IR 05000266/1997023

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-266/97-23 & 50-301/97-23

ML20217L059
Person / Time
Site:	Point Beach
Issue date:	04/03/1998
From:	Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Patulski S WISCONSIN ELECTRIC POWER CO.
References
50-266-97-23, 50-301-97-23, NUDOCS 9804070363
Download: ML20217L059 (2)

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Dcoloc6 April 3, 1998 Mr. S. A. Patuiski Site Vice President Point Beach Nuclear Plant 6610 Nuclear Road Two Rivers, WI 54241 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NO.

50-266/97023(DRS); 50-301/97023(DRS))

Dear Mr. Patulski:

This will acknowledge receipt of your letter dated March 23,1998, in response to our letter cated February 19,1998, transmitting a Notice of Violation associated with the above mentioned inspection report at the Point Beach Nuclear Plant. We have reviewed your corrective actions and have no further questions at this time. These corrective actions will be examined during future inspections.

Sincerely, /s/ M. Icach for John A. Grobe, Director Division of Reactor Safety Docket Nos. 50-266; 50-301 Enclosure: Ltr dtd 3/23/98 from S. A. Patuiski, Wisconsin Electric to J. A. Grobe, USNRC See Attached Distribution -

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. cc w/o encl: R. R. Grigg, President and Chief Operating Officer, WEPCO A. J. Cayla, Plant Manager B. D. Burks, P.E., Director Bureau of Field Operations cc w/ encl: Cheryl L. Parrino, Chairman Wisconsin Public Service Commission State Liaison Officer Distribution:

Docket File w/enci SRI Point Beach w/ encl l PUBLIC IE-01 w/enci Rlli Enf. Coordinator w/enci

- A. B. Beach w/enct  IEO w/enci(E-mail)

C. L. Caldwell w/enci DRP w/ encl Project Manager, NRR, w/enci DRS (2) w/enci Rlll PRR w/enci DOCDESK (E-mail) TSS w/enct GREENS i l l

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, Wisconsin Electnc POWER COMPANY Point Beoch Nuclecr Plant (920) 755-2321 6610 Nuclear Rd., Two Rivers. WI 54241 NPL 98-0214 10 CFR 2.201 March 23,1998 Document Control Desk U. S. NUCLEAR REGULATORY COMMISSION Mail Station P1-137 Washington,DC 20555 Ladies / Gentlemen: DOCKETS 50-266 AND 50-301 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT NOS. 50-266/97023 AND 50-301/97023 POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 In a letter from Mr. John A. Grobe dated February 19,1998, the Nuclear Regulatory Commission forwarded the results of an inspection conducted by your staff at our Point Beach Nuclear Plant. The {

inspection was conducted from October 20,1997, through November 7,1997. The inspection report included a Notice of Violation which identified three violations of NRC requirements.

We have reviewed the Notice of Violation and, pursuant to the provisions of 10 CFR 2.201, have prepared a written response to the violations as requested by your letter of February 19,1998. Our written response to the violations is included as an attachment to this letter.

We believe that the attached reply is responsive to the Notice of Violation and fulfills the requirements identified in your February 19,1998, letter.

New commitments that have not been previously docketed are identified by italics.

If you have any questions or require additional information regarding this response, please contact me.

Sincerely, / j.

cott A.Patulski Site Vice President Point Beach Nuclear Plant . Attachment

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cc: .NRC Regional Administrator NRC Resident Inspector NRC Project Manager PSCW Asukmqwmeswnmycorpnaw Y EI O y .

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.- Attchment to NPL 98-0214 March 23,1998.

Page1 DOCKETS 50-266 AND 50-301 REPLY TO A NOTICE OF VIOLATION

/ NRC INSPECTION 1RFFORTS 50-266/97023 AND 50-301/97023 POINT BEACH NUCLEAR PLANT UNITS 1 AND 2 During an NRC inspection conducted from October 20,1997, through November 7,1997, .three violations ofNRC requirements were identified. Inspection Reports 50-266/97023 and 50-301/97023 and the Notice of Violation (Notice) transmitted to Wisconsin Electric on February 19,1998, provide-details regarding the violations.

