ML17291A621

Responds to NRC 940831 Ltr Re Violations Noted in Insp Rept 50-397/94-24.Corrective actions:one-over-one Review of LCO Entry Has Been Instituted as Mgt Expectation Through End of Mar 1995

ML17291A621
Person / Time
Site:	Columbia
Issue date:	01/18/1995
From:	Parrish J WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GO2-95-010, GO2-95-10, NUDOCS 9501310123
Download: ML17291A621 (3)

Text

(ACCELERATED RIDS PROCESSING)

REGULATORY INFORMATION DISTRIBUTION SYSTEM'(RIDS)

ESSION NBR:9501310123 DOC.DATE: 95/01/18 NOTARIZED- NO DOCKET I ACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION PARRISH,J.V. Washington Public Power Supply System RECIP.NAME . RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 940831 ltr re violations noted in insp rept 50-397/94-24.Corrective actions:one-over-one review of LCO entry has been instituted as mgt expectation through end of Mar 1995.

DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Vio ation Response NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD4-2 PD CLIFFORD,J INTERNAL: ACRS 2 AEOD/DE IB 1 AEOD/SPD/RAB 1 AEOD/SPD/RRAB 1 OD%TT.C 1 DEDRO 1

~FI-LE=CENTER 02 1 NRR/DORS/OEAB 1 NRR/DRCH/HHFB 1 NRR/PMAS/IRCB-E 1 NUDOCS-ABSTRACT 1 OE DIR 1 OGC/HDS3 1 RGN4 FILE 01 1 ERNAL: LITCO BRYCE,J H NOAC NRC PDR YOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE iVASTE! COYTACTTIHE DOCI:MENTCONTROL DESK. ROOM Pl-37 (EXT. 504-2083 ) TO ELlihIINATEYOUR FAME FRO~I DISTRIBUTIO)N LISTS FOR DOCL'MEN'I'S YOU DO4 "I' L'ED!

TAL NUMBER OF COPIES REQUIRED: LTTR 20 ENCI I'

WASHINGTON PUBLIC POWER SUPPLY SYSTEM PO. Box 968 ~ 3000 George Washington Way ~ Riehiand, Washington 99352-0968 ~ (S09) 372-SOOO January 18, 1995 G02-95-010 Docket No. 50-397 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:

Subject:

WNP-2, OPERATING LICENSE NPF-21 NRC INSPECTION REPORT 94-24 UPDATED RESPONSE TO NOTICE OF VIOLATION94-24

Reference:

1) Letter GI2-94-261, dated August 31, 1994, AB Beach (NRC to JV Parrish (SS), "NRC Inspection Report 50-397/94-24 (Notice of Violation)"

Reference:

2) Letter GO2-94-230, dated September 30, 1994, JV Pamsh (SS) to NRC, "Reply to a Notice of Violation"

Reference:

3) Letter GI2-94-351, dated December 8, 1994, JM Montgomery (NRC) to JV Parrish (SS), "NRC Inspection Report 50-397/94-24" Reference 3 requested that the Supply System provide an updated response to a cited Notice of Violation. Specifically, the staff requested that actions taken or planned with regard to the apparent operator knowledge weakness in the area of Technical Specification requirements be provided. This submittal provides the requested additional information. The corrective actions identified in Reference 2 remain valid and have been completed.

The cause of the failure to recognize and enter the suppression pool level requirement for Containment Systems was personnel error. As stated in Reference 2, the operating crew did identify that the Emergency Core Cooling Systems (ECCS) requirement for the suppression pool was applicable and that the Limiting Condition for Operation (LCO) was met. Discussions with the personnel involved confirmed that they were knowledgeable of the missed Containment Systems Technical Specification, but failed to identify it after identifying and verifying compliance with the ECCS Technical Specification. As noted in Reference 2, the personnel involved have been counseled and additional training has been provided.

9501310123 950118 gp

'PDR PDR, ADOCK 05000397 9

Page 2 UPDATED RESPONSE TO NOTICE OF VIOLATION94-24 The identified failure to enter the appropriate Technical Specification is not the only example of weakness in this area. The opportunity and need to improve performance in the area of Technical Specification identification and implementation is recognized. Several actions as described below have or will be implemented.

1) A one-over-one review of LCO entry sheets has been instituted as a management expectation through the end of March, 1995. This provides a second check to ensure the correct Technical Specification is entered. The need for continued one-oyer-one reviews will be evaluated at the end of March.

2) Case studies are being developed to provide additional experience in the review and implementation of the Technical Specification requirements. These studies willprovide both individual and crew opportunities to enhance their skills in the implementation of the Technical Specification. The case studies will be based either on past experience, recognized areas of difficulty or Technical Specification complexity. Problematic case studies will then be integrated into the licensed operator training programs as the appropriate training materials are revised.

3) WNP-2 is currently developing "Improved" Technical Specifications in accordance with the guidance and format provided in NUREGs 1433/1434. These new Technical Specifications are human factored to provide Operators and other plant personnel with a format that is easier to understand and follow. The "Improved" Technical Specifications for WNP-2 are currently scheduled for submittal to the NRC in late 1995.

For the specific example cited regarding suppression pool level, the "Improved" Technical Specifications contain a single limiting condition for suppression pool level.

The Supply System understands the significance of correct identification and implementation of the Technical Specifications requirements. The actions listed above will support improved staff performance in this area.

Should you have any questions or desire additional information regarding this matter, please call me or Mr. D.A. Swank, Licensing Manager, at (509) 377-4563.

Sincerely,

. V. Parrish (Mail Drop 1023)

Vice-President, Nuclear Operations DAS/ml CC: LJ Callan - NRC RIV KE Perkins, Jr. - NRC RIV, Walnut Creek Field Office NS Reynolds - Winston & Strawn JW Clifford - NRC DL Williams - BPA/399 NRC Sr. Resident Inspector - 927N