ML20045C114
| ML20045C114 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 06/11/1993 |
| From: | Jackiw I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20045C107 | List: |
| References | |
| 50-266-93-09, 50-266-93-9, 50-301-93-09, 50-301-93-9, NUDOCS 9306220091 | |
| Download: ML20045C114 (19) | |
See also: IR 05000266/1993009
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION III
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Report Hos. 50-266/93009(DRP); 50-301/93009(DRP)
Docket Nos. 50-266; 50-301
Licensee: Wisconsin Electric Company
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231 West Michigan
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Milwaukee, WI 53201
Facility Name: Point Beach Units 1 and 2
Inspection At:
Two Rivers, Wisconsin
Dates: April 1 through May 24, 1993
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Inspectors:
K. R. Jury
J. Gadzala
T. Kobetz-
G. F. O'Dwyer
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Approved By:
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I, K. Jac @ , Chief
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Reactor Biojects Section 3A
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inspection Summarv
Jnspection from April 1 throuah May 24, 1993
.(Reports No. 50-266/93009(DRP): No. 50-301/93009(DRP)
Areas Inspected: Routine, unannounced inspection by resident inspectors of
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corrective actions on previous findings;. plant operations; radiological
controls; maintenance and surveillance; emergency preparedness; security;
engineering and technical support; and safety assessment / quality verification.
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Results: A violation of NRC requirements was cited for inadequate corrective
action (Paragraphs 2.d, 5.a, and 6.d) and three non-cited violations were
identified (Paragraphs 4.a and 6.a).
A summary follows.
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Plant Operations
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A pressurizer level instrument bistable failed low resulting in a plant
transient. Operators took prompt and appropriate _ corrective actions, but
management appeared slow in communicating guidance to the control room.
Improperly stowed equipment was identified, presenting potential seismic
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hazards. The repetitive nature of this concern makes it appear .that the plant
inspection program has not been effective.
9306220091 930611-
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ADOCK 05000266
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During surveillance test performance, a poor operating practice was identified
regarding operator alarm acknowledgement without verification.
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Radioloaical Control
An operator's exemplary actions allowed identification of a highly
contaminated filter prior to its being handled.
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A non cite'd violation was identified for not' posting a high radiation area.
Maintenance / Surveillance
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A step in the master copy of a procedure was found to be already initialed to
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signify completion of that step.
This occurred because of a weakness in the
temporary procedure change process which the licensee was addressing.
As stated in the violation, no condition report was generated to document a
fault that occurred on the fuel oil sump level control switches which caused
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the diesel to be declared inoperable. Despite extensive troubleshooting, this
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fault could not be identified and therefore the switches were left as found
and the diesel was declared operable.
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Two different type oils for a safety injection pump were inadvertently
switched during maintenance, resulting in both pump and motor being filled
with the wrong type oil. During the subsequent return to service test, the
motor bearings failed. However, no determination could be made regarding
whether the failure was due to the incorrect oil or inadequate prelubrication
of the motor bearings during maintenance. This item remains unresolved.
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Good coordination was observed in the conduct of two unrelated surveillance
tests to assure that they did not interfere with each other. . Good
communication was also noted between test personnel and the control operator.
Safety Assessment /0uality Verification
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The licensee instituted corrective actions in response to a determination that
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low temperature overpressure protection setpoints 'were inadequate.
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A non-cited violation was identified for a containment isolation valve not
being included in a leak testing program.
Enforcement discretion was granted for delaying performance of the monthly
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surveillance for Unit 2 reactor protection-instrument functions-due to plant
conditions. This prevented a potential degraded grid voltage condition.
The third door to the Unit I containment personnel _ hatch was found blocked
open.
Implementation of corrective actions for previous violations of this
third door being blocked.open were inadequate to prevent recurrence.
This is
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one of two examples of a violation for inadequate corrective action,
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DETAILS
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1.
Persons Contacted (71707) (30702)
- G. J. Maxfield, Plant Manager
- T. J. Koehler, Site Engineering Manager
R. D. Seizert, Training Manager
- J. F. Becka, Regulatory Services Manager
J. G. Schweitzer, Maintenance Manager
J. C. Reisenbuechler, Manager - Operations
N. L. Hoefert, Manager - Production Planning
J. J. Bevelacqua, Manager - Health Physics
F. P. Hennessy, Manager - Chemistry
J. A. Palmer, Manager - Maintenance
G. R. Sherwood, Manager - Instrument & Controls
W. B. Fromm, Sr. Project Engineer - Plant' Engineering
T. G. Staskal, Sr. Project Engineer - Performance Engineering
W. J. Herrman, Sr. Project Engineer - Construction Engineering
- F. A. Flentje, Administrative Specialist
Other company employees were also contacted including members of the
technical and engineering staffs, and reactor and auxiliary operators.
