17292B7391999-07-16016 July 1999 Submits Withdrawal of Request for Amend to Secondary Containment & Standby Gas Treatment Sys Ts.Util Currently Plan to re-submit Amend Request in Entirety by 991112 ML17292B7381999-07-12012 July 1999 Forwards NRC Form 396 & NRC Form 398,for If Sumsion,License OP-50487 & Ga Westergard,License SOP-50415 for Renewal of Operator Licenses.Without Encls ML17292B7171999-07-0606 July 1999 Provides Notification of Early Completion on 990630 of Exception Noted in 990629 Ltr.Equipment within Scope of GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants, Evaluated & Y2K Ready ML17292B7181999-07-0202 July 1999 Responds to 990623 RAI to Support Review of Evaluation of Planar Indication Found on Weld Number 24RRC(2)A-1 During 1998 RO ML17292B7161999-06-30030 June 1999 Forwards Addl Info Requested in 990513 Ltr to Support Review of Pending Response to GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power Operated Gate Valves. ML17292B7131999-06-29029 June 1999 Forwards Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. ML17292B7091999-06-21021 June 1999 Forwards Proprietary Response to NRC 990603 RAI Re Licensee Request for Amend to MCPR Safety Limit Tss.Proprietary Info Withheld IAW Requirements of 10CFR2.790 ML17292B7041999-06-17017 June 1999 Forwards NRC Forms 396 & 398 for Three Individuals Listed Below for Renewal of Operator Licenses.Without Encls ML17292B7031999-06-10010 June 1999 Forwards Response to NRC 990511 RAI Re License Request for Amend to Secondary Containment & SGTS Tss.Results of Addl Benchmark of Gothic Computer Code Performed to Demonstrate Modeling Capability of Drawdown Response,Encl ML17292B6841999-06-0404 June 1999 Forwards Response to NRC 990326 RAI Re WNP-2 GL 96-05 Program for Periodic Verification of design-basis Capability of MOVs ML17292B6851999-06-0101 June 1999 Forwards 1999 Quality Audit of WNP-2 Emergency Preparedness Program, Per NUREG-0654,Section Ii,Criteria P.9.Seven Problem Evaluation Requests & Nine Recommendations for Improvement Were Issued as Result of Audit Activities ML17292B6751999-05-25025 May 1999 Forwards Proprietary ABB-CE Ltr Re WNP-2 Cycle 15 SLMCPR & Core Reload Design Rept,Per Util Request for Amend Re MCPR Safety Limits.Proprietary Info Withheld,Per 10CFR2.790 ML17292B6831999-05-25025 May 1999 Informs That Request for NRC Approval of Changes to Emergency Plan Requesting Reduction in on-shift HP Staffing, Is Retracted.Util Will Resubmit Request with Required Addl Info at Later Date ML17292B6661999-05-0707 May 1999 Requests Exemption to Requirement in 10CFR55.59(a)(2) Re Annual Operating Test requirements.One-time Exemption from Requirement to Period Not to Exceed 15-months from Last Date of Passing Operating Exam for Licensee at Facility ML17292B6531999-05-0303 May 1999 Forwards Response to NRC 990402 RAI Re Licensed Operator Positive Drug Test.Encl Withheld,Per 10CFR2.790 ML17292B6561999-04-29029 April 1999 Forwards Rev 0 to Calculation ME-02-98-04, Fracture Mechanics Evaluation of N1 Safe End & Calculation Mod Record CMR-98-0243, Fracture Mechanics Evaluation of N1A Nozzle Safe End, as Suppl Info to ISI Exam ML17292B6421999-04-19019 April 1999 Responds to NRC 990319 Ltr Re Violations Noted in Insp Rept 50-397/99-01.Corrective Actions:Provisions Are Presently in Place to Maintain Adequate Level of Security GO2-99-073, Forwards Rev 39 to WNP-2 Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Effectiveness of Approved Plan.Encl Withheld IAW 10CFR73.21 & 10CFR2.7901999-04-19019 April 1999 Forwards Rev 39 to WNP-2 Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Effectiveness of Approved Plan.Encl Withheld IAW 10CFR73.21 & 10CFR2.790 ML17292B6401999-04-13013 April 1999 Requests That WNP-2 Operator Requalification Program Be Granted one-time Extension Beyond Requirement in 10CFR55.59(a)(2) for Annual Operating Tests ML17292B6371999-04-12012 April 1999 Forwards Response to NRC 990211 RAI Re Util Request for Amend to Secondary Containment & SBGTS TS ML17292B6281999-04-0606 April 1999 Informs NRC That Insp Interval Ending Date for ISI Program Plan Has Been Extended by One Year to Dec 12,2005 Due to Changes in Plant Refueling Outage Schedule GO2-99-060, Submits Rept of Status of WNP-2 Decommissioning Fund as of 981231,IAW 10CFR50.75(f)(1)1999-03-26026 March 1999 Submits Rept of Status of WNP-2 Decommissioning Fund as of 981231,IAW 10CFR50.75(f)(1) ML17292B6131999-03-24024 March 1999 Forwards Rev 0 to Calculation ME-02-98-04, Fracture Mechanics Evaluation of N1 Nozzle Safe End. Info Will Be Used to Assist NRC in Review of WNP-2 ISI Activities Associated with Evaluation of Planar Indication ML17292B5991999-03-16016 March 1999 Informs That Listed Property & Liability Insurance Coverage for WNP-2 Is in Force,In Compliance with Licensing Responsibilities Delineated in 10CFR50.54(w)(3) ML17292B5911999-03-16016 March 1999 Forwards 1998 Environ Operating Rept, Per Reporting Requirements of Section 5.4.1 of WNP-2 Epp.No Design or Operational