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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217K9681999-10-19019 October 1999 Ack Receipt of Transmitting Rev 40 to Physical Security Plan for Washington Nuclear Plant 2.Based on Determination That Changes Do Not Decrease Effectiveness of Plan,No NRC Approval Required ML17284A8981999-10-14014 October 1999 Forwards Rev 0 to WNP-2 Cycle 15,COLR 99-15, IAW Requirements of TS 5.6.5 ML17284A9061999-09-24024 September 1999 Forwards Final Rept for 990812 out-of-sequence Drills for Energy Northwest Washington Nuclear Power Project 2 (Lab, Food Control Point & Milk Sampling).No Deficiences & No Areas Requiring C/A Identified in Three Drills ML17284A8881999-09-24024 September 1999 Informs NRC of Change in Schedule Pertaining to Final Implementation of Reactor Stability long-term Solution for WNP-2 ML17292B7591999-09-24024 September 1999 Forwards Rev 24 to WNP-2 Emergency Plan,Iaw 10CFR50.4(b), 50.54(q) & 10CFR50 App E.Detailed Synopsis of Changes,Encl ML17292B7581999-09-22022 September 1999 Forwards NRC Forms 396 & 398 for Nl Hancock,License SOP-50027-3,AR Herrington,License OP-50013-3,WH Sawyer, License SOP-50023-3 & Dl Strote,License SOP-50031-3,for Renewal of Licenses.Without NRC Forms 396 & 398 ML17284A8811999-09-0909 September 1999 Forwards Response to NRC 990623 RAI to Support Review of Pending Request for Amend to Reactor pressure-temp Limit Curve TS GO2-99-168, Forwards Rev 40 to Physical Security Plan.Rev Withheld,Per 10CFR2.790(a)(3)1999-09-0808 September 1999 Forwards Rev 40 to Physical Security Plan.Rev Withheld,Per 10CFR2.790(a)(3) ML17284A8711999-08-30030 August 1999 Informs Staff of Errors in world-wide-web Database Related to WNP-2 Reactor Vessel Structural integrity.Marked-up Pages Containing Errors or Omissions Will Be Forwarded by 991201 ML17284A8751999-08-30030 August 1999 Provides Correct Page from License NPF-21 Marked to Show Rev Addressed in 990729 Application for Amend,Which Included Page That Was Inadvertently Included as Attachment 4.Replace Attachment 4 with Attached Page & Disregard Attachment 5 ML17284A8721999-08-30030 August 1999 Forwards Proprietary Info to Support Review of Request for Amend to License NPF-21,re Min Critical Power Ratio Safety Limits Tss,As Requested During 990816 Conversation. Proprietary Encl Withheld ML17292B7531999-08-24024 August 1999 Requests That Eleven Individuals Listed Below Take BWR Generic Fundamentals Examination to Be Administered on 991006 ML17292B7511999-08-24024 August 1999 Forwards Fitness for Duty (FFD) Semiannual Performance Data Rept for Jan-June 1999,per 10CFR26.71(d) ML17284A8701999-08-19019 August 1999 Forwards NRC Form 396, Certification of Medical Exam by Facility Licensee & NRC Form 398, Personal Qualification Statement - Licensee, for Jd Prescott (License SOP-50262-1).Without Encls ML17292B7501999-08-19019 August 1999 Informs Staff That Licensee Has Completed Review of NRC SER for B&Wog Util Resolution Guidance Document Addressing ECCS Suction Strainer Blockage ML17284A8681999-08-12012 August 1999 Submits Two ISI Program Plan Relief Requests for NRC Review & Approval,Per 10CFR50.55a(a)(3)(i).Proposed Alternatives Provide Acceptable Level of Quality & Safety ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML17284A8541999-08-0202 August 1999 Forwards Proprietary Addl Info to Support Review of Pending Request for Amend to MCPR Safety Limit Ts.Info Consists of Proprietary Ltr from Abb Combustion Engineering,Inc.Encl Withheld ML17284A8531999-07-30030 July 1999 Forwards Estimate of Number of Licensing Action Requests Planned for Submittal in Future,As Requested in Administrative Ltr 