ML20149H787
| ML20149H787 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 12/21/1994 |
| From: | Link B WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-94-090, CON-NRC-94-90 VPNPD-94-133, NUDOCS 9412290268 | |
| Download: ML20149H787 (4) | |
Text
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! Electnc POWER COMPANY
. 231 W Mich gon, PO Box 2046. Mdwovkee. WI 53201-2046 (414) 221-2345 VPNPD-94-133 NRC-94-090 December 21, 1994 Document Control Desk U.S.
NUCLEAR REGULATORY COMMISSION Mail Station P1-137 Washington, DC 20555 Gentlemen:
-DOCKETS 50-266 AND 50-301 REPLY TO NOTICE OF VIOLATION INSPECTION REPORTS 50-266/94020 (DRP); 50-301/94020 (DRP)
POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 On November 22, 1994, the Nuclear Regulatory Commission forwarded to Wisconsin Electric Power Company, licensee for Point Beach Nuclear Plant, the results of a routine safety inspection conducted by Messrs. T. Kobetz and A. McMurtray from September-18 through November 8, 1994.
This inspection report included a Notice of Violation (Notice) describing a Severity Level IV violation.
We have reviewed the Notice and, pursuant to the provisions of 10 CFR 2.201, have prepared a written. response of explanation concerning the identified violation.
Our written response is included as an attachment to'this letter.
If you have any questions or require additional information regarding this response, please contact us.
Sincerely,
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j Bob Link Vice President Nuclear Power KVA/jg
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NRC Resident Inspector NRC Regional Administrator, Region III
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RESPONSE TO NOTICE OF VIOLATION 4
WISCONSIN ELECTRIC POWER COMPANY POINT BEACM NUCLEAR PLANT, UNITS 1 AND 2 DOCKETS 50-266 AND 50-301 LICENSB NOS. DPR-24 AND DPR-27 During.a routine safety inspection performed by Messrs. T. Kobetz and T. McMurtray from September 18 through November 8, 1994, a violation of NRC requirements was identified.
The identified violation was classified as Severity Level IV.
Inspection Report Nos. 50-266/94020 and 50-301/94020 and the Notice-of Violation (Notice) transmitted to Wisconsin Electric on November 22, 1994, provide details regarding the violation.
We do not 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 viola-tion; (2) corrective action taken; (3) corrective action to be taken to avoid further violations; and (4) the date when full compliance will be achieved.
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VIOLATION j
10 CFR 50, Appendix B, Criterion XVI, " Corrective Action,"
requires in part, that measures be established to assure i
that conditions adverse to quality, such as deviations and J
nonconformances, be promptly identified and corrected.
Contrary to the above, a conflict in Step 7 of Emergency Operating Procedure (EOP) 0.1,
" Reactor Trip Response," was not promptly corrected in that two new revisions of the EOP were issued within 18 months without addressing the conflict.
RESPONSE TO VIOLATION:
1.
BASIS FOR DISPUTING THE VIOLATION Emergency Operating Procedure (EOP) 0.1,
" Reactor Trip Response," Revision 8, Step 4, was identified on January 23, 1993, and on June 11, 1993, to be in conflict with the EOP series foldout page for the parmneter of pressurizer level.
This step directs the operator to check that pressurizer level is greater than 12 percent.
If the level is greater than 12 percent, the operator is directed, in part, to verify that pressurizer level is trending to 20 percent.
If the pressurizer level is less than 12 percent, the operator is directed to the Response Not Obtained (RNO) column which instructs him/her, in part, to control charging to restore pressurizer level to greater than 12 percent.
s, This is inconsistent with the foldout page for EOP 0.1 which gives criteria for when Safety Injection (SI) should be actuated.
The criteria requires, in part, that SI be actuated if pressurizer level cannot be maintained greater than 14 percent with a normal containment atmosphere.
We do not agree that this condition represents a " direct conflict" in the procedure.
The procedure does not give the operators nonconservative guidance as stated in the description in the Inspection Report.
Therefore, we do not agree that this is a condition adverse to quality and, hence, do not believe it is a violation of 10 CFR 50, Appendix B, Criterion XVI.
Procedure EOP 0.1, as written, is conservative.
Step 4 of EOP 0.1, Revision 8, is based on Step 4 of the Westinghouse Owner's Group Emergency Response Guidelines, ES-0.1, " Reactor Trip Response."
The purpose of this step is to ensure normal post-trip pressurizer level response, specifically, automatic letdown isolation and pressurizer heater cutoff.
Because the Point Beach Nuclear Plant (PBNP) setpoint for automatic letdown isolation and heater cutoff (12 percent pressurizer level) is less than the level at which SI should be initiated (14 percent pressurizer level), Step 4 is a step that will not be carried out if pressurizer level falls below 14 percent.
If pressurizer level cannot be maintained greater than 14 percent, the foldout page directs the operator to initiate SI, exit EOP 0.1, and enter EOP 0,
" Reactor Trip or Safety Injection."
The step to check pressurizer level greater than 12 percent, therefore, will not be entered if pressurizer level falls below 14 percent.
The 14 percent pressurizer level at which SI should be actuated is based on the accuracies associated with the Foxboro pressurizer level transmitters.
These transmitters were replaced with Rosemount transmitters in May 1992 for Unit 1 and in October 1993 for Unit 2.
Because of the change from Foxboro to Rosemount level transmitters, a new setpoint calculation is required to determine the pressurizer level at which SI should be initiated.
As the Rosemount transmitters have lower process measurement errors than the Foxboro trans-mitters, we expect a value of less than 12 percent.
We have delayed the determination of the new setpoint in order to perform the setpoint calculation using our new setpoint methodology which is under development.
The inconsistency between Step 4 of EOP 0.1, Revision 8, and the foldout page was identified in January 1993.
Because the step would not be entered if pressurizer level fell below 14 percent, the only action that could have been taken would have been to eliminate the step completely.
If the setpoint calculation for the Rosemount transmitters demonstrates that SI can be initiated at a pressurizer level of less than 12 percent as we expect, the step would have to be
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r6 inserted.
Rather than remove the step only to reinsert it at a later date, we decided to wait until the new setpoint methodology is approved and a setpoint calculation performed to datermine'the new pressurizer level at which SI should be initiated.
Because Step 4 would never be entered, as mentioned above, we did not eliminate the step in Revisions 9 and 10 to EOP 0.1.
In summary, because Step 4 of EOP 0.1, Revision 8, would not be entered and the foldout page directed the operator to initiate SI at a conservative value of 14 percent pressurizer level, we do~not believe that the procedural; discrepancy described in the Notice constituted a condition adverse to quality, gave the operators nonconservative guidance, nor created an inadequate procedure for accident mitigation.
As such, we do not agree that this condition represents a violation of 10 CFR 50, Appendix B, Criterion XVI.
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