ML17284A585

Responds to NRC 881006 Ltr Re Violations Noted in Insp Rept 50-397/88-33.Corrective Actions:On 881011,test Performed to Determine Dynamic Flow Control Characteriztics of Sample Rack REA-SR-37.Procedure Modified

ML17284A585
Person / Time
Site:	Columbia
Issue date:	11/04/1988
From:	Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
GO2-88-229, NUDOCS 8811100200
Download: ML17284A585 (13)

See also: IR 05000397/1988033

Text

WASHINGTON

PUBLIC POWER SUPPLY SYSTEM P.O.Box 968~3000 George Washington

Way~Richland, Washington

99352 G02-88-229

November 4, 1988 Docket No.50-397 U.S.Nuclear Regulatory

Commission

Attn: Document Control Desk Mail Station Pl-137 Mashington, D.C.20555 Gentlemen:

Subject: NUCLEAR PLANT NO.2 LICENSE NO.NPF-21 NRC INSPECTION

REPORT 88-33 RESPONSE TO NOTICE OF VIOLATION The Mashington

Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated October 6, 1988.Our reply, pursuant to the provisions

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

In Appendix A, the violation is addressed with an explanation

of our position regarding validity, corrective

action and date of full compliance.

Very truly yours, G.C.S'orensen, Manager Regulatory

Programs JDA/bk Attachments

cc: JB Martin-NRC RV NS Reynolds-BCP&R RB Samworth-NRC DL Williams-BPA NRC Site Inspector-901A g OCK pgppp3~7 PDR A+881 jp4 PDC+oI

Page 1 of 2 APPENDIX A During an NRC inspection

conducted on September 6-9, 1988, a violation of NRC requirements

was identified.

In accordance

with the"General Statement of Policy and Procedure for NRC Enforcement

Actions," 10 CFR Part 2, Appendix C, (1987), the violation is listed below: A.Technical Specification 3.3.7.12 states, in part: "3.3.7.12 The radioactive

gaseous effluent monitoring

instrumentation

channels shown in Table 3.3.7.12-1

shall be OPERABLE with their alarm/trip

setpoints set to ensure that the'limits of Specification

3.11.2.1 are not exceeded...." ,"b.With less than the minimum number of radioactive

gaseous effluent monitoring

instrumentation

channels OPERABLE, take the ACTION shown in Table 3.3.7.12-1." Table 3.3.7.12-1

requires ACTION 112 for less than one Main Plant Vent Release Monitor iodine or particulate

channel, and ACTION 113 for less than one Sampler Flow Rate Monitor channel.Table 3.3.7.12-1, Table Notations, states in part: "ACTION 112-With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 30 days provided that within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the channel has been declared inoperable

samples are continuously

collected with auxiliary sampling equipment as required in Table 4.11-2.ACTION 113-With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 30 days provided that the flow rate is estimated at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />."'ontrary to the above, from 6:19 p.m.PDT on September 7, 1988, to 4:48 a.m.PDT on September 8, 1988, the main plant vent release monitor was not operable and no effluent sampler flow rate estimations

were made nor continuous

sample collection

conducted, although effluent releases con-tinued via the main plant vent.This is a Severity Level IV Violation (Supplement

IV).

'1e

Page 2 of 2 Validit of Viol ation The Supply System'acknowledges

the validity of the violation in that procedural

requirements

were not followed when the Reactor Building HVAC System was secured and the Standby Gas Treatment (SGT)System star ted.The requirements

to declare Reactor Building Effluent Control Rack REA-SR-37 inoperable, and enter the associated

Technical Specification

Action Statement, were not'performed.

Sample Rack REA-SR-37 is the isokinetic

air flow control rack for effluent monitoring

of the main plant vent.Corrective

Ste s Taken/Results

Achieved On October ll, 1988 a test was performed to determine the dynamic flow control characteristics

of REA-SR-37 by equalizing

the differential

pressure across REA-FT-7 (Reactor Exhaust Air Stack Flow Rate Transmitter), simulating

decreasing

stack flow.The purpose of the test was to collect data to determine if the effluent monitoring

system could accurately

provide a representative

'ample during low flow conditions (less than 17,000 cfm).Results of the test indicated that the system will track.vent flows to below 2,000 cfm, and maintain isokinetic

sampling to below 4,000 cfm.Accordingly, the sample rack was operable during the event period and representative

samples of main plant vent effluents were being obtained.Corrective

Action to be Taken Further data collection

is planned during the next refueling outage, when actual Reactor Building flows will be in the range of 2,000 to 4,000 cfm, to provide an expanded data base for verification

of system operability.