In accordance with the instructions provided in the Notice, our reply to the violation includes: (1) the reason for the violation, or if contested, the basis for disputing the violation; (2) the corrective action taken and the results achieved; (3) corrective action to be taken to avoid further violations; and (4) the date when full compliance will be achieved.

Violation 1:

"10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings," requires in part, .

that activities affecting quality be prescribed by documented procedures, of a type appropriate to the circumstances and that the activities be accomplished in accordance with these procedures. The procedures are to include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

Procedure NP 1.9.15, " Danger Tag Procedure," Revision 3, Section 6.2.1 stated, in part, that the preparer shall fill out the danger tag location sheet with tag sequence numbers. Section 6.3.3 stated, in part, that the qualified tagger shall position equipment / components as specified in the

" sequence" column and " required position" column on the danger tag location sheet.

Procedure NP 5.3.7, " Operability Determinations," Attachment A, " Management Expectations for Performing a Written Prompt Operability Determination," described types of conditions that should receive a written operability evaluation if the system, structure, or component was to remain in service.

Item 2.6 of this attachment listed one type of condition as ' Errors in testing, testing methodology, instrumentation or data that could invalidate surveillance testing that is used to demonstrate continued operability of SSCs [ systems, structures, and components).' Contrary to the above: a. Danger tags 97-753 and 97-800 were installed on October 7,1997, and October 18,1997, without tag sequence numbers being assigned to the danger tag location sheet.

_ b. Mlthough condition report QCR'97-0148, dated July 18,1997, documented that requirements for testing safety-related relief valves per ASME Section XI 1986-OM-1(1981) were not met in all ! cases, no prompt operabuity determination had been completed for all the affected valves as of 1

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November 7,1997.

This is a Severity Level IV violation'(Supplement 1)." ,

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/ 'A%a=* to NPL 98-0214 March 23,1998 Page 2 Response to Violation 1,a: Reason for Violation: We concur that this is a violation ofNRC requirements as characterized in the inspection report. Tag series 97-753 was written for repairs to CT-265 in the reactor coolant pump seal water return piping.

Five tags provided the isolation boundary. These tags were not sequenced. The tag series was hung without a sequence. Tag series 97-800 was written for the two-year preventive maintenance inspection of the G-02 emergency diesel generator. Tag 64 was added to place Breaker 5 of panel C79,"G-02 Emergency Diesel Generator DC Power Transfer Control Panel," in the OFF position. This tag had no sequence number.

NP 1.9.15, " Danger Tag Procedure, requires the preparer to assign a sequence and the reviewer and approver to verify that the sequence is adequate, It also requires the tagger to position the components in

 ~ the sequence provided. The cause of this violation was that involved personnel did not follow the written 4 procedural guida-e.

' Corrective Actions Taken: 1. Work control center personnel who prepare, review and approve danger tagouts were reminded of the sequencing requirements contained in NP 1.9.15, 2. The need for proper sequencing of danger tags and adherence to NP 1.9.15 were emphasized in a written communication to Operations personnel.

Corrective Actions to be Taken: By July 31,1998, we will implement afeature ofNOMS danger tagging software thatpreventsprinting of a danger tag series without tag sequence numbers assigned This willprovide an additional barrier to preventing recurrence of this type ofevent.

Date Of Full Compliance:

Full compliance will be achieved by July 31,1998.

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Response to Violation 1.b:

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Reason for Violation: , I i We concur that this is a violation ofNRC requirements as characterized in the inspection report. Quality Condition Report (QCR) 97-0148 was screened by an SRO licensed individual on July 17,1997. The , question in the screening section of the Condition Report form (PBF-1552) that asks, "Is the structure, j system or component operable?" was checked "yes;" however, no additional comments were recorded.

A sheet attached to the QCR listed the findings identified in the audit. These fmdings were worded as j

 ' programmatic issues dealing with administrative controls over testing and scheduling. No specific La..- - '        . _ . _

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-  Attchment to NPL 98-0214 March 23,1998 Page 3 inap; opriate valve tests were identified that would have questioned the operability of any currently installed valves. . This may have influenced the decision to not require an operability determination.