99-02.Twenty-nine Submittals Scheduled for Fy 2000 & Four for Fy 2001 ML17284A8301999-07-22022 July 1999 Clarifies Change of Licensee Name from Wpps to Energy Northwest & Change of Facility Name from Wppss Nuclear Project Number 2 to WNP-2,as Requested in 990719 Telcon with Js Cushing of NRC.Marked-up OL Pages,Encl ML17292B7451999-07-20020 July 1999 Forwards Rev 23 to WNP-2 Emergency Plan,Iaw 10CFR50.4(b) & 50.54(q) & 10CFR50 App E.Rev 23 Provides Updated Description Re Establishment of Separate Emergency Operation Centers for Benton & Franklin Counties ML17292B7391999-07-16016 July 1999 Submits Withdrawal of Request for Amend to Secondary Containment & Standby Gas Treatment Sys Ts.Util Currently Plan to re-submit Amend Request in Entirety by 991112 ML17292B7381999-07-12012 July 1999 Forwards NRC Form 396 & NRC Form 398,for If Sumsion,License OP-50487 & Ga Westergard,License SOP-50415 for Renewal of Operator Licenses.Without Encls ML17292B7171999-07-0606 July 1999 Provides Notification of Early Completion on 990630 of Exception Noted in 990629 Ltr.Equipment within Scope of GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants, Evaluated & Y2K Ready ML17292B7181999-07-0202 July 1999 Responds to 990623 RAI to Support Review of Evaluation of Planar Indication Found on Weld Number 24RRC(2)A-1 During 1998 RO ML17292B7161999-06-30030 June 1999 Forwards Addl Info Requested in 990513 Ltr to Support Review of Pending Response to GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power Operated Gate Valves. ML17292B7131999-06-29029 June 1999 Forwards Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. ML17292B7091999-06-21021 June 1999 Forwards Proprietary Response to NRC 990603 RAI Re Licensee Request for Amend to MCPR Safety Limit Tss.Proprietary Info Withheld IAW Requirements of 10CFR2.790 ML17292B7041999-06-17017 June 1999 Forwards NRC Forms 396 & 398 for Three Individuals Listed Below for Renewal of Operator Licenses.Without Encls ML17292B7031999-06-10010 June 1999 Forwards Response to NRC 990511 RAI Re License Request for Amend to Secondary Containment & SGTS Tss.Results of Addl Benchmark of Gothic Computer Code Performed to Demonstrate Modeling Capability of Drawdown Response,Encl ML17292B6841999-06-0404 June 1999 Forwards Response to NRC 990326 RAI Re WNP-2 GL 96-05 Program for Periodic Verification of design-basis Capability of MOVs ML17292B6851999-06-0101 June 1999 Forwards 1999 Quality Audit of WNP-2 Emergency Preparedness Program, Per NUREG-0654,Section Ii,Criteria P.9.Seven Problem Evaluation Requests & Nine Recommendations for Improvement Were Issued as Result of Audit Activities ML17292B6831999-05-25025 May 1999 Informs That Request for NRC Approval of Changes to Emergency Plan Requesting Reduction in on-shift HP Staffing, Is Retracted.Util Will Resubmit Request with Required Addl Info at Later Date ML17292B6751999-05-25025 May 1999 Forwards Proprietary ABB-CE Ltr Re WNP-2 Cycle 15 SLMCPR & Core Reload Design Rept,Per Util Request for Amend Re MCPR Safety Limits.Proprietary Info Withheld,Per 10CFR2.790 ML20206U4501999-05-19019 May 1999 Ack Receipt of Which Transmitted Rev 39 to Physical Security Plan,Per 10CFR50.54(p).No NRC Approval Is Required,Since Changes Do Not Decrease Effectiveness of Security Plan ML17292B6661999-05-0707 May 1999 Requests Exemption to Requirement in 10CFR55.59(a)(2) Re Annual Operating Test requirements.One-time Exemption from Requirement to Period Not to Exceed 15-months from Last Date of Passing Operating Exam for Licensee at Facility ML17292B6531999-05-0303 May 1999 Forwards Response to NRC 990402 RAI Re Licensed Operator Positive Drug Test.Encl Withheld,Per 10CFR2.790 