.The results of the analysis will be used to determine if any additional

actions are required.II In the interim, applicable

procedures

will be modified to notify the Plant Chemistry Department

when the Reactor Building HVAC System is secured.The intent of this corrective

action is to have the technicians

monitor REA-SR-37 indications

every four hours during such conditions

to verify sampler flow.In addition, a caution sign will be posted on the control panel for the Reactor Building HVAC System as a reminder to notify Chemistry personnel when the system is secured.Date of Full Com liance Although the Supply System is currently in full compliance, interim corrective

actions (procedural

changes and caution sign)will be completed by December 16, 1988.Further analysis of REA-SR-37 flow control characteristics

will be completed by July 1, 1989.

'I I

AC CELERATZD DISTRIBUTION

DEMONSTRATION

SYSTEM R EGULATORY INFORMATION

DISTRIBUTION

SYSTEM (RIDS)CCESSION NBR:8811100200

DOC.DATE: 88/11/04 NOTARIZED:

NO DOCKET N FACIL:50-397

WPPSS Nuclear Project, Unit 2, Washington

Public Powe 05000397 AUTH.NAME.AUTHOR AFFILIATION

SORENSEN,G.C.

Washington

Public Power Supply System RECIP.NAME

RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)SUBJECT: Responds to NRC 881006 ltr re violations

noted in Insp'Rept 50-397/88-33.

DISTRIBUTION

CODE: IE06D COPIES RECEXVED:LTR

ENCL SIZE: TITLE: Environ 6 Radiological

(50 DKT)-Insp Rept/Notice

of Violation NOTES: R Respons I D RECIPIENT ID CODE/NAME PD5 LA SAMWORTH, R INTERNAL: ACRS NMSS/LLOB 5E4 NRR/DLPQ/PEB

11 NRR/DREP/EPB

10 NRR/PMAS/ILRB12

OGC/HDS2 RES RGN2/DRSS/EPRPB

TERNAL: LPDR NSIC COPIES LTTR ENCL 1 0 1 12 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1.1 1 1 1 RECIPIENT ID CODE/NAME PD5 PD AEOD/DSP NMSS/SGOB 4E4 NRR/DOEA/EAB

11 NRR/DREP/RPB

10 NUDOCS-ABSTRACT

RKHEh 02 RGN5 FILE 01 RGN4 MURRAY,B NRC PDR RESL MARTIN,D COPIES LTTR ENCL 1 1 1 1 1" i 1 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 S A D D R I NOSE'ZO ALLRIDS" RZCZPI/MS:

PLEASE HELP US TO REDUCE HASTE.'GKELCT

'IHE DOCUMWZ CONTROL DESK, ROCN P1-37 (EZZ.20079)TO EZZMZHATE YOUR SAME HKH DISTRIBUTION

LISTS MR DOCUMEMXS KRJ DGNiT NEED)TOTAL NUMBER OF COPIES REQUIRED: LTTR 25 ENCL 24 8 A

Cl

ti WASHINGTON

PUBLIC POWER SUPPLY SYSTEM P.O.Box 968~3000 George Washington

Way~Richland, Washington

99352 G02-88-229

November 4, 1988 Docket No.50-397 U.S.Nuclear Regulatory

Commission

Attn: Document Control Desk Mail Station Pl-137 Washington, D.C.20555 Gentlemen:

Subject: NUCLEAR PLANT NO.2 LICENSE NO.NPF-21 NRC INSPECTION

REPORT 88-33 RESPONSE TO NOTICE'OF VIOLATION The Washington

Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated October 6, 1988.Our reply, pursuant to the provisions

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

In Appendix A, the violation is addressed with an explanation

of our position regarding validity, corrective

action and date of full compliance.