Corrective Actions Taken: Although a root cause addressing this and other QCRs was not initiated for several months, an evaluation of the specific findings of QCR 97-148 was completed within the 30 days provided for evaluation of a QCR. This evaluation clarified the significance of the findings. During the course of this evaluation, no discrepancies were found that questioned the operability of any equipment within the scope of the relief valve program. If a discrepancy had been identified, a new Condition Report would have been initiated to address the operability of the affected valve (s). The findings were reviewed against actual Code requirements and the specific valve tests that led to the findings were also reviewed. As a result, several-improvements to the relief valve test program were identified and action items were created to track their resolution via the QCR.

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 ' We recognize that the quality and consistency of operability determinations has not consistently met our -{

standards or our expectations. To improve our performance, the Condition Report form has been revised '1 to include a " screener comments" section. This section is used to document justification for operability screening decisions that have been made. In addition to revision of the Condition Report form, during the morning plant staff reviews of Condition Reports and Quality Condition Reports, there is a consideration of whether a prompt operability determination is needed.

Corrective Actions to be Taken: The current method for reviewing CRs and QCRs for operability concerns is considered to be adequate.

i The addition of an operability screener comments section to the Condition Report form is an enhancement that will allow for the basis for these decisions to be more readily documented. No additional corrective actions are planned at this time.

Date Of Full Compliance: We are presently in full compliance with NRC requirements. I

Violation 2: -

 .."10 CFR Part 50, Appendix B, Criterion XII, " Control ofMeasuring and Test Equipment," requires, in part, that measures be established to assure that instruments and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specified periods to j
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maintain accuracy within necessary limits. j l

Contrary to the above, on October 21,1997, while performing technical specification surveillance procedures 2RMP 9071-1 "A05 4160/480 Degraded and Loss of Voltage Relay Monthly Surveillance" and 2RMP 9071-2 "A06 4160/480 Degraded and Loss of Voltage Relay Monthly Surveillance" on Unit 2, personnel used an ~uncalibrated stopwatch to measure the 4.16 kV bus undervoltage relays 2-274/A05, h y j

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i.. Attchment to NPL 98-0214 ' March 23,'1998 Page 4 ' 2-275/A05, 2-276/A05, 2-27-4/A06(27-4), 2-27-5/A06(27-5) and 2-27-6/A06(27-6)' pickup tune delay setpoint values.

This is a Severity Level IV violation (Supplement I)."

Resnonse to Violation 2 Reason for Violation:

- We concur that this is a violation of NRC requirements as characterized in the inspection report. The measuring and test equipment (M&TE) program did not contain adequate guidance for the application of calibrated stopwatches.

2 Corrective Actions Taken: l'. Condition Report CR 97-3684 was initiated on November 4,1997.

2. A field audit of assigned Maintenance areas was completed on March 10,1998. Any uncalibrated stopwatches were removed from work areas.

3. A market survey was completed on March 14,1998. The purpose of this survey was to locate and order calibrated stopwaches. One calibrated stopwatch was ordered for trial use and possible implementation.

4. The management expectation on use of calibrated stopwatches was reinforced on March 18,1998, during meetings held with maintenance craft workers and supervision. In addition to the above, a written communication that reinforced expectations communicated during briefings was issued. Until such time as Maintenance has acquired stopwatches for sole use, personnel in the group will use calibrated stopwatches available from either the Operations or Instrument & Control group.

5. The 4160 V and 480 V degraded and loss of voltage surveillance tests (routine maintenance procedures in the 1RMP 9071,2RMP 9071,1RMP 9075, and 2RMP 9075 series) were resiewed.

Temporary changes, as appropriate, were initiated to the surveillance procedures to ensure that calibrated stopwatches will be used when performing relay timing. The governing procedures were also reviewed and verified to not contain specific timing requirements.

Corrective Actions to be Taken:. 1.I ' Calibrated stopwatches will be purchased by March 27,1998.

'2. I The calibratedstopwatches will be issued to Maintenance personnel by March 30,1998.

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:3. . Mechanical /Electricalgroup assigned calibratedstopwatches will be incorporated into the M&TEprogram by April 8,1998.

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? ' Attchment to NPL 98-0214 March 23,1998 Page 5 Date of Full Compliance Full compliance with NRC requirements will be achieved by April 8,1998.