Changes or Tests in 1998 Involved Unreviewed Environ Question ML17292B5941999-03-16016 March 1999 Forwards NRC Form 396, Certification of Medical Exam by Facility Licensee, & NRC Form 398, Personal Qualification Statement - Licensee, for MD Comstock,Mc Naulty & RR Nelson.Without Encls ML17292B6001999-03-16016 March 1999 Responds to Weakness Noted in Insp Rept 50-397/98-24. Corrective Actions:Developed Document to Identify Areas Needing Improvement,Assigned Responsibility for Actions & Provided Milestones for Achievement ML17292B5901999-03-11011 March 1999 Forwards Hard Copy of Addl Occupational Exposure Data Requested in GL 94-04,per 990303 e-mail.Original Electronic Version Was Corrupted ML17292B5681999-03-0101 March 1999 Forwards Radioactive Effluent Release Rept for 1998, IAW 10CFR50.36a(a)(2) & TS 5.6.3 & Complete Copy of WNP-2 ODCM Per TS 5.5.1 ML17292B5651999-02-22022 February 1999 Forwards Relief Request 2ISI-20,proposing Alternate Exam Expected to Reduce Dose Significantly & Still Provide Adequate Safety & Quality.Attached Relief Request Will Be Used to Support ALARA Dose Reduction Efforts During Maint ML17292B5581999-02-0404 February 1999 Requests Change to Co Which Modified WNP-2 OL to Reflect Schedule for Implementing Thermo-Lag 330-1 Fire Barrier C/As.Change Requested to Reflect That Final Implementation of C/As Will Be Completed During Fall 1999 Not Spring 1999 1999-09-09
[Table view] Category:UTILITY TO NRC
MONTHYEARML17286A2801990-08-27027 August 1990 Forwards fitness-for-duty Program Performance Data for 900103-0630,per 10CFR26.71(d) ML17286A2671990-08-23023 August 1990 Provides Info on Steps Taken to Minimize Potential Effects of NRC Maint Insp Interface Record, Form on Candor of Supply Sys Personnel When Talking W/Nrc Inspectors ML17286A2641990-08-20020 August 1990 Advises That Tech Spec Rev Re ATWS Recirculation Pump Trip Will Be Submitted by 900928,per Discussions W/ P Eng & H Lee ML17285B4341990-08-20020 August 1990 Withdraws 900302 Request for Amend to Tech Spec 3.8.1.1, AC Sources Reducing Excessive Testing of Diesel Generators. IR 05000397/19900141990-08-10010 August 1990 Provides Info Re Final Assessment of Causes & Corrective Actions Associated W/Recent 25 Kv iso-phase Bus Electrical Fault Incident,Per Request in Cover Ltr to Insp Rept 50-397/90-14.Plant Procedure 10.25.141 Will Be Revised ML17285B4171990-08-10010 August 1990 Provides Info Re Final Assessment of Causes & Corrective Actions Associated W/Recent 25 Kv iso-phase Bus Electrical Fault Incident,Per Request in Cover Ltr to Insp Rept 50-397/90-14.Plant Procedure 10.25.141 Will Be Revised ML17285B4041990-08-0202 August 1990 Submits Justification for Continued Operation W/Emergency Diesel Generator 2 Shorted Turns ML17285B3981990-07-30030 July 1990 Advises That Installation of Detector Check Valve in Fire Protection Underground Piping Sys Complete,Per 890911 Ltr. Sys Monitors for Underground Sys Leakage Over Entire Fire Protection Sys ML17285B3991990-07-27027 July 1990 Forwards Justification for Continued Operation Re Emergency Diesel Generator 2 Shorted Turns.Justification Concludes That Diesel Generator Capable of Supporting Present Operability Requirements of Tech Specs ML17285B3711990-07-12012 July 1990 Responds to NRC Bulletin 90-001, Loss of Fill-Oil in Transmitters Mfg by Rosemount. Confirms That Items 1,2,3,4 & 5 of Requested Actions of Operating Reactors Completed ML17285B3761990-07-12012 July 1990 Discusses Potential for Surface Entry & Mining Near Plant Sites.Concludes That NRC Need Not Consider Issue as One Requiring Continued Monitoring ML17285B3781990-07-11011 July 1990 Requests Waiver of Compliance from Tech Spec 3.8.1.2 Re Ac Sources - Shutdown.Waiver Will Allow Performance of Rotor Pole Ac Voltage Drop Test to Provide Confirmation That for Extended Run Degradation Condition Will Not Occur ML17285B3841990-07-10010 July 1990 Forwards Util 1990 Emergency Exercise Scenario.W/O Encl ML17285B3661990-07-0505 July 1990 Advises of Listed Organizational & Personnel Changes, Effective 900707.J Burn Will Be New Director of Projects, C Powers Promoted to Director of Engineering & J Baker Promoted to Plant Manager ML17285B3641990-06-29029 June 1990 Advises That All Equipment Identified W/Atws Safety Function Acceptable from Environ Qualification Standpoint. ATWS Equipment Has Been Determined to Be Qualified to Normal Design Environ Conditions Followed by ATWS Accident Environ ML17285B3571990-06-28028 June 1990 Responds to Generic Ltr 90-04, Request for Info on Status of Licensee Implementation of Generic Safety Issues Resolved W/Imposition of Requirements or Corrective Actions. ML20055D2391990-06-28028 June 1990 Forwards Response to Re Violations Noted in Insp Rept 50-397/90-12.Response Withheld (Ref 10CFR73.21) ML17285B3501990-06-22022 June 1990 Advises That Mods to Recirculation Pump Trip Sys Implemented During 1990 Spring Refueling Outage.Remaining ATWS Items to Be Resolved as Listed ML17285B3511990-06-20020 June 1990 Forwards WPPSS-FTS-129, BWR