ML17285A082

Responds to NRC 881027 Ltr Re Violations & Deviations Noted in Insp Rept 50-397/88-32.Corrective Actions:Missing Lock Washers Replaced & All Hydraulic Control Unit hold-down Bolts Torqued Checked

ML17285A082
Person / Time
Site:	Columbia
Issue date:	11/28/1988
From:	SORENSEN G C WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
GO2-88-249, NUDOCS 8812020259
Download: ML17285A082 (17)

See also: IR 05000397/1988032

Text

ACCELERATED

DISTUTJON DEMONSTRATION

SYSTEM REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)CESSION NBR:8812020259

DOC.DATE: 88/11/28 NOTARIZED:

NO DOCKET FACIL:50-397

WPPSS Nuclear Project, Unit 2, Washington

Public Powe 05000397 AUTH.NAME AUTHOR AFFILIATION

SORENSEN,G.C.

Washington

Public Power Supply System RECIP.NAME

RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)SUBJECT: Responds to NRC 881027 ltr re violations

noted in Insp Rept 50-397/88-32.

DISTRIBUTION

CODE: IE01D COPIES RECEIVED:LTR

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

of Vi lation Response NOTES'ECIPIENT

ID CODE/NAME PD5 PD INTERNAL: ACRS DEDRO NRR/DLPQ/PEB

11 NRR/DOEA DIR 11 NRR/DREP/RPB

10 NRR/PMAS/ILRB12

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AEOD NRR MORISSEAU,D

.NRR/DLPQ/QAB

10 NRR/DREP/EPB

10 NRR/DRIS DIR 9A NUDOCS-ABSTRACT

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LISTS FOR DOCUMlWIS RXJ DQNIT NEED)D S TOTAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24

.I WASHINGTON

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

Way~Richland, Washington

99352 G02-88-249

November 28, 1988 Docket No.50-397 U.S.Nuclear Regulatory

Commission

Attn: Document Control Desk Mail Station Pl-137 Washington, D.C.20555 Subject: NUCLEAR PLANT NO.2~LICENSE NO.NPF-21 NRC INSPECTION

REPORT 88-32 RESPONSE TO NOTICE OF VIOLATION'AND, DEVIATION The Washington

Public Power Supply System hereby replies to the Notice of Violation and Notice of Deviation contained in your letter dated October 27, 1988.Our reply, pursuant to the provisions

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

A, B and C (attached).

In Appendix A, the violation is addressed with an explanation

of our position regarding validity, corrective

action and date of full compliance.

In Appendix B, the deviation is addressed with an explanation

of our position regarding validity, corrective

action and date when corrective

action will be completed.

In Appendix C your concerns on implementation

of the process for evaluating

vendor information

and industry experience, effecting timely correc-tive action for discrepancies, and assessing questions of safety system opera-bility are addressed.

8812020255'81128

PDR ADOCK 05000$'$7 0 PDC

Page Two NRC INSPECTION

REPORT 88-32 RESPONSE TO'NOTICE OF VIOLATION AND DEVIATION The Inspection

Report on page 25 states: "The original installation

and quality inspections

of the HCUs were performed by General Electric personnel.

It appeared that the Supply System did not take any responsibility

for performing

their own quality inspections

to ensure that the HCUs were installed properly." The following is the Supply System response to this statement.

The Supply System was responsible

for overall construction

quality, which was implemented.through a multi-level

program.The installer of the HCUs, General Electric Installation

Services and Engineering, was a subcontractor

to the site mechanical

contractor (WBG)and had first line responsibility

for quality.The mechanical

contractor

was responsible

for monitoring

the GE IS8E work and quality programs.The mechanical

contractor

quality programs were overviewed

by the site construction

manager (Burns 8 Roe Inc.or Bechtel), who in turn was overviewed

by the Supply System.Although the Supply System did not perform first line inspections

of the GE IS8E work, quality programs were in place to ensure quality work.Therefore, it is not necessary to perform first line quality inspections

in order to be responsible

for work.Very truly yours, G.C.orensen, Manager Regulatory

Programs JDA'lw Attachments

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

APPENDIX A APPENDIX A Page 1 of 3 During an NRC inspection

conducted during the period of August 29 to September 30, 1988, a violation of NRC requirements

was identified.

