ML20100B056
| ML20100B056 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 11/21/1984 |
| From: | Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| NUDOCS 8412040174 | |
| Download: ML20100B056 (9) | |
Text
r
.Ricaygg l;f;c.
~ Washington Public Power Supply System P.O. Box 968 3000 GeorgeWashington Way Richland, Washington 99352 bbk)9[3724000 H!12 y
%Cm;;yy Docket No.
50-397 November 21, 1984 Mr. D.F. Kirsch, Acting Director Division of Reactor Safety and Projects U.S. Nuclear Regulatory Camission Region V 1450 Maria Lane, Suite 210 Walnut Creek, California 94596
Subject:
NUCLEAR PLANT NO. 2 LICENSE NO. NPF-21 NRC INSPECTIONS 84-09, 84-13 & 84-18
Reference:
Letter G02-84-426, 07/12/84, Supply System /NRC Letter G02-84-433, 07/26/84, Supply System /NRC Letter G02-84-479, 08/24/84, Supply System /NRC Letter G02-84-492, 09/06/84, Supply System /NRC Over the past several months, the Washington Public Power Supply System has replied to Notices of Violation.
Subsequent to our initial re-
-sponses, several discussions regarding the issues have been held with representatives of your office.
Based on the conclusions from these discussions and our analysis of the events described in three violation notices, the Supply System hereby provides amended responses to:
1)
Notice of Violation A, Letter NRC/ Supply System, 06/13/84 2)
Notice of Violation B, Letter NRC/ Supply System, 06/29/84 3)
Notice of Violation A, Letter NRC/ Supply System, 08/07/84 i
Our amended response consists of this letter and Appendix A (attached).
8412040174 841121 PDR ADOCK 05000397 G
') ZE-DI
c.
.Mr. D.F. Krisch
~ '
Page 2 NRC INSPECTIONS 84-09, 84-13 and 84-18 In Appendix A, an explanation of the violations are presented, the cor-rective. steps taken outlining results achieved, and the dates of full compliance specified.
The vertical lines in the margin indicate amended portions of each response.
Should you have any questions concerning this amended response, do not hesitate to contact me.
-::t j G. C. Sorensen Manager, Regulatory Programs GCS:RLK:mm Attachment t
t y
,,v..
.,,~.w..,
g w w
---a.
y
.e-w
,-vae--
~
- v
~
~
APPENDIX A NRC INSPECTION 84-09 April 1-30,1984 I
A.
-Notice of Violation
" Technical Specifications Section 3.6.1.3 required, in part, that "Each primary containment air lock shall_. be OPERABLE,... With one primary containment air lock door inoperable:
Maintain at least the OPERABLE door closed and either restore the inoperable air lock door to OPERABLE status -within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or lock the OPERABLE air lock door closed... Otherwise, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following E4 hours." This specifi-cation is applicable in Operational Conditions 1, 2 and 3.
Contrary to the above requirements, on April 17,1984 at 10:30 p.m. the gears in the interlock mechanism for the containment air lock doors were found to be broken, rendering the device inoperable.
The mechanism was repaired and returned to service at 5:00 p.m. on April 19, 1984.
During the period that the interlock was out of service, several entries into the containment were made by licensee personnel.
Further, on April 18, 1984, the inner door was locked closed.
However, on April 19,1984, with the outer door open, the inner door, although closed, was not locked.
Reactor operational condition 2 was in effect during the entire period."
l This is a severity level IV violation (Supplement I).
Validity of Violation The drywell air lock interlock mechanism was determined to be inoperable at 1030 hours0.0119 days <br />0.286 hours <br />0.0017 weeks <br />3.91915e-4 months <br /> on April 17, 1984 and returned to service at.1700 hours0.0197 days <br />0.472 hours <br />0.00281 weeks <br />6.4685e-4 months <br /> on April 19,1984.
During this time period the plant imposed administrative controls to prevent inadvertently having both doors open at one time. -
These administrative controls included the requirement for an operator trained in the use of the doors-to be present to operate the doors upon entry to the drywell.
In addition, access to the drywell was also limited by locking u e of the doors beginning at 1636 hours0.0189 days <br />0.454 hours <br />0.00271 weeks <br />6.22498e-4 months <br /> on April 18, 1984.
Despite the precautionary steps taken to satisfy the Technical Specifica-tion requirements, the air lock was found ' to be unlocked subeequent to the time locking was required by.the action statement.
The plant was in Mode 2 and less than 5% power throughout the event.
At least one air lock door was maintained closed and containment integrity was maintained at all times..
1.
Ctrrectiva St':ps Taktn/Results Achieved 1)
Upon discovery that the air lock was unlocked, the Shift Manager on duty immediately initiated action to have the door relocked.
2)
The air lock was repaired and returned to service on April 19, 1984.
3)
The plant was removed from TSAS 3.6.1.3.a.1 at 1700 hours0.0197 days <br />0.472 hours <br />0.00281 weeks <br />6.4685e-4 months <br /> on April 19,1984.-
Corrective Steps to be Taken In any-future. events, involving loss of operability of the air lock door interlock mechanism, repairs will be completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; otherwise one of the operable doors will be locked at all times.
