ML17291B030

Forwards Response to NRC 950816 Ltr Re Violations Noted in Insp Rept 50-397/95-20 on 950604-0715.Corrective Actions: New Maint Procedure Will Be Developed to Include Necessary Precautions

ML17291B030
Person / Time
Site:	Columbia
Issue date:	09/15/1995
From:	Parrish J WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GO2-95-178, NUDOCS 9509250062
Download: ML17291B030 (8)

See also: IR 05000397/1995020

Text

PRIORITY 1 (ACCELERATED

RIDS PROCESSING)

4 tl REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)ACCESSION NBR:9509250062

DOC.DATE: 95/09/15 NOTARIZED:

NO 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: Forwards response to NRC 950816 ltr re violations

noted in insp rept 50-397/95-20

on 950604-0715.Corrective

actions: new maint procedure will be developed to include necessary precautions.

DISTRIBUTION

CODE: IEOID COPIES RECEIVED:LTR

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

of Violation Response NOTES DOCKET g 05000397 RECIPIENT ID CODE/NAME PD4-2 PD COPIES RECIPIENT LTTR ENCL ID CODE/NAME 1 1 CLIFFORD,J

COPIES LTTR ENCL 1 1 Y INTERNAL:ACRS AEOD/SPD/RAB

DEDRO NRR/DISP/PIPB

NRR/DRCH/HHFB

OE DIR RGN4 FILE 01 2 2 1 1 1 1 1 1 1 1 1 1 1 1 AEOD/DE I B AEOD/TTC CENTE DOES~OEAB NUDOCS-ABSTRACT

OGC/HDS3 1 1 1 1 1 1 1 1 1 1 1 1 D".EXTERNAL: LITCO BRYCE,J H NRC PDR 1 1 1 1 NOAC 1 1 0 NNOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN 5DS (415-2083)

TO ELIMINATE YOUR NAME FROM DISTRIBUTION

LISTS FOR DOCUMENTS YOU DON'NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL 19

WASHINGTON

PUBLIC POWER SUPPLY SYSTEM PO.Box 968~3000 George Washington

Way~Richland, Wasl ington 993S2-0968

~(S09)372-5000 September 15, 1995 G02-95-178

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

Commission

Attn: Document Control Desk Washington, D.C.20555 Gentlemen:

Subject;WNP-2, OPERATING LICENSE NO.NPF-21 NRC INSPECTION

REPORT 95-20 RESPONSE TO NOTICE OF VIOLATION Reference:

Letter GI2-95-187, dated August 16, 1995, JE Dyer (NRC)to JV Parrish (SS),"NRC Inspection

Report 50-397/95-20

and Notice of Violation" The Washington

Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated August 16, 1995.Our reply, pursuant to the provisions

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

The Notice of Violation describes three violations (A, B, and C)cited at Severity Level IV.The Supply System respectfully

requests that Violation B be reconsidered

with regard to severity level in light of the recently revised NRC Enforcement

Policy (herein after referred to as"the Policy")guidance.Violation B deals with a condition identified

through an event where Technicians

lifted a wrong lead during testing and caused a fluctuation

in reactor vessel water level.This event was responded to in a rapid and conservative

fashion by Operations.

For violations

identified

through events, the Policy states: "the NRC may choose to give credit...simply because no prior opportunities (e.g., procedural

cautions, post-maintenance

testing, quality control failures, readily observable

parameter trends, or repeated or locked-in annunciator

warnings)existed to identify the problem." c~~J 9509250062

9509i5 PDR ADOCK 05000397 PDR

Page 2 NRC INSPECTION

REPORT 95-20, RESPONSE TO NOTICE OF VIOLATION The geneial issue of human performance

is a recognized

area for improvement

for WNP-2 as has been discussed with the staff frequently

in the recent past.Numerous corrective

actions for this problem area are either in-process

or are under development.

The corrective

actions are part of the Performance

Enhancement

Strategy for WNP-2, which will be reviewed with the staff on a periodic basis, As also stated in the Policy, enforcement

action should be used"as a deterrent to emphasize the importance

of compliance

with requirements, and to encourage prompt identification

and prompt, comprehensive

correction

of violations." For this violation, the staff stated in the Report that"The licensee's

corrective

actions were adequate." Both the specific and general corrective

actions have been or are being addressed.