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- Denotes the personnel attending the management exit interview for
summation of preliminary findings.
2.
Corrective Action on-Previous Inspectiou Findinas (92701) (92702)
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a.
(Closed) Violation (266/91025-02: 301/91025-02):
Failure to
Effectively Correct Main Steam Isolation Valve Deficiencies.
This violation, .for which a civil penalty was issued, concerned
ineffective corrective action of past main steam isolation valve
(MSIV) failures. The inspector reviewed the company's response
dated February 5, 1992, and verified that the described actions
regarding changes to correct the problems had been taken.
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Modifications were completed on the MSIVs for~both units to'
improve the reliability of the valve operators. A larger air
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cylinder was installed to increase the amount of closure' force
available to shut the valve. One side of the valve disk pivot
arm was enclosed to allow removal of packing material and thereby
reduce the amount of friction to oppose valve movement. A bellows
assembly was'added over the operator piston rod to prevent' entry
of moisture into the operator. Actions taken to improve MSIV
testing were also reviewed. Operating Procedure OP-13A,
" Secondary Systems Startup" had been revised to eliminate the-
requirement for cycling the.MSIVs prior to operability tests.
.In addition significant additional MSIV testing was included to
provide additional assurance of MSIV operability.
These. actions
were considered adequate and no additional concerns were
identified in this area. This item is closed.
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b.
(Closed) Violation (301/92018-03): One Train of the Containment
Recirculation Mode of Safety Injection Inoperable.
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During the 1991 Unit 2 refueling outage, the licensee installed
modification IWP 88-098 to allow full flow testing of containment
spray, safety injection (SI), and residual heat removal (RHR)
systems as recommended by NUREG 0578.
On September 17, 1992,
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during the subsequent refueling outage, the licensee discovered
that a foam disk wrapped in duct tape had been inadvertently left
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inside this piping during installation of the full flow test
modification. This disk had likely been used as a foreign
material exclusion plug during the modification work.
It had been
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swept out of the piping and lodged in the containment spray pump
impeller during testing. As a result, the piping associated with
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one train of the containment recirculation made of safety
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injection had been rendered inoperable.
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The licensee was cited for this violation and an associated civil
penalty was assessed. As corrective action, the plug was removed
and the system retested. A detailed inspection was then performed
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on the Unit 2 containment spray, RHR, and SI systems to identify
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any additional foreign material in these systems. The inspections
included portions of the systems affected by the modification as
well as piping dead legs and flow restrictions, and were performed
using a combination of boroscopic examinations and radiography.
Only minor amounts of foreign material were found, none of which
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was determined to pose any hazard to the equipment involved.
During the subsequent Unit I refueling outage, a similar
inspection was performed on the Unit I systems affected by this
modification.
No debris was found in any of the piping sections
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examined.
The inspector monitored the licensee's corrective
actions in this area, reviewed the results of the system
inspections, and had no further concerns. This item.is closed.
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c.
L0 pen) Violation (301/92018-04):
Inadequate Ac:eptance Criteria
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for Cleanliness Control.
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The cause of the foreign material exclusion plug, discussed in
paragraph 2.b above, being left inside the containment
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recirculation piping was due to inadequate cleanliness control.
Procedure QAP-105-PB, " Cleanliness Inspection of Fluid Systems and
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Components", Revision 1, did not include appropriate acceptance
criteria to ensure that debris was not left inside the piping.
The licensee was cited for this violation and an associated civil
penalty was assessed.
Corrective actions to prevent recurrence included a revision of
the foreign material exclusion procedure, an' assessment of
contractor controls, and a performance based surveillance of
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activities performed by onsite contractors.
The revision to the
foreign material exclusion procedure consisted of replacing the
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maintenance instruction with Point Beach administrative procedure
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PBNP 3.4.25, " Exclusion of Foreign Material From Plant Components
and Systems".
The inspector reviewed the new procedure and
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discussed its implementation with maintenance planners and system
engineers.
Several concerns were identified with this procedure.
Steps 7.3.2
and 7.3.5 provided no guidance to the planner on what criteria to
use for determining the extent of cleanliness controls required.
By the inspector's observations, the material controls of step
7.3.4 were sparsely implemented around the reactor cavity during
Unit I refueling operations. An incident involving a bag of
booties and gloves being left inside the IWlA containment accident
fan following maintenance demonstrated that the new procedure was
not being effectively utilized.
Following discussions with the
inspector, plant management indicated that additional changes were
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being considered to the foreign material exclusion procedure to
improve the guidance provided regarding the extent of controls
needed and the applicability of these controls. This item will
remain open pending additicnal progress of corrective actions and
subsequent review by the inspector.
d.
(Closed) Unresolved item (266/93002-02: 301/93002-02):
Emergency
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Diesel Generator Glycol Water Mixture.
This issue involved the use of a glycol water mixture in the
licensee's two (G01 and G02-) emergency diesel generators (EDGs).