ML17292B6561999-04-29029 April 1999 Forwards Rev 0 to Calculation ME-02-98-04, Fracture Mechanics Evaluation of N1 Safe End & Calculation Mod Record CMR-98-0243, Fracture Mechanics Evaluation of N1A Nozzle Safe End, as Suppl Info to ISI Exam ML17292B6421999-04-19019 April 1999 Responds to NRC 990319 Ltr Re Violations Noted in Insp Rept 50-397/99-01.Corrective Actions:Provisions Are Presently in Place to Maintain Adequate Level of Security GO2-99-073, Forwards Rev 39 to WNP-2 Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Effectiveness of Approved Plan.Encl Withheld IAW 10CFR73.21 & 10CFR2.7901999-04-19019 April 1999 Forwards Rev 39 to WNP-2 Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Effectiveness of Approved Plan.Encl Withheld IAW 10CFR73.21 & 10CFR2.790 ML17292B6401999-04-13013 April 1999 Requests That WNP-2 Operator Requalification Program Be Granted one-time Extension Beyond Requirement in 10CFR55.59(a)(2) for Annual Operating Tests ML17292B6371999-04-12012 April 1999 Forwards Response to NRC 990211 RAI Re Util Request for Amend to Secondary Containment & SBGTS TS ML17292B6281999-04-0606 April 1999 Informs NRC That Insp Interval Ending Date for ISI Program Plan Has Been Extended by One Year to Dec 12,2005 Due to Changes in Plant Refueling Outage Schedule ML20196K6961999-03-30030 March 1999 Ack Receipt of ,Transmitting Rev 38 to Physical Security Plan for Plant.No NRC Approval Is Required,In Accordance with 10CFR50.54(p) GO2-99-060, Submits Rept of Status of WNP-2 Decommissioning Fund as of 981231,IAW 10CFR50.75(f)(1)1999-03-26026 March 1999 Submits Rept of Status of WNP-2 Decommissioning Fund as of 981231,IAW 10CFR50.75(f)(1) ML17292B6131999-03-24024 March 1999 Forwards Rev 0 to Calculation ME-02-98-04, Fracture Mechanics Evaluation of N1 Nozzle Safe End. Info Will Be Used to Assist NRC in Review of WNP-2 ISI Activities Associated with Evaluation of Planar Indication ML20204F0261999-03-19019 March 1999 Forwards Insp Rept 50-397/99-01 on 990201-04 & 0303-05.No Violations Noted.Areas of Physical Security Plan Effectively Implemented with Listed Exceptions ML17292B6001999-03-16016 March 1999 Responds to Weakness Noted in Insp Rept 50-397/98-24. Corrective Actions:Developed Document to Identify Areas Needing Improvement,Assigned Responsibility for Actions & Provided Milestones for Achievement ML17292B5941999-03-16016 March 1999 Forwards NRC Form 396, Certification of Medical Exam by Facility Licensee, & NRC Form 398, Personal Qualification Statement - Licensee, for MD Comstock,Mc Naulty & RR Nelson.Without Encls 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML17284A8981999-10-14014 October 1999 Forwards Rev 0 to WNP-2 Cycle 15,COLR 99-15, IAW Requirements of TS 5.6.5 ML17284A9061999-09-24024 September 1999 Forwards Final Rept for 990812 out-of-sequence Drills for Energy Northwest Washington Nuclear Power Project 2 (Lab, Food Control Point & Milk Sampling).No Deficiences & No Areas Requiring C/A Identified in Three Drills ML17292B7591999-09-24024 September 1999 Forwards Rev 24 to WNP-2 Emergency Plan,Iaw 10CFR50.4(b), 50.54(q) & 10CFR50 App E.Detailed Synopsis of Changes,Encl ML17284A8881999-09-24024 September 1999 Informs NRC of Change in Schedule Pertaining to Final Implementation of Reactor Stability long-term Solution for WNP-2 ML17292B7581999-09-22022 September 1999 Forwards NRC Forms 396 & 398 for Nl Hancock,License SOP-50027-3,AR Herrington,License OP-50013-3,WH Sawyer, License SOP-50023-3 & Dl Strote,License SOP-50031-3,for Renewal of Licenses.Without NRC Forms 396 & 398 ML17284A8811999-09-0909 September 1999 Forwards Response to NRC 990623 RAI to Support Review of Pending Request for