ML17292A621

Responds to NRC 961107 Ltr Re Violations Noted in Insp Rept 50-397/96-16.Corrective Actions:Asd Testing Stopped & site- Wide Timeout for All Employees Conducted

ML17292A621
Person / Time
Site:	Columbia
Issue date:	12/06/1996
From:	Bemis P WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GO2-96-237, NUDOCS 9612130247
Download: ML17292A621 (9)

Text

CATEGORY 1 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION-'NBR:9612130247 DOC.DATE: 96/12/06 NOTARIZED: NO DOCKET ¹ FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION BEMIS,P.R. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 961107 ltr re violations noted in insp rept 50-397/96-16.Corrective actions:Full compliance was achieved when shift manager completed shift briefing & ended possible C distraction that activity could have created.

DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:

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

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL 0

PD4-2 PD 1 1 COLBURN,T 1 1 INTERNAL: ACRS 2 2 AEOD/SPD/RAB 1 1 AEO LE

/~

CENTER 1

1 1

1 DEDRO NRR/DISP/PIPB 1

1 1

1 RR/DR'CH/HNFB 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 XTERNAL: LITCO BRYCE,J H 1 1 NOAC 1 1 D NRC PDR 1 1 C

U N

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN 5D-5(EXT. I5-2083) TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL 19

WASHINGTO'8 PUBLIC POWER SUPPLY SYSTEM 1 PO. Box 968 ~ 3000 George IV<rshingron iV<ty ~ Richhnt<t, t<<<<tshington 99352-0968 ~ (509) 372-5000 December 6, 1996 G02-96-237 Docket No. 50-397 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:

Subject:

WNP-2, OPERATING LICENSE NPI'-21, NRC INSPECTION REPORT 96-16, RESPONSE TO NOTICE OF VIOLATION

References:

1) Letter, dated November 7, 1996, KE Brockman (NRC) to JV Parrish (SS), "NRC Inspection Report 50-397/96-16 and Notice of Violation"

2) Letter, GO2-96-216, dated November 1, 1996, RL Webring (SS) to NRC, "NRC Inspection Report 96-16, Additional Information"

3) Letter, GO2-96-208, dated October 28, 1996, PR Bemis (SS) to NRC, "NRC Inspection Report 96-16, Amended Response to Notice of Violation"

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

5) Letter, dated September 12, 1996, KE Brockman (NRC) to JV Parrish (SS), "NRC Inspection Report 50-397/96-16 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.

9bi2i30247 PDR ADOCK 0 5000397 8

Page 2 NRC INSPECTION REPORT 96-16, RESPONSE TO NOTICE OF VIOLATION Should you have any questions or desire additional information regarding this matter, please call me or Ms. Lourdes Fernandez at (509) 377-4147.

Respectfully, P. R. Bemis Vice President, Nuclear Operations Mail Drop PE23 Attachment LJ Callan - NRC RIV KE Perkins, Jr. - NRC RIV, Walnut Creek Field Office NS Reynolds - Winston Ec Strawn TG Colburn - NRR DL Williams - BPA/399 NRC Sr. Resident Inspector - 927N

NRC INSPECTION REPORT 96-16, RESPONSE TO NOTICE OF VIOLATION Attachment Page 1 of 4 VIOLATIONA Res atement of Violation A WNP-2 Technical Specification 6.8.l.a states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, dated February 1978.

Appendix A of Regulatory Guide 1.33, Revision 2, lists activities that should be covered by written procedures, including, "Administrative procedures for log entries and record retention, General Plant Operating Procedures, and Startup."

Procedure PPM 1.3.1, Conduct of Operations, Revision 26, step 4.6.2 (r) states, "Shift turnover of the control room staff is inappropriate when criticality is imminent."

Procedure PPM 1.3.1, Conduct of Operations, Revision 26, step 4.6.2b states, "The Reactor Operator at H13-P603 shall not be distracted by control room activities such as shift turnover, shift brief, or surveillances."

Contrary to the above, the inspectors identified that:

1. On July 27, 1996, shift turnover was conducted during the approach to criticality.

2. On July 27, 1996, the shift manager conducted the shift brief while the CRS returned to the at-the-controls area to oversee control rod withdrawals at the approach-to-criticality.

This is a Severity Level IV violation (Supplement I) (50-397/9616-03).

Res onse to Violation A The Supply System accepts the violation.

