ML17291A348: Difference between revisions

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See also: [[followed by::IR 05000397/1994015]]


=Text=
=Text=
{{#Wiki_filter:I'I.'Y'(ACCELERATED
{{#Wiki_filter:I'I.'Y'(ACCELERATED RIDS PROCESSING)
RIDS PROCESSING)
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)ACCESSION NBR:9408310140 DOC.DATE: 94/08/19 NOTARIZED:
REGULATORY
YES-FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe AUTH.NAME AUTHOR AFFILIATION PARRISH,J.V.
INFORMATION
Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
DISTRIBUTION
 
SYSTEM (RIDS)ACCESSION NBR:9408310140
==SUBJECT:==
DOC.DATE: 94/08/19 NOTARIZED:
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.
YES-FACIL:50-397
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.
WPPSS Nuclear Project, Unit 2, Washington
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:
Public Powe AUTH.NAME AUTHOR AFFILIATION
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  
PARRISH,J.V.
 
Washington
4 WASH liVGTOiV PUBLIC POWER SUPPLY SYSTEM P.O.Box 968~3000 George i Vashiagtott 1Vap~Riehlaad, 1 Uashiagtott 99352-096S
Public Power Supply System RECIP.NAME
~(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:
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
==Subject:==
action:provided
WNP-2, OPERATING LICENSE NO.NPF-21 NRC INSPECTION REPORT 94-15 REPLY TO A NOTICE OF VIOLATION  
adequate training better assure that operability
 
assessments
==References:==
will be documented
 
as required by procedures.
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).
DISTRIBUTION
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:
CODE: IE01D COPIES RECEIVED:LTR
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.  
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
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.
AEOD/TTC NRR/DORS/OEAB
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.
NRR/PMAS/IRCB-E
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.
OE DIR~REG-EI=LB 02 RGN4 FILE 01 EXTERNAL: EG&G/BRYCE,J.H.
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.
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
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.
AEOD/DEIB AEOD/SPD/RRAB
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  
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
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
))COUNTY OF BENTON)
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;
==Subject:==
and that to the best of my knowledge, information, and belief the statements
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.
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
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
\Residing g/My Commission Expires 0
Expires  
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.
0  
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 hours 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.
V~iola ion Appendix A 10 CFR Part 50, Appendix B, Criterion V, requires that activities
This is a Severity Level IV violation (Supplement I).Re onse to Violation The Supply System accepts this violation.
affecting quality shall be prescribed
1.Reason for the violation The reason for the violation was a judgement error by the engineer responsible for performing the Prompt Operability Assessments.
by documented
The individual components did not require operability assessments since they had been previously removed from service;however, the potential generic implications did require evaluation.
procedures
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.
and shall be accomplished
The engineer's judgement error resulted from inadequate training on operability requirements and the requirements of Plant Procedures Manual (PPM)1.3.12B.  
in accordance
 
with those procedures.
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.
WNP-2 Plant Procedures
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:
Manual 1.3.12B, Revision 0, paragraph 4.2.3a, states,"For degraded conditions
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.
impacting equipment operability
Two recent examples are described in the cover.letter accompanying this response.3.Corrective steps that will be taken to avoid further violations.
identified
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.
by physical evidence at the Plant, the Prompt Operability
No additional corrective actions are considered necessary.
Assessment
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.  
should be completed and documented
~'4~~~}}
within 24 hours 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~~~
}}

Revision as of 11:47, 17 August 2019

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 Energy Northwest icon.png
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)


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.

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