ML17278A412

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Responds to NRC 850807 Ltr Re Violations Noted in Insp Rept 50-397/85-22.Corrective Actions:Two Cardboard Boxes Containing Air Filters Located on 525 Ft Elevation of Radwaste Bldg & Small Plastic Bottle of Acetone Removed
ML17278A412
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 09/05/1985
From: SORENSEN G C
WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To: MARTIN J B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML17278A411 List:
References
NUDOCS 8510020104
Download: ML17278A412 (12)


See also: IR 05000397/1985022

Text

JlEQEf PEO f'hip, Washington

Public Power Supply System PO.Roxggg 3000 GaorgaWaahington

Way Richland,Waahington

99352 (gIIct)$P(-5000~il/IIO: (g REQ(pg gg p)p, September 5, 1985 Docket No.50-397 Hr.J.B.Hartin, Regional Administrator

U.S.Nuclear Regulatory

Commission

Region V 1450 Maria Lane, Suite 210 Walnut Creek, California

94596 Subject: NUCLEAR PLANT NO.2 LICENSE NO.NPF-21 NRC INSPECTION

REPORT 85-22 The Washington

Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated August 7, 1985.Our reply pursuant to the provisions

of Section 2.201, Title 10 Code of Federal Regulations, consists'of this letter, Appendix A and Appendix B.In Appendix A, an explanation

of the violation is presented, the corrective

steps taken with results achieved are outlined, and the date of full compliance

is specified.

In Appendix B, a discussion

of the Plant's implementation

of corrective

actions and implementation

of the fire protection

program is provided.Should you have any questions concern'i.ng

our response, please do not hesitate to ontact me.~~G.C.Sorensen Manager, Regulatory

Programs GCS:db Enclosure cc: Hr.W.S.Chin, BPA PDR ADOCN, OGO00397 8

r'II~I II w~li: l l.

APPENDIX A Appendix A Page 1 of 4 As a result of the inspection

conducted June 10-14, June 25-28 and July 9, 1985, and in accordance

with the NRC Enforcement

Policy (10 CFR Part 2, Appendix C), the following violation was identified.

Paragraph 2.c(14)of the WNP-2 operating license states in part: "Fire Protection

Pro ram, (Section 9.5.1, SER, SSER 83, SSER 84)The licensee shall maintain in effect all provisions

of the approved fire protection

program".Technical Specification 6.8.1 states, in part: "Written Procedures

shall be established, implemented, and main-tained covering the activities

referenced

below: g.Fire Protection

Program Implementation".

l.Administrative

Procedure AP 1.3.10.7, which was in effect until June 26, 1985, stated in part: "H.Equipment or spare parts shipped in untreated combustible

pack-ing/shipping

container s may be unpacked in safety-related

areas if required for operating/maintenance

reasons.Normally this unpacking of untreated packing/shipping

containers

will not be done in safety-related

areas.If it is necessary, a fire hazards review shall be done.All combustible

materials shall be removed from the area immediately

following the unpacking.

F.Flammable liquids in any safety-related

area or area containing

safe shutdown equipment shall be limited to 1 gallon of the flammable liquid contained in an approved safety container.

I.Temporary, portable ladders used with in the plant shall, in the interest of mitigating

flame spread, be constructed

of fiberglass;

except that step ladders, less than 9 feet in length, may be of wooden construction".

Contrary to the above requirements:

a~Two cardboard box'es,containing

air filters were located on the 525'levation

of the Radwaste Building, on June 12, 13 and 26, 1985.These items were also identified

by the licensee during an'inspection

on Nay 10, 1985.

~L I~'~'ll

Appendix A Page 2 of 4 b.Small plastic bottles (not"approved safety containers")

con-taining Acetone, a,flammable

liquid, were observed in the"B" Diesel Generator Room and on the 525'levation

of the Radwaste Building on June 13 and 26, 1985.The bottle in the Diesel Generator Room had been identified

by the licensee during an inspection

on June 5, 1985.c.A wood extension ladder about 15'ong (unextended)

was located and apparently

stored inside of the Radwaste Building on June 14 and June 26, 1985.2.Administrative

Procedure 1.3.35 which became effective June 26, 1985, stated in part: "1.3.35.6 Flammable or Combustibles

Procedures

A.Storage of combustible

materials, combustible

and flam-mable liquids and flammable gases, high efficiency

parti-culate air and charcoal filters, dry ion exchange resins, aerosol containers, or other combustible

supplies shall be controlled

in the following manner: Combustible

liquids in 5 gallon containers

or less must be removed or put into storage.a.At end of job or b.At end of shift if job is not continuous

between con-secutive shifts.Aerosol Containers

l.Alcohol and Petroleum base or flammable contents.a.Kept at work site in limited quantity.b.Removal at end of job or shift.Combustible

Materials-Vital Area 1.All combustibles

that can be eliminated

as part of the work process should be.This would include the removal of packaging materials, boxes, wrapping, etc.2.Combustibles

that enter the vital ar ea should be re-moved at the end of the job or shift if work is not continuous

between consecutive

shifts.

