ML20081L787
| ML20081L787 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 03/28/1995 |
| From: | Link B WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-95-014, CON-NRC-95-14 VPNPD-95-025, VPNPD-95-25, NUDOCS 9503310007 | |
| Download: ML20081L787 (3) | |
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POWER COMPANY 231 W Mchoon.PO Box 2046.Mwoukee WI 532012046 (414)221-2345 VPNPD-95-025 NRC-95-014 March 28, 1995 Document Control Desk-U.S. NUCLEAR REGULATORY COMMISSION Mail Station P1-137
-Washington, DC 20555 Gentlemen:
DOCKETS 50-266 AND 50-301 EESPONSE TO NOTICE OF VIOLATION' POINT BEACH NUCLEAR PLANT. UNITS 1 D gl t
In a letter from Mr. M. J. Farber dated February 28, 1995, the Nuclear Regulatory Commission forwarded to Wisconsin Electric Power Company, licensee'for the Point Beach Nuclear Plant, the results of a routine safety inspection performed by Messrs. T. Kobetz and A.
McMurtray from December 21, 1994, through February 6, 1995.
This inspection report included a Notice of Violation (Notice).
The Notice describes a violation of 10 CFR 50, Appendix B, Criterion V,
" Instructions, Procedures, and Drawings," and a violation of the Point Beach Security Plan.
As stated in the Notice, a response is not required for the violation of the Security Plan.
We have reviewed this Notice and, pursuant to the provisions of 10 CFR 2.201, have prepared a written response of explanation concerning the identified violation of 10 CFR 50, Appendix B.
Our written response is included as an. attachment to this letter.
We believe that the attached reply is responsive to your concerns and fulfills the requirements identified in your February 28, 1995, j
letter.
J If you have any questions or require additional information regarding this response, please contact us.
Sincerely, Bob Link Vice President Nuclear Power 9503310007 950328 PDR ADOCK 05000266 O
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NRC Resident Inspector jp{I NRC Regional AdminJ g g t,pp y ggjg1}y g
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^t RESPONSE TO NOTICE OF VIOLATION WISCONSIN ELECTRIC POWER CONPANY POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 DOCK 3TS 50-266 AND 50-301 LICENSE NOS. DPR-24 AND DPR-27 During a routine safety inspection performed by Messrs. T. Kobetz and A. McMurtray from December 21, 1994, through February 6,
- 1995, a violation of NRC requirements was identified.
The identified violation was classified as Severity Level IV.
Inspection Report Nos. 50-266/94025 and 50-301/94025 and the Notice of Violation (Notice) transmitted to Wisconsin Electric on February 28, 1995, provide details regarding the violation.
We agree that the events and circumstances described in the Notice are accurately characterized.
In accordance with the instructions provided in the Notice, our reply to the alleged violation includes:
(1) the reason for the violation, or if contested, the basis for disputing the violation; (2) corrective action taken; (3) corrective action to be taken to avoid further violations; and (4) the date when full compliance will be achieved.
VIOLATION:
10 CFR 50, Appendix B, Criterion V,
" Instructions, Procedures, and Drawings," requires in part that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriato to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
PBNP 4.12.54, "Use of Dedicated and Assigned Operators," requires written instructions be provided to dedicated operators when they are used for manual action in place of an automatic action of a containment isolation valve.
Contrary to the above, on at least two instances, the Duty Shift Supervisors (DSSs) failed to provide written instructions for operation of automatic containment isolation valves, 1/2 RC-508, when dedicated operators were used in lieu of the automatic closure function of these valves.
RESPONSE TO VIOLATION:
1.
REASON FOR VIOLATIONS On December 12, 1994, the DSS stationed a dedicated operator once at 1RC-508 and once at 2RC-508 while each valve was tested during troubleshooting.
The testing required disabling the valve's automatic trip function.
A dedicated operator was stationed for approximately 8 minutes at each valve during this testing to shut the valve if necessary.
In neither case was the dedicated operator provided with written instructions as required by Procedure PBNP 4.12.54.
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- The! DSS did notLrefer,to Procedure PBNP 4.12.54 when he?
j stationMd the dedicated operator and-therefore did not recall j
that written instructions were required.
Also, due1to-the simplicity of this operation, he did not think of the.needLto j
. provide written-instructions.
2.-
CORRECTIVE ACTION TAKEN The' failure'to provide written _ instructions to the dedicated
,j operators:was discovered by the NRC Resident Inspectors in-j January 1995. LTherefore,-no immediate corrective actions were.
j taken.
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3.
CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER VIOLATIONS' i'
.i License Amendments 160 and 164 for PBNP Units 1 and 2 respectively were issued by the NRC.on January 18, 1995.
These amendments clarified the definition of containment:
integrity and the operability requirements for containment l
isolation valves.
The modified specifications allow I
containment penetration flow paths, except the purge supply i
and exhaust. flow path, to be unisolated intermittently under i
administrative controls.
The Basis Section states that;the administrative controls consist of stationing a dedicated i
operator at the valve controls who is in continuous communication with the control room.
Procedure PBNP 4.12.54-was canceled on February 17, 1995, and replaced by PBNP Operations Manual (OM) 3.26,E"Use of.
l Dedicated Operators."
Procedure OM 3.26 provides. specific j
guidance for the use of a dedicated operator to operate-containment isolation valves.
Step.4.2.7.b states that written instructions shall be provided to'a dedicated i
operator for containment isolation'and boundary valves or j
containment hatches.
The instructions shall outline the dedicated operator's responsibilities including specific j
required actions, required location of the operator, initiating event, and time required to complete the action.
l These-' instructions may'be contained in an approved procedure or handwritten form.
Step 4.2.7.c requires the dedicated i
operator to be in constant communication with the control room.
All operators have been trained on the use of Procedure OM 3.26 with emphasis on the use of dedicated operators j
for containment isolation valves.
Together, License Amendments 160/164 and Procedure OM 3.26 i
provide clear and consistent guidance on the use of dedicated i
operators for containment isolation valves.
j 4.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED 1
We are presently in full compliance with NRC requirements.
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