ML17291A348

Responds to NRC 940722 Ltr Re Violation Noted in Insp Rept 50-397/94-15.Corrective Action:Plant Procedures Manual (PPM) 1.3.12 & PPM 1.3.12A Revised to Improve Implementation of Guidance in GL 91-18

ML17291A348
Person / Time
Site:	Columbia
Issue date:	08/19/1994
From:	Parrish J WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-91-18, GO2-94-198, NUDOCS 9408310140
Download: ML17291A348 (16)

See also: IR 05000397/1994015

Text

I'I.'Y'(ACCELERATED

RIDS PROCESSING)

REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)ACCESSION NBR:9408310140

DOC.DATE: 94/08/19 NOTARIZED:

YES-FACIL:50-397

WPPSS Nuclear Project, Unit 2, Washington

Public Powe AUTH.NAME AUTHOR AFFILIATION

PARRISH,J.V.

Washington

Public Power Supply System RECIP.NAME

RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)SUBJECT: Responds to NRC 940722 ltr re violation noted in insp rept 50-397/94-15.Corrective

action:provided

adequate training better assure that operability

assessments

will be documented

as required by procedures.

DISTRIBUTION

CODE: IE01D COPIES RECEIVED:LTR

ENCL SIZE TITLE: General (50 Dkt)-Insp Rept/Notice

of Violation Response NOTES DOCKET 05000397 RECIPIENT ID CODE/NAME PD4-2 PD INTERNAL: ACRS AEOD/SPD/RAB

AEOD/TTC NRR/DORS/OEAB

NRR/PMAS/IRCB-E

OE DIR~REG-EI=LB 02 RGN4 FILE 01 EXTERNAL: EG&G/BRYCE,J.H.

NRC PDR COPIES LTTR ENCL 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT, ID CODE/NAME CLIFFORD,J

AEOD/DEIB AEOD/SPD/RRAB

DEDRO NRR/DRCH/HHFB

NUDOCS-ABSTRACT

OGC/HDS3 RES/HFB NOAC COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE iVASTE!CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT.504-2083)TO ELIKII NATE YOUR NAME FROM DISTRIBUTION

LISTS I OR DOCUMENTS YOU DON'T NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 21 ENCL 21

4 WASH liVGTOiV PUBLIC POWER SUPPLY SYSTEM P.O.Box 968~3000 George i Vashiagtott

1Vap~Riehlaad, 1 Uashiagtott

99352-096S

~(509)372-5000 August 19, 1994 G02-94-198

Docket No.50-397 U.S.Nuclear Regulatory

Commission

Attn: Document Control Desk Mail Station Pl-37 Washington, D.C.20555 Gentlemen:

Subject: WNP-2, OPERATING LICENSE NO.NPF-21 NRC INSPECTION

REPORT 94-15 REPLY TO A NOTICE OF VIOLATION References:

1), Letter, dated July.22, 1994, AB Beach (NRC)to JV Parrish (SS),"Notice of Violation (NRC Inspection

Report 50-397/94-15)" 2)Letter, dated July 29, 1994, AB Beach (NRC)to JV Parrish (SS),"NRC Inspection

Report 50-397/94-19 (Notice of Violation)"'he Washington

Public Power Supply System (Supply System)hereby replies to the Notice of Violation contained in your letter dated July 22, 1994 (reference

1).Our reply, pursuant to the provisions

of Section 2.201, Title 10, Code of Federal Regulations, consists of this letter and Appendix A (attached).

As requested in reference 1 the Supply System provides the following information

regarding the actions taken to ensure prompt and thorough evaluation

and correction

of potential safety significant

deficiencies:

Plant Procedures

Manual (PPM)1,3.12,"Problem Evaluation

Request (PER)" and.PPM 1.3.12A,"Processing

of Problem Evaluation

Requests (PER)" were revised to improve implementation

of the guidance in Generic Letter, 91-18~The revisions included specifically

addressing

component as w'ell as system operability, adding an"Operable but degraded" category for operability

evaluations, and emphasizing

the need to continually

evaluate operability.

Page 2 WNP-2, OPERATING LICENSE NO.NPF-21 NRC INSPECTION

REPORT 94-15, REPLY TO A NOTICE OF VIOLATION Beginning April 29, 1994, PERs have been reviewed on work day mornings by a cross-disciplinary

team to identify potential safety significant

deficiencies.

This team also reviews plant and industry experience

related to the PER.The Technical Services Division Manager issued a memorandum

to Technical Services personnel on June 7,'994, emphasizing

management

expectations

concerning

the investigation, communication, and correction

of plant problems.Meetings were held with the Engineering

and Technical Services staffs and other plant personnel to emphasize management

expectations

concerning

treatment of operability

issues.Training was provided to Engineering

Directorate

and Technical Services'ivision

personnel on operability.

assessment

as part of their continuing

training program.This training covered the guidance in Generic Letter 91-18, associated

WNP-2 procedural

requirements, and the need to continually

assess operability.

Based on these actions, the Supply System believes performance

in promptly and thoroughly

evaluating

and correcting

potential safety significant

deficiencies

has been enhanced.Two recent examples are: On July 2, 1994, a PER was written to investigate

and correct a single Agastat relay failure identified

during surveillance

testing.A review of plant experience

identified

a potential generic issue with failure of continuously

energized safety related Agastat relays.A second PER was written on July 15, 1994, to document and evaluate the generic impact.This evaluation

included a 10 CFR 21 evaluation

and a documented

operability

assessment

showing the relays would remain operable for the time required to replace them.As a result of these actions, 52 affected relays were replaced by July 19.Due to indica'.ions

during the last op rating cycle of moisture intrusion into a containment

electrical

penetration

module containing

non-safety

related rod position indication

system cables, the Supply System examined other penetrations

to determine if a generic problem existed, The investigators

found a problem with Westinghouse

containment

electrical

penetration

modules using Scotchguard

strain relief material.The Supply System subsequently

issued a 10 CFR 21 report on this problem.An operability

assessment

was documented

and updated as new information

became available.