Transient Analysis Model, for Review & Approval ML17285B3441990-06-20020 June 1990 Advises That Util Intends to Utilize R-value of 0.13% Delta K/K in Cycle 6 Implementing Procedures.Should R-value Change in Final Startup & Operations Rept,Changed Value Shall Be Used Instead ML17285B3451990-06-19019 June 1990 Forwards Rev 10 to EPIP 13.1.1, Classifying Emergency. Rev Includes New Format of Matrix Charts Intended to Improve Identification of Symptomatic & situation-based Emergency Conditions ML17285B3431990-06-18018 June 1990 Advises of Appointment of AL Oxsen to Position of Deputy Managing Director,Effective 900601 ML17285B3461990-06-15015 June 1990 Responds to NRC Evaluation Findings of Licensed Operator Requalification Program.Quality of Written Exam & Job Performance Measure Question Bank Testing Matls Will Be Improved to Meet Std Prior to Next Program Evaluation Cycle ML17285B3301990-06-12012 June 1990 Forwards Warrant for $50,000 in Response to Order Imposing Civil Monetary Penalty Dtd 900521 ML17285B3251990-06-0707 June 1990 Advises That Calculated Max Control Room Temp Re Station Blackout Will Be Provided by 900701 ML17285B2931990-05-29029 May 1990 Responds to NRC 900426 Ltr Re Violations Noted in Insp Rept 50-397/90-09.Validity of Violation Challenged.Opposes Issuance of Severity Level IV Violation Based on Listed Reasons ML17285B2861990-05-22022 May 1990 Advises That Submittal of Improved Tech Spec Scheduled for Mar 1991 & Implementation Tenatively Scheduled for Oct 1991 ML17285B2881990-05-11011 May 1990 Forwards Engineering Std EES-4,Rev 0, Setpoint Methodology, as Committed in Util 900329 Ltr.W/O Encl ML17285B2471990-05-0101 May 1990 Advises That No Changes to Tech Specs Required as Stated in 891130 Ltr in Response to Generic Ltr 89-21 Requesting Plant Status on Implementation of USI Re ATWS ML17285B2741990-04-26026 April 1990 Advises That Util Has No Comments on Licensed Operator Annual Requalification Exam During Wks of 900226 & 0305.All Comments Resolved When Exams Administered ML17285B2321990-04-25025 April 1990 Submits Revised Scheduled Completion Dates for Commitments Made in Response to Violations Noted in Insp Repts 50-397/89-06 & 50-397/89-17 ML17285B2121990-04-19019 April 1990 Responds to Fire Protection Issues Identified in 900201 Notice of Violation.Corrective Actions:Major Hardware Changes Implemented & Independent Consultant Will Be Employed to Review Fire Protection Program ML17285B2221990-04-16016 April 1990 Forwards Status Rept for Commitments Made in 891130 Ltr Re commercial-grade Dedication Process.Resolution of 10 Samples Identified by NRC & 50 Samples Identified by Cynga Completed ML17285B1881990-04-11011 April 1990 Responds to NRC 900312 Ltr Re Violations Noted in Insp Rept 50-397/90-01.Corrective Actions:Complete Job & Task Analysis Completed for Health Physics Technician Training Program & New Program Will Include Training on Fundamentals ML17285B1821990-04-0505 April 1990 Requests Exemption from Filing Requirements of 10CFR55.45(b)(2)(iii) & (IV) to Allow Delayed Submittal of NRC Form-474, Simulation Facility Certification & to Administer Simulation Test as Upgraded,Respectively ML17285B1741990-04-0505 April 1990 Advises That NRC Approved Use of Final Feedwater Temp Reduction in Amend 77 to License NPF-21 ML20012F6141990-04-0404 April 1990 Forwards Rev 17 to Physical Security Plan.Rev Withheld (Ref 10CFR73.21) ML17285B2041990-03-29029 March 1990 Requests Review of Encl Topical Rept WPPSS-FTS-127,Rev 0, Qualification of Core Physics Methods for BWR Design & Analysis. Upon Rept Approval,Tech Spec Changes (Per Generic Ltr 88-16) Scheduled for Jan 1992 ML17285B1421990-03-29029 March 1990 Forwards Revised Schedule for Plant Equipment Setpoint Methodology Program Plan.Methodology Revised to Incorporate Latest ISA Std Draft.Setpoint Program Design Team for FY90 Onsite,Trained & Began Work on 900312 ML17285B1381990-03-29029 March 1990 Forwards Concluding Rept of Results Requested by Generic Ltr 88-14, Instrument Air Supply Sys Problems Affecting Safety- Related Equipment. Air Quality Testing Performed to Date Reveals Steadily Improving Results ML17285B1131990-03-28028 March 1990 Advises of Release of Subchannel Thermal Hydraulic Computer Code & Requests Review of VIPRE-01 Mod-02 & Issuance of SER for PWR & BWR Applications.Bwr Qualification Analyses Completed & Rept on BWR Applications Encl ML17285B1331990-03-23023 March 1990 Responds to NRC 900221 Ltr Re Violations Noted in Insp Rept 50-397/89-40.Corrective Actions:Plant Procedure 10.25.63, Emergency Lighting Insp in Process of Being Expanded to Provide Instructions & Check Sheets to Ensure Uniform Insps ML17285B1311990-03-21021 March 1990 Forwards Proposed Bases Change Re 891129 Request for Amend to Tech Spec Table 4.3.6.1, Srm/Irm Detector Not-Full-In Functional Test. Bases Change Describes Special Circumstances Re Test Exception ML17285B1291990-03-19019 March 1990 Responds to Generic Ltr 89-19 Re Resolution of USI A-47 on Safety