Specific manapment instructions have been provided to the operating l
crews to ensure implementation of this policy and to ensure full compli-i ance with Technical Specification requirements.
Our evaluation of the applicable Technical Specification (3.6.1.3) con-cluded that neither action statement adequately addressed the follow-up action required for an inoperative interlock.
The Supply System will therefore submit a Technical Specification change request to clarify the requirements.
Date of Full Compliance The air lock is operable and the plant is currently in compliance with '
Technical Specification requirements.
Issuance of all management direc-tion on air lock operation following interlock failure was completed by November 5,1984.
The Supply System will submit the Technical Specification change con-cerning follow-up action requirements for an inoperative interlock by December 21, 1984.
4 l
i l
l l
l
~
l '
hRC J:,PECTION 84-13 May 1 - June 5, 1984-B.
" Technical Specifications section 6.8.1 requires that " Written procedures shall be established, implemented, and maintained covering the activi-ties... referenced in Appendix A of Lgulatory Guide 1.33 Revision 2."
The FSAR Section 13.5.11 and 17.2, and the referenced operational Quality Assurance Program Topical Report WPPSS-QA-004, emphasize the if censee's commitment to the details of the Regulatory Guide.
The RG-1.33 Part 1.c prescribes certain administrative procedures " Equipment Control (e.g.
locking and tagging)" and the FSAR Section 13.5.1.3 clariffes that sucl.
administrative procedures include rules and instructions pertaining to clearance orders.
The Plant Procedure 1.3.8 Revision 6 requires:
(1) In section 1.3.8.2.E:
"A change of clearance status is made only after the Shift Manager has reviewed the proposed change and deter-mined that the change does not compromise the initial clearance order....
The addition and/or deletion of tags will be recorded in the " Tag Location" section and the changes initialed by the Shift Manager.
(2)
In section 1.3.8.2.C.1.a:
.the Shift Manager will authorize release of the Clearance Order by the following procedure.
.a.
Indicating " Redundant Verification" is required when the component is safety related or fire protection."
Contrary to the above, on March 28, 1984 addition of four tags (CRD-C-112, 101, 102, and 113) were made to each of three clearance orders (84-3-317, 318, and 319) for work on the control rod drive system hydraulic control units (HCU-4239, 4643, and 4207):
j (1 ) Without the changes initialed by the Shift Manager.
(2) Without the " Redundant Verification Required" indicated on any of the three clearance orders.
This is a Severity Level IV violation (Supplement I).
Validity of Violation (1 ) Additional tags were added to the clearance orders (84-3-317, 318, 319) in order to prevent recurrence of an RPS actuation (LER-028).
These additions were made under specific direction of the Shift l
Manager.
l The purpose of the restrictions on changes to clearance orders (PPM l
1.3.8.3.E) is to ' ensure safe working conditions'.
In the event of j
March 28, the clearance order had not yet been accepted by the craft personnel, the work was not yet authorized and the changes could be made without threat to personnel safety.
Prior to acceptance by the requestor, the clearance order is a work-ing document for use by Operations under the control of the Shift Manager.
Upon acceptance, the document is considered complete and any subsequent changes are governed by sec'cion 1.3.8.3.E of PPM 1.3.8 requiring signoff by the Shift Manager.
Based on this we do not consider this item a violation of Plant pro-cedures or a violation of our. license.
(2) The violation correctly identifies that the referenced clearance orders (84-3-317, 318 & 319) were authorized release without "Redun-dant Verification Required" as required for safety related equipment.
Corrective Steps Taken/Results Achieved o
The requirements for redundant veriff cation of correct equipment status for safety related and - fire protection equipment has been emphasized to all individuals authorized to release clearance orders.
o A procedure deviation to PPM 1.3.8 has been processed which incor-porates a note stating:
When an addition and/or deletion of tags is made to a clearance order prior to the clearance order acceptance by 4
the authorized individual, the changes need to be initialed by the Shift Manager to signify his approval.
Date of Full Compliance The PPM 1.3.8 procedure deviation was initiated on 10/30/84 and approved l
by the Plant Operations Committee on 11/7/84.
s NRC INSPECTION 84-18 June 6_- July 6,1984 A.
Notice'of Violation Technical Specification 6.8.1 states that written procedures shall be established, implemented and maintained covering "The applicable proce-dures recomended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978" and "The applicable procedures required to implement the requirements of NUREG-0737".
Regulatory Guide 1.33 states that typical safety related activities to be covered by written procedures include
" Bypass of safety functions 'and Jumper Control".
NUREG-0737 item I.C.6.3 states that "Except in cases of significant radiation exposure, a second j-quali1fied person should verify correct implementation of equipment con-i trol measures such as tagging of equipment".
The WPPSS Procedure 1.3.9 contains implementing details of the above requirements and specifies that procedures "shall be used for all safety-related and non-safety-related systems".
