ML17289A727

Responds to NRC 920610 Ltr Re Violations Noted in Insp Rept 50-397/92-01.Corrective Actions:Util Analyzed Each FSAR Deficiency in Rept

ML17289A727
Person / Time
Site:	Columbia
Issue date:	07/10/1992
From:	Grumme L WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GO2-92-162, NUDOCS 9207170009
Download: ML17289A727 (20)

Text

ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGU'I ATORY INFORYiA 'ON DISTR BUTION SYSTEM (BIDS)

L ESSION NBRo9207170009 DOC ~ DATEe 92/07/i0 s FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe AUTH. NAME AUTHOR AFFILIATION GRUMM",L.L. Washington Public Power Supply System RECI'P.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control rol Des Desk )

SUBJECT:

Responds to NRC 920610 ltr re violations noted in ansp rept 0

50-397/92-01.Corrective actions:util analyzed each FSAR deficiency zn rept.

~ ~

DISTRIBUTION CODE: IE01D TITLE: Gene COPIES RECEIVED:LTR al (50 Dkt)-lnsp Rept/Notice of Violation ~ Response NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 PD 1 DEAN,W. 1 1 INTERNAL: ACRS 2 2 AEOD 1 1 AEOD/DEIIB 1 1 AEOD/DSP/TPAB 1 1 DEDRO 1 1 NRR MORISSEAU,D 1 1 NRR/DLPQ/LHFBPT 1 1 NRR/DLPQ/LPEB10 1 1 NRR/DOEA/OEAB 1 1 NRR/DREP/PEPB9H 1 1 NRR/DST/DIR SE2 1 1 NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT 1 1 1 1 OGC/HDS1 1 1 REG FILE 02 1 -

1 RGN5 FILE 01 1 1 EXTERNAL: EGSG/BRYCE I J. H. 1 '

1 NRC PDR 1 1 NSIC 1 NOTE TO ALL "RIDS" RECIPIENTS PLEASE HELP US TO REDUCE WASTE) CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 23 ENCL 23

' WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Bax 968 ~ 3000 Geode Washtngton Way ~ Rtchland, lPashtngton 993524968 ~ (509) 372-5000 July 10; 1992 G02-92-162 Docket No. 50-397 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Hail Station Pl-137 Washington, D. C. 20555 Gentlemen:

Subject:

NUCLEAR PLANT NO. 2, OPERATING LICENSE NO. NPF-21 NRC INSPECTION 'REPORT 92-01 RESPONSE TO NOTICE OF VIOLATIONS The Washington Public Power Supply System hereby replies to the Notice of Violations contained in your letter dated June 10, 1992. Our reply, pursuant to the provisions of Section 2.201, Title 10, Code of Federal Regulations, consists of this letter and Appendicies A and B (attached).

In Appendix A, the violations are addressed with an explanation of our position regarding validity, corrective action and date of full compliance. Appendix B provides a listing of the open items from the EDSFI report and the Supply System plans to address these items.

Very truly yours, L. L. Grumme, Acting Director L'icensing 5 Assurance DAS/bk Attachments cc JB Hartin - NRC RV NS Reynolds - Winston & Strawn RR Assa - NRR DL Williams - BPA/399 NRC Site Inspector - 901A e

qg(0 9207170009 920710 pOJ PDR ADOCK 05000397 9 PDR W I/(

' APPENDIX A During an NRC inspection conducted from January 13 through February 14, 1992, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part C, the violations are listed below:

2,'ppendix A. 10 CFR Part 50, Appendix 8, .Criterion V, "Instructions, Procedures, and Drawings," states: "Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings...and shall be accom-plished in accordance with these instructions, procedures, or drawings..."

WNP-2 Administrative Procedure 1.2.3, Revision 17, dated November 14, 1991, "Use of Controlled Plant Procedures," paragraph 5.5.7, states that "any person performing a task for which there is a procedure is responsi-ble for doing the job as described by the -procedure."

WNP-2 Administrative Procedure 1.5. 1, Revision 16, dated February 6, 1991, and Deviation 91-1009, dated October ll, 1991, "Technical Specification Surveillance Testing Program," prescribes the following requirements:

Paragraph 1.5. 1.5 requires that "Any test results found to be outside those designated in the procedure or any abnormal circumstances that prevent completion of the procedure shall be denoted in the "Comments" section of the cove) sheet by the personnel performing the test," and

"...the Shift Hanager or appropriate Craft Supervisor responsible for the testing shall verify that all blanks have been properly completed and that any significant observations made during the test are recorded. Any additional actions necessary for Technical Specification (TS) compli-ance...will be determined and referenced on the cover sheet. The Shift Hanager's review and approval signifies acknowledgement of test comple-tion..."

Paragraph 1.5. 1.6.A requires that "Completed surveillance tests shall be reviewed for completeness and accuracy within each Department...by supervisors or alternates," including "review [or] the test results against acceptance criteria...[I]f an item has been omitted...investigate

...and review to determine if a Problem Evaluation Report (PER) is required to document a personnel error, programmatic failure, etc."

