ML17285A324
| ML17285A324 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 03/09/1989 |
| From: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Mazur D WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| References | |
| NUDOCS 8903170254 | |
| Download: ML17285A324 (6) | |
See also: IR 05000397/1988040
Text
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
1
A
SSION NBR:8903170254
DOC.DATE: 89/03/09
NOTARIZED: NO
DOCKET I
FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe
05000397
AUTH.NAME
AUTHOR AFFILIATION
MARTIN,J.B.
Region 5, Ofc of the Director
RECIP.NAME
RECIPIENT AFFILIATION
MAZUR,D.W.
Washington Public Power Supply System
SUBJECT:
Expresses
concern w/util 890213,response
to violation noted
in Xnsp Rept 50-397/88-40.
DISTRIBUTIQN CODE: IEQID
COPIES
RECEIVED r LTR L ENCL
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SIZE:
TITLE: General
.(50 Dkt)-Insp Rept/Notice of Violation Response
NOTES
RECIPIENT
ID CODE/NAME
PD5
INTERNAL: ACRS
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NRR SHANKMAN,S
NRR/DLPQ/PEB 11
NRR/DOEA DIR 11
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I
NOTE 'IO ALL "RIDS<<RECIPIENIS
PIZASE HELP US'O REDUCE WASTE!
CXÃI'ACI'IHE DOCUNEh7 CQhZROL DESK,
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TOTAL NUMBER OF COPIES
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gp,p 0 9 1989
Docket No.
50-397
Washington Public Power Supply System
P. 0.
Box 968
Richland, Washington
99352
Attention:
Mr. D.
W. Mazur
Managing Director
Gentlemen:
Subject:
Response
Inspection
Report
No. 88-40
The purpose of this letter is to express
my concern with the Supply System's
February
13,
1989 response
to the Notice of Violation (NOV) forwarded to you
on January
13,
1989 with NRC Inspection Report 50-397/88-40 for Washington
Nuclear Project
No.
2 (WNP-2), License
No. NPF-21.
I
am especially
concerned
that the Supply System did not acknowledge
the
validity of item
B of the
NOV, particularly in view of the discussions
of
this issue
between
NRC and Supply System
management
'subsequent
to the event.
Your response
indicates that your staff .is insufficiently self-critical, and
is unacceptable
because it did not properly address
the regulatory issues
discussed
below.
WNP-2 Technical Specification (TS) 4.0.3 states
that failure to perform
a
surveillance
requirement within the specified time interval constitutes
a
failure to meet the operability requirement for the Limiting Condition for
Operation
(LCO).
Paragraph
6 of your facility's Standing Orders (Plant Pro-
cedures
Manual,
PPM 1.3. 1),
as referenced
in item 8 of the
NOV, appropriately
required timely action
by the Shift Manager
when any surveillance test or
other condition indicates that
a system
or component is inoperable.
In our
view, these
requirements
clearly mandated
immediate logging of the condition
and entry into TS 3.0.3
upon plant management's
determination (at 11:00 a.m.
on November 21,
1988) that required surveillance for the degraded
voltage
protection function was delinquent.
As discussed
in the following paragraphs,
your arguments
concerning
Item
B of
the
NOV are without merit:
1.
You stated that "Plant Management
(not the Shift Manager)
assumed
the
responsibility for determination of operability...." It is our position
that plant management's
assumption of this responsibility did not
invalidate the Standing Order mandating timely logging of the condition
and entry into TS 3.0.3.
As determined
through interviews with your management,
and
as stated
in
the Notice of Violation; Supply System
management
determined (after rea-
sonable
time for eva'luation) at approximately
11:00 a.m.
on November
21
2.
3.
4.
that the channel calibration surveillance for the degraded
voltage
protection circuit on vital switchgear
SM-7 was delinquent.
Despite
this determination at ll:00 a.m., the actions required
by the Standing
Order were not initiated until 2:00 p.m.
Regardless
of the time at
which this finding was communicated
to the Shift Manager,
the require-
ments of TS 4.0.3
and Plant Procedures
Manual 1.3.1
became
operative at
ll:00 a.m.
when the determination
was
made
by cognizant personnel.
You stated that the Supply System
"pursued other means.'or
completion of
testing"
based
However, this Generic Letter
was clearly issued
to provide
uidance to licensees
on possible
TS
improvements
which could
be requeste
, and did not in any way supplant
the existing requirements
of the TS.