Amend to Reactor pressure-temp Limit Curve TS GO2-99-168, Forwards Rev 40 to Physical Security Plan.Rev Withheld,Per 10CFR2.790(a)(3)1999-09-0808 September 1999 Forwards Rev 40 to Physical Security Plan.Rev Withheld,Per 10CFR2.790(a)(3) ML17284A8751999-08-30030 August 1999 Provides Correct Page from License NPF-21 Marked to Show Rev Addressed in 990729 Application for Amend,Which Included Page That Was Inadvertently Included as Attachment 4.Replace Attachment 4 with Attached Page & Disregard Attachment 5 ML17284A8721999-08-30030 August 1999 Forwards Proprietary Info to Support Review of Request for Amend to License NPF-21,re Min Critical Power Ratio Safety Limits Tss,As Requested During 990816 Conversation. Proprietary Encl Withheld ML17284A8711999-08-30030 August 1999 Informs Staff of Errors in world-wide-web Database Related to WNP-2 Reactor Vessel Structural integrity.Marked-up Pages Containing Errors or Omissions Will Be Forwarded by 991201 ML17292B7531999-08-24024 August 1999 Requests That Eleven Individuals Listed Below Take BWR Generic Fundamentals Examination to Be Administered on 991006 ML17292B7511999-08-24024 August 1999 Forwards Fitness for Duty (FFD) Semiannual Performance Data Rept for Jan-June 1999,per 10CFR26.71(d) ML17284A8701999-08-19019 August 1999 Forwards NRC Form 396, Certification of Medical Exam by Facility Licensee & NRC Form 398, Personal Qualification Statement - Licensee, for Jd Prescott (License SOP-50262-1).Without Encls ML17292B7501999-08-19019 August 1999 Informs Staff That Licensee Has Completed Review of NRC SER for B&Wog Util Resolution Guidance Document Addressing ECCS Suction Strainer Blockage ML17284A8681999-08-12012 August 1999 Submits Two ISI Program Plan Relief Requests for NRC Review & Approval,Per 10CFR50.55a(a)(3)(i).Proposed Alternatives Provide Acceptable Level of Quality & Safety ML17284A8541999-08-0202 August 1999 Forwards Proprietary Addl Info to Support Review of Pending Request for Amend to MCPR Safety Limit Ts.Info Consists of Proprietary Ltr from Abb Combustion Engineering,Inc.Encl Withheld ML17284A8531999-07-30030 July 1999 Forwards Estimate of Number of Licensing Action Requests Planned for Submittal in Future,As Requested in Administrative Ltr 99-02.Twenty-nine Submittals Scheduled for Fy 2000 & Four for Fy 2001 ML17284A8301999-07-22022 July 1999 Clarifies Change of Licensee Name from Wpps to Energy Northwest & Change of Facility Name from Wppss Nuclear Project Number 2 to WNP-2,as Requested in 990719 Telcon with Js Cushing of NRC.Marked-up OL Pages,Encl ML17292B7451999-07-20020 July 1999 Forwards Rev 23 to WNP-2 Emergency Plan,Iaw 10CFR50.4(b) & 50.54(q) & 10CFR50 App E.Rev 23 Provides Updated Description Re Establishment of Separate Emergency Operation Centers for Benton & Franklin Counties ML17292B7391999-07-16016 July 1999 Submits Withdrawal of Request for Amend to Secondary Containment & Standby Gas Treatment Sys Ts.Util Currently Plan to re-submit Amend Request in Entirety by 991112 ML17292B7381999-07-12012 July 1999 Forwards NRC Form 396 & NRC Form 398,for If Sumsion,License OP-50487 & Ga Westergard,License SOP-50415 for Renewal of Operator Licenses.Without Encls ML17292B7171999-07-0606 July 1999 Provides Notification of Early Completion on 990630 of Exception Noted in 990629 Ltr.Equipment within Scope of GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants, Evaluated & Y2K Ready ML17292B7181999-07-0202 July 1999 Responds to 990623 RAI to Support Review of Evaluation of Planar Indication Found on Weld Number 24RRC(2)A-1 During 1998 RO ML17292B7161999-06-30030 June 1999 Forwards Addl Info Requested in 990513 Ltr to Support Review of Pending