ML17285A336

Forwards Amended Response to Notice of Violation Contained in Insp Rept 50-397/88-40.Corrective Actions:Guidance Document Will Be Prepared to Better Understand Processes Associated W/Relief from Tech Specs Re Vital Switchgear

ML17285A336
Person / Time
Site:	Columbia
Issue date:	03/22/1989
From:	Mazur D WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-87-09, GL-87-9, GO2-89-046, GO2-89-46, NUDOCS 8903270382
Download: ML17285A336 (5)

Text

D1STKBU'H ON DEMON STRATI 04 SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

CESSION NBR:8903270382 DOC.DATE: 89/03/22 NOTARIZED: NO DOCKET FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION MAZUR, D.W. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

, Forwards amended response to notice of violation contained in Insp Rept 50-397/88-40.

DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation 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 NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT 1 1 OE 5RMAN,J 1 1 OGC/HDS2 1 1 E~XX~ 02 1 1 RGN5 FILE 01 1 1 ERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 R

I NCTE 10 ALL "RIDS" RECZPZZMIS:

PLEASE HELP US IO REDUCE TVBTE! CONTACT 'IHE DOQNEÃ1'ONTROL DESK, ROOM Pl-37 (EZI'. 20079) TO ELIMINATE YOUR NAME FRCH DIGTIKBVXXON LISTS FOR DOCUMENTS YOU DON'T NEEDt TOTAL NUMBER OF COPIES REQUIRED: LTTR 25 ENCL 25

WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.o. Box 968 ~ 3000 George 11'ashington 11'ay ~ Richland, 11'ashington 99352 March 22, 1989 G02-89-046 Docket No. 50-397 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mai,l Station Pl-137 Washington, D.C. 20555 Gentlemen:

Subject:

NUCLEAR PLANT NO. 2 AMENDED RESPONSE TO NOTICE OF VIOLATION 88-40-02 (VIOLATION B)

Reference:

a) Letter, JB Martin to DW Mazur, "Response to Notice of Yiolation - Inspection Report 88-40", dated March 9, 1989 b) Letter, G02-89-020, GC Sorensen (SS) to NRC, "NRC Inspection Report 88-40 Response to Notice of Yiolation", dated February 13, 1989 The Washington Public Power Supply System hereby submits an amended response to the Notice of Violation 88-40-02 (Yiolation B) contai ned in Inspection Report 88-40 dated January 13, 1989. Our reply, pur suant 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.

This amended response is submitted as a result of discussions between Mr. Oxsen of my staff, Mr. Chaffe of Region V NRC, and Mr. Martin's letter of March 9 (reference a). In reviewing our process to proper ly respond to Notices of Viola-tions, we have identified areas of weakness and are maki ng corrective action changes to that process.

Yery truly yo rs,;

v' d4ygq'.

Managing Director Rid SD JDA/bk (90 e

Attachment Martin NRC RV cc: JB NS Reynolds - BCP&R RB Samworth - NRC DL Williams - BPA/399 NRC Site Inspector - 901A

APPENDIX A Dur ing an NRC inspection conducted on November 14 December 14, 1988, viola-tions of NRC requirements were identified. 'In accordance with 10 CFR Par t 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:

B. Section 4.0.3 of the WNP-2 Technical Specifications 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 Specifications requires written procedures to be established and implemented for "The applicable procedures recommended 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 orocedures which should be provided, "1. Administrative Procedures...b. Authorities and Responsibilities for Safe Operation and Shutdown."

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 Specifica-tions, (and) log- the condition...in a timely manner based on the significance of the condition."

to the above, the licensee determined at approximately ll:00 a.m. on P'ontrary 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 (Amended)

The Supply System acknowledges the validity of this violation. The failure to declare the SM-7 undervoltage protection circuitry inoperable while pursuing relief avenues with NRR constitutes non-conservative application of Technical Specification requirement 3,0.3. In this particular case, it should be noted that Senior Plant Management (not the Shift Manager) assumed the responsibility for determination of operability and the development of an action plan to resolve the issue. As part of the action plan to determine the operability status of the SM-7 undervoltage protection circuit, reviews of procedures, LCOs, plant configuration and testing philosophy were performed. As previously stated, the recognition that current, valid surveillance data was not available on portions of the undervoltage circuitry occurred at approximately 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br />.

Based upon the belief that NRR concurrence to proceed without complying with paragraph 3.0.3 would be forthcoming, the Supply System inappropriately delayed entry into the 3.0.3. In retrospect, the more appropriate action would have been to apply 3.0.3 at 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br />, initiate a plant shutdown, and then continue with the corrective action plan and discussions with the NRC.

Corrective Ste s- Taken/Results Achieved (Amended)

Following specific indication from Region V that relief from NRR could not proceed without entry into 3.0.3, at 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br /> on November 21, 1988 the Supply System initiated a plant shutdown. Prior to completing the shut-down, the relays in question were calibrated and the shutdown terminated per paragraph 3.0.3.

The Supply System has also requested the Technical Specification amendment suggested in Generic Letter 87-09, which would allow a 24-hour time limit for completing a missed surveillance when the allowable outage time of the action requirements is less than the 24-hour limit (which was the case of the relays involved).

Corrective Action to be Taken (Amended)

As discussed in the January, 1989 Management Meeting, at the point in time it has been determined that noncompliance with the Technical Specifications exists, the applicable LCO- will be entered and the required action statements implemented. This act'ion will be taken independently of any dialogue (e.g.

discussion of methods of relief) which may be ongoing between the Supply System and the NRC. In addition, paragraph 3.0.3 will be appropriately applied in the future.

To better understand the processes associated with the available methods of relief from Technical Specification requirements, a guidance document on this subject will be prepared- by the Plant Licensing Department.

Date of Full Com liance (Amended)

The Supply System is currently in full compliance and will conservatively apply 3.0.3 when such situations occur.