ML17290A634
| ML17290A634 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 09/03/1993 |
| From: | Vandenburgh C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Parrish J WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| References | |
| GL-92-08, GL-92-8, NUDOCS 9309290283 | |
| Download: ML17290A634 (12) | |
See also: IR 05000397/1993013
Text
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
CESSION NBR:9309290283
DOC.DATE: 93/09/03
NOTARIZED:
NO
DOCKET
CEL:50-397
WPPSS Nuclear Project, Unit 2, Washington Public
Powe
05000397
UTH.NAME
AUTHOR AFFILIATION
VANGENBURGH,C.
Region
5 (Post
820201)
RECIP.NAME
RECIPIENT AFFILIATION
PARRISH,J.V.
Washington Public Power Supply System
SUBJECT:
Ack receipt of 930709 ltr re'sponding
to IR 50-397/93-13
on
930609.
R
DISTRIBUTION CODE:
IE01D
COPIES
RECEIVED:LTR
ENCL
SIZE:
TITLE: General
(50 Dkt)-Insp Rept/Notice of Violation Response
D
NOTES:
RECIPIENT
ID CODE/NAME
PDV PD
COPIES
LTTR ENCL
1
1
RECIPIENT
ID CODE/NAME
CLIFFORD,J
COPIES
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AEOD/DSP/ROAB
AEOD/TTC
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NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK.
ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION
LISTS FOR DOCUMENTS YOU DON'T'NEED!
TOTAL NUMBER OF COPIES
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UNITED STATES
NUCLEAR REGULATORYCOMMISSION
REGION V
1450 MARIALANE
WALNUTCREEK, CAUFORNIA94596-5368
Docket No.
50-397
Washington Public Power Supply System
P. 0.
Box 968
Richland,
99352
Attention:
Mr. J.
V. Parrish
Assistant
Managing Director for Operations-
Gentlemen:
Thank you for your letter of July 9,
1993, in response
to our Notice of
Violation and Inspection
Report No. 50-397/93-13,
dated
June
9,
1993,
informing us of the steps
you have taken or plan to take to correct the items
which we brought to your attention.
Your corrective actions will be verified
during
a future inspection.
Mith regard to Violation B in the referenced
Notice of Violation, your
response
stated that you would complete
walkdowns to identify non-credited
Thermo-lag installations
on power cables
by January
31,
1994,
and perform
power cable ampacity derating,calculations
by June
30,
1994.
We note that
on
June
23,
1993, you also revised your response
"Thermo-lag 330-1 Fire Barriers," to incorporate
these actions.
The
acceptability of your proposed
schedule for the walkdowns
and calculations
will be addressed
separately
in the NRC's reply to your corrected response'to
Sincerely,
C. A. VanDenburgh,
C 'ef
Reactor
Projects
Branch
CC'r. J.
H. Swailes,
WNP-2 Plant Manager
G.
E.
C. Doupe,
Esq.,
Mr. Warren A. Bishop,
Chairman,
Energy Facility Site Evaluation Council
Mr. Alan G. Hosier, Licensing Manager,
Mr. G.
C. Sorensen,
Manager,
Regulatory Programs,
Chairman,
Benton County Board of Commissioners
M. H. Philips, Jr., Esq.,
Winston 5 Strawn
9309290283
930903
T;
ADOCK 05000397(",
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Docket File
Project Inspector
Resident
Inspector
B. Faulkenberry
S. Richards
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'WASHINGTON PUBLIC POWER SUPPLY SYSTEiii
P.o. Box968 ~ 3000George Wasbjngion Way ~ Richland, Wasbbtgd>j 99/52~,
i>09))P-5000
July 9,
1993
G02-93-178
Docket No. 50-397
U. S. Nuclear Regulatory Commission
Attn: Document Control Desk
Mail Station P 1-137
Washington, D. C.
20555
Gentlemen:
Subject:
NNP-2, OPERATING LICENSE NO. NPF-21
NRC INSPECTION REPORT 93-13
RESPONSE TO NOTICE OF VIOLATION
The Washington Public Power Supply System hereby replies to the Notice ofViolation contained
in your letter dated June 9, 1993.. 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, the violation is addressed
with an explanation of our position regarding validity,
corrective action and date of full compliance.