Implications of Control Sys in LWRs & Generic Ltr 89-21 Re Status of Implementation of Usis.Tech Specs Adequate to Verify Operability of Overfill Protection Sys ML17285B1171990-03-19019 March 1990 Suppls 900102 Response Re Implementation of fitness-for-duty Program at Facility.All Items Identified as Incomplete as of 900103 Completed at End of Jan 1990 ML17285B1121990-03-15015 March 1990 Provides Level of Property & Liability Insurance Coverage for Facility,Per 10CFR50.54(w)(2) Annual Requirement ML17285B0931990-03-0202 March 1990 Forwards Supplementary Info Re 900214 Application for Amend to License NPF-21,revising Tech Spec 3.3.7.5 to Address Failed Safety/Relief Valve Position Indicators ML17285B0741990-03-0202 March 1990 Responds to NRC 900201 Ltr Re Violations Noted in Insp Rept 50-397/89-30.Corrective Action:Plant Personnel Currently in Process of Making Improvements to Plant Operations Procedure Writers Guide ML17285B0861990-03-0101 March 1990 Forwards Compilation of Responses to Regulatory Impact Survey Questionnaire,Per Generic Ltr 90-01 ML17285B0581990-02-26026 February 1990 Forwards Washington Nuclear Plant-2 Semiannual Radioactive Effluent Release Rept,Jul-Dec 1989 & Amend 7 to Odcm. 1990-08-27
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ti WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 99352 December, 21, 1988 G02"88"274 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"24 RESPONSE TO NOTICE OF VIOLATION The Washington Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated November 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, each violation is addressed with an explanation of our, position regarding validity, corrective action and date of full compliance.
G. C. Sorensen, Manager Regulatory Programs REF/bk Attachments cc: JB Martin - NRC RV NS Reynolds - BCP8R RB Samworth - NRC DL Williams BPA NRC Site Inspector - 901A
APPENDIX A Page 1 of 8 APPENDIX A During an NRC inspection conducted from August 22 to September 2, 1988, several 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 (1988), as modified by 53 Fed. Reg. 40019 (October 13, 1988), the viola-tions are listed below:
A. Paragraph 6.8.1 of the Technical Specifications requires written procedures to be established, implemented, and maintained for surveillance and test activities of safety-related equipment.
Paragraph 6.8.2 of the Technical Specifications requires these procedures and changes to these procedures to be reviewed by the POC and approved by the Plant Manager, as set forth in administrative procedures.
Paragraph 6.8.3 of the Technical Specifications allows temporary changes to be made to procedures provided that the intent of the original procedure is not altered, the change is approved by two members of management staff (at least .one of whom holds a Senior Operator license), and the change is docu-mented, reviewed by the POC, and approved by the Plant Manager within 14 days of implementation.
Administrative Procedure 1.2.3, "Use of Procedures" (Rev. 12 dated September 18, 1987), requires procedures to be followed in the performance of plant activities. When procedures cannot be followed, a revision to the procedure or a procedure deviation must be completed. In the case of a procedure deviation, documentation prior to its implementation is not required provided the deviation has been approved by two members of plant management/supervi-sory staff and the Shift Manager is of the opinion that the work must continue.
Contra y to the above, changes were made to Surveillance Procedur e 7.4.4.3.1.4 dur ing the performance of a drywell sump flow monitor calibration on August 24, 1988, and a procedure revision or procedure deviation was not completed.
This is a Severity Level IV violation (Supplement I).
Validit of Violation The Supply System does not acknowledge the validity of this violation.
Just prior to August 22, 1988 the Drywell Sump Flow Monitor. indicated a flow that was approaching the Tech Spec limit, Section 3.4.3.2b, 5 gpm unidenti-fied leakage. A volumetric flow test (using buckets), PPMs 2. 11.3 and 2.11.5 was performed which determined that the indicated flow was greater than the actual flow. Operations requested that the loop be recalibrated. On August 22, 1988 at 0958, surveillance procedure 7.4.4.3.1.4, "Drywell Sump Flow Monitors," was started. During the performance of the procedure the Technicians noted that there were problems with the procedure which required
Page 2 of 8 a deviation. The Technicians obtained the assistance from the Maintenance Engineers to provide guidance on the procedure deviation required to remedy the problems identified with the procedure and ensure the deviation would not cause new problems. Permission was then obtained from the Shift Manager and the 18C Maintenance 'Supervisor to deviate from the procedure as necessary per PPN 1.2;3.C.3, and to provide the deviation and completed procedure for signature and approval prior to declaring the flow monitor, back in service.