In accor-dance with the"General Statement of Policy and Procedure for NRC Enforcement

Actions," 10 CFR Part 2, Appendix C (1988), the violation is listed below: P 10 CFR Part 50, Appendix B, Criterion V, is implemented

by Section 5.2.1 of Washington

Public Power Supply System's Operational

guality Assurance Program Description, Revision 11, which states: "Activities

that affect safety-related

functions of plant items shall be described by and accom-plished through implementation

of documented

procedures, instructions, or drawings as appropriate." Procedure 1.3.12, Revisions 10 and 11,"Plant Problems" step 1.3.12.5.A.1

and Revision 12, Step 1.3.12.6 require that any person who observes a plant problem shall immediately

notify his/her supervisor

and initiate a problem deficiency

report/nonconformance

repor t.Contrary to the above requirements:

(1)As of September 21, 1988, neither a problem deficiency

report nor a nonconformance

report had been prepared to identify that five safety-related hydraulic control units (HCUs)were missing a lock washer on six hold down bolts, and five additional

HCUs had seven loose hold-down bolts.The deficient conditions

were identified

on January 6, 1988.(2)As of September 28, 1988, neither a problem deficiency

report nor a nonconformance

report had been prepared to identify that HCU 26-11 was misaligned

and had installed only two of the four hold down bolts.required per design drawings.The deficient conditions

were identi-fied on September 26, 1988.This is a Severity Level IY Violation (Supplement

I).4 Validit of Violation The Supply System acknowledges

the validity of the violation.

The Supply System agrees that deficient plant conditions

which do not meet plant design requirements

should be documented

on a Nonconformance

Report (NCR)to ensure that an operability

evaluation

is performed and documented.

Also an NCR receives a more timely review by Plant Management

and Plant Operations

Staff.Every NCR is reviewed by the Plant Shift Manager (a Licensed Senior Reactor Operator)and by Plant Management

in the morning management

meeting which is chaired by the Plant Manager or Assistant Plant Manager and attended by Plant Department

Managers.Corrective

actions specified in the iomediate disposition

of an NCR.normally have a higher priority than Operational

Experience

corrective

actions.

APPENDIX A Page 2 of 3 The cause of the violation is inconsistent

implementation

of the Plant Problem Procedure which does not require a Plant Deficiency

Report (PDR)or Nonconformance

Report (NCR)to be written for every plant problem.In fact the procedure relies on individual

judgement to determine which problems require a PDR or NCR.The purpose section of the Plant Problems Procedure in paragraph 1.3.12.1 states in part"Plant Problems as applied to this procedure may not include those deficiencies

identified

and evaluated by other plant procedural

means." In the instance of the missing lock washers and loose bolts plant personnel believed that implementation

of the External Operating Experience

Review Procedure, PPM 1.10.4, was an acceptable

alter native to implementing

the Plant Problem Procedure by initiating

an NCR.In the case of the problems found with the Control Rod Drive (CRD)Hydraulic Control Unit (HCU)for CRD 26-11 an NCR was not issued until September 29, 1988 because the System Engineer intended to add the problem to the original NCR issued on September 23, 1988.The use of the Operating Experience

Review process to resolve problems related to actual physical plant problems is not appropriate

because the process does not provide a sufficient

level of management

involvement

for operability

r eview.Corrective

Ste s Taken/Results

Achieved The missing lock washers have been replaced.All HCU hold down bolts have been torqued checked.In no case were more than two bolts on any HCU found that moved during the torque verification.

Engineering

calculations

showed that only two bolts per HCU are required to meet seismic design requirements.

Based on Engineering

calculations

which verified the seismic operability

the nonconforming

condition of HCU 26-11 was approved for operation.

On October 27, 1988 the nonconforming

conditions

were reworked and HCU 26-11 now meets all design r equirements.

The Plant Problems Procedur e was revised to formally implement the"potential

problem" NCR process.A letter was sent to all plant personnel describing

the program changes.The Plant Li'censing

and Assurance Engineers were trained on their responsibilities

with regard to PDR/NCR initiation

in accordance

with the Plant Problem Procedure.

Corrective

Action to be Taken A totally new plant problem process is being developed by which actual and potential problems will be documented

on a problem evaluation

request (PER).Implementation

of the PER process removes the responsibility

for determining

the appropriate

Plant Problem process from the individual

and transfers it to Plant Management.

APPENDIX A Page 3 of 3 The External Operating Experience

Review Procedure will be revised to ensure that a PER is initiated for any problem which meets the definition

of a plant problem in the Plant Problem Procedure.

Date of Full Com liance The plant is currently in full compliance

and the planned changes to the plant problem process wi*ll further improve process implementation.

The"new" Plant Problem process will be implemented

by January 1, 1989.The external Operating Experience

Review Procedure will be revised by January 1, 1989.