1. Surveillance Procedure 7.4,9.2. 1.24, "quarterly Battery Testing 250 VDC B2-1," Step 6.H, requires the water level of each .cell to be recorded on Attachment A, Column D. Completion of this step is required to satisfy TS surveillance requirement 4.8.2. l.b. 1.

Contrary to the above, on data dated December 22, 1991, this step was marked NA on Attachment A, Column D for cells 1 through 20, but this incomplete item was not noted or resolved on the test cover sheet as required by procedure. A Craft supervisor signed for review of the surveillance procedure and a Shift Hanager signed that the surveillance procedure was completed.

Appendix A Page 2 of 16 Surveillance Procedure 7.4.8.2. 1. 12, "18 Honth Battery Testing of E-B0-1A," Step 6.A.7 and 6.A.8, requires that for load discharge tests of battery chargers, the load be a minimum of 25 amps for four lancee hours, and that the load current be measured and recorded every 15 minutes. Completion of this step is required to satisfy TS surveil-4.8;2.l..c.4.1.

Contrary to the above, on data dated Hay 17, 1990, the initial current was recorded as 2.6 amps, all remaining data was below the required 25 amps, but the out of tolerance test results were not noted or resolved on the test cover sheet as required by procedure.

A Craft Supervisor signed for review of the surveillance procedure and a Shift Hanager signed that the surveillance procedure was completed.

Surveillance Procedure 7.4.8.2. 1. 13, "18 Honth Battery Testing of E-BO-IB," Step 6.B.27 and 6.B.28, requires recording of intercell resistance readings and verification that the readings are less than or equal to 250 micro-ohms. Completion of these steps is required to satisfy TS surveillance 4.8.2. I.c.3.

Contrary to the above, on data dated may 28, 1990, all of the intercell resistance readings were recorded as greater than 250 micro-ohms with a maximum recorded resistance of 0.053 ohms (53,000 micro-ohms), b'ut these out of tolerance values were not noted or resolved on the test cover sheet as required by procedure. A Craft Supervisor signed for review oF the surveillance procedure and a Shift Hanager signed that the surveillance procedure was completed.

Surveillance Procedure 7.4.8.2. 1. 12, "18 'Honth Battery Testing of

'-BO-IA," Step 6.B.25, requires a visual inspection of the battery and the results of the inspection recorded in Attachment B, column A (titled "Internal Cell Inspection" ) and column B. completion of this step is required to satisfy TS'urveillance 4.8.2. I.c. l.

Contrary to the above, on data dated may 17, 1990, Column A was left blank, but the failu're to record the results of the internal cell inspections was not noted or resolved on the test cover sheet as required by procedure, A Craft Supervisor signed for review of the surveillance procedure and a Shift Hanager signed that the surveil-lance procedure'was completed.

Surveillance Procedure 7.4.8.2. 1.24, "guality Battery Testing 250 VDC B2-1," Step 6.R, requires the specific gravity of each cell to be compared to the average specific gravity of all the cells to verify that no single cell has a specific gravity more than 0.02 below the average.

Appendix A Page 3 of 16 Contrary to the above, on data dated Hary 24, 1991, cell 8 was recorded as having a specific gravity of 0.023 below the average, but the out of tolerance reading was not noted by the technician on the test cover sheet as required by procedure. A Craft Supervisor signed for review of the surveillance procedure and a Shift Hanager signed that the surveillance procedure was completed.

Surveillance Procedure 7.4.8.2. 1.21, "quarterly Battery Testing 24 VDC B0-1A, B0-1B, B0-2A, B0-2B," Step 7.6. 14, requires the battery float voltage to be measured, and if below a minimum value (26.8 VDC) the Shift Hanager is to be contacted, the voltage adjusted and the results recorded on the "comments" section of the data sheet.

Contrary to the above, on data dated on September. 10, 1991, an out of tolerance float voltage (26.63 VDC) was .recorded; however, the out of tolerance reading was not noted in the comments section of the procedure and the voltage was not readjusted as required by the procedure.' craft supervisor signed for review of the survei-llance procedure and a Shift Hanager signed that the surveillance procedure was completed.

Surveillance Procedure 7.4.8.2. 1.24, "quarterly Battery Testing 250 VDC B2- 1," Step 6.H, requires level to be recorded as a deviation from center line in one-quarter inch increments, with 0 being the mi.dpoint between the high and low level.

Contrary to the above, on data dated December 22, 1991, the level for cells 21 through 171 and cells 173 through 232 was recorded as "OK" rather than in one-quarter inch increments. A Craft Supervisor signed for review of the surveillance procedure, and a Shift Hanager signed that the surveillance procedure was completed.

Surveillance Procedure 7.4.8.2. 1.24, ."quarterly Battery Testing 250 VDC B2-1," Step 6.g requires the performance of a specific gravity calculation and the recording of the results of that calculation as a specific gravity deviation in Attachment A, Column H.

