ML20207R899
| ML20207R899 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 03/13/1987 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-87-029, CON-NRC-87-29 VPNPD-87-104, NUDOCS 8703180276 | |
| Download: ML20207R899 (3) | |
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lMsconsin Electnc m comr 231 W. MICHIG AN, P.O. BOX 2046, MILWA UKEE,WI 53201 (414) 221-2345 VPNPD-87-104 NRC-87-029 March 13, 1987 U. S. NUCLEAR REGULATORY COMMISSION Document Control Desk Washington, D.
C.
20555 Gentlemen:
2GG DOCKETS 50-2-77 AND 50-301 RESPONSE TO INSPECTION REPORT 50-266/87002(DRP) AND 50-301/87002(DRP)
POINT BEACH NUCLEAR PLANT This is in response to Mr. Guldemond's letter of February 10, 1987, regarding a routine inspection conducted by Messrs.
R. L. Hague and R. J. Leemon between December 1, 1986, and January 31, 1987, of activities at Point Beach Nuclear plant.
The inspection report cited one deviation.
Response to Notice of Deviation (266/87002-01)
A deviation was cited for certain activities which allegedly differed from system descriptions made to the NRC, in response to IE Bulletin 79-24, in C. W. Fay's letter to J. G. Keppler dated October 29, 1979.
The inspection report states that our facade freeze protection monitoring system is not being operated as described in our letter, which stated that freeze protection " monitoring includes a multichannel recorder located in the auxiliary building which tracks the status of each of the heat tracing channels.
Trends and gradual changes in the performance of the heat tracing circuitry can be determined by observing these point recordings."
We believe we are operating this system as we intended in 1979, because our October 29, 1979 letter also described when these point recordings would be consulted.
"If any freeze protection I
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i-NRC Document Control Desk March 13, 1987 Page 2 channel suddenly fails, a common alarm is annunciated in the control room...The heat tracing recorder can then (emphasis added) be_ checked to determine exactly which channel has caused the alarm."
Each channel setpoint is selected to be anticipatory such that an alarm is generated, and trending is started prior to the time that freezing of the line is expected.
When an alarm is received, the ensuing trend can be consulted to determine the priority and/or necessity of the repair.
In retrospect, we agree that the 1979 letter cait be read to imply that constant monitoring would be performed.
That was not the intent for two reasons:
First, there would be no purpose in running the recorder during weather conditions when freezing was unlikely.
Second, it is impractical to operate constantly the recorder presently installed due to the paper speed.
Corrective Action The inspection report noted that three points on the recorder were out of service.
We reviewed the maintenance work requests (MWR's) for heat tracing channels which were outstanding at the time of the inspection.
Three MWR's were identified as having a high priority because a drop in temperature below zero degree Fahrenheit would cause some concern.
The remaining nine MWR's have been given low priorities due to minor modifications such as labeling or testing of actual versus indicated amperage through the heat tracing circuits.
The three high-priority MWR's should be complete by April 1, 1987.
Due to the maintenance problems experienced with the present recorder and the limitations for trending due to paper speed, we plan to procure an improved chart recorder.
Installation of the new chart recorder and additional cables has begun, but is not expected to be completed prior to the end of the fall outage for Unit 2 in 1987.
The slower paper speed of the new recorder will allow longer trending when appropriate.
We continue to believe that constant operation is not technically justified and that trending upon receipt of an alarm is appropriate.
We wish to point out that the reference to statements in correspondence several years old raises the issue of what
" commitments" require notification to the NRC if changes are subsequently made.
In the large volume of correspondence between licensees and the NRC, there are many descriptions of activities to be taken which have little or no safety significance, but, rather, are included for clarification or to describe more completely an activity to be done.
To attempt to track all such statements with the intent of notifying the NRC of any change made years later would be a large administrative
, ~
NRC Document Control Desk March 13, 1987 Page 3 burden.
Further, we would expect the NRC to have significant problems with the large volume of paper which would result.
This issue was discussed with members of the NRC staff several years ago.
Based on those discussions, an in-house policy was issued to provide guidance for our own activities.
This policy states that technical commitments consist of stipulations that specified engineered design features will be maintained or that.
specified administrative controls will be followed in operating our facility.
The policy acknowledges that these technical commitments are documented in the operating licenses, the Technical Specifications, the Final Safety Analysis Report, NRC Confirmatory Orders, or in NRC safety evaluation reports which state that a licensing action is based on specific commitments.
Under this policy, we would not have reported a change from constant monitoring of freeze protection to monitoring upon alarm even if it reflected a change of our earlier intent.
If you have any questions concernin? this information, please contact us.
Very truly
- ours, fEc/ p g' C. W. Fay Vice President Nuclear Power Copies to NRC Resident Inspector NRC Regional Administrator, Region III Att: W. G. Guldemond, Chief Projects Branch 2 i
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