APPENDIX 8 APPENDIX B Page 1 of 3 If During an NRC inspection

conducted during the period of August 29 to September 30, 1988, a deviation from your commitments

to the NRC was identi-fied.In accordance

with the General Statement of Policy and Procedure for NRC Enforcement

Actions, 10 CFR Part 2,'Appendix C (1988), the deviation is listed below: The Washington

Public Power Supply System reply (WPPSS G02-88-025, dated January 29, 1988)to a Notice of Violation issued with NRC inspection

report 50-397/87-19

stated in part in Section B, under Date of Full~ghi.h hf h f h f h g f instrumentation

will be accomplished

by July 20, 1988.Contrary to the above, at the time of this inspection

the new calibration

of diesel generator fuel oil tanks DO-TK-1A, DO-TK-1B and DO-TK-2 had not been completed and the tanks had been declared operational.

This is a Deviation from a commitment.

Validit of Deviation The Supply System acknowledges

the validity of the deviation.

The Supply System did state in our response to Notice of Violation, Item B (pp 1-2)of Appendix A, of NRC Inspection

Report 50-397/87-19=

that each Diesel Fuel Oil Storage Tank Level Instrument

and Low Level Alarm would be recali-brated by July 20, 1988 and they were not.The Notice of Violation response stated the operability

of each tank is verified daily by direct measurement.

Therefore, the failure to complete the calibration

of the tank level instruments

and low level alarms had no affect on tank operability.

Also, contrary to the Notice of Deviation the tank level instruments

and low level alarms had not been declared operable at the time of the Inspection (see discussion

below).The Supply System intended to and attempted to meet this commitment.

The following is a summary of the action taken to date to meet this commit-ment.On November 3, 1987, prior to NRC Inspection

Report 87-19 being issued, Maintenance

Work Requests (NWRs)were initiated to calibrate the tank level instrument

and low level alarm for each Diesel Fuel Oil Storage Tank.Also, at this time it was determined

that new, calibration

data for each tank level instrument

was required and to obtain this data it would be necessary to transfer large quantities

of fuel oil.Between May 17 and Nay 28, 1988 the calibration

data for each Diesel'uel

Oil Storage Tank was obtained by transferring

fuel oil from tank to tank and correlating

the direct (dipstick)

measurement

of gallons of fuel in the tank to the tank level instrument

output.Using the results of the calibration

data,

APPENDIX B Page 2 of 3 the three tank level instruments

and low level alarms'were calibrated

by July 7, 1988 prior to the commitment

date;however, the instruments

and alarms could not be declared operable until the Instrument

Setpoint Change Request (ISCR), which included the calibration

data, was approved by the Plant Technical Department.

The ISCR for the Division 1 and 2 Diesel Fuel Oil Storage Tanks was approved on August 5, 1988.Non-linearity

problems were identified

in the tank calibration

data for the Division 3 Diesel Fuel Oil Storage Tank and the associated

ISCR was not approved.The Maintenance

Work Requests (NWRs)for the calibration

of the Division 1 and 2 Diesel Fuel Oil Storage Tank Level Instruments

and Low Level Alarms were completed and the instruments

and alarms were declared operable on October 3, 1988.Because of the problems with the calibration

data for the Divi-sion 3 Diesel Fuel Oil Storage Tank Level Instrument, the instrument

and alarm calibrations

cannot be completed until an extended outage.The Pl.ant Technical Staff Compliance

Group enters all outstanding

NOV cormitments

into the Plant Tracking Log (PTL)with a due date at least two weeks prior to the commitment

date.The requirement

to calibrate the Diesel Fuel Oil Storage Tanks was entered into the PTL on Febur ary 16, 1988 with a due date of July 6, 1988.A Compliance

Engineer weekly reviews an NOV PTL late report to determine commitments

due within the next two weeks.In this instance, the Compliance

Group did contact the responsible

Plant Engineer who stated that the instrument

calibrations

were complete and all that was needed was for the ISCR to be approved by the Plant Technical Staff.At this time, the Compliance

Engineer believed the commitment

date would be met.After the due date, the NRC was not notified because the Compliance

Engineer thought the instruments

were calibrated

and it was just a matter of clearing up paper work.Compliance

continued to work with the Plant Engineer and later with his Supervisor

to get the paper work completed so these items could be formally closed.Corrective

Ste s Taken/Results

Achieved The Division 1 and 2 Diesel Fuel Oil Stor age Tank Level Instruments

and Low Level Alarms were declared operable on October 3, 1988.The Division 3 Diesel Fuel Oil Storage Tank continues to be verified daily and after any Division 3 Diesel Generator operation by direct measurement.

