ML20080Q951

Responds to NRC Re Violations Noted in IE Insp Rept 50-305/83-15.Corrective Actions:Administrative Control Directive Changes Initiated,Clarifying & Defining Tagging of Equipment in Controlled Status

ML20080Q951
Person / Time
Site:	Kewaunee
Issue date:	02/03/1984
From:	Giesler C WISCONSIN PUBLIC SERVICE CORP.
To:	Shafer W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20080Q947	List: ML20080Q951
References
CON-NRC-84-23 NUDOCS 8402270257
Download: ML20080Q951 (4)

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. NRC-84-23 WISCONSIN PUBLIC S E RVICE CO RPOR ATIO N P.O. Box 1200, Green Bay, Wisconsin 54305 February 3, 1984 Mr. W. D. Shafer, Chief Projects Branch 2 U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Dear Mr. Shafer:

Docket 50-305 Operating License DPR-43 Kewaunee Nuclear Power Plant Inspection Report 50-305/83-15 The attachment to this letter provides our response to the Notice of Violation appended to the Referenced Inspection Report.

Very Truly Yours, 03 0-C. W. Giesler f

Vice President - Nuclear Power CAS/js Attach.

cc - Mr. S. A. Varga, US NRC Mr. Robert Nelson, US NRC 8402270257 840217 PDR ADOCK 05000305 G PDR FEB 6 1984

NRC6-20.2 ATTACHMENT RESPONSE TO NOTICE OF VIOLATION IE INSPECTION REPORT NO. 50-305/83-15(DPRP)

VIOLATION:

Technical Specification 6.8.1 states, " Written procedures and administrative policies shall be established, implemented and maintained that meet the requirements and recommendations of Sections 5.1 and 5.3 of ANSI N18.7-1972".

ANSI N18.7-1972, Section 5.1.5, states, in part, " Procedures shall be provided for control of equipment as necessary, to maintain reactor and personnel safety and to avoid unauthorized operation of equipment. These procedures shall require control measures such as locking or tagging to secure and identify equipment in a controlled status". Administrative Control Directive 4.3 "Tagout Control" Section 3.0 states, in part, " Danger Cards shall be used to protect equipment or to warn of unusual or dangerous conditions".

Contrary to the above, on September 28, 1983, authorization was granted to isolate the IB boric acid transfer pump, and maintenance personnel were permitted to replace the pump's discharge pressure gauge isolation valve without the use cf equipment control measures as required by ANSI N18.7-1972 and Administrative Control Directive 4.3.

This is a Severity Level IV noncompliance (Supplement I).

RESPONSE

Wisconsin Public Service acknowledges the violati)n as described.

Administrative Control Directive (ACD) changes have been initiated which will clarify and define the tagging of equipment in a controlled status.

This revision requires the placing of a tag on the appropriate control room device (e.g., uitch, etc.) for all equipment which is out of service.

The tag will also state the reason the equipment is out of service.

The revision will be completed and the administrative changes implemented by February 13, 1984.

This clarification, in conjunction with current plant procedures and poilcies, should preclude the recurrence of this type of event.

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Nr. W. D. Shafer February 3, 1984 Page 2 VIOLATION:

Technical Specification 6.9.2.b states, in part, "The reportable occurrence discussed below shall be the subject of written reports to the Director of the appropriate Regional Office within thirty days of occurrence of the event". Technical Specification 6.9.2.b(2) states, " Conditions leading to operation in a degraded mode permitted by a limiting condition for operation or plant shutdown required by a limiting condition for operation." Technical Specification 3.0 " Limiting Condition For Operation" states in Specification 3.2.c.2,-"0NE boric acid transfer pump may be out of service provided both pumps are again operable within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

Contrary to the above, while the plant was operating at power on September 28, 1983, the plant was in a limiting condition for operation when the 18 beric acid transfer pump was placed out of service far a period of approximately six hours. This condition of operating in a degraded mode was not reported as required by Technical Specifications 6.9.2.b and 6.9.2.b.(2).

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

RESPONSE

Wisconsin Public Service acknowledges the violation as described.

Shift Supervisors and Shift Technical Advisors have received guidance regarding reporting rec.airements pursuant to Kewaunee Plant Technical Specifications, 10 0FR 50.72, and 10 CFR 73.71. A review of event documentation (Incident Reports) substantiates an increased awareness of these reporting requirements.

With the January, 1984 LER rule change, this type of event (entry into a limiting condition of operation) is no longer reportable.

In order to ensure compliance with the January,1984 LER rule change .

and the associated reporting requirements, Shift Supervisors and Shift Technical Advisors were given special training in which they were provided both written and verbal guidance on 10 CFR 50.72,10 CFR 50.73, and 10 CFR 73.71 as they apply to Kewaunee Nuclear Power Plant.

.- hr. W. D. Shafer February 3,1984 Page 3 VIOLATION:

Technical Specification 6.8.1 states, " Written procedures and administrative policies shall be established, implemented and meintained that meet the requirements and recommendations of Sections 5.1 and 5.3 of ANSI N18.7-1972."

ANSI N18.7-1972, Section 5.1.2, states in part, " Procedures shall be followed.."

Administrative Control Directive (ACD) 5.4, Revision I, " Work Request", states, "This ACD establishes the method of identifying, controlling and establishing

- requirements for the documenting of corrective maintenance actions performed on plant equipment". The ACD requires that the Maintenance Work Request (MWR) form provide documentation including; component identification, applicability of post-maintenance testing, and a complete description of maintenance, performed.

Contrary to the above, after MWR No. 24052 had been processed through the Maintenance Coordinator's review it did not provide documentation as required by ACD 5.4.

This is a Severity Level V noncompliance (Supplement I).

RESPONSE

Wisconsin Public Service acknowledges the violation as described.

Meetings of Plant Supervisory Staff have been held to acknowledge and identify these deficiencies. Follow-up meetings with general plant staff addressed, and reemphasized, each individual's responsibility to provide complete work activity documentation. Those persons performing specific reviews have been directed to provide complete work activity documentation at the tiri:a of their sign off.

Interim corrective action will be the revision of ACD 5.4 (" Work Request")

to provide for more definitive delineation of responsibilities. This ACD will be revised and implemer.ted prior to the start of the 1984 Refueling Outage (March 16, 1984).

In order to identify and implement a long term resolution, selected plant staff have been designated to identify procedural and administrative deficiencies related to Maintenance Work Requests and propose corrective actions as necessary.

To date, final long term corrective actions have yet to be determined.

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