ML20204C305

Forwards Response to Notice of Violation from Insp Rept 50-397/86-25 Forwarded by .Corrective Actions: Current Window Will Be Replaced w/fire-rated Window.Validity of Item B of Violation Denied

ML20204C305
Person / Time
Site:	Columbia
Issue date:	01/28/1987
From:	Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20204C245	List: ML20204C240 ML20204C305
References
NUDOCS 8703250270
Download: ML20204C305 (4)

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WASHINGTON PUBLIC POWER SUPPIjpYSTEM W// 7 P.O. Box 968

• 3000 George \\'ashington \\'ay

• Richland, \\'ashYr tof'9g5

1. 6/&/pfgg Qocket No. 50-397 January 28, 1987 Mr. J.B. Martin, Regional Administrator U.S. Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596

Subject:

NUCLEAR PLANT N0. 2 LICENSE N0. NPF-21 NRC INSPECTION REPORT 86-25 The Washington Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated December 29, 1986. Our reply pursuant to the provisions of Section 2.201, Title 10, Code of Federal Regulations, consists of this letter and Appendix A.

In Appendix A, an explanation of our position regarding the validity of the violation is provided.

Should you have any questions regarding our response, please do not hesitate to contact me.

Very truly yours, G.C. S rensen Manager, Regulatory Programs GCS:mgm Enclosure cc: Mr. R.T. Dodds, NRC-Site 901 A Mr. J.0. Bradfute - NRR ra 2;oy;;ggujp .

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Appandix.A O ,

Page 1 of 3 APPENDIX A As a result of the' inspection conducted on' July;14-18, August 5-29 and October 22-24, 1986, and in accordance with the " General Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the following violation was identified:

Condition No.14 of Facility Operating License No. NPF-21 requires the licensee to maintain in affect all provisions of the approved fire protection program for the WNP-2-facility.

As part.of the approved fire protection program, the licensee's Final Safety Analysis Report (FSAR) requires responsibility for implementation of the program be assigned to designated individuals and administrative procedures.

Licensee procedures 1.3.10 and EI 2.40 require the licensee's fire protection staff to review design changes.affecting fire protection, to review hazardous work activities, and to investigate actual fires.

Contrary to the above, since the ' facility was licensed in 1984, the licensee failed to follow procedures in accordance with the stated requirements in that:

a. Licensee fire protection staff had not perfonned reviews of certain plant design change packages affecting fire protection as set forth in paragraph

-5.A of Inspection Report 50-397/86-25.

b. Licensee fire protection staff had not performed reviews of welding and cutting activities as set forth in paragraph 5.B(1) of Inspection Report 50-397/86-25,

c. Licensee fire protection staff had not investigated and maintained records of actual fires that occurred as set forth in paragraph 5.B(2) of Inspec-tion Report 50-397/86-25.

This is considered a Severity Level IV Violation (Supplement 1.D).

Validity of Violation

a. The Supply System acknowledges the validity of this part of the violation in that reviews of certain plant design change packages were not performed as required by Engineering procedures.

b. The Supply ' System does not acknowledge the validity of this part of the v_iol ation. As required by Section 1.3.10.5.E of Plant Procedure 1.3.10,

" Fire Protection Program," the Industrial Safet Group reviews Maintenance Work Requests on (MWRs) y and a random Fire Items basis. Protection reviewed include work actions for preplanning and proper permit usage.

g p 2-

-. App ndix A Page 2 of 3 In addition, these items are also reviewed as part of the monthly inspection program, and then checked in the Plant. Although the Supply System does not acknowledge the validity of this part of the violation, it is recognized that the process of reviewing welding and cutting activities -needs to be strengthened; therefore, the procedure will be revised accordingly,

c. - The Supply System acknowledges the validity of this part of the violation.

Corrective Steps Taken/Results Achieved

a. Nonconfomance Report (NCR) 286-0394 was written on September 15, 1986.

The NCR documented the problem of modifying a window in the Shift Manager's Office without an approved design package (reference Plant Modification Record 02-86-0343-0).

Design Change Package (DCP) 85-0115-08, which addresses the installation of an alam system for the fire protection sprinkler system in the Rad-waste System Truck Bay area, has been reviewed and approved by the

-Industrial Safety and Fire Protection Group.

All other design changes identified in this violation are in the process of being reviewed by the Industrial Safety and Fire Protection Group. It is anticipated that the review will be completed by March 2,1987.

Engineering Instruction 2.40, " Instructions for Special Design Review,"

has been revised to ensure that all fire protection-related DCPs and Basic Design Changes (BDCs) are reviewed and approved by Industrial Safety and Fire Protection personnel,

b. Plant Procedure 1.3.10 is currently being modified to strengthen the welding and cutting activities review process (see " Corrective Action to be Taken", item b).

c. An agreement between Plant Technical, Plant Operations and Industrial Safety and Fire Protection personnel has been established with regard to what constitutes a fire in tems of an investigation standpoint.

Regarding other actions performed as related to this violation, it should be noted that the Supply System is currently in the process of reevaluating the Fire Protection Program requirements and methods to ensure compliance. A fomal report is expected to be submitted to NRC, Region V, management by February 27,1987. (Reference Supply System letter G02-87-001:G.C. Sorensen to J.B. Martin: Dated 1/2/87.)

Corrective Action to be Taken

a. A DCP is being prepared to replace the current window with a special fire-rated window and perfom the modifications associated with Plant Modification Record 02-86-0343-0. The DCP will be reviewed and approved by the Industrial Safety and Fire Protection Group.

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• Appendix A

, Page 3 of 3 Plant Procedure 1.3.10 is currently being revised to ensure that all DCPs and BDCs are reviewed, by Industrial Safety and Fire Protection, for fire protection program impact.

b. Plant-Procedure.-l.3.10 is currently being revised to ensure that reviews

~o f welding and cutting activities are adequately perfomed. Specifically, the Plant Maintenance Manager will be. responsible for taking followup action to assure ~ closeout of " Transient Combustibles Pemits": and -

" Cutting-Welding-Grinding Pemits" which have exceeded the specified time limit. The Industrial Safety and Fire Protection Group will be required to audit MWRs, on a random basis, to detemine if adequate preplanning for impaiments, hazards work, etc., have_ been included in the work instructions..

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The revision-in process- also establishes a 'new position of " Fire Marshall." -Responsibilities of the Fire Marshall will include:

o Perfoming periodic reviews of welding and cutting activities.

e- Stopping any work which does not meet fire protection requirements.

c. Plant Procedure 1.3.10 is currently being revised to ensure that fires are promptly investigated and reported. A fire is now defined as "any instance'of destructive and uncontrolled burning; including explosion of combustible solids, liquids or gases.

The Shift Support Supervisor will be responsible for notifying Industrial

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Safety and Fire Protection personnel of all fires, explosions or related incidents, including unplanned fire protection impaiments. The Industrial Safety and Fire Protection Group will be responsible for investigating fires, explosions or malfunctioning fire protection equipment to detemine cause.

Date of Full Compliance

a. The window in the Shift Manager's Office will be replaced with a special fire-rated window by January -1,1988. (This is due to the long lead time required to procure such a window.)

. Plant Procedure 1.3.10 will be revised by April 1,1987.

b. Corrective action will be completed by April 1,1987.

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c. Corrective action will be completed by April 1,1987.