e

APPENDIX B Page 3 of 3 Corrective

Action to be Taken The Division 3 Diesel Fuel Oil Storage Tank Level Instrument

and Low Level Alarm will be recalibrated

during the R4 Maintenance

and Refueling Outage.The calibration

data required to recalibrate

the instrument

cannot be obtained until an Outage because of the necessity to transfer 13,000 gallons of diesel fuel between tanks using a temporary transfer pumping system.A program will be initiated whereby the Compliance

Engineer will provide each Manager a four week look ahead and overdue list of Compliance

commit-ments due.Both lists will be issued every two weeks and each Manager is responsible

to meet or notify Compliance

of changes in commitment

due dates.If required, the Compliance

Group will notify the NRC of commitment

changes.Date of Corrective

Action Com letion As stated in the Notice of Violation, the diesel fuel oil supply in the Division 3 Diesel Fuel Oil Storage Tank is verified daily and after any Division 3 Diesel Generator operation by direct measurement

and therefore the Plant is currently in full compliance.

I The Division 3 Diesel Fuel Oil Storage Tank Level Instrument

and Low Level Alarm will be calibrated

by August 1, 1989;The four week look ahead Compliance

commitments

due and Compliance

commitments

overdue lists will be implemented

by January 9, 1989.

APPENDIX C Page 1 of 2 APPENDIX CThree independent

evaluations

of the WNP-2 Operating Experience

Review (OER)Program have been performed in recent months.First, an annual program effec-tiveness evaluation

was performed by the Supply System in May, 1988, using INPO Good Practice OE-901, Rev.1, as a guide.Second, INPO performed its annual plant review in June, 1988, which included an evaluation

of the OER program.Third and finally, the Supply System performed a QA Audit in July, 1988.As a result of the issues raised by these evaluations

or audits, the Supply System developed an OER improvement

plan for WNP-2 in August and September, 1988.In summary, the evaluations

concluded that the basic processes in the OER program were adequate;however, timely implementation

of corrective

action items and review of corrective

action effectiveness

were noted as areas requir-ing improvement.

In response to these evaluations, WNP-2 has initiated, and is currently imple-menting, a plant wide OER action item backlog reduction effort and an OER program improvement

effort with the following major aspects,'.

Increased management

focus from staff and Line Managers to assure timely and effective execution of the OER program.This includes increased attention to assure that actions taken are effective as well as assuring that actions are proper and complete before closing.Supplemental

outside service resources are being applied to OER action items to attain a substantial

backlog reduction by July, 1989.Increased focus on assuring effort is applied to tasks most important to safety.4.Increased use of total plant scheduling

for OER tasks with monitoring

of performance

to schedule.5.Increased-

emphasis on establishing

firm schedules.

especially

for the hardware affecting OERs.6.Improve the periodic monitoring

of the timeliness

and effectiveness

of the OER program and provide per iodic reports to Plant and'orporate

Manage-ment.

A~

APPENDIX C Page 2 of 2 Operability/reportability

questions which arise as a result of review of industry operating experience

are dealt with as an integral part of the OER program by plant policy as implemented

in Plant procedure PPM 1.3.12-Plant Problems.Specifically, if any person, at any time during execution of his responsibilities, becomes aware of a potential or real problem regarding tech-nical adequacy, operability, or reportabi lity related to the OER issue involved, that person is responsible

to document the question on an NCR per PPM 1.3.12.Plant Management

has recently reemphasized

this policy and'has specifically

emphasized

the use of the potential problem NCR as a means of assuring that potential problems are effectively

documented

and brought to management

attention for resolution.

OER effectiveness

reviews are of two types at WNP-2.An annual, overall OER program effectiveness

assessment

is procedurally

required by NSAG assessment

procedure 1.10.8.The other type of effectiveness

assessment

would be per-formed on a selective bases as judged appropriate

by NSAG and/or plant manage-ment in accordance

with plant procedure 1.10.8.The guidelines

for selecting an individual

OER issue for assessment

may typically include;a major issue, an issue important to safety, a"repeat" issue, an issue extending over a rela-tively long period of time, an issue involving extensive interfacing

personnel or requirements, an issue randomly selected to assess effectiveness

of the industry experience

information

review or the effectiveness

of implemented

corrective

action resulting from the review.In summary, WNP-2 Has performed an assessment

of its OER program and is imple-menting corrective

actions in response to the identified

problems.We believe these actions are appropriate

and will significantly

'improve OER program effec-tiveness over the next several months of implementation.

Finally, it is our intent to establish company wide goals for the timely processing

of OER issues.These goals will consider the INPO guidelines (expected to be issued in the near future)relative to this issue.