Contrary to the above on data dated Hay 9, 1991, the technician recorded "OK" rather than a calculated specific gravity deviation in Attachment A, Column H. A Craft Supervisor signed for review of the surveillance procedure and a Shift Hanager signed that the surveil-lance =procedure was completed, even though the results of the specific gravity calculation had not been properly recorded.

Appendix A Page 4 of 16

9. Surveillance Procedure 7.4.8.2. 1.22, "quarterly Testing 125 VDC Bl-and Bl-2," Step 17, requires the technician to initial the step signifying the completion and the recording of the results of a calculation for battery specific gravity; Step 25 requires the technician to initial the step signifying that the Shift Manager has ciann been notified after the testing of the battery is completed.

Contrary to the above, on the data dated Hay 30, 1991, the techni-marked Step 17 as NA and Step 25 was left blank.. A Craft supervisor signed For review of the surveillance procedure and a Shift Manager signed that the surveillance procedure was completed, even though all the procedure steps had not been completed as required by the procedure's instructions.

10. Surveillance Procedure 7.4.8.2. 1. 12, "18 Month Battery Testing to E-B0-1A," Step 6.B.3, requires that for battery discharge tests, the load current that was recorded in the load current test oF step 6.B.2, is to be subtracted from 24 amps and that the step 6.B.3 value is to be used for the discharge test.

Contrary to the above, on data dated Hay 17, 1990, the current measured and recorded in Step 6,8.2 was 3.8 amps; however, 3.0 amps instead of 3.8 amps was used in the calculation of Step 6.B.3. A Craft Supervisor signed For review of the surveillance procedure and a Shift Manager signed that the surveillance procedure was complet-ed, even though a wrong value was used in Step 6.B.3.

11. Surveillance Procedure 7.4.8.2. 1.24, "quarterly Battery Testing 250 VOC B2-1," Step 6.G requires a temperature correction factor to be recorded, and Step 6.M requires the measured specific gravity to be corrected by the factor recorded in Step 6.G, and recorded Contrary to the above, on data dated December 22, 1991, Steps 6.G and 6.H were not accomplished. The temperature corrected factor was not recorded and the specific gravity was not corrected and recorded. This incomplete item was not noted or resolved on the test cover sheet as required by procedure. A Craft Supervisor signed for review of the surveillance procedure and a Shift Manager signed that the surveillance procedure was completed.

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

Appendix A Page 5 of 16 Validit of Violation Th e S upp 1 y System s acknowledges the validity of this' violation. The multiple instances of procedure completion inadequacies cited were the resu 1 t o f a 1 ac k oof attention to detail. In each case it appears, based d

t a on a review of available information, that Plant equipment the surveillance requirements.

p However, the 'procedural paperwork was not completed in a thorough enough manner to p rovide the necessary documentation, The root causes for this event include:

~ Work practices wer'e less than adequate in that specific instructions were not followed during the conduct and, review of surveillance tests.

~ Supervisory, methods did not ensure that job performance and self checking standards were properly communicated.

~ Procedures were less than adequate in that they did not ensure correct information was recorded on battery data she'ets.

S 1

' S stem management is concerned with the' examples of ' procedural non-compliances identified in this violation..

co This is indicative o a fa'lure of performance, expectations that documentation must be accurately and thoroughly completed. Many of the corrective actions described below go beyond the electrical procedure deficiency problems identified. It is clear we must assure 'trict and accurate .adherence to procedures.

Previously established programs, along with those actions described below, should produce these necessary changes.

Corrective Ste s Taken Results Achieved The identified procedures which did not contain sufficient information were either: I) immediately performed to verify the status and operability of the affected equipment; or 2) for those surveillances which had been rformed since the unacceptable procedure was completed the latest completed survei-llance was reviewed to verify acceptability. Technica 1 Specification compliance was verified in, each case.

Hased on a review of equipment condition and the results of subsequent surveillance testing, it was determined that the equipment was operable, but the procedure documentation was inadequate. The procedures in question have been revised to include human factors consider'ations that h ld f 'litate proper completion. The Maintenance Procedure Upgrade Program will be used to address similar problems which may i other exist in maintenance P rocedures.

The Operations Manager and the Electrical Supervisor have reviewed performance standards with the Shift Managers and Electrical Supervisors and workers, The importance of attention to detail and proper documenta-.

tion were emphasized.

Appendix A Page 6 of 16 As part of a more immediate effort to determine whether the problems noted in the EDSFI findings are localized to Electrical Haintenance or may be more wi'd esprea d , 70 recently completed m'aintenance procedures were checked for attention to detail and proper documentation 0 p 1 ances. Th'eview is found the highest error rate associated with th e Electrical Haintenance Department, but did find error s in the Hechanical and IKC Departments. These problems were identified on a PER and will e addressed through that process.

Three supervisors have recently been added to the Electrical Haintenance shop raising the number from two to five. These a supervisors to spend more time in the Plant with the electricians an in the review of documentation.