Sincerely,
J. V. Parrish (Mail Drop 1023)
Assistant Managing Director, Operations
CDM/bk
Attachments
CC:
BH Faulkenberry - NRC RV
NS Reynolds - Winston & Strawn
DL Williams - BPA/399
NRC Site Inspector - 901A
Appendix A
During an NRC inspection conducted on March 30 through May 10, 1993, violations of NRC
requirements
were identified.
In accordance
with the "General
Statement of Policy
and'rocedure
for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violations are listed
below:
A.
10 CFR 50, Appendix B, Criterion V states, in part:
"Activities affecting quality shall
be prescribed by documented instructions, procedures, or drawings of a type appropriate
to the circumstances
and shall be accomplished in accordance
with these instructions,
procedures, or drawings. Instructions, procedures, or drawings shall include appropriate
quantitative or qualitative acceptance
criteria for determining that important activities
have been satisfactorily accomplished."
Section 6.8.1 of the Technical Specifications states, in part:
"Written procedures
shall be established,
implemented,
and maintained covering
th'
activities referenced below:
c.
Surveillance and test activities of safety-related equipment."
Paragraph
5.1.2 of Plant Procedures
Manual (PPM) 1.2.3,
Revision
19,
"Use of
Controlled Plant Procedures,"
states,
"plant personnel
are responsible for operating,
maintaining, and testing plant equipment and systems per applicable plant procedures
at
all times."
PPM 1.2.3, Revision
19, Paragraph
5.1.5, states, "Ifan existing procedure
[which]
addresses
the activity to be performed is incorrect...it shall be corrected per PPM 1.2.3
or PPM 1.2.4 and then used."
PPM 1.2.3, Revision 19, Paragraph 5.3.5 states, "completion [ofthe procedure] consists
of the following...
e.
A thorough review by the Shift Manager to ensure...all signoffs are complete and
all required data has been taken, or marked N/A and appropriately document-
ed...and all acceptance
criteria has been met or appropriate Technical Specifica-
tions Actions Statements
have been entered."
Contrary to the above:
1.
In PPM 7.4.3,7.4.10,
Revision 4, performed on April 7, 1993, the craftsman
entered as-found and as-left values of 11.1 feet in Table 7.1a and 11.0 feet in
Table 7.1b (data tables for two level instruments associated
with the "B" spray
pond), although the table lists the acceptable
range
as 11.75 to 12.25 feet (an
incorrect range -the acceptable range should have been listed as 10.75 to 11.25
Appendix A
Page 2 of 6
feet).
The craftsman signed offstep 7 of Sections 7.1 and 7.2 of the procedure,
respectively, signifying that all values in Tables 7.1a and 7.1b were within the
stated tolerance.
The Shift Manager and craft supervisor reviewed and signed the
procedure to indicate complete and satisfactory test performance.
2.
In PPM 7.4.8.1.1.2.1,
Revision 19, performed on April 4, 1993, section 7.5,
steps 80 and 81 required the operator to record the level of DO-TK-1A in feet
and inches and then convert this value to gallons, based on the table in Attach-
ment 9.4. The operator entered
11 feet zero inches, which corresponds to 57,251
gallons in the table of Attachment 9.4.
However, the operator entered 57,635
gallons in step 81, a non-conservative value that was not found anywhere on the
table in Attachment 9.4.
The Shift Manager and craft supervisor reviewed and
signed the procedure to indicate complete and satisfactory test performance.
3.
In PPM 7.4.8.2.1.20, Revision 10, performed on April 7, 1993, the craftsman
entered comments
that stated that electrolyte level was high and an engineer's
concurrence
was necessary
to determine ifthe battery cell was satisfactory.
No
resolution to these comments
was documented.
The Shift Manager and craft
supervisor reviewed and signed the procedure to'indicate complete and satisfacto-
ry test performance.
4.
In PPM 7.4.8.2.1.20,
Revision 10, performed on April 7, 1993, the craftsman
entered comments stating that sedimentation levels were high for battery cells 6
and 11, and that an engineer's
concurrence
was necessary
to conclude that the
battery cells were satisfactory.
No resolution was provided for these comments.
The Shift Manager and craft supervisor reviewed and signed the procedure to
indicate complete and satisfactory test performance.
This is a Severity Level IV violation.
