ML20128M029
| ML20128M029 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 10/07/1996 |
| From: | Link B WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| VPNPD-96-085, VPNPD-96-85, NUDOCS 9610150258 | |
| Download: ML20128M029 (5) | |
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POWER COMPANY 231 W McNoon. PO Box 2046. MJwoukee. WI 53201 2046 (414)221 2345 VPNPD-96-085 October 7,1996 Document Control Desk j
US NUCLEAR REGULATORY COMMISSION Mail Station PI-137 Washington, DC 20555 Gentlemen:
DOCKETS 50-266 and 50-301 REPLY TO NOTICE OF VIOLATION I.NSPECTION REPORT 50-226/96004 (DRPH 50-301/96004 (DRP)
POINT BEACH NUCLEAR PLANT. UNITS 1 AND 2 By letter dated September 6,1996, signed by Messrs. LA. Grobe and J. L. Caldwell, the NRC fortvarded to Wisconsin Electric, Integrated Inspection Report Nos. 50-266/96004; 50-301/96004. The inspection covered the period from April 28,1996, through June i1,1996. Enclosed with the inspection report was a Notice of Violation documenting three individual violations of NRC requirements.
1 Pursuant to the requirements of 10 CFR 2.201, we are responding to each of the violations. Attached is our response which includes: (1) the reason for the violation; (2) 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.
If you have any questions or desire additional information, please contact us.
Sincerely, k
i Bob Link Vice President Nuclear Power Attachment t
TGM cc: NRC Regional Administrator NRC Resident Inspector 9610150258 961007 PDR ADOCK 05000266 O
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4 RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-266/96004 (DRP); 50-301/96004(DRP)
WISCONSIN ELECTRIC POWER COMPANY i
POINT BEACl! NUCLEAR PLANT, UNITS 1 AND 2 DOCKETS 50-266 and 50-301 LICENSE NOS. DPR-24 and DPR-27 i
During a routine safety inspection performed by Messrs. T. Kobetz, A. McMurtray, and others of your staff covering the period April 28,1996 through June 11,1996, three violations of NRC requirements were j
identified. Each of the violations were classified as a Severity Level IV. Inspection Report 50-266/96004 i
(DRP); 50-301/96004 (DRP) and the Notice of Violation (Notice) transmitted to Wisconsin Electne on September 6,1996, provide details regarding each violation.
1 In accordance with the instructions provided in the Notice, our reply to the alleged violations include: (1) the reason for the violation, or if contested, the basis for disputing the violation; (2) corrective action taken; (3) corrective actions to be taken to avoid further violations; and (4) the date when full compliance will be achieved.
VIOLATION 1 10 CFR 50.59(a)(1) states that the licensee may make changes in the facility described in the safety analysis report without prior Commission approval, unless J proposed change, involves an unreviewed safety question.
10 CFR 50.59(b)(1) requires the licensee to maintain records of changes in the facility described in the safety analysis report. These records must include a written safety evaluation that provides the bases for the determination that the change does not involve an unreviewed safety question.
Contrary to the above, the licensee did not perform a safety evaluation to determine if an unreviewed safety question exists d, prior to performing a maintenance activity per routine maintenance procedure (RMP) 9344,
" Atmospheric Steam Dump Valve Maintenance," on the Unit 2 atmospheric steam dump system, which placed the plant in a condition different from that described in Section 10.2.2 of the Final Safety Analysis Report.
This is a Severity Level IV violation (Supplement 1).
Resoonse to Violation 1:
Reason for Violation:
Maintenance on atmospheric steam dump valve 2MS-2016 via work order WO 9603344 began on June 4,1996.
l The procedure (RMP 9344) specifies the use of a temporary valve body cover (blank flange) for valve work during conditions other than cold or refueling shutdown. A procedure precaution stipulates that if the valve is worked on during periods of operation, a voluntary entry into a limiting condition for operation (LCO) is to be l
entered pursuant to Technical Specification 15.3.4.A.S. Based on the type of work involved and the required 1
plant conditions for this work, a 10 CFR 50.59 safety evaluation for the replacement flange should be performed and referenced within RMP 9344 to assure an unreviewed safety question does not exist.
