ML17285A825

Forwards Response to NRC 891005 Ltr Re Violation Noted in Insp Rept 50-397/89-23 & Assessment of Issues.Corrective Actions:Violation Discussed Extensively During Shop Meetings & Shop Mgt Structure Reorganized

ML17285A825
Person / Time
Site:	Columbia
Issue date:	11/03/1989
From:	BOUCHEY G D WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GO2-89-204, NUDOCS 8911080151
Download: ML17285A825 (10)

See also: IR 05000397/1989023

Text

ZCCEMEV TZn DlsTR1BUTIoN

DEMONSTR<xoN

sYSTzx J REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS),I, ESSION,NBR:8911080151

DOC.DATE: 89/11/03 NOTARIZED:

NO DOCKET CI':50-397

WPPSS Nuclear Project,'nit

2, Washington

Public Powe 05000397 AUTH.NAME AUTHOR AFFILIATIONS

BOUCHEY,G.D.

Washington

Public Power Supply System RECZP.NAME

RECIPIENT AFFILIATION

Document Control Branch'(Document

Control Desk)SUBJECT: Forwards'response

to NRC 891005 ltr re violation noted in Insp Rept 50-397/89-23

6 assessment

of issues.R DISTRIBUTION

CODE:.ZE01D

COPIES RECEIVED:LTR

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

of Violation Response D NOTES: RECIPIENT ID CODE/NAM PDS PD INTERNAL: ACRS AEOD/DEIIB

DEDRO NRR/DEST DIR , NRR/DOEA DlR ll NRR/DREP/RPB

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LRB 1 2 OE LZEBE FILE 02 R FILE 0 EXTERNAL: LPDR NSIC COPIES LTTR ENCL 1 1 2 2 1 1 1 1.1 1 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1.RECIPIENT

ID CODE/NAME SAMWORTHiR

AEOD AEOD/TPAD NRR SHANKMAN,S

NRR/DLPQ/PEB

NRR/DREP/EPB

10 NRR/DRIS/DIR

NUDOCS-ABSTRACT

OGC/HDS2 RES MORZSSEAUiD

NRC PDR COPIES LTTR ENCL 1, 1 1 1 1 1 1 1.1 1 1 1 1.1 1 1-1 1 1 1 h TOTAL NUMBER OF COPIES REQUIRED: LTTR 26 ENCL 26

WASHINGTON

PUBLIC POPOVER SUPPLY SYSTEivi P.O.Box 968~3000 George 11'nshi>>glo>t

11'ny~Richln~icl, 11'nsh'iitgtmr

99352 Do'cket No.50-397 U.S.'uclear Regulatory

Commission

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

November 3, 1989 G02-89-204

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

REPORT 89-23 RESPONSE TO NOTICE OF VIOLATION Reference:

1)3)The Washington

1 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 cover letter to the subject Inspection

Report, Appendix A also discusses our steps taken, or planned, to ensure improved control of maintenance

and surveillance

activities.

Appendix B provides an assessment

of those issues also presented in the cover letter with regard to the Supply System Safety System Functional

Inspection (SSFI)of the low pressure core spray system.Very truly yours, Letter, G02-89-143, G,D.Bouchey (SS)to NRC."NRC Inspection

Report 89-06", dated August 21, 1989.2)Letter, G02-89-202, G.C.Sorensen (SS)to NRC"NRC Inspection

Reports 89-06 and 89-13", dated October 31, 1989 Letter, G02-89-183, D.W.Mazur (SS)to J.B.Hartin (NRC)"Response to WNP-2 Systematic

Assessment

of Licensee Performance (SALP)Report-1989", dated October 16,'1989 4 Public Power Supply System hereby replies to the Notice of Vio ation contained in your letter dated October 5, 1989.Our reply, pursuant to the provisions

of Section 2.201, Title 10,'Code of Federal Regulations, consists of this letter and Appendices

A and B (attached).

G.D.Bouchey, Dire Licensing&Assurance JDA/bk Attachments

cc: JB Hartin-NRC RV NS Reynolds-BCPIlR RB Samworth-NRC DL Williams-BPA/399 NRC Site Inspector-901A gggl080i51

8 PDR ADOCK 05000397 6 PNU

~Aendix A During an NRC inspection

conducted on July 10-August 23, 1989 a violation of, NRC requirements

was identified.

In accordance

with 10CFR Part 2, Appendix C,"General Statement of Policy and Procedure for NRC Enforcement

Actions," the violation is listed below: A.Technical Specification 6.8.1 states in part,"Written procedures

shall be established, implemented, and maintained

covering...

