ML17285A637

Responds to NRC 890628 Ltr Re Violations Noted in Insp Rept 50-397/89-13.Corrective Actions:Radiation Barrier Posting for RWCU HX Room Removed from accordion-style Gate at Entrance to Room & Placed on Rope in Front of Gate

ML17285A637
Person / Time
Site:	Columbia
Issue date:	07/28/1989
From:	Bouchey G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GO2-89-129, NUDOCS 8908020333
Download: ML17285A637 (9)

Text

ACCELERATED D1SHDBUTION DEMONSTRATlON SYSTEM REGULATORY INFORMATION DXSTRIBUTION SYSTEM (RIDS)

SSION NBR: 8908020333 DOC. DATE: 89/07/28 NOTARIZED: NO DOCKET FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILXATION BOUCHEY,G.D. Washington Public Power Supply System RECIP.NAME RECIPXENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 890628 50-397/89-13.

ltr re violations noted in Insp Rept.

DISTRIBUTXON CODE: IE06D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: Environ & Radiological (50 DKT)-Insp Rept/Notice of Violation Respons NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 LA 1 0 PD5 PD 1 1 SAMWORTH,R 1 1 INTERNAL ACRS 2 2 AEOD/ANDERSON, R 1 1 AEOD/DSP 1 1 NMSS/LLOB 5E4 1 1 NMSS/SGDB 4E4 1 1 NRR/DLPQ/PEB 10 1 1 NRR/DOEA/EAB 11 1 1 NRR/DREP/EPB 10 1 1 NRR/DREP/RPB 10 2 2 NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS2 1 1 RE~FME~~

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TAL NUMBER OF COPIES REQUIRED: LTTR 29 ENCL 28

WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968 ~ 3000 G~>orge Washington Way ~ Richland, 1Vashington 99352 July 28, 1989 G02-89-129 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"13 RESPONSE TO NOTICE OF VIOLATION The Washington Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated June 28, 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 regarding validity, corrective action and date of full compliance.

Very truly yours, G. D. Bouchey, Di Licensing 8 Assurance JDA/bk Attachments cc: JB Martin - NRC RV NS Reynolds - BCPSR RB Samworth NRC DL Williams BPA/399 NRC Site Inspector - 901A 8908020333 890728 PDR ADOCK 0 000397 9 PDC

Appendix A Page 1 of 4 APPENDIX A During an NRC inspection conducted on April 17 - June 3, 1989, violations of NRC requirements were identified. In accordance with the 10CFR Part 2, Appen-dix C, "General Statement of Policy and Procedure for NRC Enforcement Actions,"

53 Fed. Reg. 40019 (October 13, 1988), the violations are listed below:

A. 10 CFR 20.203(b) states in par t: "Each radiation area shall be conspic-uously posted...."

Technical Specification 6.8.1 states, "Written procedures shall be estab-lished, implemented, and maintained covering the activities referenced below:

"k. Health Physics/Chemistry Support Program" Health Physics/Chemistry Support Programs procedure PPM 1.11.11, "Entry Into, Conduct In, and Exit From Radiologically Controlled Areas," states in section 1.11.11.3.A that "All work performed in a radiologically controlled area shall be performed using a Radiation Work Permit (RWP)."

Section 1.11.11.3.B states that "Health Physics personnel shall post all radiologically controlled areas in accordance with PPM 11.2.7.1, 'Area Posting'".

Health Physics procedure 11.2.7.1, "Area Posting," section 11.2.7.1.5.A.3, sgates in part, "Barrier the perimeter of the radiation ar ea at approxi-mately waist height (normally)."

Co7ttrary to the above, on May 16, a barrier was not installed across the entry to the reactor water cleanup (RWCU) heat exchanger room, which was a radiation area, and a worker who was not authorized by an RWP to be in the radiation area was allowed free access into this area.

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

Validit of Violation The Supply System acknowledges the validity of this violation. Although the radiological posting was visible, it was not adequately posted to make the Contractor Maintenance worker aware of the radiation boundary. The r easons for the violations are:

1) The Contractor Maintenance worker 's attention was directed toward supporting the wor k ongoing in the Reactor Water Cleanup (RWCU) Heat Exchanger Room. As a result, he did not r ecognize that he had entered a radiation area when he passed through the gate opening.

The gate was open approximately four feet to allow for entry/exit during work in the RWCU Heat Exchanger Room. The worker entered into the alcove at the entrance to the room.

Appendix A Page 2 of 4

2) The Health Physics (HP) Technician's attention was directed toward those persons entering and exiting the room, and controlling signifi-cant exposures. The HP Technician assumed that the worker (who was working as the outside man for the job) had signed on to the appro-priate Radiation Work Permit (RWP).

