ML17292A572

Responds to NRC 960912 Ltr Re Violations Noted in Insp Rept 50-397/96-16.Corrective Actions:Log Entry Corrected

ML17292A572
Person / Time
Site:	Columbia
Issue date:	10/28/1996
From:	Bemis P WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GO2-96-208, NUDOCS 9611050082
Download: ML17292A572 (5)

Text

4A.'j:8'GORE J.

(Ai . REGULATORY INFORMATION DISTRIBUTION SYSTEM (RZDS)

',]~ACCESSION NBR:9611050082 DOC.DATE: 96/10/28 NOTARIZED: NO DOCKET

'ACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 H.NAME AUTHOR AFFILIATION S,P.R. . Washington Public Power Supply System IP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 960912 ltr re violations noted in insp rept 50-397/96-16. CR log error was reviewed against criteria described in reference 3 for classification as a minor violation.

DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:

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

G RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD4-2 PD COLBURN,T INTERNAL: ACRS AEOD/SPD/RAB AEOD/~'.C DEDRO

+FILE DENTED NRR/DISP/PIPB NRR/DRCH/HHFB NRR/DRPM/PECB NRR/DRPM/PERB NUDOCS-ABSTRACT OE DIR OGC/HDS3 RGN4 FILE Ol EX'AL: LITCO BRYCE,J H NOAC D

NRC PDR E

ml NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL

WASHINGTON PUBLIC POWER SUPPLY SYSTEM PO. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 99352-0968 ~ (509) 372-5000 October 28, 1996 G02-96-208 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 50-397/96-16, AMENDED RESPONSE TO NOTICE OF VIOLATION

References:

1. Letter GO2-96-197, dated October 14, 1996, PR Bemis (SS) to NRC, "NRC Inspection Report 96-16, Response to Notice of Violation"

2. Letter, dated September 12, 1996, KE Brockman (NRC) to JV Parrish (SS),

"NRC Inspection Report 50-397/96-16 and Notice of Violation"

3. NRC, Inspection Manual Cha'pter 0610, "Inspection Reports," dated February 2, 1996

4. USNRC, NUREG-1600, "General Statement of Policy and Procedures for NRC Enforcement Actions," July, 1995 By Reference 1, the Supply System recently submitted a response to Inspection Report 96-16 (Reference 2). In this response, we denied Violation 50-397/9616-01. We have reconsidered this denial and accept this violation.

The Supply System believes that the control room log error is below the level of significance of a Severity Level IV violation and constitutes a minor violation consistent with the definition provided in Reference 3. Accordingly, as the minor violation has been documented in NRC Inspection Report 50-397/96-16, the Supply System requests reclassification of this violation as a Non-Cited Violation (NCV), consistent with Section IV of the NRC Enforcement Policy (Reference 4).

Specifically, the control room log error was reviewed against the criteria described in Reference 3 for classification as a minor violation as follows:

~ The error did not have any actual impact on safety. The information was not used in a decision making capacity and could therefore not have misled the operators in the approach to critical evolution. The information was correctly logged into the implemented plant startup procedure (PPM 3.1.2) which constitutes a permanent plant record.

96ii0500S2 96i028 05000397 PDR ADQCK 8 PDR

Page 2 NRC INSPECTION REPORT 96-16, AMENDED RESPONSE TO NOTICE OF VIOLATION

~ The error does not suggest a programmatic problem that could have a safety or regulatory impact. As discussed during our recent predecisional enforcement conference, the Supply System believes that no programmatic disregard for reactivity management exists at WNP-

2. Further, the error was isolated as is evidenced by the correct entry in PPM 3.1.2, and does not constitute an adverse trend in control room log maintenance.

~ The error could not be viewed as a possible precursor to a significant event. The correct count rate information was available from other sources, including the control room chart recorders, and could have been retrieved from the plant computer for a period of 30 days.

~ If left uncorrected, the error would not have become a more significant concern. As stated, the error was not used in a decision making capacity and was correctly entered into the implemented startup procedure. The Supply System does recognize, however, that the control room log constitutes a legal record. Reconstruction of any events would have been possible from the correct information in the implemented startup procedure.

~ There are no associated circumstances that add regulatory concern to this violation. There was no willfulness to log incorrect information. The Supply System complied with the requirement by correcting the log entry. Management involvement ensured individuals involved were counselled concerning the importance of self-checking when entering and reviewing data in the control room log.

As previously described in Reference 1, the reason for the violation is a personnel error. The corrective steps taken include correcting the log entry and counseling the individuals involved.

'he date full compliance was achieved was August 15, 1996 when the incorrect log entry was corrected.

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

ectf 1 P.. ei President, Nuclear Operations

'ice Mail Drop PE23 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