ML20197A780
| ML20197A780 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 12/17/1997 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Patulski S WISCONSIN ELECTRIC POWER CO. |
| References | |
| 50-266-97-15, 50-301-97-15, NUDOCS 9712230182 | |
| Download: ML20197A780 (1) | |
See also: IR 05000266/1997015
Text
D:cemb;r 17, 197
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_
- I
SI'.3 Vice President
'
Point Beach Nuclear Plant
- Wisconsin Electric Power Company
6610 Nuclear Road
Two Rivers, WI _54241
1
SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORT
,
NO. 50-266/97015(DRS); 50 301/97015(DRS)_
Dear Mr. Patuisk!:
This will acknowledge receipt of your letter dated November 13,1997, in response to
our letter dated October 14,1997, transmitting a Notice of Violation associated with inspection
Report No. 50 26C/f,7015(DRS); 50-301/97015(DRS) at the Point Beach Nuclear Power
Station. We have reviewed your corrective actions and have no further questions at this time.
- These corrective actions will be examined during future inspections.
Sincerely,-
/s/J.A. Grobe
John A. Grobe, Director
Division of Reactor Safety
Docket No. 50-266 -
Docket No. 50-301
cc w/ encl:
R. R. Grigg, President and
Chief Operating Officer, WEPCo
A. J. Cayla, Plant Manager
B. D. Burks, P.E., Director
Bureau of Field Operations
Cheryl L. Parrino, Chairman,
Wisconsin Public Service Commission
- State Liaison Officer
Distribution
Docket File w/enct
Rill PRR w/enci
Rill Enf. Coordinator w/enci
PUBLIC IE-01 w/enci
SRI, Pt. Seach w/enci
TSS w/enci
LPM, NRR w/enci
J. L. Caldwell, Rlli w/enci
DOCDESK w/enci
DrtP w/enct
A. B. Beach, Rlli w/enci
CAA1 w/enci
DRS w/enci
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NPL 97 0734
November 13,1997
Document Control Desk
U. S. NUCLEAR REGULATORY COh1 MISSION
Mr.il Station Pl.137
Washington, DC 20555 .
Ladjes/ Gentlemen:
DOCKETS 50-256 AND 50-3.01
REPLY TO A NOTICE OF VIOLATION
NRC INSPECTION REPORT NOS. 50 266/97015 AND 50 301/97015
POINT BEACII NUCLEAR PLANT. UNITS i AND 2
In a letter from Mr. John A. Grobe dated October 14,1997, the Nuclear Regulatory Commission
fonvarded the results of an inspection conducted by Reactor Inspector D. Schrum at our Point Beach
Nuclear Plant between July 7 ard July 11,1997. This inspection report included a Notice of Violation
which identified two violatio
. NRC requirements.
'
We have reviewed the Notice c. Violation and, pursuant to the provisions of 10 CFR 2.201, have
prepared a written response as required. Our written response is included as an attachment to this letter.
We believe that the attached reply is responsive to the Notice of Violation and fulfills the requirements
identified in your October 14,1997 letter.
New commitments that have not been previously docketed are identified by italics.
If you have any questions or require additional information regarding this response, please contact me.
Sincerely,
Y& .
d" -
&
A. J. Cayia
Plant Manager
Point Beach Nuclear Plant
Attachment
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NRC Regional Administrator
NRC Resident inspector
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Attachment to NPL 97-0734
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DOCKETS 50-266 AND 50-301
RFJLY TO A NOTICE OF VIOLATION
NRC INSPECTION REPORT 50-266/97015 AND 50-301/97dl5
POINT BEACH NUCLEAR PLANT UNITS 1 AND 2
L During an NRC inspection conducted from July 7,1997, through July 11,1997, two violations of NRC '
requirements were identified. Inspection Report 50-266(301)/97015 and 'he Notice of Violation
(Notice) transmitted to Wisconsin Electric on October 14,1997, provide details regarding the violations,
in accordance with the instructions provided in the Notice, our reply to the violations includes: (1) the
reason for the violation, or if contested, the basis for disputing the violation; (2) the 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.
Yiulati9utJ;
"10 CFR 50, Appendix B, Criterion V, required, in part, that activities affecting quality shall be
prescribed by documented instructions, procedures, or drawings of a type appropriate to the
circumstances and shall be accemplished in accordance with these instructions, prondures, and
draivings.
Contrary to the above, as of July 11,1997, Surveillance Procedure E-M3 1," Emergency Lighting," was
not adequate in that it did not specify the use of calibrated voltmeter, did not include a data sheet that
adequately captured the emergency lighting battery and battery charger voltage readings specified in the
procedure, and did not provide guidance as to what steps were to be taken when battery discs indicated
potential deficiencies in either the battery or battery charger.
'Diis is a Severity Level IV violation (Supplement 1)."
Reason for Violation 1
% e concur with Violation 1 as characterized in the inspection report. This violation is generally
attributable to an inadequate emphasis on the importance of the emergency lighting system and is
Specifically attributable to inadequate development of a procedure (E-M3-1," Emergency Lighting") and
!ailure of personnel to identify the procedural inadequacies during use of the procedure.
