ML17284A576

Responds to NRC 880823 Ltr Re Violations Noted in Insp Rept 50-397/88-27.Corrective Actions:Plant Procedure 4.12.4.5, Design Basis Ash Fallout, Revised to Better Define When & How Filters Should Be Replaced

ML17284A576
Person / Time
Site:	Columbia
Issue date:	10/24/1988
From:	SORENSEN G C WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
RTR-REGGD-01.033, RTR-REGGD-1.033 GO2-88-220, NUDOCS 8811020281
Download: ML17284A576 (4)

See also: IR 05000397/1988027

Text

ACCELERATED

DISTRIBUTION

DEMONSTRATION

SYSTEM REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)CESSION NBR:8811020281

DOC.DATE: 88/10/24 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)l SUBJECT: Responds to NRC 880823 ltr re violations

noted in Insp Rept 50-397/88-27.

DISTRIBUTION

CODE: IEOID COPIES RECEIVED: LTR (ENCL (SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice

of Violation Response NOTES RECIPIENT ID CODE/NAME PD5 PD I NTERNAL: ACRS DEDRO NRR/DLPQ/PEB

11 NRR/DOEA DIR 11 NRR/DREP/RPB

10 NRR/PMAS/ILRB12

OE L EBERMAN,J F 02 RGN5 FILE 01 ERNAL: LPDR NSIC COPIES LTTR ENCL 1.1 2 2 1 1 1 1 l,l 2 2 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME SAMWORTH,R

AEOD NRR MORI SSEAU I D NRR/DLPQ/QAB

10 NRR/DREP/EPB

10 NRR/DRIS DIR 9A NUDOCS-ABSTRACT

OGC/HDS2 RES/DSR DEPY NRC PDR RESL MARTIN,D COPIES LTTR ENCL 1 1 1 1 1 1 1~1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 8'D, D 8 A NOXK K)ALL"RIDS" RECIPIENTS'ZEASE

HELP US TO REDUCE HASTE!CXÃI'ACZ'IHE DOCUMENTS CDWZROL DESK BOOM Pl-37 (EXT.20079)KO%LIMEADE YOUR NAME PMH DISTRIBUTION

LISTS PDR DOCUMEMZS YOU DGNPT NEED>TOTAL NUMBER OF COPIES REQUIRED: LTTR , 25 ENCL 25

WASHINGTON

PUBLIC POWER SUPPLY SYSTEM I'.0.Box 968~3000 George Washington

Way~Richland, Washington

99352 October 24, 1988 G02-88-220

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

Commission

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

S ubject: NUCLEAR PLANT NO.2 LICENSE NO.NPF-21 NRC INSPECTION

REPORT 88-27 RESPONSE TO NOTICE OF VIOLATION The Washington

Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated September 23,.1988.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, CM~g4~r G.C.Sorensen, Manager Regulator'y

Proyrams JDA/bk Attachments

cc: JB Hartin-NRC RV NS Reynolds-BCP8R RB Samworth-NRC DL.Williams

-BPA NRC Site Inspector-901A88il020281

881024 PDR ADOCK 05000'F7 9 PDC

APPENDIX A During an NRC inspection

conducted on July 8-August 23, 1988 a violation of NRC requirements

was identified.

In accordance

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

Actions," 10 CFR Part 2, Appendix C (1987), the violation is listed below: Technical Specification 6.8.1 states in par t: "Hritten procedures

shall be established, implemented, and maintained

covering the activities...

recommended

in'Appendix A of Regulatory

Guide 1.33, Revision 2, February 1978." Appendix A of Regulato'ry

Guide 1.33, Revision 2, February 1978 states, in part,"The following are typical safety related activities

that should be covered by written procedures....6.w.

Acts of Nature." Contrary to the above, as of July 19, 1988, procedures

had not been esta-blished to provide for the installation

and replacement

of air intake filters designed to protect the Emergency Diesel Generators

in the event of volcanic ash fallout.This is a Severity Level IY Yiolation (Supplement

1).Val i di t of Vi ol ati on The Supply System acknowledges

the validity of this violation.

The reason for the violation was insufficient

follow-through

on a commitment

made in response to NRC Unresolved

Item 87-19-09 (Design concerns regarding ash filters for the diesel generators).

Although Plant Procedure (PPM)4.12.4.5,"Design Basis Ash Fallout" (Revision 3), was issued on June 17, 1988, the commitment

to determine 1)the manhours required to install the ash fall filters, and 2)the number of replacement

filters needed to sustain the Plant for the expected ash fallout period had not been completed.

Corrective

Ste s Taken/Results

Achieved 1.PPM 4.12.4.5 was revised to better define when and how the filters should be replaced.Major changes include 1)providing storage and staging locations for the filters, and 2)modifying filter changeout requirements.

2.Dedicated filters have been procured and are currently stored on site.In the event of an ash fallout occurrence, these filters will be moved from the storage area to the staging locations specified in PPM 4.12.4.5.Corrective

Action to be Taken Regarding the reason for the violation (insufficient

follow-through

on commitments), the Plant Tracking Log (PTL)monitors the processing

of external and other commitments

by tracking initial entry, document processing

and final closeout.A PTL task force has been established

to review the accuracy of information

in PTL, update the assigned responsibility

for each task, and reprioritize.

In addition, periodic followup status reviews will be performed to ensure completion

of assigned actions.Date of Full Com liance PPN 4.12.4.5 (Revision 4)will be i ssued by October 31, 1988.