Corrective Action to be Taken Since the findings cited reflect specific problems w'ith individual rocedures, as well as management tolerance of performance that does not t t ble standards ) extensive additional corrective actions are planned to resolve these problems and prevent their eir recur-rence.

The Supply System has initiated a self-assessment of procedural compliance within each department at WNP-2 and the major support organizations to

.WNP-2. The results of this assessment, including identification of corrective actions, will be completed by September 30, 1992. In addition, each organization has been tasked with development and implementation of a performance monitoring program to assure the corrective actions implemented result in maintained performance.

better determine the scope of the problems noted in the inspection To

't' findings, as well as other Supply System identified issues, a technical assessmen t was in>>a e d i'n April 1992 to analyze procedure compliance issues. Th'ssessment is asse included a review of procedure related PE Rss from January .1991 to Harch 1992. This assessment, which will be comple y July 17, 1992, preliminarily concluded that similar procedure compliance problems exist in other plant and site departments. The product of the t ill be the identification of generic causes of procedural compliance .problems. It was concluded, based on a. review of the pre l iminary ra ft fo the assessment 7 that the corrective actions proposed in this response, and other actions already implemented by thee Su pp 1 y System, should result in the desired changes needed to resolve procedure compliance problems.

8 l an k s mar k e d "N/A" as being outside the scope of the original surveil-1 ance proce dure ure are now required to be initialed by a Shift Hanager. This requirement is being incorporated as a permanent change in Technical Specification Surveillance Testing Program, and in the interim has been implemented as a night order. The revision to this procedure is currently in the review and approval cycle.

Appendix A Page 7 of 16 As part of a long-term solution directed at the root causes of the

'problems noted, the Supply System will undertake the following steps intended to improve job performance and strengthen procedure compliance:

~ Write and adopt a "Conduct of Maintenance" procedure applicable to each of the maintenance shops with provisions for procedure adherence and professional conduct similar to those in the existing "C on d ucct ooF Operations" procedure, PPH 1.3. 1. This procedure will

=

provide strong guidelines regarding management expectation professional conduct including adherence to the administrative requirements of procedures. One of the primary concepts in this procedure will be that supervisors will be held accountable for both their workers'nd their own actions. This procedure will be issued by September 30, 1992.

The Conduct of Maintenance procedure will provide guidelines for supervisors to set an example of professional conduct, including adherence to the administrative requirements of procedures and use of self checking practices. The Plant Manager and department managers, using the Conduct of Maintenance procedure, will discuss these concepts with first line supervisors who will then discuss them with their workers.

The "self-checking" training program will be expanded to include all members of the Maintenance department. The program will establish the department supervisors as owners of the program. This program will train craftsmen to self-check their work and will encourage immediate discussion of errors caused by failure to self-check with the responsible individuals and as part of the weekly department meetings. Self-checking successes will also be discussed and highlighted in these meetings. Self-checking training for Maintenance shop personnel will be completed by November 30, 1992.

The "personally preventable" approach, which has been incorporated successfully into Health Physics activities, will be expanded to the Maintenance shops following completion of training on self-checking and the Conduct of Maintenance procedure, This approach will be used, where applicable, to achieve management's expectations.

Specifically, personnel involved in procedure violations that are personally preventable or repetitive due to a failure to self-check, will be retrained in the appropriate areas. Interaction management techniques will be used for personnel with repetitive personally-preventable problems.

In addition to the above steps which are directed toward improving the work ethic and personal responsibility for a work product, several actions are scheduled or have been completed which will provide additional manpower in key areas, will change the manner of doing business, and will ensure prompt attention to important matters.

Appendix A Page 8 of 16 A supervisor or engineer is being assigned to eachh Volume 7 surveil-lance procedure performed by Electrical Haintenance between now and b 1992 to ensure management's expectations regarding procedure documentation are understood and met by craf t p ersonnel.

Lessons learned related to procedural compliance i'n the Electrical Haintenance shop will be applied to the other maintenance shops and departments.

Date of Full Com liance P

'h During the EDSFI the Supply System responded to each concern by either re-f ffected surveillance 'procedure or by reviewing documenta-tion to ensure a. satisfactory surveillance procedure was c y applicable. Full compliance was achieved for each item as it was brought up, The Supply System is currently in" full Technical Specification compliance.

-10 CFR Part 50, Appendix B, Criterion V, '"Instructions, Procedures, and Drawings, t t es:

s a "A'ctivities affecting quality shall be prescribed by documented instructions, procedures, or drawings,...andn shall be sha accomplished in 'accordance with these instructions, procedures, or draw-ings.... II Related Plant Procedure 1.6.2, Revision 12, dated January 20, 1992

'afety "Control of Drawings and Support Data," Section 5.2, states that "Controlled Top Tier Drawings are promptly revised to show an up-to-date as-built configuration through the red-lining process."