On January 18, 1993, the EDG vendor notified the licensee that the
use of glycol as an engine coolant would result in derating of the
EDGs by five percent. The licensee reevaluated the loads for' EDGs
G01 and G02 and found that the worst case loading of EDG G01 was
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not substantially affected by the derating. However, the licensee
determined that the half-hour design basis accident (DBA) load
requirement of 2909 KW was 11 KW above the derated capacity of
2898 KW for EDG G02. The licensee removed 239 KW of load from EDG
G02 and thereby restored the operability of G02. On January 25,
1993, the licensee replaced the glycol mixture in the G02 EDG with
the required treated water.
The inspector determined that since original installation in 1970,
the engine coolant has been a glycol water mixture instead of
treated water as recommended by the vendor. The concern was that
the glycol mixture would not provide adequate cooling if the EDG
was fully loaded.
However, the original and existing EDG vendor
and maintenance instruction manuals specified water and a
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corrosion inhibitor for the engine coolant.
The inspector found-
that revisions to the maintenance instruction manuals were issued
to file and not reviewed by plant personnel. This was considered
a weakness.
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10 CFR Part 50, Appendix B, Criterion III, " Design Control,"
requires that design measures provide for the selection and review
for suitability of materials and processes that are essential to
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the safety-related functions of the structures, system, and
components. The failure to install the appropriate EDG engine
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coolant was a violation of Criterion III.
However, the violation
was not cited because the criteria specified in Section VII.B.2 of
the " General Statement of Policy and Procedures for NRC
Enforcement Actions," (Enforcement Policy, 10 CFR Part 2,
Appendix C, were met.
Specifically, when the vendor notified the
licensee, prompt corrective action was taken. Additionally, the
worst case loading of 2909 KW for the first half-hour following a
DBA was only 11 KW or 0.38% above the manufacturer's EDG rating
and, therefore, the safety significance was minimal.
Furthermore,
since the DBA load requirements drop off after the first half-
hour, the actual seven day kw loads of 2584 were well within the
200 hour0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> EDG rating. Moreover, in 1970 the G01 EDG was tested at
3053 KW for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> followed by load cycling between 2850 and
3053 KW for an additional 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />.
Based on the above
information, this item is closed.
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No violations or deviations were identified.
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3.
Plant Operations (71707) (71710) (93702)
The inspectors evaluated licensee activities to confirm that the
facility was being operated safely and in conformance with regulatory
requirements. These activities were confirmed by direct observation,
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facility tours, interviews and discussions with plant personnel and
management, verification of safety system status, and review of facility
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records.
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To verify equipment operability and compliance with technical
specifications (TS), the inspectors reviewed shift logs, Operations'
records, data sheets, instrument traces, and records of equipment:
malfunctions. Through work observations and discussions'with Operations
staff members, the inspectors verified the staff was knowledgeable of
plant conditions, responded promptly and properly to alarms, adhered to
procedures and applicable administrative controls, was cognizant of in
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progress surveillance and maintenance activities, and was aware of
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inoperable equipment status. The inspectors performed channel
verifications and reviewed component status and safety-related
parameters to verify conformance with TS.
Shift changes were observed,
verifying that system status continuity was maintained and that proper
control room staffing existed. Access to the control room was
restricted and operations personnel carried out their assigned duties in
an effective manner. The inspectors noted professionalism in most
facets of control room operation.
Plant tours and perimeter walkdowns were conducted to verify equipment
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operability, assess the general condition of plant equipment, and to
verify that radiological controls, fire protection controir, physical
protection controls, and equipment tag out procedures were properly
implemented.
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a.
Unit 1 Operational Status
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The unit commenced this period in refueling outage 20.
This
40 day outage was completed three days early. The reactor was
restarted on May 4 and the unit was placed on line May 6.
Full
power was reached on May 10.
b.
Unit 2 Operational Status
Power was reduced to 60 percent on April 1 to isolate two of the
four main condenser water boxes and search for a suspected tube
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leak.
Sodium levels had increased in the steam generators and
condenser inleakage was suspected.
No leak could be found and
sodium levels subsequently returned to normal even though all the
condenser water boxes were returned to service the next day.
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cause of the elevated sodium levels was attributed to chemical
hideout return in the steam generators.
On April 5, pressurizer level instrument bistable 2LC-4280 failed
low. This caused all pressurizer heaters to deenergize and
primary coolant letdown to isolate as designed. The inspector
responded to the control room and noted that operators took prompt
and appropriate immediate corrective actions. Charging flow was
minimized to reduce the rate of level rise in the pressurizer due
to letdown flow being isolated. The rising pressurizer level
compressed the bubble sufficiently to counter the effects of
pressure drop due to the loss of pressurizer heaters. Operators
were dispatched to manually shut pressurizer heater supply
breakers but the failed bistable was identified as the cause of
the event and was replaced before level departed the normal band.