Very truly yours, G.C.orensen, Manager Regulatory

Programs JDA/bk Attachments

cc: JB Martin-NRC RV NS Reynolds-BCP8R RB Samworth-NRC DL Williams-BPA NRC Site Inspector-901A PD~~00200 S~~L04 R ADOCK 0500035'7 PDC QoC Iii

0

Page 1 of 2 APPENDIX A During an NRC inspection

conducted on September 6-9, 1988, a violation of NRC requirements

was identified.

In accordance

with the"Gener al Statement of Policy and Procedure for NRC Enforcement

Actions," 10 CFR Part 2, Appendix C, (1987), the violation is listed below: A.Technical Specification 3.3.7.12 states, in part: "3.3.7.12 The radioactive

gaseous effluent monitoring

instrumentation

channels shown in Table 3.3.7.12-1 shall be OPERABLE with their alarm/trip

setpoints set to ensure that the limits of Specification

3.11.2.1 are not exceeded....""b.With less than the minimum number of radioactive

gaseous effluent monitoring

instrumentation

channels OPERABLE, take the ACTION shown in Table 3.3.7.12-1." Table 3.3.7.12-1

requires ACTION 112 for less than one Main Plant Vent Release Monitor iodine or particulate

channel, and ACTION 113 for less than one Sampler Flow Rate Monitor channel.Table 3.3.7.12-1, Table Notations, states in part: "ACTION 112-With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 30 days provided that within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the channel has been declared inoperable

samples are continuously

collected with auxiliary sampling equipment as required in Table 4.11-2.ACTION 113-With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 30 days provided that the flow rate is estimated at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />." Contrary to the above, from 6:19 p.m.PDT on September 7, 1988, to 4:48 a.m.PDT on September 8, 1988, the main plant vent release monitor was not operable and no effluent sampler flow rate estimations

were made nor continuous

sample collection

conducted, although effluent releases con-tinued via the main plant vent.This is a Severity Level IV Violation (Supplement

IV).

Page 2 of 2 Validit of Violation The Supply System acknowledges

the validity of the violation in that procedural

requirements

were not followed when the Reactor Building HVAC System was secured and the Standby Gas Treatment (SGT)System started.The requirements

to declare Reactor Building Effluent Control Rack REA-SR-37 inoperable, and enter the associated

Technical Specification

Action Statement, were not performed.

Sample Rack REA-SR-37 is the isokinetic

air flow control rack for effluent monitoring

of the main plant vent.Corrective

Ste s Taken/Results

Achieved On October 11, 1988 a test was performed to.determine the dynamic flow control characteristics

of REA-SR-37 by equalizing

the differential

pressure across REA-FT-7 (Reactor Exhaust Air Stack Flow Rate Transmitter), simulating

decreasing

stack flow.The purpose of the test was to collect data to determine if the effluent monitoring

system could acc'urately

provide a representative

sample during low flow conditions (less than 17,000 cfm).Results of the test indicated that the system wil,l track vent flows to below 2,000 cfm, and maintain isokinetic

sampling to below 4,000 cfm.Accordingly, the sample rack was operable during the event period and representative

samples of main plant vent effluents were being obtained.Corrective

Action to be Taken Further data collection

is planned during the next refueling outage, when actual Reactor Building flows will be in the range of 2,000 to 4,000 cfm, to provide an expanded data base for verification

of system operability.

The results of the analysis will be used to determine if any additional

actions are required.In the interim, applicable

procedures

will be modified to notify the Plant Chemistry Department

when the Reactor Building HVAC System is secured.The intent of this corrective

action is to have the technicians'onitor

REA-SR-37 indications

every four hours during such conditions

to verify sampler flow.In addition, a caution sign will be posted on the control panel for the Reactor Building HVAC System as a reminder to notify Chemistry personnel when the system is secured.Date of Full Com liance Although the Supply System is currently in full compliance, interim corrective

actions (procedural

changes and caution sign)will be completed by December 16,'988.Further analysis of REA-SR-37 flow control characteristics

will be completed by July 1, 1989.

"