C t onrary t o th e aabove as of February 13, 1992, the following controlled T T'er Drawings which were located in the control roo m , were not promptly revised to show an up-to-date as-built configuration thr h ou g h the red-lining process:

1. Controlled Top Tier Drawing E519, "Hotor Valve and Hiscellaneous Control Elementary Diagram," Sheet 35, showed fuse F2 to be a 10A fuse; however, RFTS-90-10-13, dated October 10, 1990, identified the fuse installed F2 as a 20A fuse.

2.'ontrolled Top Tier Drawing E526, "Hiscellaneous Equipment Elementa-ry Diagram," .Sheet 1, showed a 1A fuse at terminal point 320

{drawing coordinates K,7); however, RFTS-90-08-030, dated October 16, 1990, identified the installed fuse as a 1-4/10A fuse.

3. Controlled Top Tier Drawing EWD-'81E-0001, "Electrical Wiring Diagram Reactor Building Emergency Cooling System Sample Room Filter REA-SU-115," showed a 3A fuse for FUl and FU2 {drawing coordinates E,4);

however, RFTS-91-08-030, dated August 6, 1991, identified the installed fuses as 3-2/10 A fuses.

This is a Severity Level IV violation {Supplement I),

Appendix A Page 9 of 16 Val i di t of Viol ation The Supply System acknowledges the validity of this violation. The root fr cause 0 this 1 violation was less than adequate Change Management in that change related documents, in this case the fuse-control program, were not revised when the current Problem Evaluation Request (PER) process was implemented in 1988. The fuse control program pre-dates the PER process at WNP-2. With the establishment of. the PER process a PER should have been generated to document Top Tier drawing deficiencies followed by a Request For Technical Services (RFTS) to evaluate the condition. The review of the PER would have placed the appropriate priority on the RFTS.

However, as identified by the NRC, there wer e instances where Plant personnel chose to wait for the engineering evaluation of the discrepancy to be performed under the RFTS. Then, if an actual problem existed with the installed fuses or the Top Tier drawings, a PER was'generated.

Th e fuse u control program (PPN 1.3,47) normally requires replacement with the identical or an evaluated equivalent fuse. However, if it is kno w n that the installed fuse is of the wrong type, and this is verified on design documents, the PPN permits replacement with the correct fuse. The replacement fuse log sheets are reviewed quarterly to ensure the Plant configuration is being maintained as designed.

Corrective Ste s Taken Results Achieved An engineering review was performed to determine whether the fuse sizes questioned in the EDSFI report were in fact correct. Of the three NRC identified fuse concerns, one affected a spare fuse and the other two were small increases in fuse size.

Engineering has completed a review of the 15 RFTSs related to fuses identified by the NRC during the EDSFI. In addition, Engineering has reviewed all outstanding fuse RFTSs (161) to determine if a Top Tier drawing discrepancy was involved. Forty-four of the RFTSs identified Top Tier drawing discrepancies. A PER was written to document these discrepancies. Subsequently, the appropriate fuses were installed and the Top Tier drawings were redlined to reflect the Plant configuration.

Recent Interoffice Nemorandums from the Plant Hanager reiterated management's expectations for the generation of PERs for non-conforming conditions. These expectations have been specifically communicated to personnel involved in the fuse control program.

Appendix A Page 10 of 16 Corrective Action to be Taken Clear direction is under development for use in the fuse control program regarding documenting, on PERs, discrepancies between installed fuses and T op T'ser rawings. As stated above, expectations on PER generation. have already been verbally communicated. Mritten direction regar generation for fuse concerns will be provided by July 24, 1992.

re ardin ing PER Date of Full Com liance Full compliance was achieved on July 3, 1992, when the last of the 44 identified fuses was replaced and the Top Tier drawings were redlined.

10 CFR

' Part 50, Appendix B, Criterion Y, "Instructions, Procedures, and D rawings, sstates: a "Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings,...and accomplished in accordance with these"'instructions, procedures, or draw-ings.... II Safety Related Plant Procedure 1.6.2, Revision 12, dated January 20, 1992, "Control of Drawings and Support Data," Section 5.2, states that "Controlled Top Tier Drawings are promptly revised to show an up-to-date as-built configuration through the red-lining process." Section 5.4 requires that "Top Tier drawings shall be red-lined upon completion of field work and prior to returning equipment to operation."

C on trary a to the above as of February 14, 1992, for equipment which had been modified and returned to operation some time between 1985 to 1 controlled Top Tier Drawing was not red-lined to show an up-to-date as-built configuration. Specifically, Controlled Top Tier Drawing E508, 80 'h "Power and Instrumentation AC Power Panels Schedules," Sheet 1, Revision control room ) showed that breaker 6 on power panel PP-7A-F supplied power to a chlorine analyzer; however, Breaker 6 was a s p are breaker. The breaker was converted to a spare breaker by Project Engineering Directive (PED) 218-E-C358.

