ML17292A400

Responds to RAI Re Insp Rept 50-397/96-01.Plant Procedure PPM 1.3.42 Revised to Clarify Trouble Shooting Guidance & Restrictions

ML17292A400
Person / Time
Site:	Columbia
Issue date:	08/02/1996
From:	Bemis P WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GO2-96-154, NUDOCS 9608130296
Download: ML17292A400 (5)

Text

CATEGORY j REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9608130296 FACIL:50-397 DOC.DATE: 96/08/02 NOTARIZED: NO Nuclear Project, Unit 2, Washington Public DOCKET I WPPSS Powe 05000397

~ AUTH. NAME AUTHOR AFFILIATION EMIS,P.R.

~ ~ Washington Public Power Supply System RECIP.NAME

~ RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to RAI re insp.Repts 50-397/96-01.Plant procedure PPM 1.3.42 revised to clarify trouble shooting guidance &

restrictions.

DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:

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

RECIPIENT COPIES RECIPIENT COPIES G 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 FILE CENTE 1 1 NRR/DISP/PIPB 1 1 HHFB 1 1 NRR/DRPM/PECB 1 1 NRR/DRPM/PERB 1 1 NUDOCS-ABSTRACT 1 1 OE DIR 1 1 OGC/HDS3 1 1 RGN4 FILE 01 1 1 ERNAL: LITCO BRYCEiJ H 1 1 NOAC 1 1 NRC PDR 1 1 D N

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN 5D-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

WASHINGTON PUBLIC POWER SUPPLY SYSTEM PO. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 993SZ-0968 ~ (S09) 372-5000 August 2, 1996 G02-96-154 Docket No. 50-397 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:

Subject:

NRC INSPECTION REPORT 96-01, RESPONSE TO REQUEST FOR ADDITIONALINFORMATION

References:

1) Letter GI2-96-118 dated May 1, 1996, TP Gwynn (NRC) to JV Parrish (SS), "NRC Inspection Report 50-397/96-01 and Notice of Violation"

2) Letter GO2-96-113 dated May 31, 1996, PR Bemis (SS) to NRC, "WNP-2, Operating License NPF-21, NRC Inspection Report 96-01, Response to Notice of Violation"

3) Letter GI2-96-175 dated July 2, 1996, SJ Collins (NRC) to JV Parrish (SS), "NRC Inspection Report 50-397/96-01 Response to Notice of Violation" As requested by Reference 3, enclosed as an attachment to this letter is a further description of the corrective actions being taken to strengthen Supply System work control and troubleshooting processes. Additional comments are also provided in the a t~ ment regarding the violation noted in Reference 1.

Should you have any questions or desire additional information regarding this matter, please call me or Ms. L. C. Fernandez at (509) 377-4147.

. R. Bemis (Mail Drop E20) ice President, Nuclear Operations Attachment cc: LJ Callan - NRC RIV TG Colburn - NRR KE Perkins, Jr. - NRC RIV, WCFO DL Williams - BPA/399

- NRC Sr. Resident Inspector - 927N e AAc.c. NS Reynolds Winston & Strawn 9608i30296 960802 PDR ADOCK 05000397 8 PDR

NRC INSPECTION REPORT 96-01, RESPONSE TO REQUEST FOR ADDITIONALINFORMATION Attachment Page 1 of 1 As noted in Reference 2, the Supply System is revising the PPM 1.3.7 series of work control procedures, and revising plant procedure PPM 1.3.42, "Troubleshooting Plant Systems and Equipment," to clarify troubleshooting guidance and restrictions. Additional details, though subject to change, of the planned revisions are as follows:

- PPM 1.3.7D, "Work Planning," is being revised to remove the allowance for troubleshooting and performance of corrective maintenance during a field walkdown and prior to detailed planning of a work order task.

- PPM 1,3.7G, "Work Implementation," is being revised to remove the allowance for job investigations, and to add a "precaution and limitation" to refer to PPM 1.3.42, "Troubleshooting Plant Systems and Equipment," for all troubleshooting activities.

- PPM 1.3.7G, "Work Implementation," is also being revised to redefine what work can be performed under mundane and minor work processes.

- PPM 1.3.42, "Troubleshooting Plant Systems and Equipment," is being revised to reference the PPM 1.3.7 series of procedures, to clearly state that troubleshooting determined to be low risk can be performed as minor maintenance, and to clearly state the limitations as to when low risk troubleshooting can be performed, such as only when equipment is de-energized, by-passed, or isolated.

These procedure changes will be completed by September 15, 1996.

With respect to NRC comments made in the enclosure to Reference 3, regarding the NRC's review of References 1 and 2, the following additional information is offered:

- The enclosure to Reference 3 stated that "Compensatory actions for Average Power Range Monitor A, such as bypassing it during this expanded scope investigation, were not considered."

As stated in Reference 2, these actions were considered. Not having APRM "A" in bypass while obtaining readings was acknowledged as a minimal risk due to the nature of the troubleshooting and the plant shutdown conditions. The system engineer and the Control Room Supervisor (CRS) discussed placing the equipment in bypass and determined that it was not necessary.

- Reference 3 provided a correction to Reference 1 to clarify that PERs 296-0043 and 296-0125 are examples of "similar events which exemplify a repeated loss of control over safety-related work activities due to procedural nonadherences,..."

It should be noted that both of these PERs address the same event, the discovery and repair of damaged linkage associated with DG2 outside/recirculation damper DMA-AD-21/2. The Supply System acknowledges that, although associated with the same event, the PERs document different aspects of the work control issue. Procedure enhancements have been made as a result of the DG2 damper event to strengthen work control processes.