This was considered acceptable because the floor drain sump flow monitoring instrumentation system does not provide any automatic actuation, but instead, provides indication and high flow alarm only'. Therefore, volumetric flow tests were performed within the required frequency to monitor, leakage flow rates relative to the allowable Technical Specification limits. The Shift Manager had decided the work must continue because the accuracy of the drywell sump flow monitor. system was in question and the sump flow indicator was approaching the Technical Specification limit.
The procedur e was completed the afternoon of August 24, 1988 'and the proce-dure deviation was written from the notes made during the performance of the procedure. The deviation received approval signatures on August 25, 1988 at 0800 and the procedure was signed off as .completed satisfactorily at 0826 on August 25, 1988. The equipment was not .returned to service prior to imple-mentation and sign off of the procedure deviation.
Per Plant Procedure 1.2.3, Section C.3, the deviation is not required to be documented prior, to its implementation providing it . has been approved verbally by two members of the. Plant Management Supervisory Staff. This process should be followed only when, in the judgment of the Shift Manager, work must continue as was the case here.
Corrective Ste s Taken/Results Achieved PPN successfully performed.
Corrective Action to be Taken No further corrective action is planned.
Date of Full Com liance The Supply System is currently in full compliance.
APPENDIX A Page 3 of 8 10 CFR 50.72(b)(2)(ii) requires the licensee to notify the NRC as soon as practical and in all cases within four hours of any event or condition that results in an automatic Reactor- Protection System (RPS) actuation that is not part of a preplanned sequence during testing or reactor operation.
Contrary to the above, the following RPS actuation were not part of the preplanned'equence during testing or reactor operation, and were not reported to the NRC as required:
o At 0844 on May 29, 1988, during Node 5 operation, an .RPS actuation occurred during initial testing of the alternate rod insertion (ARI) system. The RPS actuation occurred when air. pressure bled off the scram valves after the ARI system was placed in the test mode and the scram air. header was isolated. Control rod drive air, system leakage resulted from undocumented air, system leaks, and the RPS actuation was not a normal occur rence and was not anticipated in the ARI system test proce-dur.e.
At 1553 on August 26, 1988, during Node 5 operation, an RPS actuation occurred when Division II RPS power was transferred from the alternate to the normal source. The RPS actuation was due to switch over-travel during the power transfer evolution. The control room logs did not indicate that testing was in progress at the time of the RPS actuation, and the licensee could not produce a maintenance work order or other documentation to demonstrate that testing was in progress during the August 26 event.
This is a Severity Level IV violation (Supplement I).
Validit of Violation The Supply System does not acknowledge the validity of this violation:
"Actuation of an ESF, including the RPS, that results from and is part of the preplanned sequence during testing or reactor operation need not be reported" (10CFR50.72(b)(2)(ii) and 10CFR50.73(2)(2)(iv)). "Operation of an ESF as part of a planned. operational procedure or test (e.g., startup testing) need not be reported. However, if during the planned operating procedure or test, the ESF actuates in a way that is not part of the planned procedure that actuation must be reported." (Page 13 NUREG 1022)
Scram Discharge Volume High High Reactor Protection System Actuation.
As stated in the regulations quoted above, any RPS actuation that is part of a preplanned sequence during testing need not be reported. The event cited in this violation occurred as part of a preplanned testing sequence and therefore is not reportable. P'erformance of the Pre-Operational (pre-op) Test Procedure for the Anticipated Transient Without Scram (ATWS) Alternate Rod Insertion (ARI) System was the cause
APPENDIX A Page 4 of 8 of this event. A step in the ARI Pre-Operational Test Procedure required isolation of the Control Rod Drive Scram Air Header. Some bleed off of air pressure in the header was expected, and in. fact, there was a procedure step to record the amount of pressure lost during the test. While the amount of bleed down was not known prior to the test, the consequences of a large decrease in air header pressure were known.
That is the scram valves open and 'the Scram Discharge Volume (SDV) drain valves close whereby the "'scram water, fills the SDV and causes an RPS actuation on high water level. The test procedure purposely did not open the bypass valve which would have prevented the actuation. The Event Precursor reviewer stated to the Reactor Systems Supervisor that if the sequence of events in the procedure establish a condition where an RPS actuation could occur, thi s would constitute preplanning. There-fore, the RPS actuation was the result of a preplanned sequence of testing, and the actuation did not occur in a way that was not part of the procedure.
The condition of the control rod drive system having "undocumented air system leaks" is irrelevant since the Control Rod Drive System, includ-ing the scram air header meets all operational requirements. The scram header. air leaks were investigated following this event because of concerns expressed about the rapidity of the bleed down., No major leaks were discovered and it was judged to be determined impractical to fix most of the minor leaks found during power operation. Those leaks which can be repaired without major piping disassembly scheduled to be repaired in R-4.
August 26, 1988 RPS Actuation.
"On August 25, 1988, at 2211 hours0.0256 days <br />0.614 hours <br />0.00366 weeks <br />8.412855e-4 months <br />, while performing a channel functional test and calibration of the Reactor Protection System RPS Bus "A" EPA breakers, a full RPS actuation occurred due to momentary loss of power to both divisions of RPS. The cause of this event is switch over travel, which'eenergized both divisions of RPS simultaneously" (from WNP-2 Licensee Event Report 88-30).