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

Appendix A Page ll of 16 Validit of Violation The Supply System acknowledges the validity of this violation. The root cause for this violation was work practices less than adequate in that the appropriate paperwork was generated to have the drawings updated in 1983, but the tracking system identified status of the modification was never changed to reflect the completion of field work. The instance cited involved a Project Engineering Directive (PED) issued during startup which, in 1992 at the time of the EDSFI, was still listed as pending while it should have been designated as field installation complete. This designation would have triggered the required drawing changes. The document used to initiate the Plant design change request, a Startup Deficiency Report (SDR), was initiated and completed. The completion signature on the SOR indicated field work completion. We were unable to determine why this completed information did not get into the Document Control System for posting against affected drawings. This 'resulted in the Top Tier drawing not being updated in a timely manner.

The PEO process in place during startup has been replaced at WNP-2.'his violation is not believed to be representative of the current design change process. As stated in the violation, current procedures provide direction for promptly updating Top Tier drawings following completion of a Plant modification.

The Supply System previously recognized that there were transition PEDs which had been implemented and were still statused as pending. A PER was generated and a review of pending PEDs was completed.

Corrective Ste s Taken Results Achieved The PEO has been evaluated and verified not to constitute a safety problem. Electrical Design Engineering has also completed a review of equality Class I modifications (PEDs, FDIs, and FDDRs) which still show a pending completion status on the document control system (OCS). One additional Top Tier drawing change was identified and corrected during this review.

, Corrective Action to be Taken Sixty-four mechanical and '-civil transition PEDs were reviewed for completion. A close-out of the associated paperwork will be completed by September 30, 1992. In addition, 12 Class 2 Electrical Transition PEOs were reviewed and appropriate documentation changes have been completed.

Date of Full Com liance A review of Class 1 transition documents, and necessary drawing changes, will be completed by September 20, 1992. The Supply System is not aware of Top Tier drawing discrepancies caused by pending status PEDs.

Appendix A Page 12 of 16 Technical Specification 6.8. 1 states that written procedures shall be established, implemented, and maintained covering:

"d, Surveillance and test activities of safety-related equipment."

Contrary to the above, as of February 14, 1992, the licensee did not imp 1 e m e nt administrative controls to maintain updated surveillance procedures for certain facility design changes. Specifically, s ever al thermal overload devices had been changed for motor operated valves, but these changes were not incorporated into the Valve Data Sheets for valves HS-V-20, HS-V-16, RWCU-V-l, HPCS-V-15, SW-V-4C, SW-V-54 and HPCS-V-1 in Surveillance Procedure 7.4.8.4.3.3, Revision 4, dated Hay 10, 1990.

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

Validit of Violation The Supply System acknowledges the validity of this violation. The root cause for this violation was less than adequate work practices in that documents were not followed correctly.. PPH 1.4, 1 requires that a Plant Pr cedure Checklist be completed for each modification. This checklist was completed for these, thermal overload changes but in each case th e required surveillance procedure change was not identified. Plant personnel failed to recognize the impact these changes had on Technica l Specification surveillance procedures, In addition, one of the overloads had been changed as part of a substitution performed under a type 55BDC (Basic Design Change) package. The 55BDC process, however, is intended to update design documentation to match the as-built configuration of the Plant, not to change the configuration. This process does not require an evaluation of the potential impact on Plant procedures since a 55BDC is intended to update the drawing to match the actual Plant configuration.

Corrective Ste s Taken Results Achieved During the EDSFI, the Supply System completed a review of Technical Specification thermal overload surveillance procedures and verified that the previously completed testing satisfied the surveillance criteria applicable to the new overloads. Operability was not impacted by these procedural deficiencies, The required revision of PPH 7.4.8.4.3.3 to include the applicable overload information was completed on June 3, 1992.

Appendix A Page 13 of l6 Corrective Action to be Taken A weakness in the Plant Procedure Checklist process is its reliance knowledge to identify procedure changes associated with Plant on'ersonnel d'f'cations mo 1 1 To resolve this weakness in identifying procedures a word searchable computer information base containing the full-tex 0

procedures will be used to support these reviews. Computer software to support this project is installed, and a large number of plant procedures have been converted into the necessary format for input into the information base. This corrective action will provide a tool to help re-

'solve the specific problem, but will not be effective without appropriate attention to detail. It is expected that the Self-Checking and Personally Preventable programs (applicable to all personnel) which were discussed as 1 -t rm corrective actions for Violation A also will improve effective-ness here. Effective programs implemented by personnel dedicat ed to uality should prevent future occurrences of similar problems. The completion of procedure conversions to the proper format'nd loading of the files into the word searchable software is schedul'ed for completion. by June, 1, 1993.

This response will be provided to the WNP-2 Procedure Coordinators who perform reviews for the Plant Procedure Checklist as a remainder of the importance of performing a thorough review for potentially impacted proce-dures.

Date of Full Com liance Full compliance was achieved on June 3, 1992, when the procedure revision was approved. However, compliance with the applicable surveillance requirements was achieved by the original testing performed in 1991.