Should you have any questions or desire additional

information

regarding this matter, please call me or D.A.Swank at (509)377-4563.Sincerely,.Parrish (Mail Drop 1023)Vice President, Nuclear Operations

CD M/ml 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

Appendix A VIOLATIONS

During an NRC inspection

conducted on June 4 through July 15, 1995, three violations

of NRC requirements

were identified.

In accordance

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

Actions," (Enforcement

Policy), 60 FR 34381, June 30, 1995, the violations

are listed below: A.10 CFR Part 50, Appendix B, Criterion V, states"procedures

shall include appropriate

quantitative

or qualitative

acceptance

criteria for determining

that important activities

have been satisfactorily

accomplished." Contrary to the above, on June 6, 1995, Plant Procedure Manual (PPM)3.1.1,"Master Startup Checklist," did not contain appropriate

qualitative

or quantitative

acceptance

criteria to assure proper installation

of the control rod housing support which resulted in the housing support being installed improperly (a jam nut was missing and gaps were not properly adjusted).

~This is a Severity Level IV violation (Supplement

I)(397/9520-01).

Technical Specification 6.8.1.d requires that surveillance

procedures

be implemented.

Surveillance

Procedure PPM 7.4.3.7.5.18, Revision 6, Steps 7.3.2 and 7.3.3 required technicians

to identify and lift leads for Terminal Block E51A-SRV-1

in the rear of Cabinet H13-P612.Contrary to the above, on July 12, 1995, while performing

Surveillance

Procedure PPM 7.4.3.7.5.18, Revision 6, Steps 7.3.2 and 7.3.3, technicians

did not identify and lift leads for Terminal Block E51A-SRU-1

in the rear of Cabinet H13-P612 and lifted the incorrect lead.This is a Severity Level IV violation (Supplement

I)(397/9520-02).

C.10 CFR 50.59(b)(1)

states"The licensee shall maintain records of changes in the facility...made pursuant to this section, to the extent that these changes constitute

a change to the facility and described in the safety analysis report.These changes must include a written safety evaluation

which provides a basis for determination

that the change, test, or experiment

does not involve an unreviewed

safety question." Contrary to the above, as of July 3, 1994[sic], Temporary Modification

Request (TMR)95-030 resulted in a change to the facility as described in the Final Safety Analysis Report (FSAR), but a written safety evaluation

was not performed.

This is a Severity Level IV violation (Supplement

I)(397/9520-03).

Appendix A Page 2 of 5 R P E The Supply System accepts this violation.

REA N F R THE VI LATI A review of the details relating to the physical misadjustments

and missing jam nut indicate that the errors likely occurred in previous years since no work was done on the control rod drive housing support steel during the 1995 outage.The portion of plant procedure PPM 3.1.1 relating to verification

of the correct arrangement

of the control rod drive housing support steel was the same during both 1994 and 1995, and provided no explicit acceptance

criteria.Therefore, the cause of the violation was over-reliance

on the skill and knowledge of personnel charged with assuring that the control rod drive housing support steel was correctly configured.

RRE KE A R LT HIEVED The missing jam nut was installed and the misadjustments

were corrected on June 8, 1995 in support of the restart after the 1995 outage.E T V V LTI A new maintenance

procedure will be developed to include the necessary precautions, methodology, acceptance

criteria, and required documentation

to govern proper removal and reinstallation

of the control rod drive housing support steel.A new visual inspection

procedure will also be developed to assure that the work is done in compliance

with the new maintenance

procedure.

This new inspection

procedure will constitute

a Technical Specification

surveillance

procedure and will verify conformance

with Technical Specifications 3.1.3.8 and 3.10.7 which require the control rod drive housing support steel to be in place during Modes 1, 2, and 3 and during reactor vessel inservice leak and hydrostatic

testing, respectively.

In addition, appropriate

startup procedures

will be revised to ensure that the visual inspection

of the control rod drive housing support steel has been completed as part of the activities

performed in support of startup after an outage.Plant procedure PPM 3.1.1 currently requires verification

that the support steel is installed.

DATE OF F L MPLIAN E WNP-2 will be in full compliance

on October 1, 1995 when the new surveillance

procedure has been approved for use and the startup procedures

have been revised.

Appendix A Page 3 of 5 R P ET I LATI B The Supply System accepts this violation.

REA F EVI LA Plant procedure PPM 7.4.3.7.5.18,"Accident Monitoring

Instrumentation

RCIC Flow Indication

-CC," requires verification

by two people that the correct component has been identified

prior to lifting leads.This requirement

was the result of a similar event that occurred in 1986.In addition, plant procedure PPM 1.3.60,"Verbal Communication

Policy" requires 3-way communications

which includes verbal"repeat back" of steps executed during the performance

of critical procedures.