Response to GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power Operated Gate Valves. ML17292B7131999-06-29029 June 1999 Forwards Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. ML17292B7091999-06-21021 June 1999 Forwards Proprietary Response to NRC 990603 RAI Re Licensee Request for Amend to MCPR Safety Limit Tss.Proprietary Info Withheld IAW Requirements of 10CFR2.790 ML17292B7041999-06-17017 June 1999 Forwards NRC Forms 396 & 398 for Three Individuals Listed Below for Renewal of Operator Licenses.Without Encls ML17292B7031999-06-10010 June 1999 Forwards Response to NRC 990511 RAI Re License Request for Amend to Secondary Containment & SGTS Tss.Results of Addl Benchmark of Gothic Computer Code Performed to Demonstrate Modeling Capability of Drawdown Response,Encl ML17292B6841999-06-0404 June 1999 Forwards Response to NRC 990326 RAI Re WNP-2 GL 96-05 Program for Periodic Verification of design-basis Capability of MOVs ML17292B6851999-06-0101 June 1999 Forwards 1999 Quality Audit of WNP-2 Emergency Preparedness Program, Per NUREG-0654,Section Ii,Criteria P.9.Seven Problem Evaluation Requests & Nine Recommendations for Improvement Were Issued as Result of Audit Activities ML17292B6751999-05-25025 May 1999 Forwards Proprietary ABB-CE Ltr Re WNP-2 Cycle 15 SLMCPR & Core Reload Design Rept,Per Util Request for Amend Re MCPR Safety Limits.Proprietary Info Withheld,Per 10CFR2.790 ML17292B6831999-05-25025 May 1999 Informs That Request for NRC Approval of Changes to Emergency Plan Requesting Reduction in on-shift HP Staffing, Is Retracted.Util Will Resubmit Request with Required Addl Info at Later Date ML17292B6661999-05-0707 May 1999 Requests Exemption to Requirement in 10CFR55.59(a)(2) Re Annual Operating Test requirements.One-time Exemption from Requirement to Period Not to Exceed 15-months from Last Date of Passing Operating Exam for Licensee at Facility ML17292B6531999-05-0303 May 1999 Forwards Response to NRC 990402 RAI Re Licensed Operator Positive Drug Test.Encl Withheld,Per 10CFR2.790 ML17292B6561999-04-29029 April 1999 Forwards Rev 0 to Calculation ME-02-98-04, Fracture Mechanics Evaluation of N1 Safe End & Calculation Mod Record CMR-98-0243, Fracture Mechanics Evaluation of N1A Nozzle Safe End, as Suppl Info to ISI Exam ML17292B6421999-04-19019 April 1999 Responds to NRC 990319 Ltr Re Violations Noted in Insp Rept 50-397/99-01.Corrective Actions:Provisions Are Presently in Place to Maintain Adequate Level of Security GO2-99-073, Forwards Rev 39 to WNP-2 Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Effectiveness of Approved Plan.Encl Withheld IAW 10CFR73.21 & 10CFR2.7901999-04-19019 April 1999 Forwards Rev 39 to WNP-2 Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Effectiveness of Approved Plan.Encl Withheld IAW 10CFR73.21 & 10CFR2.790 ML17292B6401999-04-13013 April 1999 Requests That WNP-2 Operator Requalification Program Be Granted one-time Extension Beyond Requirement in 10CFR55.59(a)(2) for Annual Operating Tests ML17292B6371999-04-12012 April 1999 Forwards Response to NRC 990211 RAI Re Util Request for Amend to Secondary Containment & SBGTS TS ML17292B6281999-04-0606 April 1999 Informs NRC That Insp Interval Ending Date for ISI Program Plan Has Been Extended by One Year to Dec 12,2005 Due to Changes in Plant Refueling Outage Schedule GO2-99-060, Submits Rept of Status of WNP-2 Decommissioning Fund as of 981231,IAW 10CFR50.75(f)(1)1999-03-26026 March 1999 Submits Rept of Status of WNP-2 Decommissioning Fund as of 981231,IAW 10CFR50.75(f)(1) ML17292B6131999-03-24024 March 1999 Forwards Rev 0 to Calculation ME-02-98-04, Fracture Mechanics Evaluation of N1 Nozzle Safe End. Info Will Be