During previous surveillances using E-M3-1, maintenance personnel used the uncalibrated . eter
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mounted on the emergency lighting unit to determine battery voltage. However, in September 1996, the
procedure was revised to require measurement of battery / charger voltage levels within a range +/- 0.3
volt, Because the mounted meter is incremented in one-half volt increments, it lacked the accuracy to -
satisfattority conduct the test; however, the procedure was not revised at that time to specify the use of a
calibrated voltmeter. Personnel who conducted thetest under this procedure attempted to read the
mounted meter to the accuracy prescribed in the procedure and failed to question the adequacy of the
procedure.
.
Attachment to NPL 97-0734
Page 2
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Personnel did not consistently record voltage readings because the procedure and data sheet did not
- provide specific instructions for measuring and recording the voltage data. And finally, the procedure
did not provide specific guidance for unsatisfactory battery disc indication because it relied on the skill-
of the-craft and questioning attitude of the maintenance personnel assigned to perform the surveillance.
In addition, the procedure had not been routinely reviewed such that the rising standards and
expectations for emergency lighting systems were addressed by procedure improvements.
Corrective Actions Taken:
To increase the significance _ f the PBNP emergency lighting system, Wisconsin Electric has included
o
the system in the scope of the Maintenance Rule equipment and has committed to upgrade t'.e pedigree
of the system to a classification of" Augmented Quality." Under the Maintenance Rale, the emergency
lighting system was evaluated as an A(2) system; a system which meets its per% nance criteria.
In addition, the Fire Protection / Appendix R Rebaselining Project was initiated in 1997 to improve the
reliability of the fire protection system and generally raise the significance of related equipment issues.
Corrective Actions to be Taken:
1.
Procedure E Al3-1, " Emergency Lighting" has been revised to require the use c.fa calibrated
voltmeter on the battery terminals to measure battery and charger voltage. The r evisedprocedure
also requires recording the specific value ofvoltage, andprovides guidancefor out-of-tokrance
voltage readings or abnormalfloating dia indications.
2.
By the end ofAfay. I993, the entire emergency lighting surveillance and maintenance program will
be assessed with respect to the associated Electric Power Research Institute (EPRI) Nuclear
Alaintenance Applications Center (NAMC) standard, and the appropriate program :hanges and
.
hardware changes will be completed by that time.
3.
Electrical testpoints wdl be installed on theface ofeach emerger:cy lighting unit tofacilitate
testing with a calibrated, portable meter. These modifications will be completed by the end of
Afay,1993.
Date Full Campliance Will be Achieved;
Full compliance will be achieved when the program is assessed and the appropriate enhancements
completed in May,1998.
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Attachment to N?L 97-0734
Page 3
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XinlatituL2:
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" Point Beach Technical Specification 15.6.8.1.8 required that the Gre protection program be
I
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implemented and maintained using approved procedures.
Point Beach Procedure MWP 126," Emergency Lighting Eight liour Operational Test," Revision
a.
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0, dated March 22,1994, required the annual testing of Groups I,11,111, and IV emergency lighting
,
batteries.
Point Beach Procedure MWP 126," Emergency Lighting Eight Hour Operatie.al Test," Revision
4, dated August 23,1996, soecines the use of a digital multimeter for measuring battery and
battery charger output voltages.
Contrary to the above, on February 3,1995, electrical maintenance personnel did not correctly
implement MWP 126, Revision 0 in that the required annual testing of Group IV emergency
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lighting batteries was not completed. In addition, as of July 11,1997, electrical maintenance
personnel were using the uncalibrated voltmeter located on the front of the emergency lighting
,
units in lieu of the required digital multimeter.
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This is a Severity Level IV violation (Supplement 1).
b.
Point Beach Procedure E M31," Emergency Lighting," Revision 4, Step 6 required that the
correct alignment of emergency lighting units be verined using existing painted markines installed
on emergency lighting mounting brackets.
Contrary to the above, as of July 11,1997, procedure E M3 1 was not correctly implemented in
that electrical maintenance personnel were not verifying the correct alignment of a number of
emergency lighting units due to the absence of painted markings on these units.
.
-
This is a Severity Level IV violation (Supplement 1)"
Point Beach Prc4edure, PC 74," Conducting and Evaluating Fire Drills," Revision 5, paragraph 2.3
c.
stated: " Individual Fire Brigade members shall participate in at least two drill (sic) per year."
Contrary to the above, as of July 11,1997, fire brigade personnel, wna were listed as quali6ed Orc
brigade members, had not participated in the required fire brigade drills.
This is a Severity Level IV violation (Supplement 1)"
Rrnan for Violation 2.a -
We concui with Violation 2.a as characterized in the icspection report. Personnel did use the
uncalibrated voltmeter on the emergency lighting units rather than the digital multimeter required by tne
pmcedure MWP 126. There was a lack of verbatim compliance in this instance primani:y due to the
ready-availability of the uncalibrated voltmeter on the face of each unit and the general perception in the
past that the emergency lighting system was not a safety significant system which required a quality
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voltage measurement. The procedure did not provide adequate controls to preclude use of the in place
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' voltmeter. These procedural shortfalls resulted from an inappropriate reliance on the skill-of the craft.