It allows that jumpers positively identified in ap-proved procedures are excluded from the requirements of this procedure.
To qualify for the exclusion, the other procedure must:
"a.
Clearly spectfy that the Shift Manager must be notified prior to installation and removal, h.
The other procedure identifies the need for independent ver-ification of installation and removal, and e.
The jumpers or lifted lead tags are controlled by the Shift Manager and are issued by him to the procedure used to control the work".
Contrary to the above, on June 25, 1984, Supply System technicians used procedure ' 7.4.3.3.1.44, which involved the installation of two jumpers, but the procedure did not " Clearly specify that the Shift Manager must be notified prior to installation and removal" nor did it identify "the need for' independent verification of installation and removal".
The Shift l
Manager was not notified prior to the installation or removal of the jumper and did not issue a jumper tag "to the procedure used to control the work".
The ' jumpers were applied to the initiation logic of the 7
engineered safeguard auto depressurization system.
This is a severity level IV violation (Supplement I).
Validity of Violation This violation notice involves three distinct issues.
The first issue concerns notification of the Shift Manager prior to installation or re-moval of jumpers.
Plant procedures require that the Shift Manager auth-orize (by signature) performance of all surveillance test procedures with the exception of HP/ Chemistry procedures.
This is obtained immediately prior to test performance.
If, during performance of a test, it becomes apparent that the test may be interrupted and/or completion of the test delsyed,- the Shift Manager is notified.
Upon completion of testing, the Shift Manager reviews the results and system status and again signs the procedure.
The Shift Manager is knowledgeable of the surveillance and this notification process provides the information required for' jumper and/or lifted lead status.
The Shift Manager authorized perfomance of this surveillance test and was knowledgeable of the jumper status, therefore no further notification was required. u
~
F Tha s::cend. issu2 involvss ind pendent ~ varification of the - installation 1
.and removal of two jumpers.
PPM 1.3.9, Control of Electrical and Mechan-
'ical Lifted Leads and Jumpers, paragraph 1.3.9.3.B.2.b, revision 4 dated i-12/22/83,. states that the other procedure must " Identify the need for independent verification ~ of installation and removal (if required)".
The
- intent of this exclusion is to provide the Shift Manager an option; he may-or may not assign an independent verifier to the procedure activity.
The WNP-2 approach to independent verification of -jumpers / lifted leads was outlined in the September 19, 1983 letter from J.W. Baker to J.D.
i Martin.
It stated that " Independent verification of these devices will be required on the installation and removal for all safety related sys-tems and fire protection where the work is not _ being done to an approved i
i procedure.
Independent verification will not be required if the device is installed and removed and documented in an approved procedure".
This approach was reviewed and concurred with by the NRC as documented in your -
report. number 84-08, dated April 27, 1984.
Installation and removal of the jumpers in question was specified and documented in the surveillance
. procedure and thus did not require independent verification.
r
' The last item involves use of jumper tags.
As the violation notice cor--
rectly noted, no jumper tag was issued "to the procedure used to control.
the work".
This resulted from contradictions in the exclusion conditions of PPM 1.3.9 (paragraph 1.3.9.3.B.2., Condition e.) which required the issuance of a jumper tag, thus defeating the intent of the other exclusions.
Corrective Steps Taken/Results Achieved A deviation to PPM 1.3.9 was -approved on 7/25/84 to eliminate further l
confusion on the use of lifted lead / jumper tags during surveillances.
PPM 1.3.9 no longer specifies lifted lead / jumper tag use when the exclu-sfons specified under 1.3.9.3.B are met.
The Supply System was in the process of reviewing INPO Good Practice OP-202 when this event occurred and our corrective action followed the guidelines of OP-202.
Further analysis of the Plant's position of lifted leads and jumpers re-sulted in a decision to specify that jumpers used during surveillance tests should be controlled and checked out through the Shift Manager.
The jumper (s) will be checked out to specific surveillance -test proce-dures.
A procedure deviation incorporating these instructions was processed on 11/5/84.
Additionally, a letter was -issued which provides additional clarification on the issue of independent verification with regard to surveillance testi ng. - The letter outlined acceptable methods for the performance-of independent verification and provided direction on the relationship.to procedure content.
The Plant's intention is-to have each Surveillance Test procedure's implementing logic written in such a manner as to pre-vent the subsequent completion of procedure steps unless the lifted lead /
jumper steps are correctly followed.
For those instances where it is not possible to write test logic in this manner, a second individual will be assigned verification responsibilities.
The PPM 1.3.9 procedure will be revised to implement these instructions.
In support of our. long term objectives in this area, the Plant Mainte-nance Department will review all Electrical and Instrument and Control surveillance test procedures for lifted lead / jumper identification and verification.
Date of Full Compliance o
The clarification letter to Department Managers and Maintenance Department Supervisors was issued on 11/01/84.
o Revise PPM 1.3.9 by 12/1/84.
o The Maintenance Department surveillance test procedure review will be completed by 2/28/85.