Similar work performed in the past on this valve was evaluated in accordance with 10 CFR 59.59(a)(1) and also applies to this work and procedure RMP 9344. Past work performed via work plans contained appropriate 10 CFR 50.59 documentation. The work plans were upgraded to a routine maintenance procedure via the
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Maintenance Procedures Upgrade Project (PUP). Reviews of RMP 9344 should have identified the need for a safety evaluation instead of a 10 CFR 50.59 screening for this work. This work was subsequently evaluated and 1
it was determined that it does not pose an unreviewed safety question.
Corrective Action Taken:
A temporary change to procedure RMP 9344 was initiated on June 14,1996 to reference 10 CFR 50.59 safety evaluation report SER 93-078-01. This safety evaluation report evaluates the use of a blank flange in place of l
the valve bonnet during work on the atmospheric steam dump valves.
s Corrective Action Taken to Avoid Further Violations:
This violation and NP 10.3.1, " Authorization of Changes, Tests, and Experiments (10 CFR 50.59 and 72.48 Reviews)," were reviewed and discussed with the Maintenance PUP. This discussion included a review of the i
Temporary Modification procedure. Specific examples of temporary changes, including the installation of the l
blank flange, were discussed along with the applicability of these processes to temporary changes.
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j All procedures that have completed the procedures upgrade process were reviewed to ensure that any other procedural temporary modifications were implemented in accordance with our procedures. No other instances were identified where temporary modifications were implemented without the required evaluations.
The temporary change will be made a permanent change to the procedure during a procedure upgrade. The permanent change will be completed by October 18,1996.
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Date When Full Compliance Will Be A ved:
4 We will be in full compliance by October 18,1996.
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VIOLATION 2:
10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality be prescribed by documented l-procedures and be accomplished in accordance with those procedures.
i The installation of a blank flange on steam dump valve 2MS-2016, a temporary modification, is an activity affecting quality.
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Nuclear Power Business Unit Procedure NP 7.3.1, " Temporary Modifications," Section 4.2.2. requires that the Initiation and Technical Review sections of the Temporary Modification Form be completed for a temporary modification.
Contrary to the above, the licensee did not complete the Initiation and Technical Review sections of the Temporary Modification Form for the temporary modification to valve 2MS-2016 involving the installation of a blank flange.
4 This is a Severity Level IV violation (Supplement I).
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1 Resoonse to Violation 2:
Reason for Violation:
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Maintenance of atmospheric steam dump valve 2MS-2016 via work order WO 9603344 began on June 4,1996.
He procedure specifies use of a temporary valve body cover (blank flange) for valve work during reactor i
operating conditions other than cold or refueling shutdown. A precaution stipulates that if the valve is worked i
during reactor operating conditions, voluntary entry into a limiting condition for operation (LCO) is to be entered pursuant to Technical Specification 15.3.4.A.S. RMP 9344 Step 7.3.8 describes the installation of the j
blank flange that allows for the exit of TS 15.3.4..A.S. Prior to LCO exit, an operator is verified available should the need arise for operation of the atmospheric steam dump valve isolation valve if steam dump line operation is j
needed. RMP 9344 Step 7.11.9 removes the temporary blank flange and enters back into TS 15.3.4.A.5 LCO.
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NP 7.3.1, " Temporary Modifications,"(TM) Step 4.2.2 states, " Documentation of a procedural TM shall be
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made by completing the initiation and Technical Review sections of the TM form. No TM number is to be j
assigned. The TM form and supporting documents shall be attached to the procedure cover sheet (PBF-0026a) and the procedure shall be approved per the requirements of NP 1.2.2." NP 1.2.2," Technical Procedure l
Classification, Review and Approval," contains the same requirements. Contrary to this requirement, RMP 9344 was reviewed and approved by the Manager's Supervisory Staff without the procedural temporary modification documentation required by NP 7.3.1.
