ML17285A252

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Responds to NRC 890113 Ltr Re Violations Noted in Insp Rept 50-397/88-40.Corrective Actions:Plant Procedure 7.0.0 Revised to Require Carbon Sampling Between 720 & 900 H of Operation & Filter Sampling Performed When 720 H Reached
ML17285A252
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 02/13/1989
From: Sorensen G
WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GO2-89-020, GO2-89-20, NUDOCS 8902210481
Download: ML17285A252 (13)
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WASHINGTON PUBLIC POWER SUPPLY SYSTEM p\

P.O. Box 968 ~ 3000 George Washinglon Way ~ Richland, Washington 993$ 2;,'~

February 13, 1989 G02"89-020 Docket No. 50-397 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Nail Station P1-137 Hashington, D.C. 20555 Gentlemen:

Subject:

NUCLEAR PLANT NO. 2 LICENSE NO. NPF-21 NRC INSPECTION REPORT 88-40 RESPONSE TO NOTICE OF VIOLATION The Hashington Public Power Supply System hereby replies to the Notice of Violation contained in your, letter dated January 13, 1989. Our reply, pursuant to the provisions of Section 2.2201, 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.

Very truly yours, G. C. Sorensen, Hanager, Regulatory Programs JDA/lw Attachments cc: JB Hartin - NRC Rv NS Reynolds BCPER RB Samworth - NRC DL Hilliams - BPA/399 NRC Site Inspector - 901A

APPENDIX A During an tions of NRC

'ion inspec requirements

'RC conducted on November 14 - December 14, 1988, viola-were identified. In accordance with 10 CFR P art 2 A endix C, "General Statement of Policy and Procedure for. NRC Enforcement Actions f " 53 Fed. Reg. 40019 (October 13, 1988), the violations are 'listed A. Secti on 4

'Each

..7 2 o control f th e room emergency HNP-2 Technical Specifications states, filtration system train shall in part. that be demons trated operable: d. After, every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of char coal adsorber operation by verifying within . 31 days after removal that a laboratory analysis of a repr esentative carbon sample...meets the laboratory testing criteria of...Regulatory Guide 1.52."

Section ..

4 0 2 o Surveillance f thee Technical Specification states, Requirement shall be performed within the sp ecified time in part, that 0

hat "Each Eac interval with: a. A maximum allowable extension not to exceed 25K of the surveillance interval.'ontrary to the above, as of 12:00 am, November 7, 1988, charcoal adsorber train "8" had been operated for 933.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> without a sample of the char-coal adsorber having been taken.

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

Yalidit of Violation The Supply System acknowledges the validity of the violation.

The Supply System, prior to this Notice of Violation, interpreted Technical Specification 4.7.2.d to mean a charcoal sample had to be obtained and analyzed within 31 days of the filter reaching 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of operation and that the filter was operable during the 31 day sample

d. This was thought to be an accurate and literal interpretation of the Technical Specification. The NRC inter in p r etation of Specification 4.7.2.d is that a charcoal sample must be obtained within the next 180 hours0.00208 days <br />0.05 hours <br />2.97619e-4 weeks <br />6.849e-5 months <br /> of operation (25% of 720 hour0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> s) after the filter reac h es 720 ho u,rs of operation, and that 'he sample must be analyzed Wl'th ln 31 days after the sample is taken. This differ. n interpretation of Technical Specification 4.7.2.d is the cause of this violation.

Appendix A Page,2 of 4 Corrective Ste s Taken/Results Achieved A sample was taken from the charcoal filters associated with train B on November 8, 1988 after 933 hours0.0108 days <br />0.259 hours <br />0.00154 weeks <br />3.550065e-4 months <br /> of service. The test showed an efficiency of 99.815 + .075. The acceptance criteria is 99K or gr eater efficiency.

A letter was issued by the Plant Technical Manager to the Plant Operations Manager defining how Technical Specification 4.7.2.d is to be implemented.

Briefly the letter states a filter sample should be taken when the 720 servi'ce hour time is reached, and that no more than 900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> (125%)

should be accumulated prior to taking the sample.

Corrective Action to be Taken No fur ther corrective actions are required to be in full compliance; however, the following actions are planned.

Plant Procedure 7.0.0 will be revised to require sampling between 720 and 900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> of operation.

A Technical Specification change will be submitted to clarify the wording of Technical Specification 4.7.2.d.

