ML17290A797

Responds to NRC 931029 Ltr Re Violations Noted in Insp Rept 50-397/93-40 on 930927-1001.Corrective Actions:Counseled Personnel on Procedure Compliance

ML17290A797
Person / Time
Site:	Columbia
Issue date:	11/29/1993
From:	Parrish J WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GO2-93-277, NUDOCS 9312090123
Download: ML17290A797 (9)

See also: IR 05000397/1993040

Text

XVASHIYiGTOX

PLBL C PORTER SLPPLY SYSTE~l P.O.Box 9Q~3000 Geog>e ll"nabab:.>soss

lairs~Elcssksnd.

Ll is.'omyon 99o52-0968

~(>Yi9)$72-SMO November 29, 1993 G02-93-277

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

Commission

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

Subject: WNP-2, OPERATING LICENSE NO.NPF-21 NRC INSPECTION

REPORT 93-40 RESPONSE TO NOTICE OF VIOLATION 27 C7 m l le RM (~\C7'LO The Washington

Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated October 29, 1993.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.

Sincerely,/.V.Parrish{Mail Drop 1023)Assistant Managing Director, Operations

REF/bk Attachments

cc: BH Faulkenberry

-NRC RV NS Reynolds-Winston 4 Strawn3W Clifford-NRR DL Williams-BPA/399 ,'RC Site Inspector-927N

Appendix A During an NRC inspection

conducted during the period of September 27 through October 1, 1993, 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, the violation is listed below: A.10 CFR Part 50, Appendix R, Section III.L3.d, states: At 3-year intervals, a randomly selected unannounced

drill must be critiqued by qualified individuals

independent

of the licensee's

staff.A copy of the written report from these individuals

must be available for NRC review and shall be retained as a record as specified in section III.I.4 of this appendix.Section 6.6.4.e of Washington

Public Power Supply System Nuclear Operation Standard, NOS-39,"Fire Protection

Program," Revision 5, dated August 16, 1993, states: Triennially

an unannounced

drill shall be critiqued by qualified persons independent

of the Supply System.Contrary to the above, as of September 30, 1993, the licensee had no record of an unannounced

drill which was critiqued by qualified persons independent

of the Supply System in the past three years.This is a Severity Level IV violation (Supplement

Q, Validi f Vi lati n The Supply System acknowledges

the validity of this violation.

The root cause for this event is failure to comply with procedural

requirements.

In accordance

with NOS-39 the Managers of Operations

and Health, Safety and Fire Protection

are responsible

for the performance

of fire drills including an unannounced

drill critiqued by an independent

evaluator every three years.Similar criteria identified

in Generic Letter 82-21,"Technical

Specifications

for Fire Protection

Audits," led to the incorporation

of a randomly selected unannounced

fire drill critiqued by an independent

evaluator into QA's 1985 Triennial Fire Protection

Audit.This resulted in a misinterpretation

that QA had accepted responsibility

for the performance

of future randomly selected unannounced

drills critiqued by an independent

evaluator.

A drill meeting these requirements

had not been planned and performed since the 1985 QA Triennial Fire Protection

Audit.

Appendix A Page 2 of 2 The primary contributing

cause is Inadequate

Interface Among Organizations.

The organization

with the ultimate responsibility

for performing

fire drills was not clearly defined in NOS-39 and the implementing

procedure PPM 1.3.10,"Fire Protection

Program." Both the Operations

Department

and the Health, Safety and Fire Protection

Department

were assigned responsibility

for the performance

of fire drills.orrective te T ken/Re ult Achieved Appropriate

personnel in both the Operations

and Health, Safety and Fire Protection

departments

have been counselled

on procedure compliance.

2.An unannounced

drill was observed by a qualified individual

independent

of the licensee's

staff on October 20, 1993.3 A Scheduled Maintenance

System{SMS)task was put in the SMS system to provide notification

of the required drill.4 Plant Procedure, PPM 1.3.10,"Fire Protection

Program Implementation," was changed to clearly refiect the requirement

for the drill.Nuclear Operation Standard, NOS-39, was changed to clarify responsibilities

to obtain the independent

audit.6.PPM 1.3.10 was changed to require HSFP to be responsible

for conducting

the independently

critiqued three year randomly selected unannounced

drill.7.Other NOS fire drill requirements

have been reviewed to assure proper interfaces

and responsibilities

are identified.

rrective Acti n t be Take No further actions were identified.

Da e of Full m lian II The Supply System was in full compliance

on October 20, 1993, when the randomly selected unannounced

drill was witnessed by an independent

evaluator.

0i P'

ACCELERATED

DISTRIBUTION

DEMONSTFM.TION

SYSTEM REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)CESSION NBR:9312090123

DOC.DATE: 93/11/29 NOTARIZED:

NO DOCKET FACIL:50-397

WPPSS Nuclear Project, Unit 2, Washington

Public Powe 05000397 AUTH.NAME AUTHOR AFFILIATION

PARRISH,J.V.

Washington

Public Power Supply System RECIP.NAME

RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)SUBJECT:.Responds to NRC 931029 ltr re violations

noted in insp rept 50-397/93-40

on 930927-1001.Corrective

actions:counseled

personnel on procedure compliance.

