ML17285A427
| ML17285A427 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 04/26/1989 |
| From: | Bouchey G WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8905010287 | |
| Download: ML17285A427 (10) | |
Text
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DE M04 >TR4TION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
CESSION NBR:8905010287 DOC.DATE: 89/04/26 NOTARIZED: NO DOCKET N
FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH.NAME AUTHOR AFFILIATION BOUCHEY,G.D.
Washington Public Power Supply System RECIP.NAME RECIPXENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 890327 ltr re violations noted in Insp Rept 50-397/89-04.
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TITLE: General (50 Dkt)-Insp Rept/Notice of Violation esponse NOTES INTERNAL:
RECIPIENT ID CODE/NAME PD5 PD ACRS AEOD/DEXIB DEDRO NRR/DEST DIR NRR/DLPQ/QAB 10 NRR/DREP/EPB 10 NRR/DRIS DIR 9A NUDOCS-ABSTRACT OGC/HDS2 RGN5 FILE 01 COPIES LTTR ENCL 1
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1 RECIPIENT ID CODE/NAME SAMWORTH,R AEOD AEOD/TPAD NRR SHANKMAN,S NRR/DLPQ/PEB 11 NRR/DOEA DIR "11 NRR/DREP/RPB 10 NRR/PMAS/XLRB12 0
I-EBERMAN~~
REG FILE 02-.
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MrZ 'IO ALL RICS" RZCIPIWZS PIZZA HELP US 'IO REDUCE HASTE!
CDM1'ACT 'IHE 1XXXMWZ CC5TROL DESK, RDCN Pl-37 (EXT. 20079)
'IO ELIKI2QTE HER NAME PKR DIPHGBUTION LISTS H)R DOCtKERIS YOU DGH'T NEED!
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WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968
~ 3000 George tl'ashington Way
~ Richland, H'ashington 99352 April 26, 1989 G02-89-071 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 89-04
RESPONSE
TO NOTICE OF VIOLATION The Washington Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated March 27, 1989.
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 regar ding validity, corrective action and date of full compliance.
Very truly yours, G.
D. Bouchey, Director Licensing 8 'Assurance JDA/bk Attachments cc:
JB Martin -
NRC RV NS Reynolds - BCP8R RB Samworth -
NRC DL Williams - BPA/399 NRC Site Inspector - 901A 89050}0287 ay0q1g PDR ADCICK 050003'r'7 Q
0
APPENDIX A During an NRC inspection conducted on January 9 - February 7,
1989, violations of NRC requirements were identified.
In accordance with 10CFR 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.
The WNP-2 Technical Specifications, Section 3.8.1.1, require that three separate and independent diesel generators be OPERABLE.
The Technical Specifications, Section 4.8.1.1.2, state in par t:
"Each of the above required diesel generators shall be demonstrated OPERABLE:...e.
At least once per 18 months during shutdown, by:...7.
Verifying that all automatic diesel generator trips are automatically bypassed upon loss of voltage on the emergency bus concurrent with an ECCS actuation signal except:
"(b) For Division 3, engine overspeed, generator differential current and emergency manual stop."
Contrary to the above:
1.
The incomplete starting sequence trip was not verified to be bypassed when the Division 3 diesel generator was tested per Plant Procedures Hanual (PPM) 7.4.8.1.1.2.8, Revision 2, on April 28, 1987 and Hay 16, 1988.
2.
The licensee determined on Harch 3, 1989 that surveillance performed on the above dates had verified opening of only one of three relay contact pairs which must function to bypass diesel generator trips.
This is a Severity Level IV Violation (Supplement I).
Validit of Violation The Supply System acknowledges the validity of this violation.
The NRC is correct in its assessment that
- 1) the incomplete starting sequence trip was not verified to be bypassed when the Division 3 Diesel Generator (DG-3) was tested per the Technical Specification surveillance procedure, and
- 2) the procedure verified opening of only one of three relay contact pairs which function to bypass Diesel Generator trips.
On December 1,
1988 a Technical Specification Amendment Request was sub-mitted to the NRC so that the Technical Specifications would be consistent with the design of the automatic bypass function of the diesel generator trips.
Discussions of the issue at that time focused on 1) current plant configuration,
- 2) function of the incomplete start sequence
- feature, and 3) modifying the Technical Specifications to match the design of the system.
As a result, Supply System personnel did not followup on the issue of noncompliance with the Technical Specifications as written.
APPENDIX A Page 2 of 5 Regarding the bypassing of other diesel generator trips issue, the Supply System interpreted Technical Specification 4.8.1.1.2.e.7 as requiring.
testing of the bypass
- function, not that each trip is bypassed.
As a result of that interpretation, it was deter mined that the surveillance program was adequate in that the "bypass function" was verified to be operable (verification of the bypass function was accomplished by pushing a test button on Temperature Switch DCM-TS-4).