Specifically, the Generic letter
states
on page I that "Licensees ... are encouraged
to propose
changes
to their TS that are consistent with the guidance
provided in the
enclosures;
however,
these
changes
are voluntary ...."
The Supply
'ystem
had in fact not proposed
such
changes
to the
WNP-2 TS.
In
discussions
subsequent
to the event,
the
NRC staff emphasized
and Supply
System
management
recognized
the voluntary nature of the Generic Letter
and its intended
use
as guidance.
You stated that it was the Supply System's belief that
a method of
relief was available to complete
the testing without requiring
a
shutdown.
However, the granting of relief from the requirements
of the
TS is considered
by the
NRC only after receipt of a written request,
and
no written request
was submitted until approximately 6:00 p.m.
PST.
You indicated (at the top of page
4) that your staff believed
NRC
representatives
were
aware of and condoned
the Supply System's
delay in
applying the requirements
of TS 4.0.3
and 3.0.3.
Although your staff
discussed
the delinquent surveillance with NRC representatives
on
November 21, these representatives
did not indicate that the require-
ments of the
TS could be set aside while a request for relief was con-
sidered.
In addition,
a "Timeline" of the event,
prepared
by the
WNP-2
plant staff on November 22, indicated that the
NRC Resident
Inspector
commented
to the plant staff at 8:30 a.m.
and again at ll:00 a.m.
on
November 2I that
TS 3.0.3 appeared
to be applicable regarding
the
operability of the degraded
voltage protection function.
Your statement
that
"No further corrective action is planned" is
unacceptable.
This violation clearly indicated insufficient under-
standing of regulatory requirements
on the part of the
WNP-2 plant staff,
including management.
Failure to take appropriate corrective action
appears
to have directly contributed to the recurrence of this concern
(associated
with delinquent surveillance of the Division 3 diesel
generator)
in December
1988.
The
NRC fully expects
licensees
to comply with requirements
of the Technical
Specifications
and required station procedures.
We understand
the relation-
ship which exists
between
the licensed staff and plant management,
and did
-3-
hiAR 0 9 Icgg
not intend this
NOV to impugn the performance of the Shift Manager
on duty.
However, in recognition of the responsibilities
assigned
to the licensed
staff, your plant staff and management
must recognize their obligation to
inform the Shift Manager of circumstances
that could affect, operation of the
plant.
Any known condition that affects
the operability of safety related
equipment
must
be promptly brought to the attention of the Shift Manager,
and
any actions
required
by the
TS must
be initiated.
During recent
management
meetings,
you have expressed
the Supply System's
objective of improving its performance
and having
WNP-2 considered
in the top
ten percent of operating nuclear plants.
The lack of self-critical appraisal
in your, February
13 letter does
not appear to be consistent with this
objective.
In summary,
we conclude that Violation B of the January
13,
1989
NOV is
valid.
In view of the
comments
presented
above,
and
based
upon the March 8,
1989 telephone
discussion
between
Mr. A. L. Oxsen of the Supply System staff
and Mr. A. E, Chaffee of this office, it is our understanding
that you will
resubmit your response
to this, violation.
We further understand
that you
will transmit this response
within fourteen
days of receipt of this letter.
Your response
to item A of the Notice is considered
acceptable,
and will be
examined during
a future inspection.
In accordance
with 10 CFR 2.790(a),
a copy of this letter and your response
will be placed in the
NRC Public Document
Room.
.The response
directed
by this letter is not subject to the clearance
proce-
dures of the Office of Management
and Budget
as required
by the Paperwork
Reduction Act of 1980,
PL 96-511.
Sincerely,
J.
B. Martin,
Regional Administrator,.
cc:
A. L. Oxsen, Assistant
Managing Director for Operations
G.
D. Bouchey, Director, Assurance
5 Licensing
C.
M. Powers,
WNP-2 Plant Manager
A. G. Hosier,
WNP-2 Licensing Manager
G.
C. Sorensen,
Manager,
Regulatory
Programs
G.
E.
Doupe,
Esq.
N. S. Reynolds,
Debevois,
Cook, Purcell
5 Reynolds
State of Washington
bcc:
Docket File
Project Inspector
Resident
Inspector
B. Faulkenberry
A. Chaffee
G. Knighton,
R.
Zimmerman
P. Johnson
R. Samworth,
A. Johnson
G.
Cook
M. Smith
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