Reason for Violation A Regarding part 1 of Violation A, the oncoming and offgoing Control Room Supervisors (CRS) did conduct their turnover just prior to when criticality was imminent. Prior to the turnover the offgoing CRS observed the neutron instrumentation and the control rod pull sheet and judged that the reactor was not in the "approach-to-criticality" range. As the CRSs were completing their turnover the announcement was made that criticality was imminent. They immediately finished their turnover transferring the Reactivity Manager responsibilities, and both CRSs approached the control board to attend directly to reactivity maneuvers.

NRC INSPECTION REPORT 96-16, RESPOiNSE TO NOTICE OF VIOLATION Attachment Page 2 of 4 The Supply System believes that the shift turnover activities were well planned, proper attention was given to approach-to-critical activities by control room personnel, and the roll of Reactivity Manager was attended to properly by the CRSs. However, we recognize that the phrase approach-to-critical is not well defined in our procedures. Accordingly, we have changed our conduct of operations procedure to better define this term to eliminate any possible confusion in the future regarding the meaning of this phrase.

Regarding part 2 of Violation A, the Shift Manager did conduct a shift briefing during approach-to-critical activities. Prior to the oncoming shift arriving, the offgoing control room personnel discussed the plan for conducting the various turnovers. It was decided that the CRSs could complete their turnover prior to approach-to-criticality, and since the Control Room Operator (CRO) and Shift Engineer were holding over and had no need to participate in the shift briefing the Shift Manager could conduct the shift briefing while the CRS, CRO and Shift Engineer attended to the approach to criticality.

orrective Ac i ns Taken and Re ults Achieved Reference 2 provides a comprehensive list of the corrective actions taken as a result of our investigation into the three reactivity management issues addressed in Reference 5 and discussed at the recent pre-decisional enforcement conference. The corrective actions specifically applicable to this violation which have been completed are items 5, 13, 15 and 25.

rrective e s That Will Be Taken o Avoid Further Viola ions Reference 2 provides a comprehensive list of the corrective actions taken as a result of our investigation into the three reactivity management issues addressed in Reference 5 and discussed at the recent pre-decisional enforcement conference. The corrective actions specifically applicable to this violation which are yet to be completed are items 27 and 28.

Date of Full om liance Full compliance was achieved when the Shift Manager completed the shift briefing and ended the possible distraction that activity could have created.

NRC INSPECTION REPORT 96-16, RESPONSE TO NOTICE OF VIOLATION Attachment Page 3 of 4 VI LATI N 8 Restaemen of Viol tion 8 Criterion V of 10 CFR 50, Appendix 8, states, in part, "Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances... These instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."

WNP-2 Technical Specification 6.8.l.a states in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, dated February 1978.

Appendix A of Regulatory Guide 1.33, Revision 2, recommends procedures covering the reactor recirculation system.

Contrary to the above, Procedure PPM 8.3.339, "Test Instructions - Reactor Recirculation (RRC) Adjustable Speed Drive (ASD) and Reactor Digital Feedwater (DFW) Control Power Ascension Test Program," Revision 1, was inadequate. The procedure did not contain sufficient instructions to preclude the manipulation of facility controls as expressly prohibited by 10 CFR 50.54(i), in that, the reactor recirculation control system was operated by a non-licensed individual on July 20, 1996.

This is a Severity Level IV violation (Supplement 1) (50-397/9616-05).

Res onse Violation 8 The Supply System accepts the violation.

Reason for Violation 8 The Supply System failed to properly control the activities of a contract test engineer during ASD testing. This resulted in the engineer's inadvertent changing of recirculation pump speed.

A discussion of this event, the precautions taken prior to the event, and a summary of the corrective actions taken immediately after the event were provided to the staff during the recent pre-decisional enforcement conference.

NRC INSPECTION REPORT 96-16, RESPONSE TO NOTICE OF VIOLATION Attachment Page 4 of 4 orrective Actions Taken and Results Achieved The ASD testing was stopped and a site-wide Timeout for all employees was conducted.

Reference 2 provides summary of the Timeout and provides a comprehensive list of the corrective actions taken as a result of our investigation into the three reactivity management issues addressed in Reference 5 and discussed at the recent pre-decisional enforcement conference. The corrective actions specifically applicable to this violation which have been completed are items 5, 18, 22, 23 and 24.

orrective Ste s That Will Be Taken to Av id Further Violation All corrective actions have been completed.

Date of Full Com liance Full compliance was achieved when the ASD test procedure was revised to ensure only licensed personnel take actions that could impact reactor power.