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

B. Section 4.0.3 of the RNP-2 Technical Specification states, in part, that "Failure to perform a Surveillance Requirement within the specified time interval shall constitute a failure to meet the OpERAB1LITY requirements for a Limiting Condition for Operation,"

Section 6.8.1 of the Technical Specification requires written procedures to be established and implemented for "The applicable procedures recom-mended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978."

Appendix A of Regulatory Guide 1.33,- Revision 2 includes in the listing of procedures which should be provided, "1. Administrative Procedures...b.

Authorities and Responsibilities for Safe Operation and Shutdown."

Appendix A page 3 of 4 f

Plant Procedures manual l.3.1, Stan din ing Orders/Night Orders, Revision 14, states the following in Attachment I, Standin 0 eratin r e ther condition indicates that Shift manager is to begin the action required y fications, (and) log the condition...in a timely T h 1 S 'f e ec n manner t'h ase a system significance of the condition,"

ve the licensee determined at approximately ll:00 a.m.

on ove 2 , 98 tha the channel calibr ation Sur veillance Requir ement delinquent, but the Shift Managerr did not og th e o d't o or begin the ot log action require uired by the Technical Specifications i.e.,

place the unit in at least STARTUP wi within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />) until 2:00 p.m.

This is a Severity Level IY violation {Supplement I).

Yalidit of Yiolation The Supply System ' does not acknow e gee thee validity of this violation as owled Mana er acted as required by an oc I~ 3 ~ I "Standing Orders/Night Orders, " by beginning egin the action required by f

the Techni cal Speci i cats ons and log ging the con i ion determined that the rel ays were not veri ab e fi o 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br />.

a t Mana ement {not the Shift Manager) assumed b'1't the r esponsibility for determina ion o p y d d 1 d 1 issue. As a part o e p a operability staatus u of the SM-7 degr ade d vo a lt ot t o t reviews of procedures, LCOs, plant lant con configuration igura and testing philosop h y performed. 'ere Concurrently with the reviews ws per orme , the Supply System also pursued erformed, o pl 'o of o testingg the circui sis for. our decision o pu s 7-09 A discus ed in the letter ed surveillance does not of itself cause equipment to be inopera for a hutdown based on mi ed overl conservative ac ion w rable upon completion o f th e d 11 r 87-09 the NRC concluded that 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> s was an acceptable time limit for co p e tiing a mi s d s r eillance when the allowable outage time of the action requirements was ess limit (which was the case of the relays involved).

Appendix A Page 4 of 4 Validit of Yiolation (continued)

Continuing with the action plan to resolve the operability issue, the decision was made to involve NRR, Region V and the Senior NRC Resident Inspector in the pr ocess. The NRC was made aware of our decision 'to consider application of the principles of Generic Letter 87-09 to this issue and, after several discussions, it was our belief that a method of relief was available to complete the testing without requiring a shutdo n.

It is the opinion of the Supply System that these discussions were active and proceeding to a resolution that would not require placing SN-7 in an inoperable condition from the period between 1100 and 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br /> on November 2I, 1988.

However, at 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br /> it was made clear to Plant Management by the NRC that the principles of Generic Letter 87-09 could not be applied to HNP-2 and, as a result, we were in Technical Specification Section 3.0.3 (absent formal relief). Accordingly, at 1400 hour0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br /> s the Supply System entered 3.0.3 and initiated the required Plant Shutdown. Prior to completing the shutdown, the relays in question were calibrated and Section 3.0.3 was exited.

Although the Supply System does not agree with the validity of this violation, our under standing of the guidance provided in Generic Letter 87-09, and the . Maiver of Compliance and Discretionary Enforcement processes is improved. Accordingly, in the future Specification 3.0.3 will be appropriately applied.

Corrective Ste s Taken/Results Achieved 0 N ember 21 1988 Section 3.0.3 was entered. In addition, formal discussions regarding Technical Specification compliance have taken p la c e between the Supply System, Region Y and NRR.

Corrective Action to be Taken No further corrective action is planned.