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This restored normal control of pressurizer heaters and coolant
letdown flow. Although the technical staff was assembled to
determine a course of response to the event, management appeared
slow in communicating guidance to the control room.
The unit operated at full power during the remainder of this
period with the exception of requested load following power
reductions,
c.
Enaineered Safeauards Features System Walkdown (71710)
The inspectors performed a detailed walkdown of portions of the
auxiliary feedwater system in order to independently verify
operability.
The auxiiiary feedwater system walkdowns included
verification of the following items:
- Inspection of system equipment conditions.
- Confirmation that the system check-off-list and operating
procedures were consistent with plant drawings.
- Verification that system valves, breakers, and switches were
properly aligned.
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- Verification that instrumentation was properly valved in and
- Verification that valves required to be locked had appropriate
locking devices.
- Verification that control room switches, indications, and
controls were satisfactory.
- Verification that surveillance test procedures properly
implemented the TS's surveillance requirements.
A minor deficiency was identified. Chemical addition tank outlet valve
AF-85A was a normally shut valve that was found open.
The valve did not
affect the safety function of the auxiliary feedwater system. This
deficiency was communicated to plant management for correction.
The
inspector observed that the attached funnels for the chemical addition
tanks did not have covers to prevent foreign material entry and were
significantly corroded. This presented the potential to transfer these
corrosion products to the steam generators.
Licensee management was
reviewing the observation.
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d.
Eauipment Stowaae
During various vital area tours, the inspectors noticed equipment that
was neither properly stowed nor restrained, presenting potential seismic
hazards. The inspectors discussed with plant management the repetitive
nature of this concern and that it appeared the plant inspection program
had not been effective. Additionally, the inspectors were concerned
that a violation was recently issued for inadequate equipment stowage
and that the licensee responded that they were in compliance with
equipment stowage requirements.
The licensee committed to revise their
docketed response to the Notice of Violation (92024-01), to address
these additional concerns. Corrective action adequacy will be monitored
on a continuing basis and documented when the violation is closed.
No violations or deviations were identified.
4.
Radioloaical Controls (71707)
The inspectors routinely observed the plant's radiological controls and
practices during normal plant tours and the inspection of work
activities.
Inspection in this area included direct observation of the
use of Radiation Work Permits (RWPs); normal work practices inside
contaminated barriers; maintenance of radiological barriers and signs;
and health physics (HP) activities regarding monitoring, sampling, and
surveying. The inspectors also observed portions of the radioactive
waste system controls associated with radwaste processing.
From a radiological standpoint the plant was in good condition, allowing
access to most sections of the facility. When discrepancies were
identified, the HP staff responded quickly.
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a.
Hiah Radiation Area not Posted
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On May 6 a plant health physics technician identified a high
radiation area in the auxiliary building that was not posted.
The technician immediately posted the area as required and HP
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management initiated a review of- the change in radiological
conditions. This review revealed that the area had been surveyed
and identified as meeting the conditions for posting as a high
radiation area during the two previous weekly surveys.
The
failure to post the area was immediately recognized by plant
personnel, a condition report was generated, and an investigation
initiated. The licensee's corrective actions were prompt and
thorough.
Their investigation included performing a Human
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Performance Enhancement System (HPES) evaluation of this event and
others involving personnel errors and/or inattention to detail.
The failure to post the area after it was identified as-a high
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radiation area is a violation of Technical Specification 15.6.11.
However, this violation was not cited because the identification
and corrective actions satisfy the criteria specified in Section.
VII.B of the " General Statement of Policy and Procedure for NRC
Enforcement Actions", (Enforcement Policy 10 CFR Part 2,
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Appendix C).
b.
Hiah Radiation Levels on Filter
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On April 15, while preparing to change a filter. downstream of a
liquid radioactive waste holding tank, an operator noted that
radiation levels were about 5 rem /hr on contact with the filter
housing and 400 mrem /hr at 30 cm from the surface. Although there
was no specific procedural requirement directing the operator to
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check radiation levels prior to attempting replacement of that
filter, he was following standard plant precautions for such
operations. Since these high levels were unexpected, the operator
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did not attempt to replace the filter but instead contacted health
physics for assistance. His exemplary actions prevented
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unnecessary exposures to radiation and a potential-overexposure.
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The area was subsequently surveyed, posted, and the filter was
removed and placed in an appropriate storage location.
Additionally, the licensee performed dosimetry review and
determined no inadvertent exposures had occurred prior to the area
being posted.
Based on an isotopic analysis of the filter
entrapment, the licensee determined that the likely source of the
high activity was residue from cleaning of several highly
contaminated valves. The decontamination room sink where the
cleaning was done drained into the liquid waste tank and the job
had been done the day before the activity on the filter was found.