On August 26, 1988; Contr ol Room Operators (CROs) (Licensed Reactor Operators) were preparing to transfer RPS "B" power from its alternate to normal power supply. Because of the full RPS trip of the previous day, the Shift Manager, Control Room Supervisor, and System Engineer determined that an opportunity existed to investigate the August 25, 1988 event. This process was consistent with the approved Plant Troubleshooting Procedure. -
The same CRO who performed the power transfer the previous day was instructed to do the power transfer in the exact manner of the previous day with RPS System Engineer watchi.ng. CRO duties are rotated daily and it is unlikely that the same CRO would have performed this task on both days and by observing the August 26, 1988 RPS power transfer, the RPS System Engineer was able to determine the cause of the August 25, 1988 event. Therefore, this RPS actuation is considered a preplanned test and is not reportable.
APPENDIX A Page 5 of 8 Corrective Ste s Taken/Results Achieved Pre-op procedures were successfully performed.
II Corrective Action to be Taken No further corrective action is planned.
Date of Full Com liance The Supply System is currently in full compliance.
ACCELEPCTED +STRIBUTIO.'l DEMO4RXTIOY, SYSTEM I,
'EGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:8812280272 DOC.DATE: 88/12/21 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 'ECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to 50-397/88-24.
NRC 881123 ltr re violations noted in Insp Rept DISTRIBUTION CODE: XE01D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response N.OTES RECIPIENT ID CODE/NAME COPIES LTTR ENCL RECIPIENT ID CODE/NAME COPIES LTTR ENCL j
PD5 PD 1 1 SAMWORTH,R 1 1 A INTERNAL: ACRS 2 2 AEOD 1 1 D AEOD/DEIIB 1 1 'EDRO 1 1 NRR SHANKMAN,S 1 1 NRR/DLPQ/PEB 11 1 1 NRR/DLPQ/QAB 10 1 1 NRR/DOEA DXR 11 1 1 NRR/DREP/EPB 1 1 NRR/DREP/RPB 10 2 2 DIR 9A 10'RR/DRIS 1 1 NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT 1 1 .WEBB N,J 1 1 OGC/HDS2 1 1 R G ILE 02 1 1 RGN5 FILE 01 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 RESL MARTIN,D 1 1 R
I NOTE rO ALL "RIDS RECIPIENTS.
PLEASE HELP US K) REDUCE WASTE.'CT 'lHE DOCUMEMI'XKQRL DESK, RXM Pl-37 (EXT. 20079) %0 EIlIMINA!PE KR3R NAME HKH DISTBZK7ZION LISTS FOR DOCUMENIS YOU DONiT NEED)
TOTAL NUMBER OF COPXES REQUIRED: LTTR 25 ENCL 25
WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 99352 December, 21, 1988 G02-88-274 Docket No. 50-397 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Nail Station Pl-137 Washington, D.C. 20555 Gentlemen:
Subject:
NUCLEAR PLANT NO. 2 LICENSE NO. NPF-21 NRC INSPECTION REPORT 88"24 RESPONSE TO NOTICE OF VIOLATION T he Washington Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated November 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, each viotation is addressed with an explanation of our, position regarding validity, corrective action and date of full compliance.
Very truly yours, G. C.'Sorensen, Manager Regulatory Programs REF/bk Attachments cc: JB Martin - NRC RV NS Reynolds - BCP8R RB Samworth - NRC DL Williams - BPA NRC Site Inspector - 901A yPo/
APPENDIX A Page 1 of 8 APPENDIX A During an NRC inspection conducted from August 22 to September 2, 1988, several 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 (1988), as modified by 53 Fed. Reg. 40019 (October 13, 1988), the viola-tions are listed below:
A. Paragraph 6.8.1 of the Technical Specifications requires written procedures to be established, implemented, and maintained for. surveillance and test activities of safety-related equipment.
Paragraph 6.8.2 of the Technical Specifications requires these procedures and changes to these procedures to be reviewed by the POC and approved by the Plant Manager, as set forth in administrative procedure es.
Paragraph 6.8.3 of the Technical Specifications allows tempo ary changes to be made to procedures provided that the intent of the original procedure is not altered, the change is approved by two members of management staff (at least one of whom holds a Senior Operator license), and the change is docu-mented, reviewed by the POC, and approved by the Plant Manager within 14 days of implementation.
Administrative Procedure 1.2.3, "Use of Procedures" (Rev. 12 dated September 18, 1987), requires procedures to be followed in the performance of plant activities. When procedures cannot be followed, a revision to the procedure or a procedure deviation must be completed. In the case of a procedure deviation, documentation prior to its implementation is not required provided the deviation has been approved by two members of plant management/supervi-sory staff and the Shift Manager is of the opinion that the work must continue.
Contrary to the above, changes were made to Sur veil l ance Procedure 7.4.4.3.1.4 during the performance of a drywell sump flow monitor calibration on August 24, 1988, and a procedure revision or procedure deviation was not completed.
This is a Sever ity Level IY violation (Supplement I).
Validit of Violation The Supply System does not acknowledge the validity of this violation.
Just prior to August 22, 1988 the Drywell Sump Flow Monitor. indicated a flow that was approaching the Tech Spec limit, Section 3.4.3.2b, 5 gpm unidenti-fied leakage. A volumetric flow test (using buckets), PPMs 2. 11.3 and 2.11.5 was performed which determined that the indicated flow was greater than the actual flow. Operations requested that the loop be recalibrated. On August 22, 1988 at 0958, surveillance procedure 7.4.4.3.1.4, "Drywell Sump Flow Monitors," was started. During the performance of the procedure the Technicians noted that ther e were problems with the procedure which required
APPENDIX A Page,2 of 8 a deviation. The Technicians obtained the assistance from the Maintenance Engineers to provide guidance on the procedure deviation required to remedy the problems identified with the procedure and ensure the deviation would not cause new problems. Permission was then obtained from the Shift Manager and the IEC Maintenance Supervisor to deviate from the procedure as necessary per PPN 1.2.3.C.3, and to provide .the deviation and completed procedure for, signature and approval prior to declaring the flow monitor back in service.