10 CFR Part 50, Appendix 8, Criterion Y, "Instructions, Procedures, and Drawings," states: "Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings,...and shall be accom-plished IIin accordance with these instructions, procedures, or draw-i ngs ~ ~ ~ ~

Maintenance Procedure 10. 1.5, Revision 13, dated march 9, 1989, "Scheduled Maintenance System," Section 7.2. 11, states that "The Maintenance Manager will biennially form a committee...[to] review the scheduled Maintenance Program..." This requirement was unchanged in Revision 14 of this procedure issued May 13, 1991.

Contrary to the above, as of February 14, 1992, no committee had been formed.

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

Appendix A Page 14 of 16

, Validit of Violation Th e S upp ly System acknowledges the validity of this violation. The root cause of this violation was work practices were less than adequate i'n that the Scheduled Maintenance System (SHS) task which required the committee to be convened was not performed or recognized as being late. A contributing cause for this violation was that written procedures and documents placed an inappropriate emphasis on information when this task was classified as an "other" in the SHS system.

The Supply System stated at the Enforcement Conference held on Hay 27, 1992, that, based on a preliminary review, it appeared that a computer input error was the cause for this violation. However, based on further review it was concluded that the input error occurred after the task had already gone late. There was a window of opportunity for the task to have been recognized and completed in accordance with the SNS program requirements. The task shows up first on the list of items coming due in the next month, then on the list of the items which have gone past their due date, and finally on the overdue list {greater than 25% past the due date). Based on the incorrect entry date for the task completion, this would have appeared on the coming due and past due lists for about a 'tem six month period. The past due lists are reviewed by the Department Manager on a weekly basis.

The ability to identify and complete this task was hindered by the task .

being classified as an "other" task. There are a large number of tasks which are not Technical Specification, Equipment gualification, Essential, or Preventive Maintenance related and fall-into a single "other" category.

The past due report mentioned above contains the past due items from each of the categories mentioned.

On February 26, 1990, Phase I of the Reliability Centered Haintenance (RCH) project was initiated with a team of Supply System engineers in the three major disciplines, headed by a Program Supervisor and dedicated full time for two years. Using the PH Reviewers Guide, the team evaluated the existing Preventive Maintenance Program, a subset of SNS, to minimize scheduling inefficiencies and consolidate work on equipment. Although the RCN review was performed and meets the intent of an SMS committee review, it did not provide strict compliance with the procedural requirements in place at the time.

Corrective Ste s Taken Results Achieved PPN 10. 1.5 has been revised to incorporate the RCN methodology and review criteria. Since the ongoing RCN activities meet the intent of the review committee, the requirement to form a review committee have been deleted from the procedure and removed from the SHS system. The Haintenance Manager has been counseled on the importance of thoroughly reviewing the SHS reports and completing tasks in a timely manner.

Appendix A page 15 of 16'orrective Action to be Taken Th e SMS o th er category tasks h'

will be reviewed to determine if there are t as k s w lc ) becausee of ' their importance, should be moved to anotheran category to improve visibility. =This action will be compl e t ed b y October 31, 1992.

Date of Full Com'iance The Supply System was always in full compliance with the intent of the proce d ure. ri compliance was achieved on Haunch 26; 1992, when the Strict procedure revision was implemented which deleted the requ'rement to form a review committee.

10 CFR 50.71{e) requires licensees to update the originally submitte bmitted Final Safety Analysis Report {FSAR) no less than annually and states that the revision shall reflect all changes up to a maximum of 6 months prior to the date of filing the revision.

Contrary to the above, as of February 14, 1992, the following are examples where the WP-2 FSAR was not updated to .reflect changes:

The FSAR (pg 9.5-50) provides an unreferenced number of 22,000 Btu/min or 1,320,000 Btu/hr for room heat load. The FSAR was not updated to reflect 1989 heat load test results of 1,627,000 Btu/hr.

S ec t'ion 3 1 1 1 of the MNP-2 FSAR, on page 8.3-2, states that"...startup transformer circuit breakers are interlocked to close only after the 1

norma 1 so urce circuit bre'akers have opened..." The interlocking arrangement was not installed, and had not been, since startup u i 1983 in but the FSAR was not revised.

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

Validit of Violation The Supply System acknowledges the validity of this violation. The root causes for this violation were: 1) written document presentation deficien-cies in that the room heat load value was located in a heat exchanger design data table where it was difficult to find; and 2) less than d t h e management in that during the Plant construction period cancellation of a design change, specifically developed to bring in the Plant f rmance with the FSAR description, resulted in the observed difference between the FSAR and the Plant configuration. Cancel lation of the change did not trigger a FSAR change.

Appendix A page 16 of 16 "

Corrective Ste s Taken Results Achieved The Supply System analyzed each of the FSAR deficiencies noted in the t'eport inspec ion epo No deficiencies have a significant effect on safety, nor do any represent unreviewed safety questions under 10 CFR 5 50.59.

The FSAR deficiencies noted in Attachment 3 of the EDSFI report have been reviewed with DRD personnel to sensitize them to the types of errors being found. It is expected that the DRD effort will identify for resolution other FSAR deficiencies which may exist.