The licensee evaluated their procedures and precautions for
changing potential radioactive filters and determined that
additional precautions were warranted.
Filter change procedure
and task sheet changes and operator aids were among the controls
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considered. An area radiation monitor was installed on the
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laundry / chem tank outlet filter to alert operators to abnormal
radiation levels.
No violations or. deviations were identified; however, one non-cited
violation was identified.
5.
Maintenance / Surveillance Observation (62703) (61726)
a.
Maintenance
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The inspectors observed safety-related maintenance activities on
systems and components to ascertain that these activities were
conducted in accordance with TS, approved procedures, and
appropriate industry codes and standards._ The inspectors
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determined that these activities did not violate limiting
conditions for operation (LCOs) and that required redundant
components were operable.
The inspectors verified that required
administrative, material, testing, radiological, and fire
prevention controls were adhered to.
Specifically, the inspectors observed / reviewed the following
maintenance activities:
RMP 96 (Revision 9), Reactor Head and Upper Internals
Removal and Installation
During a review of procedure RMP 96, the. inspector noted
that step 3.3.1 of the master copy, which was marked up to
incorporate several temporary changes, was already initialed
to signify completion of that step. This occurred because
the person making the temporary changes.used a photostatic
copy of the procedure that had been in use at the time the
need for the temporary changes was identified. Although
this was the method directed by plant instructions, the
intent was that initials be removed from those pages being
entered into the master procedure.
Preexistent initials on
a procedure create the potential to omit performance of the
initialled step.
Following discussions with the inspector, plant management
reviewed their temporary change process to determine
appropriate revisions to prevent recurrence. A proposed
revision to this procedure to address the deficiency was
scheduled for review by the Manager's Supervisory Staff on.
June 1.
The inspector discussed the proposed changes with
plant management.
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IWP 91-209*A-01 (Revision 0), Modification of Main Steam
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Isolation Valve IMS-2017, Unit 1
This modification completes the physical corrective action
implemented by the company to address design deficiencies in
the main steam isolation valves that had contributed to
numerous past failures of the valves to close upon demand.
The most significant of these had occurred September 29,
1991, and is documented in Inspection Report 266/301/91025.
MWR 931852, Troubleshooting and Repair of G-01 Fuel Oil Sump
Level High/ Low Switches
While manually filling the G-01 emergency diesel generator
fuel oil sump, a fault occurred with the fuel oil sump level
control switches which caused the diesel to be declared
inoperable and required entry into a seven day limiting
condition for operation. During normal operation, these
mercury switches control transfer of fuel oil from the day
tank to the engine sump. Although extensive engineering
support of the ensuing evaluation of this problem was
observed by the inspector, no cause for the fault was
identified.
All attempts to recreate the faulty indication were
fruitless and the level control switches operated properly
during ensuing diesel runs.
Consequently, the switches were
left as found and the diesel was declared back in service.
A modification had previously been scheduled to change the
location of these switches due to vibration concerns during
diesel operation.
Although the licensee had a condition report system to
document conditions that might appear to be adverse to the
safe conduct of operation, including events or conditions
that might provide data to the operating experience review
program, no condition report was generated to document this
event. This is one of two examples of a violation for
inadequate corrective action (266/93009-01A).
MWR 932349 SI pump oil change and inspection
On April 12, the oil in Unit I safety injection pump 1-P15f
was replaced. The motor also had its oil replaced and its.
bearings removed and inspected.
During the ensuing return
to service test, the motor bearings failed.
The reactor was
in a refueling outage at the time and therefore'the pump was
not required to be operable.
An evaluation of the cause and
discussion with the mechanic performing the work, indicated
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that the bearings had not been adequately lubricated prior
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to reassembly. The motor was replaced with a refurbished
motor and both-pump and motor were satisfactorily tested and
returned to service. The reactor was subsequently started
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up following completion of the refueling outage.
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As a matter of routine, the old motor bearing oil was sent
offsite for analysis. The pump and motor used different
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types of oil for lubrication of their bearings, Rykon #32
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and #68, respectively.
During interviews, the mechanic
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stated that the labels on the portable containers used to
these containers and had fallen off.
Believing he
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transport the oil to the job site did not adhere properly to
remembered which oil was in each hand and by performing a
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color comparison, he filled the pump and motor with the oil
he believed to be correct. After the motor bearings failed,
he informed his supervisor that he may have put the wrong
oil in each component.
The motor oil analysis results were received May 12 and
indicated that, based on measured viscosity, the wrong oil
had been used in the motor bearings.
At this time, the
plant contacted the pump vendor who initially stated that
improper viscosity oil in the pump would have-little effect
on operability.
Based on this information, the plant deemed
that the pump had remained operable. A followup contact by
the vendor indicated that the higher viscosity oil did
present a concern to pump operation.
This concern was.due-
to potential inadequate pump bearing lubrication.