V Qa~~P5 1 E if I,

V Appendix A Page 3 of 4 3.When removal is not possible, a Transient Combustible

Permit is required".(This paragraph also required this permit to be located in the area of the combus-tible materials.)

Contrary to the above requirement, on June 27, 1985, with no work in pr ogress in the described areas the following conditions

existed.a~Aerosol containers

with flammable contents had not been removed at the end of a shift in that, aerosol cans of a cleaning agent"Conq-R-Dust" labeled as"flammable" had been left unattended

in the Reactor Building on the 606'2 cans), the 571'1 can)and the 548'2 cans)elevations.

b.c~d.Combustibles

in a vital area had not been removed in that on the 501'levation

of the Reactor Building, several plywood (apparently

untreated)

and cardboard boxes, about two gallons of oil in a polyethylene

jug and a pile of yellow plastic, were located near the containment

entry on June 26 and 27, 1985.No Transient Combustible

Permit was located in the area.Combustibles

in a vital area had not been removed in that six-teen large plastic drums were located on the 501'levation

of the Reactor Building to be used for collecting

liquid from the Standby Liquid Control System.No Transient Combustible

Permit was located in the area.Combustibles

in a vital area had not been removed in that four open cabinets full of anti-contamination

clothing and other combustible

materials were being stored on each of the 471', 501', 522'nd 548'levations

and three open cabinets were stored on the 571'levation

of the Reactor Building.In addi-tion, on the 548'levation

were eleven large polyethylene

bags and on the 501'levation

were seven cardboard boxes of cloth-ing.No Transient Combustible

Permit was located in the area.Previous licensee analysis showed the amounts in the cabinets exceeded that which could safely be stored in the respective

areas.This is a repeat of a violation issued on March 19, 1985.This is a Severity Level IY Violation (Supplement

I)Validity of Violation The Supply System concurs with the validity of this violation.

The steps taken to correct specific areas of concern are included in Corrective

Actions.

~)~~F l'lt

4 g t Corrective

Actions Appendix A Page 4 of 4 Item 1: Item 2: a~b.C.a~Both cardboard boxes located on 525'levation

of the Radwaste Building.on'June 12, 13 and 26, 1985 were removed.The small plastic bottles of acetone were removed from the"B" Diesel Generator Room and the 525'levation

of the Radwaste Building.The wooden extension ladder was removed from the Plant on June 26, 1985.Plant Laborers have conducted a tour of the entire Plant and have removed aerosol cans whose contents are labeled as"flam-mable" as well as cans whose contents failed to state that they're"non-flammable".

Additionally, aerosol cans containing

flammable liquids will be removed from vital Plant areas at job completion

or at the end of the shift if the job is not continuous.

b.c~d.The combustibles

were removed from the 501'levation and from the Plant.It should be noted, however, that these combus-tibles were an accumulation

of material due to a major cleanup at the termination

of the recent Maintenance

Outage and, as such, had been accumulated

from diverse locations within con-tainment and the 501'levation

of the Reactor Building.PPM 1.3.35, Rev.0 with the new requirement

for a Transient Combus-tible Permit, had just been approved on the same day as the NRC inspection.

The large plastic drums located on the 501'levation

of the Reactor Building have been removed.Metal drums will be used for this purpose in the future.The anti-contamination

clothing has been reduced to the amount delineated

on the analysis performed by Industrial

Safety and Fire Protection.

The anti-contamination

clothing on the 501'levation

is now contained in two metal enclosed cabinets.Date of Full Com liance The Supply System is now in full compliance

with the delineated

violations.

l (I S I t~1 g f', p~t E 0 fl

APPENDIX B Appendix 8'age 1 of 1 The Supply System was requested in the cover letter of NRC Inspection

Report 85-22 to respond to concerns of..."Apparent lack of management

attention to the implementation

of effective corrective

actions and your apparent failure to apply sufficient

atten-tion to the area of fire protection

program implementation".

~Res ense It is the Supply System's position that the NRC's concern, as stated, does not reflect the actions in progress by Plant Management

prior to and during the inspection

period.The need for improvements

in the area of housekeeping/fire

protection

has been identified

by management

and programmatic

improvements

have been and are continuing

to be developed utilizing input from both Plant Staff as well as Fire Protection

Specialists.

The concerns addressed by the NRC stem from a lack of adequate interim cor-rective action by the Plant Staff while formalizing

the program upgrade.The importance

of interim corrective

action has since been stressed by the Plant Manager to the Staff.The MNP-2 Plant Management

will continue to focus on the programmatic

aspects of problems in order to provide lasting solutions to any problem.In addi-tion, the Staff will be more sensitive to interim corrective

actions until program changes are implemented.

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