Used to Assist NRC in Review of WNP-2 ISI Activities Associated with Evaluation of Planar Indication ML17292B5991999-03-16016 March 1999 Informs That Listed Property & Liability Insurance Coverage for WNP-2 Is in Force,In Compliance with Licensing Responsibilities Delineated in 10CFR50.54(w)(3) ML17292B5911999-03-16016 March 1999 Forwards 1998 Environ Operating Rept, Per Reporting Requirements of Section 5.4.1 of WNP-2 Epp.No Design or Operational Changes or Tests in 1998 Involved Unreviewed Environ Question ML17292B5941999-03-16016 March 1999 Forwards NRC Form 396, Certification of Medical Exam by Facility Licensee, & NRC Form 398, Personal Qualification Statement - Licensee, for MD Comstock,Mc Naulty & RR Nelson.Without Encls ML17292B6001999-03-16016 March 1999 Responds to Weakness Noted in Insp Rept 50-397/98-24. Corrective Actions:Developed Document to Identify Areas Needing Improvement,Assigned Responsibility for Actions & Provided Milestones for Achievement ML17292B5901999-03-11011 March 1999 Forwards Hard Copy of Addl Occupational Exposure Data Requested in GL 94-04,per 990303 e-mail.Original Electronic Version Was Corrupted ML17292B5681999-03-0101 March 1999 Forwards Radioactive Effluent Release Rept for 1998, IAW 10CFR50.36a(a)(2) & TS 5.6.3 & Complete Copy of WNP-2 ODCM Per TS 5.5.1 ML17292B5651999-02-22022 February 1999 Forwards Relief Request 2ISI-20,proposing Alternate Exam Expected to Reduce Dose Significantly & Still Provide Adequate Safety & Quality.Attached Relief Request Will Be Used to Support ALARA Dose Reduction Efforts During Maint ML17292B5581999-02-0404 February 1999 Requests Change to Co Which Modified WNP-2 OL to Reflect Schedule for Implementing Thermo-Lag 330-1 Fire Barrier C/As.Change Requested to Reflect That Final Implementation of C/As Will Be Completed During Fall 1999 Not Spring 1999 1999-09-09
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R EGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
CCESS'ION NBR:9606070058 DOC.DATE: 96/05/31 NOTARIZED: NO 'OCKET FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION BEMISEP.R. Washington Public Power Supply System RECZP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 960501 ltr re violations noted in insp rept 50-397/96-01.Corrective actions:reviewed event w/Control Room Supervisor a sys engineer & counseled Instrumentation 6 Controls technician re need for self-checking.
DISTRIBUTION CODE: IEOZD COPIES RECEIVED:LTR ) ENCL I SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Uiolation Response NOTES:
RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD4-2 PD 1 1 COLBURN,T 1 1 INTERNAL: ACRS 2 2 AEOD/SPD/RAB 1 1 1 1 DEDRO 1 1 1 1 NRR/DISP/PIPB 1 1 NRR DRCH/HHFB 1 1 NRR/DRPM/PECB 1 1 NUDOCS-ABSTRACT NRR/DRPM/PERH 1 1 1 OE DIR 1 1 OGC/HDS3 1 1 RGN4 FILE 01 1 1 TERNAL: LITCO BRYCE,J H 1 1 NOAC 1 1 NRC PDR 1 1 NOTE TO ALL "RIDS" RECIPIENTS: CONTROL DESK, PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT ROOM OWFN SD-5(EXT. 415-2083) TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL 19
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si WASHINGTON PUBLIC POWER SUPPLY SYSTEM PO. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 99352-0968 ~ (509) 372-SOOO May 31, 1996 G02-96-113 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 96-01, RESPONSE TO NOTICE OF VIOLATION h
Reference:
Letter dated May 1, 1996, TP Gwynn (NRC) to JV Parrish (SS), "NRC Inspection Report 50-397/96-01 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 enclosed as Attachment A.
Should you have any questions or desire additional information regarding this matter, please call me or Ms. L. C. Fernandez at (509) 377-4147.