Based on
this new information, the plant declared the pump inoperable
and changed the oil in the pump to assure that it contained
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the proper oil. The old pump oil was also sent for analysis
to verify its type and.the pump was inspected for abnormal
indication of bearing or- oil slinger ring wear.
Analysis of the old pump oil was-received May 24 and it also
was determined to have been the wrong type.
This verified
that the pump and motor oils had been switched during the
maintenance evolution.
This. item remains unresolved pending
the licensee's root cause determination and subsequent
evaluation by the inspector (266/93009-02).
b.
Surveillance
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The inspectors- observed certain safety-related surveillance
activities on systems and components to ascertain that these
activities were conducted in accordance with. license requirements.
For the surveillance test procedures listed below, the inspectors
determined that-precautions and LCOs were adhered to, the required
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administrative approvals and tag-outs were obtained prior to test
initiation, testing was accomplished by qualified ~ personnel in
accordance with an approved test procedure, test instrumentation
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was properly calibrated, the tests were completed at the required
frequency, and that the tests conformed to TS requirements.
Upon
test completion, the inspectors verified the recorded test data
was complete, accurate, and met TS requirements; test
discrepancies were properly documented and rectified; and that
the systems were properly returned to service.
Specifically, the inspectors witnessed / reviewed selected portions
of the following test activities:
ORT 3 (Revision 25), Safety Injection Actuation with Loss of
Engineered Safeguards AC, Unit 1
During performance of this test the inspector identified a
weakness in the way operators were acknowledging alarms.
This test induced numerous alarms which required
acknowledgement by one of several operators either
performing the test or whom were on watch. The inspector
observed operators who were inducing alarms during the test,
and acknowledging alarms without visually verifying which
alarms were actually being acknowledged.
This was observed
during portions of the test which required securing the
emergency diesel generators. The electrical distribution
system control board and annunciators were part of Unit 2's
control board, the unit that was operating during the test.
The inspector questioned the operators (including a senior
reactor operator) about this practice and was told that the
operator on watch was responsible for ensuring other alarms
were not present. The inspector considered acknowledgement
of alarms without verification to be a weakness and a poor
operating practice. The concern was disseminated to each
shift and the operations manager will reinforce proper alarm
acknowledgement practices during future shift meetings.
ORT 17 (Revision 0), Containment Integrated Leak Rate Test,
Unit 1
TS-1 (Revision 37), Emergency Diesel Generator G-01 Biweekly
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TS-2 (Revision 37), Emergency Diesel Generator G-02 Biweekly
TS-10 (Revision 12), local Leak Test of Containment Hatches
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The inspector observed testing of the Unit 2 containment
upper personnel airlock and questioned certain aspects of
the plant's local leak rate test methodology.
This will be
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reviewed as an inspector follow item in a future inspection
(301/93009-03).
TS-30 (Revision 12), High and Low Head Safety injection
Check Valve Leakage Test (Cold Shutdown), Unit 1
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ICP 5.22 (Revision 11), Feedwater Control
The technician performing the work was very knowledgeable of
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the system being worked on and of the conduct of the test.
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A completed data sheet from the previous performance of this-
annual test was used by the technician to assist him in
evaluating test results. The inspector observed good
coordination between this test and .an unrelated test being.
performed on other control circuitry to assure that the
tests did not interfere with each other.
IT-4 (Revision 31), Low Head Safety Injection Pumps and
Valves (Monthly), Unit 2
Ultrasonic testing of the reactor vessel nozzles.
No deviations were identified; however, one example of a violation was -
identified.
6.
Safety Assessment /0uality Verification (40500) (90712) (927001
Wisconsin Electric's quality assurance programs were inspected to assess
the implementation and effectiveness of programs associated with
management control, verification, and oversite activities.
Special
consideration was given to issues which may be indicative of overall
management involvement in quality matters such as self improvement
programs, response to regulatory and industry initiatives, the frequency
of management plant tours and control room observations, and management
personnel's attendance at technical and planning / scheduling meetings.
a.
Licensee Event Report (LER) Review
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The inspector reviewed LERs submitted to the NRC to verify that'
the details were clearly reported, including accuracy of the
description and corrective action taken. -The inspector determined
whether further information was required, whether generic
implications were indicated, and whether the event warranted
onsite follow up. The inspector also verified that appropriate
corrective action was taken or responsibility was assigned and
that continued operation of the facility was conducted in
accordance with Technical Specifications and did not constitute an
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unreviewed safety question as defined in 10 CFR 50.59. The
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following LERs were reviewed and closed:
266/301/93-003
Nonconservative Setpoints for the Low
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Temperature Overpressure System
This report described a condition t.here the setpoints for the low
temperature overpressure (LTOP) system were nonconservative.