Plant procedure PPM 1.2.3,"Use of Controlled

Plant Procedures," requires the use of"STAR (Stop-Think-Act-Review)" to ensure adequate self-checking

of actions prior to the performance

of procedural

steps.In this case, 3-way communications

were not used and the"STAR" and two person verification

processes were inadequately

followed because both individuals

did not fully verify the identifier

of the terminal block for the leads they were lifting.Therefore, the cause of the violation was human error as evidenced by the failure to correctly implement procedural

requirements.

Based on panel inspections

and interviews

with the individuals

involved, a contributing

cause of the violation was that panel identification/labeling

is confusing in some cases due to the use of General Electric (GE)identifier"codes" in lieu of standard WNP-2 system identifiers.

RRE TEP TAKEN AND R T A HIE D The on-shift operations

crew identified

the lifted lead error and the Shift Manager directed the technicians

to reland the lifted leads in less than one minute.The operations

crew then monitored RPV level to ensure that the automatic controls restored level to the normal operating band.The prompt action by the on-shift operations

crew prevented the transient from becoming a significant

challenge to the plant.A Problem Evaluation

Request (PER)was initiated and a plant time-out was held on July 13, 1995 to emphasize self-checking

and teamwork.The I&C shop time-out also reinforced

management's

expectations

regarding formal 3-way communications.

The technicians

involved have been counseled and were required to attend additional

laboratory

training on the maintenance

training instrumentation

and control system mock-up facility to refresh their skills in these areas.

Appendix A Page 4 of 5 RRE TEP T BE TAKEN T AV ID F THER VI LATI Signal Resistance

Units (SRUs)in control room cabinets H13-P612 and H13-P613 will be relabeled as necessary to ensure clear identification.

I&C craft personnel will be trained on GE identifiers

and a cross-reference

relating GE identifiers

to WNP-2 system identifiers

will be made available.

A F MPLI E Full compliance

was achieved on July 12, 1995 when the leads on the incorrect terminal block were relanded and the reactor pressure vessel level was restored to the normal operating band.R P E The Supply System accepts this violation.

RE F RTHEVI L TI The cause for this violation was an inadequate

review of the FSAR by the system engineer due to an over-reliance

on a computer program which assists in reviewing Licensing Basis Documents (LBDs).TMR 95-30 removed the disk position indicating

light bulbs for a testable check valve from a control room panel because the indicating

lights were giving operators false position indication.

The indicating

lights are actuated by limit switches on the check valve.Prior to implementing

the TMR, the system engineer performed a key word search of an electronic

version of the FSAR using a computer program.Computer word searches assist in reviews of LBDs and help in providing a response to Question No.4 of the 10CFR50.59

Review.Question No.4 asks: "Does this implementing

activity change or affect the intent of a procedure or process from the intent of the commitments

described, outlined, or summarized

in the LBD?" The word search did not identify a statement in the FSAR that reads: "...valve test provisions

are provided[on testable check valves]includii;g

limit switches to indicate disc movement." Based solely on the key word search results, the system engineer incorrectly

determined

that implementation

of the TMR would not change or affect the process for identifying

disc movement as described in the LBD.Consequently, a safety evaluation

was not performed to determine if implementation

of the TMR represented

an unreviewed

safety question.

~~~Appendix A Page 5 of 5 RRE TEP TAKE R LT HIE ED The system engineer involved was counseled on August 9, 1995.Additional

guidance for performing

computer word searches was provided to managers and supervisors

on August 15, 1995 for distribution

to personnel responsible

for LBD searches.A 10CFR50.59

safety evaluation

was performed for TMR 95-30 and approved by the Plant Operating Committee (POC)on September 6, 1995.The safety evaluation

concluded that implementation

of the TMR does not represent an unreviewed

safety question.R E P T E KE T ID THER LA A similar event was identified

on July 14, 1995 and it was recognized

that there was generic impact.As a result, the lessons learned from this event as well as the subsequent

event will be incorporated

into Licensing Basis Impact Determinations

initial and refresher training which are required for personnel performing

10CFR50.59

screening reviews and safety evaluations.

These events will also be incorporated

into the next Plant and Industry Events training.DATE F F L MPLIAN E Full compliance

was achieved on September 6, 1995 when the safety evaluation

for TMR 95-30 was approved by POC.