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The procedure cover sheet questions the author whether the procedure change implements a temporary j
modification and requires the documentation to be attached. -The procedure author failed to identify that the l.
work should have invoked the temporary modification process. liowever, the procedural requirements within j
RMP 9344 to install and remove the temporary modification were appropriated fulfilled.
Corrective Action Taken:
Condition Report CR 96-380, initiated on June 10,1996, documents this event. A historical search of the j
Condition Report database was performed with no similar deviations noted.
The procedure author and the Maintenance Procedures Upgrade Project (PUP) team discussed the implications of this violation and the relevancy ofNP 7.3.1," Temporary Modifications." Subsequent to approval, the appropriate TM documentation was included with RMP 9344.
NP 7.3.1," Temporary Modifications," was reviewed for adequacy of the procedure and the temporary l
modification process. It was determined this is an isolated incident and no change to the procedure nor process is required.
i A reminder of the requirements for procedural implementation of temporary modifications was sent all personnel on September 25,1996. This reinforced the need for adhering to the procedural requirements in NP 7.3.1 with respect to procedural temporary modifications.
A memorandum will be sent to all Manager's Supervisory Staff (onsite review committee) and first line i
supervisors discussing this event, the lessons learned, and reinforcing the need for procedural compliance. This memo will be sent by October 11,1996. Followon discussions will be held at the next regularly scheduled i
meetings with these groups. The next Manager's supervisory staff meeting is scheduled for October 15,1996.
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The next meeting of first line supervisors will occur following the present Unit 2 refueling outage and will be completed prior to the end of the year.
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Date When Full Compliance Will Be Achieved:
Full compliance will be achieved by December 30,1996.
YlOLATION 3:
Technical Specification 15.6.8, requires that the plant shall be operated and maintained in accordance with Major Procedures supporte i by Minor Procedures.
Step 6.4 of Point Beach Nuclear Plant Health Physics Manual procedure HP 3.2.2, "RCA Contaminated Areas, Tools, Equipment and Materials Posting Requirements," which is a Minor procedure, requires that material being removed from a contaminated area either be surveyed by Health Physics prior to being removed or packaged and labeled and placed in a designated area until Health Physics can perform the surveys.
Contrary to the above, during dry cask k.ading operations for the second VSC-24 cask, the licensee failed to perfomi a survey of a wrench prior to removing it from a contaminated area.
This is a Severity Level IV violation (Supplement IV).
Enponse to Violation 3:
Reason for Violation:
This event occurred during the installation of the housing for a RO-2 (2A) radiation survey meter. The housing is attached to the spent fuel pool (SFP) bridge so the meter and electronics are not within the SFP foreign materials exclusion area. A Health Physics technologist (HPT) on the clean side of the step-off pad entrance to the SFP handed another HPT who was standing on the SFP bridge a small wrench so the survey meter housing could be attached to the SFP bridge railing. The second HPT had changed his gloves prior to handling the wrench. He then attached the housing and handed the wrench back to the first HPT who wiped the wTench off and handed the wrench to a third HPT who subsequently placed the wrench back into storage. This is a violation of HP 3.2.2 that clearly states that material removed from a contaminated area be surveyed.
Corrective Action Taken:
The procedural non-compliance was discussed with the three HPTs. Following the discussions, the HPTs fully understood the deviation from health physics practices. This event was also discussed at a Health Physics group meeting.
Corrective Action Taken to Avoid Further Violations:
- We recognize concerns regarding contamination control practices at Point Beach. Evaluations to improve contamination control practices are in progress and will include procedure changes as appropriate to be completed prior to March 29,1997, which is the start of the next Unit I refueling outage.
The Unit 2 Refueling 22 Health Physics pre-outage brief will include discussions relating to this event.
Date When Full Compliance Will Be Achieved:
Ws, will be in full compliance by March 29,1997.
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