The applicable

procedures

recommended

in Appendix A of Regulatory

Guide 1.33, Revision 2, February 1978." Appendix A of Regulatory

Guide 1.33, Revision 2, February 1978 states in paragraph 9.a that"Haintenance

that can affect the performance

of safety-related equipment shoul'd be properly preplanned

and performed in accordance

with written procedures...." Plant procedure manual 10.24.12, Revision 4 (dated June 10, 1989),"Instrument

Tubing and Fitting Usage Instructions," states in paragraph 10.24.12.4: "Use proper sized wrenches when tightening

fittings.Always'use a second wrench to hold the connector firmly when tightening, or loosening, the connecting

nut." Plant Procedures

Hanual (PPH)10.24.12 also states in paragraph 10.24.12.7.c.1 that, when retightening

the connectors,"This advance (re-tightening)

need only be 10-20 degrees (less than I/3 of a hex flat)(past the original position):" Contrary to the above, on July 20,'989, following a surveillance

test on reactor recirculation

instrumentation, a maintenance

technician

tightened the connectors

for a test connection

isolation valve using an adjustable

'rench on the valve and a properly sized wrench on the connecting

nut.He tightened the nut approximately

one hex flat.This is a Severity Level IV violation (Supplement

I).Validit of Violation The Supply System acknowledges

the validity of this violation.

The.reason for the violation was that the technician

was not aware of the specific guidance (less than one-third hex flat)in Plant Procedure (PPH)10.24.12, and he adjusted the connection

approximately

one hex flat.In the cover letter to the subject inspection

report, it was requested that the Supply System, in addition to the specific responses directed, also discuss the steps taken or planned to ensure improved control of maintenance

and surveillance

activi'ties.

These steps are discussed in the applicable

sections of this NOV response.

Appendix A Page 2 of 3 Corrective

Ste s Taken Results Achieved 2)This violation was discussed extensively

during I&C Department

shop meetings to'nsure a good understanding

regarding Parker-Hannifin

tube fitting installation/re-installation

methodology.

With regard to ensuring improved control of maintenance

and surveillance

activities', the Maintenance

shop management

structure was reorganized (in response to the 1988 SALP Report)to provide each shop (Electrical,-

I&C and Mechanical)

with an engineering

supervisor

and a work control supervisor, both reporting to the shop supervisor.

The engineering

group is primarily responsible

for the preparation

and review of maintenance

procedures, and preparation

of work packages, The work control supervisor

is responsible

for implementa-

tion of the work packages in conformance

with established

procedures.

This reorganization

was recently implemented (February, 1989)and, as such, has not yet reached.its full potential.

We will continue to monitor the effectiveness

of this arrangement.

A shop practices document was prepared by Plant I&C supervision

to outline expected duties of the I&C Technicians

during the performance

of surveillances.

All Plant I&C Technicians

were trained on this document.Current plans are to prepare shop practice documents for the Maintenance

Work.Request (MWR)and Preventive

Maintenance (PM)processes, and provide training on such.Corrective

Action to be Taken Plant Procedure 10.24.12 will be added to those procedures

which are included in the initial and continuing

training programs for Plant I&C Technicians.

2.With regard to ensuring improved control of maintenance

and surveillance

activities, the Supply System committed to a complete review of the work control process in response to NRC Inspection

Report 89-06 (Reference

1).This included any necessary'raining

that may be required.The review is expected to result in changes to the overall process including added rigor in.the areas of work instruction

clarity, step-by-step

work description

and sign-off, work package planning and control of changes to the package.Additional

staffing has been provided to coordinate

this effort.A major part of the review will be directed toward improving the human factors elements of the process.The end product of this activity will be improved work packages for the craftsmen.'he

review is scheduled to be completed by December 1, 1989;with formal changes to the program to be completed by February 1, 1990 (Reference

2).

Appendix A Page 3 of 3 In a broader context, the Supply System is currently introducing

its"guality Improvement" program to employees at all levels in the organization.

A major thrust of this program is that quality is the responsibility

of each individual.

The long-term goal is to instill in each employee a sense of pride in performance,=seeking to identify problems and make corrections

when they first appear.Training for supervisors

and managers is ongoing and scheduled for completion

during the first quarter of 1990.The schedule for other employees is currently being developed and the training will follow accor-dingly.Date of Full Com liance Plant Procedure 10.24.12 will be added to the Plant 18C Training Program by December 8, 1989.Initial training on the procedure will be completed by December 30, 1989.

Appendix B As requested in the cover letter to the subject inspection

report, the following is an assessment

of those issues relating to the Supply System SSFI of the Low Pressure Core Spray (LPCS)System.The a licabilit of findin s to other lant safet s stems and the assessment

resolution

of that a licabilit:

As you are aware, the Supply System is currently performing

a self-initiated SSFI on the AC Electrical

Distribution

System.This is currently scheduled to be concluded in December, 1989.We believe that the SSFI methodology

has significant

benefit for the Supply System in assessing whether the system is being operated and maintained

in a manner that preserves full capability

to perform its'safety

related'ission.