Respectfully, P. 's (Mail D op PE20)
Vi esi ent, Nucl Operations REB Attachment 0700.io cc: LJ Callan - NRC RIV KE Perkins, Jr. - NRC RIV, Walnut Creek Field Office NS Reynolds - Winston & Strawn TG Colburn - NRR DL Williams - BPA/399 NRC Sr. Resident Inspector - 927N 9b0b070058 9b053i PDR ADQCK 05000397 6 PDR
NRC INSPECTION REPORT 96-01, RESPONSE TO NOTICE OF VIOLATION Attachment A Page 1 of 4 R TATEMENT F VI LATI N During an NRC inspection conducted on March 25-28, 1996, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," (60 FR 3481:,June 30, 1995), the violation is listed below:
Section 6.8.1.A of the facility's Technical Specification requires that procedures be established, implemented, and maintained covering the activities of applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Section 9 of Appendix A, Regulatory Guide 1.33, Revision 2 states, in part, that maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures.
Licensee Procedure 1.3.42, Revision 13, "Troubleshooting Plant Systems and Equipment,"
requires that a troubleshooting plan be developed prior to performing troubleshooting and that the troubleshooting activities be described in step-by-step detail. The procedure further requires that prior to conducting troubleshooting, a briefing involving the Control Room Supervisor/Shift Manager, work supervisor, work performer, and others, as necessary, be conducted and that prior to implementation, the troubleshooting plan be approved by two senior reactor operators, Section 4.3 of Procedure 1.3.7G, Revision 9, "Work Implementation," requires that the
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Operations Support Team ensure that the craft assigned to perform the Job Investigation are briefed on the limits of the Job Investigation at hand and that the craft should investigate the
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problem described on the Job Investigation Sheet. ~
Contrary to the above, on March 27, 1996, craft performing investigative troubleshooting in accordance with Job Investigation Work Sheet DIC: 1008.5 worked outside the defined scope of the plan when they performed work on the "A" channel of the Average Power Range Monitor. Job Investigation Work Sheet DIC: 1008.5 directed work to be performed solely upon the "D" channel of the Average Power Range Monitor. The investigative troubleshooting performed on the "A" channel was not preplanned, documented, briefed, nor properly authorized.
This is a Severity Level IV violation (Supplement I) 50-397/9601-01 ~
0 NRC INSPECTION REPORT 96-01, RESPONSE TO NOTICE OF VIOLATION Attachment A Page 2 of 4 R P NET VI LATI N The Supply System denies this violation.
Technical Specification 6,8.1,a requires that written procedures be established, implemented, and maintained covering the activities of applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
V Appendix A to Regulatory Guide (RG) 1.33 Revision 2, clarifies the requirements for written procedures for safety related activities by stating:
Maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.
Skills normally possessed by qualified maintenance personnel may not require detailed step-by-step delineation in a procedure. The following types of activities are among those that may not require detailed step-by-step written procedures ...
(2) Trouble-Shooting Electrical Circuits ...
The activity performed, trouble-shooting of electrical circuits, was controlled by procedures appropriate to the circumstances. Specifically, the plant was in Mode 4, Cold Shutdown, during which the Average Power Range Monitor (APRM) and Rod Block Monitor channels are not required to be operable per Technical Specifications 3.1.4.3, 3.2.2, 3.3.1, 3.3.6, or 3.3.7.5.
The activity was preplanned and controls were followed to ensure an adequate level of review and authorization.
The Instrumentation and Controls (1&C) technician performing the trouble-shooting and responsible system engineer overviewing the task were both trairied and experienced individuals.
Therefore, the Supply System concludes that the performance of investigative trouble-shooting on APRM "A" on March 27, 1996 was in accordance with the requirements of 10 CFR Part 50, Appendix B, Criterion V, Technical Specification 6.8.1.a, and Regulatory Guide 1.33. In addition, the activities were conducted in accordance with WNP-2 procedures.
