ML17285A336

Forwards Amended Response to Notice of Violation Contained in Insp Rept 50-397/88-40.Corrective Actions:Guidance Document Will Be Prepared to Better Understand Processes Associated W/Relief from Tech Specs Re Vital Switchgear

ML17285A336
Person / Time
Site:	Columbia
Issue date:	03/22/1989
From:	MAZUR D W WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-87-09, GL-87-9, GO2-89-046, GO2-89-46, NUDOCS 8903270382
Download: ML17285A336 (5)

See also: IR 05000397/1988040

Text

D1STKBU'H ON DEMON STRATI 04 SYSTEM REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)CESSION NBR:8903270382

DOC.DATE: 89/03/22 NOTARIZED:

NO FACIL:50-397

WPPSS Nuclear Project, Unit 2, Washington

Public Powe AUTH.NAME AUTHOR AFFILIATION

MAZUR, D.W.Washington

Public Power Supply System RECIP.NAME

RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)SUBJECT:, Forwards amended response to notice of violation contained in Insp Rept 50-397/88-40.

DISTRIBUTION

CODE: IE01D COPIES RECEIVED:LTR

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

of Violation Response NOTES: DOCKET 05000397 RECIPIENT ID CODE/NAME PD5 PD INTERNAL: ACRS AEOD/DEIIB

NRR SHANKMAN,S

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10 NRR/PMAS/ILRB12

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10 NRR/DRIS DIR 9A NUDOCS-ABSTRACT

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LISTS 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 11'ashington

11'ay~Richland, 11'ashington

99352 March 22, 1989 G02-89-046

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

Commission

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

Subject: Reference:

NUCLEAR PLANT NO.2 AMENDED RESPONSE TO NOTICE OF VIOLATION 88-40-02 (VIOLATION

B)a)Letter, JB Martin to DW Mazur,"Response to Notice of Yiolation-Inspection

Report 88-40", dated March 9, 1989 b)Letter, G02-89-020, GC Sorensen (SS)to NRC,"NRC Inspection

Report 88-40 Response to Notice of Yiolation", dated February 13, 1989 Rid SD (90 e The Washington

Public Power Supply System hereby submits an amended response to the Notice of Violation 88-40-02 (Yiolation

B)contai ned in Inspection

Report 88-40 dated January 13, 1989.Our reply, pur suant 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.

This amended response is submitted as a result of discussions

between Mr.Oxsen of my staff, Mr.Chaffe of Region V NRC, and Mr.Martin's letter of March 9 (reference

a).In reviewing our process to proper ly respond to Notices of Viola-tions, we have identified

areas of weakness and are maki ng corrective

action changes to that process.Yery truly yo rs,;v'd4ygq'.Managing Director JDA/bk Attachment

cc: JB Martin-NRC RV NS Reynolds-BCP&R RB Samworth-NRC DL Williams-BPA/399 NRC Site Inspector-901A

APPENDIX A Dur ing an NRC inspection

conducted on November 14-December 14, 1988, viola-tions of NRC requirements

were identified.

'In accordance

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

Actions," 53 Fed.Reg.40019 (October 13, 1988), the violations

are listed below: B.Section 4.0.3 of the WNP-2 Technical Specifications

states, in part, that"Failure to perform a Surveillance

Requirement

within the specified time interval shall constitute

a failure to meet the OPERABILITY

requirements

for a Limiting Condition for Operation." Section 6.8.1 of the Technical Specifications

requires written procedures

to be established

and implemented

for"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, includes in the listing of orocedures

which should be provided,"1.Administrative

Procedures...b.

Authorities

and Responsibilities

for Safe Operation and Shutdown." Plant Procedures

Manual 1.3.1, Standing Orders/Night

Orders, Revision 14, states the following in Attachment

I Standin 0 eratin Orders: "6.If any surveillance

test or other condition indicates that a system is not operable as required by the Technical Specifications, the Shift Manager is to begin the action required by the Technical Specifica-

tions, (and)log-the condition...in

a timely manner based on the significance

of the condition." P'ontrary to the above, the licensee determined

at approximately

ll:00 a.m.on November 21, 1988 that the channel calibration

Surveillance

Requirement

for the degraded voltage protection

circuit on vital switchgear

SM-7 was delinquent, but the Shift Manager did not log the condition or begin the action required by the Technical Specifications (i.e.', Section 3.0.3;place the unit in at least STARTUP within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />)until 2:00 p.m.This is a Severity Level IV violation (Supplement

I).Validit of Violation (Amended)The Supply System acknowledges

the validity of this violation.

The failure to declare the SM-7 undervoltage

protection

circuitry inoperable

while pursuing relief avenues with NRR constitutes

non-conservative

application

of Technical Specification

requirement

3,0.3.In this particular

case, it should be noted that Senior Plant Management (not the Shift Manager)assumed the responsibility

for determination

of operability

and the development

of an action plan to resolve the issue.As part of the action plan to determine the operability

status of the SM-7 undervoltage

protection

circuit, reviews of procedures, LCOs, plant configuration

and testing philosophy

were performed.

As previously

stated, the recognition

that current, valid surveillance

data was not available on portions of the undervoltage

circuitry occurred at approximately

1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br />.

Based upon the belief that NRR concurrence

to proceed without complying with paragraph 3.0.3 would be forthcoming, the Supply System inappropriately

delayed entry into the 3.0.3.In retrospect, the more appropriate

action would have been to apply 3.0.3 at 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br />, initiate a plant shutdown, and then continue with the corrective

action plan and discussions

with the NRC.Corrective

Ste s-Taken/Results

Achieved (Amended)Following specific indication

from Region V that relief from NRR could not proceed without entry into 3.0.3, at 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br /> on November 21, 1988 the Supply System initiated a plant shutdown.Prior to completing

the shut-down, the relays in question were calibrated

and the shutdown terminated

per paragraph 3.0.3.The Supply System has also requested the Technical Specification

amendment suggested in Generic Letter 87-09, which would allow a 24-hour time limit for completing

a missed surveillance

when the allowable outage time of the action requirements

is less than the 24-hour limit (which was the case of the relays involved).

Corrective

Action to be Taken (Amended)As discussed in the January, 1989 Management

Meeting, at the point in time it has been determined

that noncompliance

with the Technical Specifications

exists, the applicable

LCO-will be entered and the required action statements

implemented.

This act'ion will be taken independently

of any dialogue (e.g.discussion

of methods of relief)which may be ongoing between the Supply System and the NRC.In addition, paragraph 3.0.3 will be appropriately

applied in the future.To better understand

the processes associated

with the available methods of relief from Technical Specification

requirements, a guidance document on this subject will be prepared-by the Plant Licensing Department.

Date of Full Com liance (Amended)The Supply System is currently in full compliance

and will conservatively

apply 3.0.3 when such situations

occur.