(Supplement Q
Validit of Violation
The Supply System acknowledges
the validity of this violation. The root cause of the multiple
examples of procedure completion deficiencies was a lack of attention to administrative details.
Reviews of pertinent information and interviews with the involved utilitycraft and supervisory
personnel verified that, in each case, plant equipment was operable and satisfied the surveillance
requirements.
However, plant management's
expectation of "strict adherence" to administrative
details
associated
with procedure
performance
completion
is not being
consistently
met.
Procedural paperwork and reviews are not being completed in a thorough enough manner to
meet plant documentation standards.
Appendix A
Page 3 of 6
Since procedure adherence problems continue to occur, the numerous previous corrective actions
implemented by Supply System
management
to resolve this issue have not been completely
successful.
It is evident that special attention must be given to the associated
administrative
aspects
of procedure
compliance.
The corrective actions described
below are intended
to
produce the necessary
improvements in this area.
In addition, a self assessment
audit willbe
conducted to assure that these corrective actions,
as well as those previously established,
were
effective.
The self assessment
willalso identify any other procedure adherence problem areas
requiring special management
attention.
Corrective Ste
s Taken/Results
Achieved
1.
The identified procedures were reviewed to assure plant equipment operability. WNP-2
Technical Specification compliance was verified in each case.
i
2.
The utilitycraft and supervisory personnel involved in this violation were counseled
on
the corrections to their errors that were necessary
to meet plant surveillance procedure
completion and documentation standards.
An Interoffice Memorandum gOM) was issued to Operations, Maintenance, Technical
and Radiation Protection Departments
on May 24, 1993, to reemphasize
the uses of
"N/A," asterisk/number
and single line-out during procedure performance.
4
PPMs 7.4.8.1.1.2.1,
7.4.8.1,1.2.11
and 7.4.8.1.1.2.12
were revised
to instruct the
procedure
user to read'the
fuel oil storage
tank levels to the nearest
inch (always
rounding down) for the most conservative measurement.
5.
PPM 7.4.8.1.1.2.12 was revised to change Attachment 9.3 to show the normal position
of the Lube Oil Soakback Pump as "OFF" instead of "ON."
Corrective Action to be Taken
Conduct training for affected reviewers by August 31, 1993, on procedure requirements
concerning review of completed procedures.
This will include Shift Managers,
Shift
Engineers/Shift Technical Advisors and discipline supervisors with potential procedure
review responsibilities.
2.
Evaluate by October 31, 1993, the procedure completion review process to determine if
the level of review and methodology are appropriate
to assure
adequate
attention to
technical and administrative details.
3.
Conduct followup audits no later than September
1, 1993,
assessing
plant personnel
performance concerning surveillance procedure documentation and procedure adherence.
k
I'
I
Appendix A
Page 4 of 6
r
A mechanism for trending progress willbe established,
as well as a method of feedback
to the performers
and reviewers.
Audits will be conducted
on a monthly basis for
approximately four months, at which time the audit frequency and need to continue will
be evaluated.
Date of Full Com liance
Each procedural administrative deficiency item identified in this Inspection Report was presented
in the NRC Resident
Inspector and Plant Manager meeting on April 22,
1993.
The Plant
Manager responded
by assigning responsible
discipline reviewers to rereview the associated
procedures,
then meet individually with the NRC Inspector by April 28, 1993, to compare
findings,
Full compliance
was achieved
for each item based
on the discussions
in those
meetings.
B.
10 CFR 50, Appendix B, Criterion V, and section 5.2.1 of the WPPSS
Operational
Quality Assurance Program Description (OQAPD) require that activities affecting quality
be prescribed by drawings appropriate
to the circumstances.
WNP-2 Drawing E797
implements these requirements for the standby service water (SSW) pumphouse electrical
chases.
Contrary to the above, on April 16, 1993, an activity affecting quality existed that was
not described by drawings appropriate to the circumstances,
in that Thermolag System
330 fire retardant material was used to protect cabling in the SSW pumphouse, but was
not reflected in Drawing E797.
4
This is a Severity Level IV violation. (Supplement I).
Validit of Violation
The Supply System acknowledges
the validity of this violation.
The Inspection Report stated
that Thermolag
was found during a tour of the "B" SSW pumphouse.
