ML20212N825

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Responds to Re Violation Identified in Insp Rept 50-266/86-21.Response Addresses Hardware Aspects of Problem But Fails to Provide Corrective Actions Re Inappropriate Approach to Calculating Difference Between Type a Test Data
ML20212N825
Person / Time
Site: Point Beach NextEra Energy icon.png
Issue date: 03/10/1987
From: Hehl C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Fay C
WISCONSIN ELECTRIC POWER CO.
References
NUDOCS 8703130169
Download: ML20212N825 (2)


See also: IR 05000266/1986021

Text

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Docket No. 50-266

Docket No. 50-301

Wisconsin Electric Power Company

ATTN: Mr. C. W. Fay

Vice President

Nuclear Power Departownt

231 West Michigan, Room 308

Milwaukee, WI 53201

Gentlemen:

This is in response to your letter dated February 4,1987, which addressed a

violation identified in Inspection Report No. 266/86021. We have completed

our review of your letter and have the following observations.

A review of violation 266/86021-02 does not support your contention that it is

based on the guidance provided in Section 3 of the report. Rather, the violation

is based solcly on the requirenents of 10 CFR 50 Appendix J Section III.A.3(b)

which have not changed since the 1984 test and your Technical Specifications.

Your response to the violation adequately addressed the hardware aspects of

the problem, but is not obvious what corrective actions you have or are

going to implement regarding the inappropriate approach to calculating the

difference between the Type A test data and the supplemental test data which

was inconsistant with your previous analysis and industry practice. The fact

that an NRC inspector erred in 1984, by agreeing to the inappropriate

calculation, does not relieve you of the responsibility to comply with the

regulations and has no bearing on the appropriateness of the violation.

For the above reasons, we do not agree with your position that the Unit 1

1904, CILRT was valid and the violation remains unchanged.

The infomation provided in Section 3 of the inspection report is intended to

be guidance for your use. The inforn.ation is not considered interpretations,

but is supplied so that licensee's will have a better understanding of how the

NRC reviews and evaluates test data. As a point of clarification, we assume

that your specific coninents on page 2 of your response are on Section 3.b(5? of

thereportandnotSection3.b(3)asreferenced. Additionally,Section3.b(5)

1

states that "The start of the CILRT must be noted in the test log at the tinee

the lictnsee determines that the containment stabilization has been

satisfactorily completed," which is in agreanent with what you were told by the

inspectors. Further,Section3.b(5)doesacknowledgethatre-initializationof

a test retrospectively is, at tires, justified ard lists three examples.

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Wisconsin Electric Power Company

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Regarding your respense to the open items, we will examine those catters

during a subsequent inspection.

Sincerely,

wirinsT Sfcnoa D C. U M 1

C. W. Hehl, Chief

Operations Branch

J. J. Zach, Plant Manager

DCS/RSB (RIDS)

Licensing Fee Managecent Branch

Resident Inspector, RIII

Virgil Kanable, Chief

Boiler Section

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Nary Lou Munts, Chairperson

Wisconsin Public Service

Connission

ColletteBlum-Meister(SLO),

WI Div. of En.ergency Government

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