The activities associated with obtaining oscilloscope readings on instruments other than APRM "D" were within the bounds of the PPM 1.3.7 series of work control procedures, and these procedural controls were appropriate to the circumstances. APRM "D" was declared inoperable after demonstrating a "noisy" and unstable output. A Work Request (WR) was generated. PPM 1.3.7C, section 5.2.3, provides for the use of a Job Investigation Sheet (JIS) to investigate the problem prior to dispositioning the WR. PPM 1.3.7D, section 5.5, notes that detailed planning for a Work Order Task should include a field walkdown, and that trouble-shooting should be
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NRC INSPECTION REPORT 96-01, RESPONSE TO NOTICE OF VIOLATION Attachment A Page 3 of 4 done if necessary. In this instance, baseline readings of power supply outputs from other APRMs were deemed necessary to understand whether maintenance on APRM "D" was required. The responsible system engineer requested that the Operational Support Team (OST)
Supervisor provide I&C technician support for obtaining output readings on the APRM power supplies. The OST Supervisor briefed the technician on the general aspects of the assignment, as required by PPM 1.3,7G, section 4.3. The defined activity was understood by the I&C technician, the system engineer, and the licensed Control Room Supervisor (CRS). A half-scram resulted when test leads were mispositioned while taking readings on APRM "A." The lead reversal error could not have been prevented by additional work instructions as correct lead placement is within the skill level of the technician.
The Notice of Violation (NOV) states that the craft performing investigative trouble-shooting in accordance with the JIS were outside the defined scope of the plan by working on the "A" channel of the APRM. No corrective maintenance was performed on APRM "A." The required power supply output readings were taken off of jacks located on the panel fronts and installed for activities of this nature. Barring the personnel error which occurred, investigative readings taken on channel "A" were non-intrusive. PPM 1.3.7G, section 4.3, directs the craft to investigate the problem described in the JIS. Therefore, this activity is within the scope of the JIS and appropriate to support the decision making process for corrective maintenance on APRM ItD II The NOV states that troubleshooting on APRM "A" was not preplanned, documented, briefed, or authorized. The system engineer planned the work with the I&C technician and briefed and received authorization from the CRS. Detailed step-by-step procedures would be excessive in this situation where attaching oscilloscope leads to a panel front connection is a skill possessed by the technician.
The Inspection Report states that the violation has been issued due to "similar recent events thaving] occurred which exemplify a repeated loss of control over safety-related work activities due to procedural nonadherences..." The Supply System does not agree that the half-scram resulted from a loss of control over safety-related work activities due to procedural non-adherence. The half-scram resulted from a personnel error (i.e. reversing the leads). Obtaining readings from the panel front of the APRMs was a planned event between the system engineer and I&C technician, with briefings conducted with the CRS, and with authorization from the CRS. Additional conservatism might have been gained by placing APRM "A" in "bypass" prior to taking readings. Not having APRM "A" in bypass while obtaining readings was acknowledged as a minimal risk due to the nature of the trouble-shootirig and the plant shutdown conditions. The APRMs are not required to be operable in Mode 4.
As noted by the NRC, this event had minor safety consequences. Although, the activity was within the bounds of the PPM 1.3.7 series of procedures, the procedures do not clearly differentiate between investigation and trouble-shooting. The extent the JIS process can be used to perform investigations is not clearly delineated. The procedures will be clarified.
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NRC INSPECTION REPORT 96-01, RESPONSE TO NOTICE OF VIOLATION Attachment A
'Page 4 of 4 The Supply System does not agree that the two previous events referenced in the Inspection Report support aggregation to this NOV. The Inspection Report references the previous similar events as Problem Evaluation Requests (PERs) 296-0222 and 296-0125. PER 296-0222 addresses the half-scram event cited by this NOV. PER 296-0125, though acknowledging other weaknesses in the PPM 1.3.7 series of procedures, primarily addressed emergency maintenance and post-maintenance and operability testing issues, and not investigative trouble-shooting. It is our understanding that the PER 296-0125 issue will be cited separately as an NOV addressing Supply System work practices.
RRE TIVE TEP TAKEN AND R LT A HIEVED Although no violation of requirements occurred, the following corrective actions were taken for the event.
The consequences of this event were reviewed with the CRS and the system engineer regarding the need'for conservative decision making,
- 2. The I&C technician was counseled on the need for self-checking to prevent incidences such as this test lead reversal error.
RRE TIVE TEP T BE TAKEN As an enhancement, the PPM 1.3.7 series of procedures will be revised to clarify troubleshooting guidance and restrictions, and to identify the applicability of PPM 1.3.42, "Troubleshooting Plant Systems and Equipment."