ML17285A701

Responds to NRC 890802 Ltr Re Violations Noted in Insp Rept 50-397/89-20.Corrective Action:Memo Placed in Training Audit File Notifying Lead Auditor to Include Listed Depts in Future Audits

ML17285A701
Person / Time
Site:	Columbia
Issue date:	08/29/1989
From:	Bouchey G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GO2-89-146, NUDOCS 8909050327
Download: ML17285A701 (4)

See also: IR 05000397/1989020

Text

ACCELERATED

DISCI'RIBUTION

DEMONSTRATION

SYSTEM REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)ESSION NBR:8909050327

DOC.DATE: 89/08/29 NOTARIZED:

NO'DOCKET ACIL:50-397

WPPSS Nuclear Project, Unit 2, Washington

Public Powe 05000397 AUTH.NAME'UTHOR AFFILIATION.,BOUCHEY,G.D.

Washington

Public Power Supply System RECIP.NAME

" RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)SUBJECT: Responds to NRC 890802 ltr re violations

noted in Insp Rept 50-397/89-20.

DISTRIBUTION

CODE: IE01D COPIES RECEIVED:LTR

L ENCL SIZE: gITLE: General (50 Dkt)-Insp.Rept/Notice

of Vi lation esponse NOTES: D RECIPIENT IDCODE/NAME

'D5 PD INTERNAL: ACRS AEOD/DEIIB

DEDRO NRR SHANKMAN,S

NRR/DLPQ/PEB

NRR/DREP/EPB

10'NRR/PMAS/ILRB12

OE LIEBERMAN,J

FIL 02 GN ILE 01 EXTERNAL: 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 1 1 RECIPIENT ID CODE/NAME SAMWORTH,R

AEOD AEOD/TPAD LOIS,ERASMIA

NRR/DEST DIR NRR/DOEA DIR 11.NRR/DREP/RPB

10 NUDOCS-ABSTRACT

OGC/HDS2 RES MORISSEAU,D

NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1'1.1 1 1 2 2 1 1 1 1 1 1 1 1 h OTAL NUMBER OF COPIES REQUIRED: LTTR 26 ENCL 26

ti WASHINGTON

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

Way~Richland, Washington

99352 August 29, 1989 G02-89-146

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 89"20 RESPONSE TO NOTICE OF VIOLATION The Washington

Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated August 2, 1989.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, i~goal.C/~G.D.Bouchey, Director Licensing&Assurance JDA/bk Attachments

cc: JB Martin-NRC RV NS Reynolds-BCP8R RB Samworth-NRC DL Williams-BPA/399 NRC Site Inspector-901A<C~l

APPENDIX A During an NRC inspection

conducted on July 10-14, 1989, two violations

of NRC requirements

were identified.

In accordance

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

Actions," 10 CFR Part 2, Appendix C, (1988), as modified by 53 Fed.Reg.40019 (October 13, 1988), the violation is listed below: A.Technical Specification 6.5.2, Cor orate Nuclear Safet Review Board, states in part: "Audits of unit activities

shall be performed under the cognizance

of the CNSRB.These audits shall encompass:

b.The performance, training and qualifications

of the entire unit staff at least once per 12 months." Contrary to the above, as o'f July 10, 1989, an audit of the performance, training and qualifications

of the entire unit staff had not been conduc-ted for a period of 21 months, in that Equipment Operators were specifi-'ally

excluded as part of the regularly scheduled audit of 1988, having been last reported as audited on October 9, 1987.This is a Severity Level IV violation (Supplement

VII).Validit of Violation The Supply System acknowledges

the validity of this violation.

The reason for the violation is that, during the audit, the team leader made the decision to concentrate

efforts on the review of licensed operations

personnel and outage personnel, and not review non-licensed

operations

personnel.

This decision was based upon the knowledge that previous audits have found that equipment operators were properly trained and qualified.

The plan for Audit 88-453 was developed to include a sampling of members from each department

of the unit staff.The scope included Health Physics/Chemistry, Maintenance, Plant Technical (Shift Technical Advisors)and Operations (licensed and non-licensed).

Also included for review, were Nondestructive

Examination

and Inspection

personnel, and non-Supply

System outage craft personnel.

These two, latter groups are not defined as members of the unit staff.

Appendix A Page 2=of 2 Corrective

Ste s Taken/Results

Achieved 1)A 100K review of the training, qualification

and performance

records for all Equipment Operators (EOs)was conducted on July 17-18, 1989 and no-discrepancies

were noted.Records show that at least five EOs are assigned to each shift that are certified to perform the duties of a Reactor Building/Radwaste

Operator and Radwaste Control Room Operator.Currently, 29 EOs are fully certified for these two areas.-Records also show that the same EOs were certified at the time Audit 884 53 was performed in September, 1988.2)A memo has been placed in the training audit file notifying the lead auditor to include the following departments

in future audits: a)b)c)d)Maintenance (Mechanical, Electrical

and Instrument

and Controls)Health Physics/Chemistry (including

HP/Chem Support)Operations (Licensed and Non-Licensed

personnel)

Plant Technical (all disciplines, including Shift Technical Advisors)Corrective

Action to be Taken No further corrective

action is planned.Date of Full Com liance The Supply System is currently in full compliance.