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

1 gc Cp~ ~TH) Dl STKBU'T1 ON DE M ON STRA,TI ON SYs TEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

CESSION NBR:8902210481 DOC.DATE: 89/02/13 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)

R

SUBJECT:

Responds to NRC 890113 50-397/88-40.

ltr re violations noted in Insp Rept I

DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR TZTLE: General (50 Dkt)-Insp Rept/Notice of Vino 2 ation ENCL SIZE-

Response

NOTES RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 PD 1 1 . SAMWORTH,R 1 1 INTERNAL: ACRS 2 2 AEOD 1 1 AEOD/DEIIB 1 1 DEDRO 1 1 NRR SHANKMAN,S 1 1 NRR/DEST DIR 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 OE

~LEI-EB,J NRR/PMAS/ILRB12 02 1

1, 1

1 1

1 NUDOCS-ABSTRACT OGC/HDS2 RGN5 FILE 01 1

1 1

1

'1 1

ERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 R

I MZE TO ALL "RIDS>> RECIPZZMXS PIZASE HELP US TO REZVCE ROOM

~! CONI'ACZ THE DOCK& Z CONSOL D~MKi P1-,37 (EXT. 20079) TO ELIMINATE YOUR NME FRCH DIPBGBUZIGN LISTS EOR DOCUMENIS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 25 ENCL 25

WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968 ~ 3000 George 'Washington Way ~ Richland, Washington 99352 February 13, 1989 G02-89-020 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 88-40 RESPONSE TO NOTICE OF VIOLATION The Washington Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated January 13, 1989. Our reply, pursuant to the provisions of Section 2.2201, Title 10, Code of Feder.al 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.

~

Very truly yours, G. C. Sorensen, Manager, Regulatory Programs JDA/lw Attachments cc: JB Martin - NRC Rv NS Reynolds - BCP8R RB Samworth -, NRC DL Williams - BPA/399 NRC Site Inspector, - 901A 89C~22$ 048l 890218 POD'DOCV O~iAO(>,.::"-r7 r~o

APPENDIX A I

During an NRC inspection conducted on November 14 - December 14, 1988, viola-tions of NRC requirements were identified, In accordance with 10 CFR Part 2, Appendix C, "General Statement of Policy and Procedure for. NRC Enforcement Actions," 53 Fed. Reg. 40019 (October 13, 1988), the violations are listed below:

A. Section 4.7.2 of the WNP-2 Technical Specifications states, in part, that

'Each control room emergency filtration system train shall be demonstrated operable: d. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of char coal adsorber operation by verifying within 31 days after removal that a laboratory analysis of a repres'entative carbon sample...meets the laboratory testing criteria of...Regulatory Guide 1.52."

Section 4.0.2 of the Technical Specification states, in part, that "Each Surveillance Requirement'hall be performed within the specified time interval with: a. A maximum allowable extension not to exceed 25K of the surveillance interval.'ontrary to the above, as of 12:00 am, November 7, 1988, charcoal adsorber.

train "B" had been operated for 933.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> without a sample of the char-coal adsorber having been taken.

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

Validit of Yiolation The Supply System acknowledges the validity of the violation.

The Supply System, prior to this Notice of Yiolation, interpreted Technical Specification 4.7.2.d to mean a charcoal sample had to be obtained and analyzed within 31 days of the filter reaching 720 hour0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> s of operation and that the filter was operable during the 31 day sample analysis period. This was thought to be an accurate and literal interpretation of the Technical Specification. The NRC interpretation of Specification 4.7.2.d is that a charcoal sample must be obtained within the next 180 hours0.00208 days <br />0.05 hours <br />2.97619e-4 weeks <br />6.849e-5 months <br /> of operation (25K of 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br />) after the filter reaches 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of oper ation, and that the sample must be analyzed within 31 days after the sample is taken. This difference in the interpretation of Technical Specification 4.7.2.d is the cause of this vi ol ati on.

Appendix A Page 2 of 4 Corrective Ste s Taken/Results Achieved A sample was taken from the charcoal filters associated with train B on November 8, 1988 after 933 hours0.0108 days <br />0.259 hours <br />0.00154 weeks <br />3.550065e-4 months <br /> of service. The test showed an efficiency of 99.815 + .07%. The acceptance criteria is 99K or greater efficiency.

A letter was issued by the Plant Technical Manager to the Plant Operations Manager-defining how Technical Specification 4.7.2.d is to be implemented.

Briefly the letter states a filter sample should be taken when the 720 service hour time is reached, and that no more than 900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> (125K) should be accumulated prior to taking the sample.

Corrective Action to be Taken No further corrective actions are required to be in full compliance; however, the following actions are planned.

