ML20023C342
| ML20023C342 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 05/09/1983 |
| From: | Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Burstein S WISCONSIN ELECTRIC POWER CO. |
| Shared Package | |
| ML20023C343 | List: |
| References | |
| NUDOCS 8305170241 | |
| Download: ML20023C342 (2) | |
See also: IR 05000266/1982017
Text
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Docket No. 50-266
Docket No. 50-301
Wisconsin Electric Power Company
ATTN:
Mr. Sol Berstein
Executive Vice President
Power Plants
231 W. Michigan
Milwaukee, WI 53201
Gentlemen:
Thank you for your letter of January 21, 1983, responding to the items
of noncompliance which we brought to your attention in Inspection Report
No. 50-266/82-17; 50-301/82-17, which was forwarded to you by our letter
dated November 30, 1982. Your corrective actions, as appropriate, will
be reviewed during subsequent inspections.
In response to your letter we have the following comments:
1.
Your response to violation #1, Item a(1), Noncompliance 2.b(1) (82-17
01A, " Fire Pump Testing") disagrees with our position that this is
an item of noncompliance and stated that the pump test results indicate
adequate pump performance.
We have asked NRR to advise us concerning
the correct fire pump test requirements in the light of your commitments
to BTP 9.5-1 and your Technical Specifications. We will address your
response in a separate letter after we receive NRR's position.
2.
Regarding your disagreement with noncompliance 2.b(2) (82-17-01B, " Fire
Signaling System Testing"), it is our position that since fire protection
systems and equipment alarm annunciators are the only means of notifying
the reactor operator that the systems are actuated, that these alarms
do have a significant impact on safe plant operation. Therefore, 10
'
CFR 50, Appendix B, Criterion XI is applicable to testing and verifica-
tion of alarm annunciation in TS-7 (monthly Diesel Fire Pump Functional
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Test), TS-17 (annual Testing of Diesel Room Sprinkler Valves), TS-19
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(Annual Fire Pump Capacity Test) and TS-26 (Fire Main Flow Test).
3.
Violation #1, Item a(2) is being withdrawn as an example of aniitem of
noncompliance.
4.
Regarding your comment on violation #1, Item b, Noncompliance 2.b(4e)
(82-17-01d, " Test Acceptance Criteria, Annual Fire Pump Capacity Tests"),
we understand your philosophy as stated in Section 1.85 of the Point
Beach FSAR, which states in part, " Supervisors may direct that data be
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Wisconsin Electric Power Company
taken without the data taker being cognizant of the acceptance criteria
when it is considered that forehand knowledge of the acceptance criteria
may prejudice results." However, we could find no evidence that accept-
ance criteria had been supplied to the individual reviewing the test
results for TS-19.
This is especially of concern for tests where the
applicable Technical Specification surveillance requirements are
ambiguous as they are for fire pump testing.
5.
Regarding violation #3, Item b., it should be noted that the procedures
..
and video tape, pertaining to handling of leaks and spills of flammable
materials, were neither referred to by site personnel nor made available
to our inspectors during the inspection. This suggests to us that some
of your representatives were not aware that such procedures and video
tapes existed. We will review the material at a future inspection at
which time a decision will be made whether to withdraw this example of
an item of noncompliance.
The inconsistancy between the NFPA codes and standards and your Technical
Specification requirements for fire pump testing and your position on the
largest expected fire system flow rate, as stated in your letter (C. W. Fay
to J. G. Keppler) dated February 24, 1983, have been referred to NRR for
review. We expect to receive NRR's response to our request by May 30, 1983,
and will contact you at that time.
Your cooperation with us is appreciated.
Sincerely,
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R. L. Spessard, Director
Division of Engineer
cc:
J. J. Zach, Plant Manager
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DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII
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John J. Duffy, Chief
Boiler Section
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Peter Anderson, Wisconsin's
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Ness Flores, Chairperson
Wisconsin Public Service
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