In response to NOV 89-09-02, the Suply System committed to provide enhanced posting of certain radiological controlled ar eas. The efforts associated with this commitment were directed toward high traffic areas where the potential existed for an access barrier to be left down after entry. In this particular case, the posting of the RWCU Heat Exchanger Room was evaluated and determined to be adequate because the room is in a low traffic area and the door is normally locked.

Corrective Ste s Taken/Results Achieved

1) All Contractor Boilermakers (including the worker. involved) were instructed to be aware of radiation area postings and of the need to be signed-in on an appr opriate RWP.

2) The HP Technician involved was counselled on the need to maintain a high level of awareness of HP requirements at all times.

3) The radiation barrier posting for the RWCU Heat Exchanger Room was removed .from the accordion-style gate at the entrance to the room, and placed on a rope at head height in front of the gate. This will eliminate the need for tHe barrier/posting to be moved aside during entry to the room; therefore, assuring that the Radiation Area is conspicuously posted and clear ly demarcated.

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 4 10 CFR 50.72(b)(2) stated in part: "...the licensee shall notify the NRC as soon as practical and in all cases, within four hours of...(1) Any event, found while the reactor is shut down, that, had it been found while the reactor was in operation, would have resulted in the nuclear power plant, including its principal safety barriers, being seriously degraded...."

Contrary to the above, during testing of the high pressure core spray (HPCS) system conducted on May 12, 1989 during the annual refueling outage, a failed socket weld on a high point vent caused a non isolable leak to exist between the wetwell of the primary containment and the reactor building. This loss of primary containment integrity was dis-covered at 3:15 a.m. and was not reported until 12:05 p.m.

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

Validit of Violation The Supply System acknowledges the validity of this violation. The reason for the violation is that Plant personnel did not properly evaluate the four-hour reportable requirements of 10CFR50.72 for this event.

Corrective Ste s Taken/Results Achieved 1), On May 12, 1989 at 1205 hours0.0139 days <br />0.335 hours <br />0.00199 weeks <br />4.585025e-4 months <br /> the NRC was verbally notified of the event. As required by 10CFR50.73, an LER (89-015) was prepared and submitted to the NRC on June 8, 1989.

2) A representative of the Compliance Group now attends Management Review Committee (MRC) meetings on a daily basis. The pur pose of MRC is to provide initial assessment, assignment of priority and alloca-tion of resources for each Problem Evaluation Request (PER). The function of the Compliance representative at the MRC meeting is to review those PERs and provide input on reportability.

Corrective Action to Be Taken Training briefings on reportability/compliance issues will be presented to Plant Operators and Shift Technical Advisors during requalification training.

Date of Full Com liance Although the Supply System is currently in full compliance, the training briefings will commence with Requalification Cycle 89-05 (July 31 September 2, 1989).

Appendix A 4 of 4'age 10 CFR 50.73(a) states in part: "(1) The holder of an operating license...shall submit a Licensee Event Report (LER)...within 30 days after the discovery of the event....(2) The licensee shall report:...(v)

Any event or condition that alone could have prevented the fulfillment of the safety function of...systems that are needed to...(A) Shut down the reactor and maintain it in a safe condition;...or (D) Mitigate the conse-quences of an accident."

Contrary to the above, the licensee failed to report within 30 days, and had not reported as of June 12, 1989 an event that occurred on February 10, 1989, in which inoperability of the suction valve from the. suppression pool to the high pressure core spray (HPCS) system could have prevented the HPCS system from performing its safety function.

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

Validit of Violation The Supply System acknowledges the validity of this violation. The reason for this violation is a difference in the interpretation of the regulation between the Supply System and the Commission.

Following the failure of HPCS-V-15 to fully close, a formal reportability evaluation was performed which considered several criteria including 10CFR50.73(a)(2)(v) and 10CFR Part 21. This evaluation concluded that the HPCS system was operable and capable of meeting its safety functions because the system was lined up to the Condensate Storage Tank. As a result, the system was capable of maintaining vessel inventory for a sufficient period of time to allow for compensatory operator actions such as- manually opening HPCS-V-15. Accordingly, it was our position that this the fulfillment of a was not a condition which alone could have pr evented safety system to mitigate the consequences of an accident.

The failure of HPCS-V-15 was, however, determined to be reportable under 10CFR Part 21. The NRC was formally notified of this determination on April 26, 1989.

Me also examined our process by which reportability evaluations are per-formed, and the process was determined to be adequate.

Corrective Ste s Taken/Results Achieved There were no immediate corrective actions taken for this violation.

II Corrective Action to be Taken

1) A Licensee Event Report will be prepared and submitted to the NRC.

2) The application of regulation 10CFR50.73(a)(2)(v), as it applies to single-train systems, will be discussed during Licensed Operator Requalification Training.

Date of Full Com liance

1) The LER will be submitted to the NRC by August 25, 1989 (30 days from Plant Operating committee approval of this NOV response).

2) Discussions on the application of 10CFR50.73(a)(2)(v) will be held during Requalification Cycle 89-06 (September 4 - October 6, 1989).