This was considered acceptable because the floor drain sump flow monitoring instrumentation system does not provide any automatic actuation, but instead, provides indication and high flow alarm only. Therefore, volumetric flow tests were performed within the required frequency to monitor, leakage flow rates relative to the allowable Technical Specification limits. The Shift Manager had decided the work must continue because the accuracy of the drywell sump flow monitor. system was in question and the sump flow indicator was approachi ng the Technical Specification limit.
The procedur e was completed the afternoon of August 24, 1988 'and the proce-dure deviation was written from the notes made during the performance of the procedure. The deviation received approval signatures on August 25, 1988 at 0800 and the procedure was signed off as completed satisfactorily at 0826 on August 25, 1988. The equipment was not returned to service prior to imple-mentation and sign off of the procedure deviation.
Per Plant Procedure 1.2.3, Section C.3, the deviation is not required to be
, documented prior to its implementation providing it has been appr oved verbally by two members of the Plant Management Supervisory Staff. This process should be followed only when, in the judgment of the Shift Manager, work must continue as was the case here.
Corrective Ste s Taken/Results Achieved PPN successfully performed.
Corrective Action to be Taken No fur ther corrective action is planned.
Date of Full Com liance The Supply System is currently in full compliance.
APPENDIX A Page 3 of 8 10 CFR 50.72(b)(2)(ii) requires the licensee to notify the NRC as soon as practical and in all cases within four hours of any event or condition that results in an automatic Reactor. Protection System (RPS) actuation that is not part of a preplanned sequence during testing or reactor operation.
Contrary to the above, the following RPS actuation were not part of the preplanned sequence during testing or reactor operation, and were not reported to the NRC as required:
o At 0844 o'n May 29, 1988, during Mode 5 operation, an RPS actuation occurred during initial testing of the alternate rod insertion (ARI) system. The RPS actuation occurred when air. pressure bled off the scram valves after the ARI system was placed in the test mode and the scram air, header was isolated. Control rod drive air, syste~ leakage resulted from undocumented air. system leaks, and the RPS actuation was not a normal occurrence and was not anticipated in the ARI system test proce-dure.
o At 1553 on August 26, 1988, during Mode 5 operation, an RPS actuation occurred when Division II RPS power was transferred from the alternate to the normal source. The RPS actuation was due to switch over-travel during the power, transfer evolution. The control room logs did not indicate that testi ng was in progress at the time of the RPS actuation, and the licensee could not produce a maintenance work order or, other documentation to demonstrate that testing was in progress during the August 26 event.
This is a Severity Level IV violation (Supplement I).
Validit of Violation The Supply System does not acknowledge the validity of this violation:
"Actuation of an ESF, including the RPS, that results from and is part of the preplanned sequence during testing or reactor, operation need not be reported" (10CFR50.72(b)(2)(ii) and 10CFR50.73(2)(2)(iv)). "Operation of an ESF as part of a planned operational procedure or, test (e.g., startup testing) need not be reported. However, if during the planned operating procedure or test, the ESF actuates in a way that is not part of the planned procedure that actuation must be reported." (Page 13 NUREG 1022)
Scram Discharge Volume High High Reactor. Protection System Actuation.
As stated in the regulations quoted above, any RPS actuation that is part of a preplanned sequence during testing need not be reported. The event cited in this violation occurred as part of a preplanned testing sequence and therefore is not reportable. Performance of the Pre-Operational (pre-op) Test Procedure for. the Anticipated Transient Without Scram (ATWS) Alternate Rod Insertion (ARI) System was the cause
APPENDIX A Page 4 of 8 of this event. A step in the ARI Pre-Operational Test Procedure required isolation of the Control Rod Drive Scram Air Header-. Some bleed off of air pressure in the header was expected, and in fact, there was a procedure step to record the amount of pressure lost during the test. While the amount of bleed down was not known prior to the test, the consequences of a large decrease in air header pressure were known.
That is the scram valves open and 'the Scram Discharge Volume (SDV) drain valves close whereby the scram water. fills the SDV and causes an RPS actuation on high water level. The test procedure purposely did not open the bypass valve which would have prevented the actuation. The Event Precursor reviewer stated to the Reactor Systems Supervisor that if the sequence of events in the procedure establish a condition where an RPS actuation could occur, this would constitute preplanning. There-fore, the RPS actuation was the result of a preplanned sequence of testing, and the actuation did not occur in a way that was not part of the procedure.
The condition of the control rod drive system having "undocumented air system leaks" is irrelevant since the Control Rod Drive System, includ-ing the scram air header meets all operational requirements. The scr am header air leaks were investigated following this event because of concerns expressed about the rapidity of the bleed down. No major leaks were discovered and it was judged to be determined impractical to fix most of the minor leaks found during power operation. Those leaks which can be repaired without major piping disassembly scheduled to be repaired in R-4.
August 26, 1988 RPS Actuation.