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Under the previous procedure, the program relied on the knowledge of maintenance personnel to ensure
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that an appropriate voltmeter was used for the test to obtain the requisite precision. The procedure also
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relied on the knowledge of maintenance personnel to recognize that no external test points were
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provided on the lighting unitst and that removal of the battery cover would be necessary to obtain battery
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terminal voltages,
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Grfndve Actions Taken:
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- As discussed in the reply to Violation 1, the signincance of the P11NP emergency lighting system has
been increased by the changes to the Maintenance Rule program, by the quality classlucation upgrade,
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!
and by virtue of the ongoing enhancements of the Fire Protection / Appendix R Rebaselining Project.
- These programmatic improvements have raised the general level of awareness and significance of Fire
!
Protection equipment.
GrndttAdons to be Taktn_to PrettnLReturnncti-
,
1.
As discussed in the reply to Violation 1, the entire emergency lighting surveillance and
,
maintenance program will be assessed and enhanced as appropriate.
2.
As discussed la the reply to Violation 1, electrical test points will be installed on the face of each
emergency lighting unit to facilitate testing with a calibrated, portable meter.
3.
In the interim period. MWP 126 will be revisedprint to the next scheduledperformance (currently
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scheduled in February 1998). This revision will require the removal ofthe battery cover and use
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ofa :alibrated voltmeter on the battery terminals to mecsure battery and charger voltage. This
.
supplementalguidance willpreclude fitture use ofthe existing voltmeters on theface ofeach
emergencylighting unit.
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Date Full Comnllance Will be Achievedt
Full compliance will be achieved when the program is assessed and the appropriate enhancements
completed in May,1998,
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Reason for Violation 2.b
,
.We concur with Violation 2.b as characterized in the inspection report. In some cases, alignment
markings were not evident on the emergency lighting units. The absence of these markings precluded
the verification of proper ulignment during performance of procedure MWP 126.
This violation was caused by a failure of maintenance personnel to comp'y verbatim with the procedure.
.in those cases where alignment markings were not available, we believe the maintenance personnel
applied their common sense to check lamp alignment, but did not exhibit a good questioning attitude to
id.ntify and correct the lack of alignment markings. This violation is generally attributable to an
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inadequate emphasis on the importance of the emergency lighting system and failure of personnel to
identify the procedural inadequacies during use of the procedure.
Cometive Actionslakts:
As diset.ssed in the reply to Violation 1, the significance of the PilNP emergency lighting system has
been increased by the changes to the Maintenance Rule program, by the quality classification upgrade,
-
,
and by vinue of the ongoing enhancements of the Fire Protection / Appendix R Rebaselining Project.
,
These programmatic improvements have raised the general level of awareness and significance of Fire
.
. Protection equipment.
'
Currectire.Asilentin_hclakenJo Prevent Returrencri
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1.
As discussed in the reply to Violation 1, the entire emergency lighting surveillance and
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maintenance program will be assessed and enhanced as appropriate.
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- 2.
In the interim period. Mll'P 126 will be revisedprior to the next scheduledperformance. This
revision will ensure that remedial action is takenfor emergency lighting units that lack alignment
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markings. The appropriate alignment is derivedfrom the emergency lighting study.
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11als_Eull Compliance Will be Ach!cygdi
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!
Full compliance will be achieved when the program is assessed and the appropriate enhancements
complete ' In May,1998.
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Reason _for_Ylulatlunic
We concur with Violation 2.c as characterized in the inspeaion report. For previous Orc drills, the scope
of the " Fire litigade Database" did not distinguish between active and passive participation in a fire drill.
Therefore, Control Operators (COs) who did not leave the Control Room during a fire drill may have
been given credit for drilling as a member of the fire brigade. Only the Fire 13rigade Chief and those
personnel who don fire fighting gear and turnout at the scene of the fire drill should have received credit
for active participation in the twice-per year fire drill.
.
Corresthe Actions Taken:
.
On August 7,1997, the PilNP Fire Protection and Safety Coordinator revised the Fire 13dgade Database
to remove the names of CDs, because these individuals are no longer assigned the duties of the fire
brigade, and are no longer subject to the training requirements of PC-74. COs have not been used for
fire brigade assignments since November 1996. This revision ensures that the traditional definition of
" fire brigade" will be observed and there will be no future confusion about the participation of control
operators for the subject raining requ'rement, in the future, only the Fire 13rigade Chief and those fire
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brigade members who turnout in fire fighting equipment and actively participate at the scene of the fire
drill will be given credit for actively participating in the fire drill.
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Attachment to Ni>L 97-0734
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CurrtclirrAc11onttu.hclaken to Prtitn1]{ccutuncti
'lhe aforementioned change to the l' ire lirigade Database is an adequate measure to prevent recurrence.
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DatclulLCutupliance Will bcAchirndt
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Full compliance with NitC requirements was achieved when the Fire 11rigade Database was revised on
August 7,1997.
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