Violation 3:

' "10 CFR Part 50 Appendix B, Criterion XVI, " Corrective Action," requires, in part, that measures be established to assure that conditions adverse to quality, such as deficiencies and nonconformances, are promptly identified and corrected. Violation 50-266/96002-05(DRP), 50-301/96002-05(DRP), dated April 17,1996, identified that changes to the plant, systems and parameters were not routinely updated into the final safety analysis report (FSAR).

Contrary'to the above, as of November 7,1997, corrective actions to the above violation were not sufficient to assure that previous changes to plant systems that affected the FSAR were identified and corrected as follows-

a. During a screening on October 1,1997, the licensee failed to identify that the FSAR had never been updated to reflect a change to procedures which occurred in 1988. q b. The licensee had not revised the FSAR to correct the description of the effects of a loss of a

 ' transmission line to the plant, although the need for such a revision was identified in 1993.

Thisis a Severity Leve: TV violation (Supplement I)."

Response to Violation 3: Reason For Violation: We concur that these examples are violations of NRC requirements for timeliness in updating the FSAR.

However, we would like to clarify the violations as related to their characterization within the Inspection

Report.

For Violation 3.a, we concur that a change in the method for discharging radioactive liquids was made in 1988 which should have been reflected in the FSAR. A screening was performed for procedure changes made in 1997 related to the discharge of the B CVCS Holdup Tank (OP-10E). While this procedure was essentially a complete rewrite of the procedure, only a few changes within the procedure constituted actual changes to how the discharge is controlled. These changes were appropriately screened for j i evaluation under the criterion of 10 CFR 50.59.

We believe that evaluation of the changes meets the requirements of the regulations and the PBNP

' implementing procedure, NP 10.3.1, " Authorization of Changes, Tests and Experiments  j
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. (10 CFR 50.59/72.48 Reviews)." Evaluation of the changes limits the scope of the licensing basis review involved. Therefore, it is not expected that such a review would identify discrepancies in FSAR information if the FSAR information is not altered by the change in the facility or its operation.

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' March 23,1998 Page 6 Violation 3.b is a result of the responsible engineer not appropriately prioritizing the importance of updating the FS AR for changes made to the facility for which he was responsible.

Corrective Actions Taken: In resp ase, to previous violations identified in Inspection Report 96-002, WE undertook a knowledge-based, cover-to-cover review of the FSAR. As committed, this review will be completed with submittal of the annual update to the NRC, scheduled in June,1998. This review is a comprehensive process utilizing contractor support with reviews by appropriate engineering, operations, design basis,and functional area experts as appropriate. This process is intended and is expected to identify and correct such discrepancies.

The failure of the engineer to initiate changes over an extended period of time, despite havirig an assigned item to specifically update the FSAR, is considered to be an isolated occurrence ofless than adequate individual performance. We believe this to be the case due to the low number of discrepencies of this nature identified in via Condition Reports, that are independent of our ongoing FSAR review. The low number ofidentified discrepancies is evidence that the efforts of managment and supervisors to stress the importance of maintaining the integrity of the FSAR are having the desired result. The issue ofless than adequate individual performance has been discussed with the involved individual, who now understands the importance of submitting FSAR updates as established via procedural guidance.

Corrective Action To Be Taken: The FSAR updates will be made in theforthcoming 1998 annualFSAR update. The annual update of the FSAR will be submitted in June,1998.

It is currently our intention to revise affectedprocedures such that when a 10 CFR 50.59/72.48 evaluation is submitted to the Manager 's Supervisory Stafffor review, the proposedFSAR change package accompanies the safety emluation. However, aprocess improvement team effort is inprogress that is evaluating our design controlprocesses. The process improvement team is benchmarking our practices against those ofother nuclear utilities and will be making improvement recommendations that may differfrom our currentplans. It is our intention that corrective actions taken be reflective of industry standards andpractices. Accordingly, by July 31,1998, we will take corrective actions, including appropriate procedure revisions that are reflective ofindustry standard, to ensure that FSAR change packages are prepared andsubmittedfor inclusion in annual FSAR updates. . Date of Full Compliance: Full compliance with NRC requirements will be achieved for the identified discrepancies by July 31,1998. }}