Prior to,startup, 6 safety related and 3 non-safety

related modules were replaced, and safety related functions from 3 modules were rerouted.A recent NRC inspection

report (reference

2)noted that this problem was resolved in a technically

sound manner.

0

Page 3 WNP-2, OPERATING LICENSE NO.NPF-21 NRC INSPECTION

REPORT 94-15, REPLY TO A NOTICE OF VIOLATION If you have any questions or desire additional

information

regarding this matter please contact me or D.A.Swank at (509)377-4563.'incerely

J.Parrish (Mail Drop 1023)Assistant Managing Director, Operations

BRH/bk Attachments

CC: LJ Callan-NRC RIV KE Perkins, Jr.-NRC RIV, Walnut Creek Field Office NS Reynolds-Winston&Strawn JW Clifford-NRC DL Williams-BPA/399 NRC Sr.Resident Inspector-927N

STATE OF WASHINGTON

))COUNTY OF BENTON)Subject: Reply to Notice of Violation 94-15.I.J.V.PARRISH, being duly sworn, subscribe to and say that I am the Assistant Managing Director, Operations

for the WASHINGTON

PUBLIC POWER SUPPLY SYSTEM, the applicant herein;that I have the full authority to execute this oath;that I have reviewed the foregoing;

and that to the best of my knowledge, information, and belief the statements

made in it are true.DATE , 1994.V.'Parrish, Assistant Managing Director erations On this date personally

appeared before me J.V.PARRISH, to me known to be the individual

who executed the foregoing instrument, and acknowledged

that he signed the same as his free act and deed for the uses and purposes herein mentioned.

t GIVEN under my hand and seal this~day of c.-<1994.Notary Public in and for the STATE OF WASHINGTON

\Residing g/My Commission

Expires

0

V~iola ion Appendix A 10 CFR Part 50, Appendix B, Criterion V, requires that activities

affecting quality shall be prescribed

by documented

procedures

and shall be accomplished

in accordance

with those procedures.

WNP-2 Plant Procedures

Manual 1.3.12B, Revision 0, paragraph 4.2.3a, states,"For degraded conditions

impacting equipment operability

identified

by physical evidence at the Plant, the Prompt Operability

Assessment

should be completed and documented

within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of when the physical evidence was identified." Contrary to the above, the licensee failed to complete or document a Prompt Operability

Assessment

following its identification

of significantly

degraded Buna-N diaphragms

in scram solenoid pilot valves for Control Rods 02-19 and 14-55, a condition impacting equipment operability, on February 9 and 17, 1994, respectively.

This is a Severity Level IV violation (Supplement

I).Re onse to Violation The Supply System accepts this violation.

1.Reason for the violation The reason for the violation was a judgement error by the engineer responsible

for performing

the Prompt Operability

Assessments.

The individual

components

did not require operability

assessments

since they had been previously

removed from service;however, the potential generic implications

did require evaluation.

The engineer assessed the operability

of the Scram Solenoid Pilot Valves (SSPVs)based on scram time history, the lack of additional

leaking SSPVs during the January 31 half scram that identified

the Control Rod 02-19 SSPV problem, and frequent discussions

with General Electric Nuclear Energy and his counterparts

at other boiling water reactors.The engineer's

conclusion

that the remaining SSPVs were operable was reasonable

given the information

available;

however, these evaluations

should have been documented

as Prompt Operability

Assessments.

The engineer's

judgement error resulted from inadequate

training on operability

requirements

and the requirements

of Plant Procedures

Manual (PPM)1.3.12B.

Appendix A Page 2 of 3 2;Corrective

steps that have been taken and the results achieved.After extensive consideration

by engineering

personnel and senior management, a Prompt Operability

Assessment

was completed on April 3, 1994.This assessment

was part of the Basis for Continued Operation performed following the March 26, 1994, failure of Control Rod 06-39 to scram.The engineer who was responsible

for performing

the operability

assessments

assisted in preparation

for the enforcement

conference

on this issue, and attended the June 30, 1994, meeting.As a result, the engineer understands

the importance

of strict procedural

adherence.

Meetings were held with the Engineering

and Technical Services staffs and other plant personnel to emphasize management

expectations

concerning

documentation

of operability

issues.PPM 1.3.12 was revised on April 27, 1994, with the following enhancements

regarding operability:

Specifically

addressed component as well as system operability

Added.'Operable

but degraded'ategory

for evaluation

Emphasized

the continual evaluation

of operability

Training was provided to Engineering

Directorate

and Technical Services Division personnel on operability

assessment

as part of their continuing

training program.This training included the documentation

requirements

associated

with the operability

assessment

process at WNP-2.These actions have enhanced performance

in documenting

operability

issues in accordance

with procedures.

Two recent examples are described in the cover.letter accompanying

this response.3.Corrective

steps that will be taken to avoid further violations.

The Supply System believes that the above actions, when taken together,'provide adequate training to better assure that operability

assessments

will be documented

as required by procedures.

No additional

corrective

actions are considered

necessary.

0

Appendix A Page 3 of 3 Date when full compliance

will be achieved.Full compliance

with respect to the matter identified

above was achieved on April 3, 1994, when a Prompt Operability

Assessment

was completed addressing

SSPV diaphragm degradation.

~'4~~~