DISTRIBUTION

CODE: IE01D COPIES RECEIVED:LTR

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

of Vio ation Response NOTES: R D RECIPIENT ID CODE/NAME PDV PD INTERNAL: ACRS AEOD/DSP/ROAB

AEOD/TTC NRR/DORS/OEAB

NRR/DRIL/RPEB

NRR/PMAS/ILPB1

NUDOCS-ABSTRACT

OGC/HDS1 RES/HFB EXTERNAL: EG&G/BRYCE,J.H.

NSIC COPIES LTTR ENCL 1 l.2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME CLIFFORD,J

AEOD/DEIB AEOD/DSP/TPAB

DEDRO NRR/DRCH/HHFB

NRR/DRSS/PEPB

NRR/PMAS/ILPB2

0 R REG F 02 GN5~T'TLE 01 NRC PDR 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 D D'R D NOTE TO ALL"RIDS" RECIPIENTS:

D D PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT.20079)TO ELIMINATE YOUR NAME FROM DISTRIBUTION

LISTS FOR DOCUMENTS YOU DON'T NEED!AL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24

XVA.HL~GTO~PLBL C?O~W E t SL'PPL.SYSTEM P.O.Box 9Q~$000 Gcwrge Kill)ingrow

4L"c>l'Iiicla(anc(, lt'asl)ington

99q5~-568 509)372-5000 November 29, 1993 G02-93-277

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

Commission

Attn: Document Control Desk Mail Station P1-137 Washington, D.C.20555 Gentlemen:

Subject:, WNP-2, OPERATING LICENSE NO.NPF-21 NRC INSPECTION

REPORT 93-40 RESPONSE TO NOTICE OF VIOLATION The Washington

Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated October 29, 1993.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.

Sincerely,.V.Parrish (Mail Drop 1023)Assistant Managing Director, Operations

REF/bk Attachments

CC: BH Faulkenberry

-NRC RV NS Reynolds-Winston&Strawn JW Clifford-NRR DL Williams-BPA/399 NRC Site Inspector-927N 93120Voi23

05000397"~wt 93ii29 PDR ADOGK pDR 8

Appendix A During an NRC inspection

conducted during the period of September 27 through October 1, 1993, 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, the violation is listed below: A.10 CFR Part 50, Appendix R, Section III.I.3.d, states: At 3-year intervals, a randomly selected unannounced

drill must be critiqued by qualified individuals

independent

of the licensee's

staff.A copy of the written report from these individuals

must be available for NRC review and shall be retained as a record as specified in section III.I.4 of this appendix.Section 6.6.4.e of Washington

Public Power Supply System Nuclear Operation Standard, NOS-39,"Fire Protection

Program," Revision 5, dated August 16, 1993, states: Triennially

an unannounced

drill shall be critiqued by qualified persons independent

of the Supply System.Contrary to the above, as of September 30, 1993, the licensee had no record of an unannounced

drill which was critiqued by qualified persons independent

of the Supply System in the past three years.This is a Severity Level IV violation (Supplement

I).Validit of Vi la i n The Supply System acknowledges

the validity of this violation.

The root cause for this event is failure to comply with procedural

requirements.

In accordance

with NOS-39 the Managers of Operations

and Health, Safety and Fire Protection

are responsible

for the performance

of fire drills including an unannounced

drill critiqued by an independent

evaluator every three years.Similar criteria identified

in Generic Letter 82-21,"Technical

Specifications

for Fire Protection

Audits," led to the incorporation

of a randomly selected unannounced

fire drill critiqued by an independent

evaluator into QA's 1985 Triennial Fire Protection

Audit.This resulted in a misinterpretation

that QA had accepted responsibility

for the performance

of future randomly selected unannounced

drills critiqued by an independent

evaluator.

A drill meeting these requirements

had not been planned and performed since the 1985 QA Triennial Fire Protection

Audit.

Appendix A Page 2 of 2 The primary contributing

cause is Inadequate

Interface Among Organizations.

The organization

with the ultimate responsibility

for performing

fire drills was not clearly defined in NOS-39 and the implementing

procedure PPM 1.3.10,"Fire Protection

Program." Both the Operations

Department

and the Health, Safety and Fire Protection

Department

were assigned responsibility

for the performance

of fire drills.rrec ive t Taken/Re ul Achieved Appropriate

personnel in both the Operations

and Health, Safety and Fire Protection

departments

have been counselled

on procedure compliance.

2.An unannounced

drill was observed by a qualified individual

independent

of the licensee's

staff on October 20, 1993.3 A Scheduled Maintenance

System (SMS)task was put in the SMS system to provide notification

of the required drill.4.Plant Procedure, PPM 1.3.10,"Fire Protection

Program Implementation," was changed to clearly refiect the requirement

for the drill.~~~~5.Nuclear Operation Standard, NOS-39, was changed to clarify responsibilities

to obtain the independent

audit.6.PPM 1.3.10 was changed to require HSFP to be responsible

for conducting

the independently

critiqued three year randomly selected unannounced

drill.7.Other NOS fire drill requirements

have been reviewed to assure proper interfaces

and responsibilities

are identified.

rrec'v Acti n e Take No further actions were identified.

Date f Full m liance The Supply System was in full compliance

on October 20, 1993, when the randomly selected unannounced

drill was witnessed by an.independent

evaluator.