A Supply System
walkdown of the "A" a'nd "B" SSW pumphouses
conducted
on June
18,
1993, found no
Thermolag installations in the "B" SSW pumphouse.
However, several Thermolag installations
were found in the "A" SSW pumphouse for electrical separation
barriers.
Therefore, it is
assumed
that the NRC Inspector
tour on April 16,
1993,
was actually of the "A" SSW
pumphouse.
Certain Thermolag installation configurations could cause elevated internal temperatures of the
enclosed electrical power cables.
This could cause premature aging of power cables supplying
safety related equipment.
In Licensing Event Report (LER) 86-033-02,
the Supply System
committed to perform
a power cable ampacity derating evaluation
on all electrical cabling
protected by Thermolag.
This was in response to original problems encountered with duct bank
Appendix A
Page 5 of 6
cable derating and NRC concerns identified in NRC Region V Report No. 50-397/86-25-16.
Based
on this evaluation, calculations would be performed on scheduled
raceway continuous
power cables enclosed in Thermolag barrier installations that met certain configuration criteria.
None of the Thermolag installations found during the Supply System walkdown of the "A"SSW
pumphouse met the criteria for power cable ampacity derating calculations.,Two spared cables
and
one instrument
and control cable were found in the pumphouse
that had Thermolag
applications that met the configuration criteria. However, since they were not continuous power
cables, they did not meet the criteria that requires performance ofampacity derating calculations.
Accordingly, this violation had no impact on the safety related equipment located in the "A"
SSW pumphouse.
There is; however,
a potential impact on safety related equipment located
elsewhere in the plant.
Thermolag was applied in many places for electrical separation.
Later reviews showed that it
was not required.
The electrical cables could still be in use, but no 10CFR50, Appendix R
credit was taken for the Thermolag.
These applications are not presently depicted on design
drawings and may not exist in the design documentation data base.
Previous walkdowns were
performed to verify Thermolag applications for Appendix R criteria only or to verify electrical
installations where the criteria did not require Thermolag.
NonAppendix R (noncredited)
Thermolag applications were not consistently incorporated into the design documentation
data
base or design drawings as there were no plant procedural requirements to include field installed
fire barriers in design documents.
The root cause of this violation was the lack of procedural
requirements.
This resulted in a condition where documentation was not available to assure that
power cable ampacity derating calculations were performed in all cases where required.
The design
documentation
data base
was used
to meet the power cable ampacity derating
evaluation commitments of LER 86-033-02.
Since all noncredited Thermolag applications on
power cables may not be documented,
the ampacity derating calculations may not be complete.
The April 13, 1993, response
to NRC Generic Letter 92-08 takes credit for these original
calculations.
Consequently,
as was pointed out by the NRC, the Generic Letter response may
have been deficient.
Corrective
te
s Taken/Results
Achieved
1.
Problem Evaluation Request (PER) 293-428 was initiated on April23, 1993, to address
the apparent inadequate power cable ampacity derating evaluation performed in response
2.
A Request for Technical Services (RFTS 93-03-066) was initiated on March 16, 1993,
to update drawings to reflect as-built Thermolag tray installations in the "A" SSW
pumphouse.
Appendix A
Page 6 of 6
3.
A revised response
to NRC Generic Letter 92-08 was submitted on June 23, 1993, to
include corrective actions to identify Thermolag installations not previously identified on
design drawings.
Corrective Action to be Taken
Walkdown criteria for a Thermolag inspection willbe developed by July 31, 1993.
2.
Walkdowns willbe performed by January 31, 1994, to identify noncredited Thermolag
installations on power cables in accordance with the criteria developed by Engineering.
3.
The Thermolag walkdown data will be incorporated into appropriate electrical design
documents by June 30, 1994.
4.
Power cable ampacity derating calculations willbe completed by June 30, 1994.
5.
No generic design documentation control corrective actions are seen as necessary.
This
deficiency is restricted
to electrical design documents.
Original plant documentation
controls failed to fully incorporate Thermolag applications that were not required.
The
importance of documenting
these applications
was apparently not clearly understood.
Documentation controls are in place to adequately maintain design documents current,
and prevent recurrence of this deficiency.
Date of
ull Com liance
Full compliance will be achieved
on June 30,
1994, when electrical design documents will
reflect the current Thermolag installation configurations that can impact power cable ampacity
calculations.
N
0