Corrective Action to be Taken Engineering Instruction 2. 15 will be modified to specify the need to identify FSAR sections as interfacing documents when performing calcula-tions. SCNs, when required, will be prepared. in conjunction with the calculation effort. This procedure revision is currently in the review process and is expected to be completed by August 14, 1992.

By September 1, 1992, SCNs will be generated to correct the EDSFI identified deficiencies with the FSAR. A FSAR Amendment incorporating these corrections will be submitted to the NRC by November 15, 1992.

The database reconstitution efforts (DRD and calculation upgrade) will continue with enhanced expectations on identification and resolution of FSAR discrepancies, Date of Full Com liance The FSAR concerns identified in Inspection Report 92-00) wil.l be addressed's stated above, a FSAR Amendment will be submitted by November 15, 1992, addressing the NRC concerns documented in the EDSFI.

report. This Amendment will result in full compliance.

'Appendix B Action Plan to Resolve EDSFI Team Ins ection Follow-u Items

1. Follow-up Item (50-397/92-01-02), The maximum SSM (UHS) temperature appears not to have been established.

2. Follow-up Item, {50-397/92-01-03), Sufficient data is not available to support the worst case SSH cooling flows to the diesels.

3. Fol.low-up Item (50-397/92-01-04), Sufficient data is not available to determine the most limiting diesel generator or diesel generator electrical equipment room temperatures.

4. Follow-up Item {50-397/92-01-05), Calculations indicate the 81 Battery Charging Room and the Electric Equipment and Repair Shop may, under worst case accident conditions, exceed WNP-2 Technical Specifications limits.

Planned Action: For items 1 through 4 above, calculations were performed to document the acceptability of the MNP-2 design. The calculations were reviewed with members of the NRC Staff in June 1992. These calculations have been verified and are in the review and approval process with final approval expected by August 14, 1992.

'. Follow-up Item {50-397/92-01-06), Sufficient test data or. analysis is not available to support SEVR cabinet cooling under worst case accident conditions.

Planned Action: Testing of the SEVRs was performed in conjunction with the 24-hour run diesel generator testing during the R7 refueling and maintenance outage. This testing revealed that the temperature difference between the SEVR area in the cabinet and the general room temperature, with the cabinet doors, removed as required by procedure when room temperatures exceed a preset level, was approximately 5'F. This temperature differential is acceptable.

6. Follow-up Item (50-397/92-01-08), The agreement between BPA and the Supply System for control of the MNP-2 switchyard is not sufficiently detailed to assure switchyard maintenance activities are adequately controlled. This

, item will be reevaluated when the Supply System and BPA establish a revised agreement.

Planned Action: The Supply System has controls in place to ensure BPA work in the switchyard is performed in a safe and acceptable manner.

Preliminary discussions have been held on this subject, and working agreements are in place. The Supply, System will work to complete a written agreement with BPA by December 1, 1992.

' Appendix Page 2 of B

2

7. Circuit breaker contact resistance '

acceptance criteria has not been established. Some S MNP 2 EDS breakers may have high contact resistance.

Su 1 S stem will evaluate this item and, if necessary, r or to th xt refueling outage when'd most

. breaker testing is performed. Several op t'ions rd viable, including adding acceptance criteria and/or tren ing lt B eaker manufacturers will be contacted to determine the appropriate approach and'pplicablee acce p tance criteria if used.

-Ol-ll) No requirement exists to document and disposition the step s of maintenance or survei'llance proc rocedur s th t are not performed. The present licensee prac tice ice bypaasses management's review and control of deferred maintenance.

As described

'lin the attached S

response to NOV 92-01A, ecification Surveillance Testing Program, re uire that "N/As" in completed PPH surveillance procedures be initialed'y a i a evaluation will be made of non-surveillance activities o

'f t'ons other than the current Shift Hanager's '

review of documentation is necessary Thi1

=

subsequent process changes, if required, will be complete'd b y December 31, 1992.

9. Follow-up Item (50-397/92-01-19), Grounding system resistance is to be veri'fied.

Planned Action; Subsequent to the ED SFI thee Su pp ly System located the startup test which verified the acceptability o e an g em. The system resistance was 0. 1 ohms. WNP-2 is oca e ssysstem.

in a dry area wi'th little rainfall or ground moisture.

f Degradation o th e s ystem would therefore not be expected.

The Supply System will, however, review common iindustr y practice an d willwi factor this information into a decision on performance of periodic testing of the sy stem. A decision on the need for periodic'esting of the Plant grounding sys em will be made by December 31, 1992.

10.

to include

/

Follow-up Item {50-39 7/92-01-20) finding.

Coordinat'ion calculation to be revised t'f team Planned Action: The 'o calc coordination calculations for the SH-7, SH-8, and SH-4 will be revised to include an eva l ua ion o thee concerns raised by this item. These calculation revisions will e completed by December 31, 1992.