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This information was provided to the licensee from Westinghouse
Electric Corporation in a letter dated March 15, 1993. The
location of the reactor coolant system pressure transmitters was
not considered in the LTOP setpoint development analysis. With
reactor coolant pumps running and developing a differential
pressure across the core, the reactor vessel pressure is greater
than that seen by pressure transmitters. 'As a result, the LTOP
setpoint is about 34 psig too high to operate both reactor coolant
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pumps throughout the entire temperature range during the worst
case mass input transient.
As corrective action, the licensee considered several options.
Changes were made to procedures OP-1A, " Cold Shutdown.to Low Power
Operation" and OP-3C, " Hot Shutdown to Cold Shutdown" to ensure
that one reactor coolant pump was secured when cold leg
temperature was below 160' F and to require that the control
switch for the idle pump be red-tagged out.
Restricting operation.
to one reactor coolant pump would reduce the differential pressure
across the core sufficiently that the maximum allowable vessel
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pressure would not be exceeded even with the existent LTOP
setpoints and pressure transmitter locations. At temperatures
above 152
F, the maximum allowable pressure would be sufficiently
high to permit unrestricted coolant pump operations under the
existent configuration,
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The licensee had submitted an exemption request with respect to
this issue to allow use of recently approved American Society of
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Mechanical Engineers (ASME) Code Case N-514.
Plant management
stated that they intended to withdraw this specific exemption
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request and instead await conclusion of the routine ASME code
approval process before proceeding. Any additional compensatory
measures were to be included in the follow on correspondence.
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This item is being tracked by' Unresolved Item 266/93006-01;.
301/93006-01.
301/93-003 Monthly Reactor Protection and Safeguards and Nuclear
Instrumentation Systems Testing Not Performed Within
Required Periodicity
This report described the event where portions of the monthly
reactor protection system and safeguards and nuclear
instrumentation system tests required by plant technical
specifications were not performed within their required
periodicity. A notice of enforcement discretion was granted by
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the NRC for this occurrence due to the extenuating circumstances.
Details appear in paragraph 6.c below. The licensee had
previously submitted a change to their technical specifications to
increase the periodicity of these tests based upon observed
acceptable instrument drift data.
266/93-004 Containment Hatch Temporary Third Door Tied Open
During Refueling Operations
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This report described the tying open of the temporary third door
of a containment personnel hatch during refueling operations.
Details appear in paragraph 6.d below. The plant was cited for
this violation due to inadequate implementation of corrective
action for a previous similar event.
266/93-005 Inadvertent Engineered Safety Feature Actuation
This report described the inadvertent actuation of.an engineered
safety feature while adjusting the time delay relay setpoint for a
containment accident fan. On April 15, while adjusting time delay
relays for Unit I containment' accident fans, service water
isolation valve ISW-2880 inadvertently stroked shut.
The licensee
considered this an actuation of an engineered safety feature and
the NRC was notified via the emergency notification system. This
valve supplied Unit 1 turbine building auxiliaries and its
function was to automatically isolate nonessential loads during a
safety injection event if at least four service water pumps were
not running 30 seconds after the pumps received a start signal.
This automatic isolation had no adverse consequences since Unit I
was shutdown for refueling at the time and the emergency cooling
systems were not required to be operational. Additionally, only
non-essential loads were isolated by this valve.
If this event
had occurred during power operation, it would not have been safety
significant. The cause of this event was a-minor equipment
configuration difference between Units 1 and 2 actuation circuitry
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for this function. Unit 2 circuitry utilized separate relays for
controlling containment fan . starting and service water isolation;
however, Unit 1 circuitry had both these functions on two contacts
off the same relay. The Unit 2 containment accident fan relays
had been adjusted earlier that day without incident.
Later, while
adjusting Unit I relay time delays, the service water isolation
occurred because the requisite time interval had elapsed following
relay actuation.
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To prevent recurrence of this event, the configuration of Unit I
relays was changed to correspond to that of Unit 2 with the
different actuation functions being controlled by separate relays.
The inspector discussed this event with plant personnel and had no
further concerns.
266/301/93-006
Containment Isolation Valve not Leak Tested in
Accordance with Technical Specification
Requirements
This report described discovery of a containment isolation valve
which was not included in a leak testing program as required by
Technical Specification 15.4.4.III, " Type C Tests".
Containment
isolation valve CV-369A, for the chemical and volume control
system and RHR cross connect line, had not been leak tested on
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either unit. CV-369A was the first isolation valve located
outside containment.
This condition was identified while investigating a boric acid
buildup on the socket weld between the pipe and valve, which was
due to a crack in the weld.
During the ensuing engineering
evaluation, it was identified that CV-369A was a containment
isolation valve subject to required leak testing, but was not
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included in the testing program.