It also identifies

issues that may be applicable

to other safety systems.'ur intent is to continue to perform SSFls.2.'With regard to the observations

which resulted from the LPCS SSFI, the observations

which may be applicable

to other systems have been categor-ized.The observations

within each category will be compared to actions the Supply System air'eady has underway in response t'o previously

identified

issues (Engineering

Improvement

Plan, Configuration

Hanagement

Improvement

Program, etc)~Appropriate

actions will be recommended

for consideration

and resolution

of programmatic

issues.The establishment

and im lementation

of a Su 1 S stem Confi uration Control Pro ram: The Supply System currently has in place an effective configuration

control program.However, it was recognized

that improvements

to this program were necessary as a result of the SSFI performed by the NRC on three WNP-2 systems in 1987.Subsequent

reviews, including our self-initiated

SSFI, supported this concern.As you are aware, a Nuclear Operating Standard (NOS-32)was issued in June, 1989 which established

basic policies and responsibilities

for the Configuration

Hanagement

Program.A Configuration

Hanagement

Improvement

Program (CHIP)was also recently approved which established

actions, responsibilities, and schedules for necessary improvements.

A number of Supply System organizations

are currently supporting

this effort.The CHIP.program will be based upon the documents and hardware identified

through the Design Requirements

Documents process.Other activities

are currently underway which relate to'the Configuration

Hanagement

Program.These include:

Appendix 8 Page 2 of 3 Resolution

of programmatic

issues identified

in the LPCS SSFI as=previously

discussed.

Particular

attention will be directed to the timeliness

of programmatic

actions which relate to Level I observations.

0 Resolution

of programmatic

issues ide'ntified

through the Plant Problem Evaluation

process.Development

of five Design Requirements

Doc'uments

during this fiscal year for three safety systems and two topical areas.Current plans are to prepare ten documents next year.Performance

of SSFIs on safety significant

systems.Performance

of actions Mentified~ii the Engiiieering

Improvement

Program.Continuation

of technical assessments

in engineering

design and operational

activities

by Nuclear Safety Assurance which relate to configuration

management.

For the above reasons, we believe that necessary actions are currently underway which provide the resolution

of identified

configuration

control issues and to detect configuration

management

issues which may exist in other systems.3.Im rovement of lant trackin mana ement information

s stems to make these less redundant and more user friendl with flexible sortin s stems:Plant tracking/management

i'nformation

system improvements

have been implemented

for approximately

a year which addressed the user friendliness

andaorting

capability

of the Plant Tracking Log (PTL).A number of action commitments

are now being tracked by the PTL instead ef other commitment

logs in order to obtain increased management

attention and to eliminate possible redundancy.

We now currently use the PTL as the single tracking mechanism for corrective

action tracking for NOVs, LERs, Inspection

Report open items, gA surveillances, audits, etc.We have reviewed PTL entri,es for accuracy and assessment

o'f responsibilities, provided sort capability

for late actions as well as 30, 60 and 90 day.look ahead reports to trigger, prompt action.We have commitment-type

sponsors who set goals and track progress of commitments.

The PTL is now a useful management

tool.A recent gA*audit'of this are confirmed the e'R'ectiveness

of PTL and monitoring

efforts to achieve consistent

results of PTL closure efforts.

Appendix 8 Page 3 of 3 The Supply System has previously

recognized

the need, however, for improvements

to our information

management

system.A program is currently being developed to improve the quality of Supply System information

management

systems and, over time, make the information

available to individuals

in the organization.

In addition, the Supply System has recently established

a position (Director, Information

Services)to provide overall policy and direction for this program in addition to other responsibilities, The Supply System also recognizes

the need, however, to deal with the backlog of actions requiring resolution..

Actions have been initiated to secure a contractor

to assist in resolution

of these backlog issues.Current plans are to select a contractor, establish prioritized

issues for resolution, and initiate contractor

actions on these issues within the near future.We believe that the above actions will provide improvements

to our information

management

system and reduce the backlog of important issues which need resolution.

Polic re ardin use of the Vital Maintenance

Work Re uest rocess: Our policy on use of vital MWRs was revised after the 1988 SALP recommenda-

tions.The elements of that policy include limited use of vitals to force creation of a normal MWR if the vital activity is to take more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to complete, and management

review of the appropriate

use of the vital process at our Management

Review Committee (MRC)morning meetings.To date, we believe the vital process is under control and working as intended;however, we will continue to monitor this process and make changes where necessary.

Polic re ardin field modification

of maintenance

rocedures:

The cases cited in the SSOMI NOVs (NRC Inspection

Report 89-06)on unauthorized

or inappropriately

authorized

deviations

to MWR work instructions

were clearly a violation of our existing program.We addressed these issues in our response to the specific NOVs.Further work control initiatives

were discussed in the recently-submitted

SALP update report (Reference

3)which provide for better control and review of such changes and the circumstances

which required deviations.

Cl'