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| issue date = 11/04/1988
| issue date = 11/04/1988
| title = 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
| title = 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
| author name = SORENSEN G C
| author name = Sorensen G
| author affiliation = WASHINGTON PUBLIC POWER SUPPLY SYSTEM
| author affiliation = WASHINGTON PUBLIC POWER SUPPLY SYSTEM
| addressee name =  
| addressee name =  
Line 14: Line 14:
| page count = 13
| page count = 13
}}
}}
See also: [[followed by::IR 05000397/1988033]]


=Text=
=Text=
{{#Wiki_filter:WASHINGTON
{{#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:
PUBLIC POWER SUPPLY SYSTEM P.O.Box 968~3000 George Washington
 
Way~Richland, Washington
==Subject:==
99352 G02-88-229
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).
November 4, 1988 Docket No.50-397 U.S.Nuclear Regulatory
In Appendix A, the violation is addressed with an explanation of our position regarding validity, corrective action and date of full compliance.
Commission
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
Attn: Document Control Desk Mail Station Pl-137 Mashington, D.C.20555 Gentlemen:
            +
Subject: NUCLEAR PLANT NO.2 LICENSE NO.NPF-21 NRC INSPECTION
A OCK 881 jp4 pgppp3~7
REPORT 88-33 RESPONSE TO NOTICE OF VIOLATION The Mashington
                                                                                +oI PDC
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).
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 Appendix A, the violation is addressed with an explanation
A. Technical Specification 3.3.7. 12 states, in part:
of our position regarding validity, corrective
      "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...."
action and date of full compliance.
    ,"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."
Very truly yours, G.C.S'orensen, Manager Regulatory
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:
Programs JDA/bk Attachments
      "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.
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
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.
Page 1 of 2 APPENDIX A During an NRC inspection
This is a Severity Level IV Violation (Supplement IV).
conducted on September 6-9, 1988, a violation of NRC requirements
 
was identified.
1 e
In accordance
 
with the"General Statement of Policy and Procedure for NRC Enforcement
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.
Actions," 10 CFR Part 2, Appendix C, (1987), the violation is listed below: A.Technical Specification
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.
3.3.7.12 states, in part: "3.3.7.12 The radioactive
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.
gaseous effluent monitoring
Accordingly, the sample rack was operable during the event period and representative samples of main plant vent effluents were being obtained.
instrumentation
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.
channels shown in Table 3.3.7.12-1
. 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.
shall be OPERABLE with their alarm/trip
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.
setpoints set to ensure that the'limits of Specification
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.
3.11.2.1 are not exceeded...." ,"b.With less than the minimum number of radioactive
Further   analysis       of   REA-SR-37   flow control     characteristics     will   be completed by July 1, 1989.
gaseous effluent monitoring
 
instrumentation
'I I
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
AC CELERATZD           DISTRIBUTION           DEMONSTRATION             SYSTEM R EGULATORY INFORMATION     DISTRIBUTION SYSTEM (RIDS)
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
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)
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
==SUBJECT:==
were made nor continuous
Responds to NRC 881006 50-397/88-33.
sample collection
ltr re violations noted in Insp'Rept R
conducted, although effluent releases con-tinued via the main plant vent.This is a Severity Level IV Violation (Supplement
DISTRIBUTION CODE: IE06D       COPIES RECEXVED:LTR       ENCL     SIZE:               I TITLE: Environ   6   Radiological (50 DKT)-Insp Rept/Notice of Violation       Respons D
IV).  
NOTES:
'1e
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
Page 2 of 2 Validit of Viol ation The Supply System'acknowledges
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
the validity of the violation in that procedural
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
requirements
I 8
were not followed when the Reactor Building HVAC System was secured and the Standby Gas Treatment (SGT)System star ted.The requirements
A NOSE 'ZO ALL ''RIDS" RZCZPI/MS:
to declare Reactor Building Effluent Control Rack REA-SR-37 inoperable, and enter the associated
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)
Technical Specification
TOTAL NUMBER OF COPIES REQUIRED: LTTR           25  ENCL     24
Action Statement, were not'performed.
 
Sample Rack REA-SR-37 is the isokinetic
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:
air flow control rack for effluent monitoring
 
of the main plant vent.Corrective
==Subject:==
Ste s Taken/Results
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).
Achieved On October ll, 1988 a test was performed to determine the dynamic flow control characteristics
In Appendix A, the violation is addressed with an explanation of our position regarding validity, corrective action and date of full compliance.
of REA-SR-37 by equalizing
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
the differential
      ~~00200 S~~L04 ADOCK 0500035'7 QoC PDC                                                          Iii
pressure across REA-FT-7 (Reactor Exhaust Air Stack Flow Rate Transmitter), simulating
 
decreasing
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:
stack flow.The purpose of the test was to collect data to determine if the effluent monitoring
A. Technical Specification 3.3.7. 12 states, in part:
system could accurately
      "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...."
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
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:
sampling to below 4,000 cfm.Accordingly, the sample rack was operable during the event period and representative
      "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.
samples of main plant vent effluents were being obtained.Corrective
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."
Action to be Taken Further data collection
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.
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
This  is a Severity Level IV Violation (Supplement IV).
of system operability.
 
.The results of the analysis will be used to determine if any additional
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.
actions are required.II In the interim, applicable
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.
procedures
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.
will be modified to notify the Plant Chemistry Department
Accordingly, the sample rack was operable during the event period and representative samples of main plant vent effluents were being obtained.
when the Reactor Building HVAC System is secured.The intent of this corrective
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.
action is to have the technicians
The results of the analysis will be used to determine            if  any additional actions are required.
monitor REA-SR-37 indications
In the interim, applicable procedures will be modified to notify the Plant Chemistry Department when the Reactor Building HVAC System is secured.
every four hours during such conditions
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.
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
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.
actions (procedural
Further    analysis    of   REA-SR-37    flow control    characteristics    will   be completed by July 1, 1989.
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 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 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 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

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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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