"On August 25, 1988, at 2211 hours0.0256 days <br />0.614 hours <br />0.00366 weeks <br />8.412855e-4 months <br />, while performing a channel functional test and calibration of the Reactor Protection System RPS Bus "A" EPA breakers, a full RPS actuation occurred due to momentary loss of power to both divisions of RPS. The cause of this event is switch overtravel, which deenergized both divisions of RPS simultaneously" (from WNP-2 Licensee Event Report 88-30).
On August 26, 1988, Control Room Operators (CROs) (Licensed Reactor Operators) were preparing to transfer, RPS "B" power from its alternate to normal power supply. Because of the full RPS trip of the previous day, the Shift Manager, Control Room Supervisor, and System Engineer determined that an opportunity existed to investigate the August 25, 1988 event. This process was consistent with the approved Plant Tr oubleshooting Procedure. The same CRO who performed the power transfer the previous day was instructed to do the power transfer in the exact manner of the previous day with RPS System Engineer watching. CRO duties are rotated daily and this it is unlikely that the same CRO would have performed task on both days and by observing the August 26, 1988 RPS power transfer., the RPS System Engineer was able to determine the cause of the August 25, 1988 event. Therefore, this RPS actuation is considered a preplanned test and is not reportable.
APPENDIX A Page 5 of 8 Corrective Ste s Taken/Results Achieved Pre-op procedures were successfully performed.
Corrective Action to be Taken No further, corrective action is planned.
Date of Full Com liance The Supply System is currently in full compliance.
APPENDIX A Page 6 of 8 Technical Specification 6.8.1 states, in part, that "Written procedures shall be established, implemented, and maintained covering ... the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978." These include "Procedures for Performing Maintenance".
Paragraph E of Administrative Procedure 1.3.9, Revision 9, "Control of Elec-trical and Mechanical Jumpers and Lifted Leads," states in part that any deviations to the determination/retermination data sheet following Shift Manager approval shall be reauthorized by the Shift Manager.
Contrary to the above, each of the "determination/retermination" sheets associated with completed maintenance work requests NWR-A-0110 (trouble-shooting blown fuses on the power supply to solenoid pilot valves for NS-V22A-D) and NHR-AU9257 (repair of leaking valve RHR-V53-B) contained a cable which had been determinated but not reterminated. The changes to the work instruction had not been authorized by the Shift Manager.
This is a Severity Level IV violation (Supplement I).
Validit of Violation The Supply System acknowledges the validity of the violation relative to the incompleteness of data sheets.
Changes to the work scope require Shift Manager. approval. However, changes to the work instructions do not require authorization from the Shift Manager provided the work scope is not changed.
Successful operability -tests demonstrated the cables with undocumented r eter-mination had been properly reterminated. This indicates that the scope of work had not been changed, but that checkoff and verification had not been documented on the data sheets.
Corrective Ste s Taken/Results Achieved Training was performed on 10-21-88 on PPN 1.3.9, Contr ol of Electrical and Mechanical Jumpers and Lifted Leads, emphasizing Determ/Reterm requirements.
Corrective Action to be Taken The procedures and Determ/Reterm Data Sheet in PPM 1.3.9 will be revised to provide more overview that will reduce the probability of documentation omissions.
Date of Full Com liance Revise PPN 1.3.9 prior to R-4 outage, expected to begin during April 1989.
~
APPENDIX A Page 7 of 'S 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action", requires measures to be established to assure that conditions adverse to quality, such as defective equipment and nonconformances, are promptly identified and corrected.
Contrary to the above as of September, 2, 1988, two torque wrenches and one leak rate monitoring instrument had been identified 12-18 months prior. to the inspection as being out of calibration, but an evaluation of the impact of this lack of calibration had not been performed.
This is a Severity Level IV violation (Supplement I).
Yalidit of Yiolation The Supply System agrees with the violation in that the resolution corrective action was not taken in a timely manner,.
Corrective Ste s Taken/Results Achieved A review was completed of the Plant installed equipment that was calibrated and torqued using the three pieces of M8TE in question. The results were as follows:
o Torque Wrench //39433
- Corrective Action - None
- Any work performed utilizing this torque wrench had been redone undei later work packages prior, to the discovery of this violation.
o Tonque Wrench 843121
- Corrective Action - None
- A review of the MWRs utilizing this torque wrench indicated the bolting was gC-II non-pressune boundary or, that it was a temporary installaton (AY1144, Spool Piece).
o Leak Rate Monitor. 827221 Corrective Action - None
- The calibration error. was in the conservative direction, i.e.,
indicated leakage higher, than the actual leakage. On all plant equip-ment the monitor, was used during the period of out-of-calibration, the total leakage indications for. each were well below the allowable 1imi ts.
The review revealed that recalibration and/or. retorquing was not necessary and the disposition was closed. If the review would have revealed a recali-bration was needed, an NCR/PDR would have been generated and appropriate action taken.
0 APPENDIX A Page 8 of 8 Corrective Action to be Taken bilityy The 18C Supervisor, and/or Engineer will be counseled as to their responsi-per PPM 1.5.4 and the timeliness of any required corrective action.
The procedure, PPM 1.5.4, will be revised to include time limits for, review and corrective actions on all out-of-calibration measuring and test equip-ment. Also, the procedure is void on the tracking of these deficiencies. A tracking mechanism will be incorporated in this revision to the procedure.
All supervisors will be reminded of their. need to take prompt action in helping resolve outstanding deficiencies of measuring and test equipment.
Date of Full Com liance:
February 1, 1989.
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