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{{#Wiki_filter: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:
{{#Wiki_filter: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:==
==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).
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.
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
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 PDR g
            +
A OCK 881 jp4 pgppp3~7
                                                                                +oI PDC


Page 1 of 2 APPENDIX A During an NRC inspection conducted on September 6-9, 1988, a violation of NRC requirements was identified.
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:
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 hours 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 hours."'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).  
A. Technical Specification 3.3.7. 12 states, in part:
'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.
      "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...."
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
    ,"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."
'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.
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:
.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.  
      "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 hours after the channel has been declared inoperable samples are continuously collected with auxiliary sampling equipment as required in Table 4.11-2.
'I I AC CELERATZD DISTRIBUTION DEMONSTRATION SYSTEM R EGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)CCESSION NBR:8811100200 DOC.DATE: 88/11/04 NOTARIZED:
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 hours."
NO DOCKET N FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH.NAME.AUTHOR AFFILIATION SORENSEN,G.C.
    '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.
Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
This is a Severity Level IV Violation (Supplement IV).
 
1 e
 
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 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:==
==SUBJECT:==
Responds to NRC 881006 ltr re violations noted in Insp'Rept 50-397/88-33.
Responds to NRC 881006 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 ALL''RIDS" RZCZPI/MS:
ltr re violations noted in Insp'Rept R
PLEASE HELP US TO REDUCE HASTE.'GKELCT
DISTRIBUTION CODE: IE06D       COPIES RECEXVED:LTR       ENCL     SIZE:               I TITLE: Environ   6   Radiological (50 DKT)-Insp Rept/Notice of Violation       Respons D
'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:
NOTES:
RECIPIENT          COPIES            RECIPIENT         COPIES              S ID CODE/NAME         LTTR ENCL      ID CODE/NAME        LTTR ENCL PD5 LA                   1      0    PD5 PD                  1    1 SAMWORTH, R             1      1 A
INTERNAL: ACRS                     2      2    AEOD/DSP                1    1 NMSS/LLOB       5E4     1      1    NMSS/SGOB      4E4      1" i 1            D NRR/DLPQ/PEB 11         1      1    NRR/DOEA/EAB 11        1    1 NRR/DREP/EPB 10         1      1    NRR/DREP/RPB 10        2    2 D
NRR/PMAS/ILRB12         1     1     NUDOCS-ABSTRACT        1   1 OGC/HDS2                1     1         RKHEh      02      1   1 RES                      1     1     RGN5    FILE 01        1   1 RGN2/DRSS/EPRPB          1     1. RGN4 MURRAY,B           1   1 TERNAL: LPDR                      1     1     NRC PDR                1   1 NSIC                    1     1     RESL MARTIN,D          1   1 R
I 8
A NOSE 'ZO ALL ''RIDS" 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
 
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:==
==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).
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.
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
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 R
Page 1 of 2 APPENDIX A During an NRC inspection conducted on September 6-9, 1988, a violation of NRC requirements was identified.
      ~~00200 S~~L04 ADOCK 0500035'7 QoC PDC                                                         Iii
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 hours 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 hours." 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.
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:
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.
A. Technical Specification 3.3.7. 12 states, in part:
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.  
      "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 hours 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 hours."
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.
 
"}}
"}}

Latest revision as of 08:09, 4 February 2020

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 Energy Northwest icon.png
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)
v • d • e


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 PDR g

+

A OCK 881 jp4 pgppp3~7

+oI PDC

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).

1 e

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 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 50-397/88-33.

ltr re violations noted in Insp'Rept R

DISTRIBUTION CODE: IE06D COPIES RECEXVED:LTR ENCL SIZE: I TITLE: Environ 6 Radiological (50 DKT)-Insp Rept/Notice of Violation Respons D

NOTES:

RECIPIENT COPIES RECIPIENT COPIES S ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 LA 1 0 PD5 PD 1 1 SAMWORTH, R 1 1 A

INTERNAL: ACRS 2 2 AEOD/DSP 1 1 NMSS/LLOB 5E4 1 1 NMSS/SGOB 4E4 1" i 1 D NRR/DLPQ/PEB 11 1 1 NRR/DOEA/EAB 11 1 1 NRR/DREP/EPB 10 1 1 NRR/DREP/RPB 10 2 2 D

NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS2 1 1 RKHEh 02 1 1 RES 1 1 RGN5 FILE 01 1 1 RGN2/DRSS/EPRPB 1 1. RGN4 MURRAY,B 1 1 TERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 RESL MARTIN,D 1 1 R

I 8

A NOSE 'ZO ALL RIDS" 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

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 R

~~00200 S~~L04 ADOCK 0500035'7 QoC PDC 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 hours."

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.

"

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