ML17285B074

Responds to NRC 900201 Ltr Re Violations Noted in Insp Rept 50-397/89-30.Corrective Action:Plant Personnel Currently in Process of Making Improvements to Plant Operations Procedure Writers Guide

ML17285B074
Person / Time
Site:	Columbia
Issue date:	03/02/1990
From:	Bouchey G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GO2-90-034, GO2-90-34, NUDOCS 9003130415
Download: ML17285B074 (6)

See also: IR 05000397/1989030

Text

ACCELERATED

DISTjUBUTION

DEMONSHRATION

SYSTEM i REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)ACCESSION NBR:9003130415

DOC.DATE: 90/03/02 NOTARIZED:

NO DOCKET FACIL:50-397

WPPSS Nuclear Project, Unit 2, Washington

Public Powe 05000397 AUTH.NAME AUTHOR AFFILIATION

BOUCHEY,G.D.

Washington

Public Power Supply System RECIP.NAME

RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)SUBJECT: Responds to NRC 900201 ltr re violations

noted in Insp Rept 50-397/89-30.

DISTRIBUTION

CODE: IE01D COPIES RECEIVED:LTR

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

of Violation Response NOTES'ECIPIENT

ID CODE/NAME PD5 PD INTERNAL: ACRS AEOD/DEIIB

DEDRO NRR/DLPQ/LPEB10

NRR/DREP/PEPB9D

NRR/DRIS/DIR

NRR/PMAS/ILRB12

OGC/HDS2 RES MORISSEAU,D

XTERNAL: LPDR'NSIC 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 1 1 RECIPIENT ID CODE/NAME SAMWORTH,R

AEOD AEOD/TPAD NRR SHANKMAN,S

NRR/DOEA DIR 11 NRR/DREP/PRPB11

NRR/DST/DIR

SE2 NU-TRACT EG FI 02 FILE 01 NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 2 2 1 1 1 1 1 1 1 1 1 1 NO'IE TO ALL"RIDS" RECIPIENIS:

PLEASE HELP US TO REDUCE WASTE(CONTACT THE,DOCUMENI'ONTROL

DESK, ROOM Pl-37 (EXT.20079)TO ELMINATE YOUR NAME FROM DISTRIBUTION

LISIS FOR DOCUMENTS YOU DON'T NEEDt.TOTAL NUMBER OF COPIES REQUIRED: LTTR 25 ENCL 25

WASHINGTON

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

Way~Richland, Washington

99352 March 2, 1990 G02-90-034

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

Commission

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

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

REPORT 89-30 RESPONSE TO LEVEL IV NOTICE OF VIOLATION Reference:

Letter, JB Hartin (NRC)to DW Hazur (SS), dated February 1, 1990 The Washington

Public Power Supply System hereby replies to the Level IV Notice of Violation contained in your letter dated February 1, 1990.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.

As requested in the referenced

letter, Appendix A also provides measures we will implement to provide assurance that similar problems do not remain undetected

or uncorrected.

The referenced

letter also included a Level II Notice of Violation, for which a response was not required.We are currently evaluating

our position with regard to this issue.Accordingly, a 30-day extension for this item was requested and granted by the Office of Enforcement.

Very truly yours, I G.D.Bouchey, Dire or Licensing E Assurance JDA/bk Attachments

cc: JB Hartin-NRC RV NS Reynolds-BCP8R RB Samworth-NRC DL Williams-BPA/399 NRC Site Inspector-901A~00313001

900302 PDR ADOCK 05000397.A FDC~+o

APPENDIX A During NRC inspections

conducted during the periods of March 3-24, 1986, January 12-15, 1987, June 6-10, 1988 and October 23-27, 1989, violations

of NRC requirements

were identified.

These violations

involved the implementa-

tion of the fire protection

program.In accordance

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

Actions", 10 CFR Part 2, Appendix C (1989), the violations

are set forth below: III.WNP-2 Technical Specification 6.8.I.g requires that written procedures

be established, implemented

and maintained

covering Fire Protection

Program implementation.

Contrary to the above, on October 25, 1989, Revision No.12 of Abnormal Procedure No.PPM 4.12.1.1, which implements

the WNP-2 Control Room Remote Shutdown capability, a required element of the Fire Protection

Program, was not appropriate

to the circumstances

in that: A.Step No.A.10 incorrectly

required that RHR system valve No.V-123B, instead of valve No.V-123A, be closed.B.C.Step No.A.27 incorrectly

required that cooling fan No.RRA-FN-1 be made operable prior to RHR pump room No.2B exceeding specified temperature

limits, rather than requiring fan No.RRA-FN-3, (which provides cooling to RHR Pump Room No.2B)to be operable.Rather than specifying

the appropriate

cooling equipment, Step No.A.27 incorrectly

required that Equipment No.WMA-TI-9, which is only a temperature

indicator, be made operable prior to the Remote Shutdown Panel Room exceeding specified temperature

limits.This is a Severity Level IV Violation (Supplement

I).Validit of Violation The Supply System acknowledges

the validity of this violation.

