ML17291A874

Responds to NRC 950522 Ltr Re Violation Noted in Insp Rept 50-397/95-09.Corrective Actions:Equipment Replacement Interval Reviewed for Safety Related Items for Which Basis for Qualified Life Other than Thermal Aging

ML17291A874
Person / Time
Site:	Columbia
Issue date:	06/21/1995
From:	Parrish J WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GO2-95-115, NUDOCS 9506300081
Download: ML17291A874 (6)

Text

yPRIORITY 1e (ACCELERATED RIDS PROCESSING) i REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9506300081 DOC.DATE: 95/06/21 NOTARIZED: NO DOCKET FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 P AUTH. NAME AUTHOR AFFILIATION PARRISH,Z.V. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 950522 ltr re violation noted in insp rept 50-397/95-09.Corrective actions:equipment replacement interval reviewed for safety related items for which basis 0 for qualified life other than thermal aging.

DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation esponse NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD4-2 PD 1 1 CLIFFORD,Z 1 1 INTERNAL: ACRS 2 2 AEOD/DEIB 1 1 AEOD/SPD/RAB 1 1 AEOD/~C 1 1 DEDRO 1 1 LE GENTLER 1 1 NRR/DISP/PIPB 1 1 NRR/DORS/OEAB 1 1 NRR/DRCH/HHFB 1 1 NUDOCS-ABSTRACT 1 1 OE DIR 1 1 OGC/HDS3 1 1 RGN4 FILE Ol 1 1 EXTERNAL: LITCO BRYCE,J H 1 1 NOAC 1 1 NRC PDR 1 1 0 NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN SD8 t415-2083) TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL 19

WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 99352-0968 ~ (509) 372-5000 June 21, 1995 G02-95-115 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 95-09, RESPONSE TO NOTICE OF VIOLATION

Reference:

Letter dated May 22, 1995, AB Beach (NRC) to JV Parrish (SS), "NRC Inspection Report 50-397/95-09 and Notice of Violation" The Supply System's response to the referenced Notice of Violation, pursuant to the provisions of Section 2.201, Title 10, Code of Federal Regulations, is attached.

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

Sincerely, Uvf'1 J. V. P Drop 1 3 Vice res t, uclear Ope 'ons CJF/ml Attachment 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 950630008i 95062i PDR ADOCK 05000397 9 PDR

Appendix A Page 1 of 2 Appendix A VI LATI N During an NRC inspection conducted on March 5 through April 22, 1995, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions, 10 CFR Part 2, Appendix C, the violation is listed below:

A. 10 CFR Part 50, Appendix B, Criterion V, states, in part, "Activities affecting quality shall be prescribed by documented instructions, procedures or drawings of a type

'ppropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings."

Equipment Engineering Standard EQES-2, "Technical Requirements for Electrical Equipment Environmental Qualification, Revision 4, permits extending the qualified life of components by 25 percent only for those components whose qualification was based on thermal aging.

Contrary to the above, on March 28, 1995, it was identified that the qualified life of Hydrogen Sensor 1301 had been extended by 25 percent and the sensor had not been qualified by thermal aging.

This is a Severity Level IV violation (Supplement I) (397/9509-01).

R P NET VI LATI N The Supply System accepts this violation.

EA NF R VI TI The cause of the violation was inadequate standards. Engineering Standard EQES-2 uses the standard Arrhenius methodology to allow adding a 25% time increment to the maintenance interval when the technical basis for qualified life is thermal aging at design maximum abnormal operating temperatures. However, the Qualification Related Maintenance Summary (QRMS) form prepared under Engineering Standard EQES-4, "QID File Format and Organization" to specify the qualified life of an item did not clearly designate whether the data to be entered was the maintenance interval or the qualified life as predicted from technical considerations, and was ambiguous about adding the 25% time increment to the time specified. Engineers doing this repetitive work used the guidance on the QRMS form because the other pertinent standard EQES-11, "Qualification Scheduled Maintenance List, Database Management Standard for Drawing M937" did not provide any additional guidance. Tiierefore use of this form lent itself to a commission of errors.

Appendix A Page 2 of 2 RRE VE TEP TAKEN A R T A HIE D Equipment replacement intervals were reviewed for safety related items for which the basis for qualified life was other than thermal aging to determine if the 25% extension had been erroneously applied. No other cases were found. Engineering Standard EQES-11 was revised to require the QRMS form differentiate between maintenance interval and qualified life.

Standard EQES-4 was revised to include the new QRMS form, and to require the engineer to state both the maintenance interval and the qualified life determined from technical considerations. This change assures that both values are considered and documented by the engineer, and aids in checking that maintenance needed to preserve the qualification of the item will occur before the end of qualified life.

Engineers involved in equipment qualification were trained in use of the revised standard and QRMS form, emphasizing that the maintenance interval can be extended by 25% only for items where thermal aging of materials in a component is the basis for prediction of qualified life, and that the 25% increment should not be applied in a way that results in scheduling maintenance past the end of qualified life.

The outdated hydrogen and oxygen sensors were replaced with qualified units. Additionally, the QRMS forms for the sensors were corrected, as was the data in the maintenance scheduling system.

RRE TIVE P T ET E T V ID THER VI LATI Based on the corrective steps taken above, no additional corrective steps are planned, DATE F F MPLIAN The Supply System has been in full compliance since April 17, 1995, at which time the erroneous QRMS form and maintenance interval for the sensors had been corrected, and data in the maintenance scheduling system had been verified as having no similar errors.

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