Plant Procedure 7.0.0 will be revised to require sampling between 720 and 900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> of operation.

A Technical Specification change will be submitted to clarify the wording of Technical Specification 4.7.2.d.

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

Section 4.0.3 of the WNP-2 Technical Specification states, in part, that "Failure to perform a Surveillance Requirement within the specified time interval shall constitute a failure to meet the OPERABILITY requirements for a Limiting Condition for Operation,"

Section 6.8.1 of the Technical Specification requires written procedures to be established and implemented for "The applicable 'procedures recom-mended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978."

Appendix A of Regulatory Guide 1.33, Revision 2 includes in the listing of procedures which should be provided, "1. Administrative Procedures...b.

Authorities and Responsibilities for Safe Operation and Shutdown."

Appendix A Page 3 of 4 N

Plant Procedures manual 1.3.1, Standing Orders/Night Orders, Revision 14, states the following in Attachment I, Standin 0 eratin Orders:

"6. If any surveillance test or other condition indicates that a system is not operable as required by the Technical Specifications, the Shift manager is to begin the action required by the Technical Speci-fications, (and) log the condition...in a timely manner based on the significance of the condition,"

Contrary to the above, the =licensee determined at approximately 11:00 a.m.

on November, 21, 1988 that the channel calibration Surveillance Requirement for, the degraded voltage protection circuit on vital switchgear SM-7 was delinquent, but the Shift Manager did not log the condition or begin the action required by the Technical Specifications (i.e., Section 3.0.3; place the unit in at least STARTUP within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />) until 2:00 p.m.

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

Validit of Violation The Supply System d'oes not acknowledge the validity of this violation as written. The Shift Manager acted 'as required by Plant Procedur e (PPM) 1.3.1, "Standing Orders/Night Orders," by beginning the action required by the Technical Specifications and logging the condition when it was determined that the relays were not verifiable to be operable at 1400 hours.

In this particular case, Plant Management (not the Shift Manager) assumed the responsibility for determination of operability and developed a plan of action to resolve the issue. As a part of the plan to define the operability status of the SM-7 degraded voltage protection circuit, reviews of procedures, LCOs, plant configuration and testing philosophy wer e performed.

Concurrently with the reviews performed, the Supply System also pursued other means for completion of testing the circuitry without requiring a Plant Shutdown. The basis for our decision to pursue other means was guidance provided in Generic Letter 87-09. As discussed in the letter, the NRC has recognized that a missed surveillance does. not, of itself, cause equipment to be inoperable. Therefore, a shutdown based on a missed surveillance would be an overly conservative action when the equipment could be proven operable upon completion of the missed surveillance.

Furthermore, in Generic Letter 87-09 the NRC concluded that 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> was an acceptable time limit for completing a missed surveillance when the allowable outage time of the action-requirements was less than the 24-hour limit (which was the case of the relays involved).

Appendix A Page 4 of 4 Validit of Violation (continued)

Continuing with th'e action plan to resolve the operability issue, the decision was made to involve NRR, Region V and the Senior NRC Resident Inspector in the process. The NRC was made aware of our decision to consider application of the principles of Generic Letter 87-09 to this issue and, after several discussions, it was our belief that a method of relief was available to complete the testing without requiring a shutdown.

It is the opinion of the Supply System that these discussions were active and proceeding to a resolution that would not require placing SN-7 in an

. inoperable condition from the period between 1100 and 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br /> on November 21, 1988.

However, at 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br /> it was made clear to Plant Management by the NRC that the principles of Generic Letter 87-09 could not be applied to WNP-2 and, as a result, we were in Technical Specification Section 3.0.3 (absent formal relief). Accordingly, at 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br /> the Supply System entered 3.0.3 and initiated the required Plant Shutdown. Prior to completing the shutdown, the relays in question were calibrated and Section 3.0.3 was exited.

Although the Supply System do'es not agree with the validity of this violation, our understanding of the guidance provided in Generic Letter 87-09, and the Waiver of Compliance and Discretionary. Enforcement processes is improved. Accordingly, in the future Specification 3.0.3 will be appropriately applied.

Corrective Ste s Taken/Results Achieved On November, 21, 1988 Section 3.0.3 was entered. In addition, formal discussions regarding Technical Specification compliance have taken place between the Supply System, Region V and NRR.

Corrective Action to be Taken No further corrective action is planned.

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

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