A formal root cause analysis was performed for this violation and, although the reason for the procedural

deficiencies

could not be specifically

determined, contributing

factors were identified

and are discussed as follows: RHR-V-123B

-Contributing

causes are 1)E ui ment Desi n Deficien-uLII I (pl f"R" RIIR I I h RIIR"P" mimic), and 2)E ui ment Desi n Deficienc Labelin Less Than~d(-->>p f I hl bid Rllll-123).RRA-FN-1-Contributing

cause is E ui ment Desi n Deficienc Drawin s LTA (inadequate

information

on the flow diagram for Reactor Building HVAC).WMA-TI-9-Contributing

cause is Personnel Lack of Atten-'h I f1 1 I bl headings).

Appendix A Page 2 of 3 Corrective

Ste s Taken Results Achieved Plant Procedures (PPMs)4.12.1.1,"Control Room Fire/Evacuation", and 4.12.1.2,"RPV Remote Cooldown", were revised to correct the deficiencies

noted.2.3.A procedural

training course, developed by a consultant

specifically

for WNP-2, was planned prior to the receipt of this violation.

The training course, which was completed on January 19, 1990, provided 1)an outline of the fundamental

elements of procedures, 2)appropriate

human factors elements specific to procedures, and 3)verification

and validation

techniques.

The course also included exercises to practice and demonstrate

the methods presented, with specific focus on the review of existing WNP-2 procedures.

Several members of the Plant staff (including

guality Assurance)

involved in the procedure review and development

process participated

in this training.As a part of the root cause efforts, an evaluation

of the consequen-

ces of these procedural

deficiencies

was performed.

The results of the evaluation

are presented as follows: a~RHR-V-123B

b..The current revision of PPM 2.4.2,"Residual Heat Removal System", administratively

mitigated this deficiency.

In the PPM Valve Checklist attachment, both RHR-V-123A

and RHR-V-123B are specified"CLOSED".The System Power Supply Checklist attachment

directs that electrical

breakers for both valves be cautioned tagged open during modes 1, 2 and 3.Therefore, if a control room fire occurs during a plant condition when an overpressure

in the RHR system could occur, the boundary is administratively

maintained

through lineups specified in PPM 2.4.2.This administrative

control was added to PPM 2.4.2 in May 1986.RRA-FN-1 This deficiency

was mitigated because when the RHR 2B pump is energized, RRA-FN-3 is automatically

started.Additionally

the procedure requires hourly temperature

monitoring

of the pump room.If the temperature

exceeds 150'F, operators are instructed

to make the cooling equipment operable.The highest safe operating temperature

for the pump is listed as 200'F.The following sequence of events would have to occur for the pump room to exceed the safe operating temperature:

The fan would fail to automatically

energize.The temperature

would increase to above 150'F.The operator would energize the incorrect fan RRA-FN-1.

Appendix A Page 3 of 3~Assuming the incorrect fan was energized the temperature

would continue to increase.~During the next hourly reading the operator does not notice an increase in room temperature

with the, pump room fan not in service, after having energized a fan previously.

~Hourly readings continue with no actions by operators in light of situational

conflicts (see above)until room temperature

exceeds 200'F.c)WHA-TI-9 Guidance contained in the body of the procedure provided the correct actions to be taken if Remote Shutdown Room Temperature

increased.

Since no incorrect information

was included, and the guidance contained the corrective

action for the condition, the impact of this editorial deficiency

was negligible.

Corrective

Action to be Taken 2.Plant personnel are currently in the process of making improvements

to the Plant Operations

Procedure Writer's Guide.Plant Operations

personnel are in the process of developing

an.improved Procedural

Verification

Program.The current plan is to include checklists

in this process, which would significantly

increase the opportunity

to detect the type errors identified

in this violation.

Verification

is concerned with written correctness

and technical accuracy.Written correctness

ensures information

is incorporated

as specified by administrative

guidance.Technical accuracy ensures proper incorporation

of generic and plant specific technical information.

Date of Full Com liance 1.The revised Plant Operations

Procedure Writer's Guide will be issued by July 1, 1990.2.The Procedural

Verification

Program will be initiated by July 1, 1990