Because the temperature
'witch is bypassed on an ECCS signal, it was felt that the requirements of the Technical Specifications were satisfied
- and, as a result, DG-3 was operable.
In addition, although only one of three contacts was actually verified to be operable by surveillance, it was felt that the relay was operable due to its design.
The relay is an HFA relay and it would have been highly unlikely that only one set of contacts would operate and the others not.
- However, at the point in time it was determined that the DG-3 incomplete starting sequence trip was not verified to be bypassed as required by. tHe Technical Specifications, the appropriate LCO should have been entered and the appropriate actions taken.
Corrective Ste s Taken/Results Achieved
" 1)
On February 1,
1989 a request was submitted to the NRC for waiver of compliance from the Technical Specification sur veillance requirements appli'cable to the Division 3 incomplete start sequence bypass verifi-cation until the changes requested above could be granted.
On February 2,
1989 the NRC granted the waiver of compliance.
2)
On February 2,
1989 a functional test of the test button associated with Temperature Switch DCM-TS-4 was successfully performed.
3) 4)
On February 3,
1989 a temporary procedure was successfully completed which verified operation of the remaining contacts on the DG-3 bypass relay.
I
\\
On March 30, 1989 'the Supply System received Amendment No.
66 to the Operating License which deleted the requirement to verify bypassing of the DG-3 incomplete start sequence trip.
5)
As discussed in our amended response to NOV 88-40-02, 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.
APPENDIX A Page 3 of 5 Corrective Action to be Taken 1)
Pl nt Procedure (PPM) 7.4.8.1.1.2.8, "HPCS Diesel Generator LOCA Test", is currently in the process of being revised to require test-ing of all contacts on the DG-3 bypass relay.
2)
A process is currently being considered to review Technical Specifi-cation requirements and associated surveillance procedures for accuracy and consistency.
Date of Full Com liance 2)
Although the Supply System is currently in full compliance, PPM 7.4.8.1. 1.2.8 will be issued by May 5, 1989.
A de'cision on the Technical Specification review process is'xpected to be made by August 31, 1989.
APPENDIX A Page 4 of 5 Section 4.0.3 of the MNP-2 Technical Specifications states 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 3.8.1.1 of the Technical Specifications, in ACTION Statement c.,
states that with DG-3 inoperable, action shall be taken to demonstrate the OPERABILITY of remaining A.C.
- sources, and that the high pressure core spr ay (HPCS) system shall be declared inoperable unless DG-3 is restored to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Contr ary to the
- above, the 1 icensee determined in November 1988 that required verification of -the incomplete start sequence trip bypass for 06-3 had not been performed as specified in the Techni.cal Specifications, as set forth in item A. above, and did not take the actions specified.
This is a Severity Level IV Violation (Supplement I).
Validit of Violation The Supply System acknowledges the validity of this violations Had DG-3 been declared inoperable, this violation would not have occurred because the applicable LCO would have been entered and the appropriate actions taken (see response to Violation A).
Corrective Ste s Taken/Results Achieved As discussed in the response to Violation A, at the point in time that it has been determined that noncompliance with the Technical Specifications
- exists, the applicable LCO wi 11 be entered and the required action state-ments implemented.
As a result of discussions with the NRC, the Supply System also has an increased level of understanding with regard to Technical Specification compliance.
Corrective Action to be Taken No further corrective action is planned for this violation.
Date of Full Com liance The Supply System is currently in full compliance.
APPENDIX A Page 5 of 5 10 CFR 50.73 (a) states in part:
"(1) The holder of an operating license for a nuclear power plant (licensee) shall submit a License Event Report
{LER) for any event of the type described...within 30 'days after the discovery of the event....
(2)
The licensee shall report:.:.(i)(B) any operation or condition prohibited by the plant's Technical Specifica-tions....",
Contrary to the above, the licensee determined in 1988, as described in'a letter submitted to the NRC on December 2,
1988 that a Division 3 diesel generator trip bypass verification had not been performed as required by the 'Technical Specifications, and did not issue a license event report within 30 days after this determination.
This is a Severity Level IV Violation {Supplement I).
Validit of Violation The Supply System acknowledges the validity of =.this violation.
If DG-3 had been declared inoperable, this violation would not have occurred because the applicable LCO would have been entered and the appropriate actions taken (See response to Violation A), including the writing of an LER.
Corrective Ste s Taken/Results Achieved No immediate corrective actions were taken with regard to this violation.
Corrective Ste s to be Taken A Licensee Event Report will be prepared and submitted to the NRC.
Date of Full Com liance The LER will be submitted to the NRC by Hay 19, 1989 (30 days from Plant Operating Committee approval of this NOV response).
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