However, this violation was not
cited because the identification and corrective actions satisfy -
the criteria specified in Section VII.B of the " General Statement
of Policy and Procedure for NRC Enforcement Actions", (Enforcement
Policy 10 CFR Part 2, Appendix C). The licensee's investigation
of the cause determined that the valve was incorrectly classified
during a review of containment penetrations conducted in 1984 to
determine which valves should be subject to testing.
As
corrective action, the piping associated with CV-369A was modified
during the recent Unit I refueling outage to permit leak testing
of this valve.
The valve was subsequently leak tested with
acceptable results.
A similar modification was scheduled for Unit
2 during its next refueling outage in the fall of 1993.
b.
Manaaer's Supervisory Staff Meetina
The inspector observed sessions 93-08, 93-09 and 93-10 of the
Manager's Supervisory Staff meetings.
Issues discussed included a
request for enforcement discretion to postpone required testing,
as built walkdowns of control board wiring, low temperature
overpressure protection setpoints, seismic mounting of post
accident instrumentation, and crossover steam isolation valves.
c.
Enforcement Discretion for Testina
On April 9, the NRC informed the licensee that enforcement of
requirements to perform monthly surveillance of certain reactor
protection instrument functions would be waived for up to 30 days.
This was in response to the licensee's request to postpone
performance of those tests that increased the probability of a
Unit 2 scram while both Unit I and the Kewaunee Nuclear Plant were
both shut down for refueling outages.
Loss of Unit 2 under these
conditions could result in a degraded grid voltage condition as
discussed in Inspection Report 50-266/93006;50-301/93006.
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The surveillances involved were monthly reactor protection and.
safeguards circuit testing. All these tests, with the exception
of reactor trip breaker testing, had already been reviewed for
testing at a quarterly interval and a technical specification
change request was in the final stage of being issued by the NRC.
The company analyzed reactor trip breaker performance data to
verify that instrument setpoints would not drift beyond setpoint
limits and thereby justified extending the test interval.
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The enforcement discretion was also predicated on the testing
being performed within two weeks following return to service of
either Unit 1 or Kewaunee.
The Kewaunee plant was started up
April 16 and Point Beach completed the deferred tests April 28.
This ended the requirement for the enforcement discretion. The
inspector observed portions of this testing and no unexpected
conditions were noted.
d.
Temocrary Third Door to Containment Blocked Open Durina Refuelino
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On April 8, with refueling operations in progress, the licensee
discovered the temporary third door to the Unit I containment
personnel hatch secured open.
Technical Specification 15.3.8.1
required a temporary third door on the outside of the personnel
lock be in place whenever both doors in a personnel lock were open
during refueling operations. The door was immediately secured by
the individual that discovered it open. A sign had been posted on
both sides of the door stating " Refueling In Progress, Keep This
Door Closed, Do Not Block Open".
The licensee conducted an evaluation of this event and determined
the door was open for 15 minutes or less. A HPES evaluation was
also performed to determine root causes and contributing factors.
While the individual responsible for this event could not be
determined, the licensee did identify that the security guard-
stationed at the entrance to containment was not notified that
refueling activities were in progress and that the door was to
remain closed.
Security guard notification and control of the temporary third
door were actions that had been committed to in response to a
previous occurrence of this door being open on October 10, 1991.
Additionally, a violation was issued for this door being blocked
open during refueling operations in 1989 (see Inspection Report
50-301/88022). Hovrave", implementation of corrective actions for
the previous violations were inadequate to prevent recurrence.
This is one of two examples of a violation for inadequate
corrective action (266/93009-01B).
No deviations were identified; however, an example of a violation and a
non-cited violation were identified.
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7.
Outstandina Items (92701)
Inspection Follow Up Items
Inspection follow up items are matters which have been discussed with
Wisconsin Electric management, will .be reviewed further by the
inspector, and involve some action on the part of the NRC, company or
both. A follow up item disclosed during the inspection is discussod in
paragraph 5.b.
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Unresolved Items
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Unresolved . items are matters about which more information is required in
order to ascertain whether they are acceptable items, items of
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noncompliance, or deviations. An unresolved item identified during the
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inspection is discussed in paragraph 5.a.
8.
Non-cited Violations
During this inspection, certain of your activities, as described above
in Paragraphs 2.d, 4.a, and 6.a, appeared to be in violation of NRC
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requirements. However, these violations were categorized at Severity
Level TV or V and they are not being cited because they meet the
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criteria specified in Section VII.B of the " General Statement of
Policy and Procedures for NRC Enforcement Actions", (10 CFR Part 2,
Appendix C)'.
9.
Exit Interview (71707)
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A verbal summary of preliminary findings was provided to the Wisconsin
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Electric representatives denoted in Section 1 on May 26, at the
conclusion of the inspection. No written inspection material was
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provided to company personnel during the inspection.
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The likely informational content of the inspection report with regard to
documents or processes reviewed during the inspection was also
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discussed.
Wisconsin Electric management did not identify any documents
or processes that were reported on as proprietary.
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