ML20214G086
| ML20214G086 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 08/15/1986 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20214G014 | List: |
| References | |
| CON-NRC-86-80 VPNPD-86-362, NUDOCS 8611250552 | |
| Download: ML20214G086 (5) | |
Text
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s Wisconsin Electnc eom cown 231 W MICHIGAN.P.o BOX 2046, MILWAUKEE.WIS3201 (414)277-2345 VPNPD-86-362 NRC-86-80 August 15, 1986 Mr. James G. Keppler Regional Administrator U.
S. NUCLEAR REGULATORY COMMISSION Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Keppler:
DOCKETS 50-266 and 50-301 RESPONSE TO SALP 5 REPORT POINT BEACH NUCLEAR PLANT Your letter dated June 23, 1986, forwarded the SALP Board Report for the Point Beach Nuclear Plant covering the period from October 1, 1984 through March 31, 1986.
The results of this report were presented and discussed during a.Teeting with you and members of your staff a?. the Point Beach Nuclear Plant on July 18, 1986.
As a result of our review of this report and your presentation, we uish to note several comments and corrections concerning this assessment.
As we discussed during the meeting on July 18, 1986, with one exception, we had no disagreements with the SALP performance classifications for the functional areas evaluated.
The one area in which we believe the category rating does not accurately reflect our performance dt. ring this period is in Fire Protection and Housekeeping.
As documented by the SALP report, no violations occurred in this category during this SALP period.
Continued improvement was shown.
Significant modifications involving cutting, grindirg, and welding were accomplished without incident.
A more 8611250552 861117 PDR ADOCK 05000266 PDR G
AUG 2 019861
Mr. James G. Keppler August 15, 1986 Page 2 i
aggressive management attitude toward fire protection and housekeeping was also acknowledged.
The only negative factor mentioned in the report and at the meeting was our failure to complete several Appendix R modifications, in accordance with the regulatory schedule, or to request a schedular exemption in a more timely fashion.
We feel that this observation does not properly fall under this performance category in that it involved a licensing schedule commitment and not specifically a fire protection problem.
We note that the discussion under the licensing performance category at Page 25 of the SALP report also lists this incident as a supporting observation of the SALP rating in that category.
Accordingly, and taken as a whole, we believe that the SALP rating for this area should be adjusted to Category 1.
In addition to this comment, we noted some inaccuracies in this report, which we suggest be corrected as follows:
1.
On Pages 7 and 8 under " Analysis of Radiological Controls", there is a lengthy discussion concerning staffing and stability of staffing in the Health j
Physics area.
The report states that we initiated action near the end of the assessment period to improve the radiation protection program staffing by adding new positions and upgrading the Radiation Protection Technician position and selection I
criteria.
This is not correct.
We initiated actions to upgrade the Radiation Control Operator position over two years ago.
The process necessary to complete this action included I
labor union negotiations and took time to resolve.
i To infer that we responded only after " repeated concerns expressed by NRC, Region III personnel" does not reflect our initiative regarding this matter.
We also would clarify the statement in the report regarding authorization for two new " professional" positions.
We increased our quota for Radiation Control Operator by two to allow the displacement of two contractors in the area of radioactive waste I
handling.
Since a " professional" position in our usage typically requires a college degree, we do not consider these new quotas to be " professional" positions.
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Mr. J. G. Keppler August 15, 1986 Page 3 2.
Two editorial corrections are needed on Page 9.
In the fourth line, the word " communicator" should be " annunciator".
In the second full paragraph, the word " reactor" in " Reactor Water Storage" should be " refueling".
3.
On Page 11 the report discusses contractor errors, specifically in fire barrier packing, which caused interruptions of. power.
The report says that there
' have been " increased instances of this type", although no other examples are given.
While not justifying mistakes, please note that these are examples of problems associated with backfitting an operating plant.
We continue to exert diligence as we comply
. with the requirements of new regulations, even though we and others in the industry have concerns with the technical bases for some of these actions.
4.
On Page 16 there is a discussion on our notification system.
The first event identified in the report was, in fact, our first unusual event.
We used the system accepted by the NRC and exercised in drills to make our notification.
The last phrase in the second paragraph is technically incorrect.
We did not say the notification would be made by "someone in the control room".
Our commitment was that notifications will not be made by security officers, but, rather, by someone in the plant organization who can respond to questions from the NRC duty officer.
l In the paragraph discussing the second event, there is an inaccurate inference.
This report states, "An attempt to close the main steam isolation valves from l
i the control room was unsuccessful..."
This infers that neither main steam isolation valves went shut.
Actually, one did close on demand from the control room.
Later in the paragraph, the report states "This information was not volunteered by the licensee."
We wish to point out that the Resident l
Inspector was in the control room during the day and was fully aware of the situation.
We may be faulted for providing insufficient detail to the duty officer, l
I but the Resident Inspector had all the information, and there was no attempt to conceal anything.
It should be noted that the reason for not mentioning the failure of the MSIV to close during discussions with the NRC duty officer is because it was not germane to the incident which caused the declaration of an unusual event.
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Mr. J. G. Keppler August 15, 1986 Page 4 5.
In the section on Security on Page 19, it should be noted that Fox Valley Technical Institute, which i
administers the training program, is not a college.
6.
There is another editorial error in the middle of Page 20 under outages.
The new schedule is not distributed to all " management"; not every supervisor and management employee receives his or her own copy.
All key supervisors, however, do receive the information.
7.
The first full paragraph on Page 22 does not fully reflect the accomplishments concerning QA inspector training achieved during the SALP period.
The training of inspection personnel was completed in 1985, and qualifications were subsequently documented.
The documentation of inspector qualifications was reviewed during an NRC follow-up inspection conducted during the week of June 23.
Evidence was presented to the inspector to show satisfactory completion.
We understand this item is now considered to be closed by the NRC.
8.
Also on Page 22, the report states that the emergency procedure issue regarding qualification of Limitorque motor-operated valve operator internal wiring has not been resolved, nor corrective action initiated.
This statement is in error and should be deleted.
In our February 14, 1986 letter to NRC, Region III on Limitorque MOV internal wiring, we provided a justification for continued operation for each of the EQ MOV's.
We also committed to issue a Special Order to operations personnel discussing potential operator failure and the fact that local operation may be required.
This Special order was issued on February 28, 1986.
As part of normal operator training, the operators know how to operate MOV's locally.
The MOV Task Force has recommended that i
operators receive enhanced training on MOV design and operation, but this has not yet been implemented. It should also be noted that the internal wiring on all EQ MOV's has been replaced on Unit 1 and also on Unit 2 MOV's, except for ten valves, eight of which are in containment.
Mr. J. G. Keppler August 15, 1986 Page 5 9.
A final editorial error was noted toward the bottom of Page 22.
The word " plants" should be " plant".
This SALP report includes one Board recommendation on Page 27 regarding licensing activities.
Although we have been using a computer-based commitment tracking system for a number of years, we agree that our system could be improved to identify better those commitments involving modifications and submittals as described in the NRC staff safety evaluations, Commission's Orders, and Regulations.
Accordingly, we are modifying our program to accord such commitments a higher priority and management attention.
We also intend to take steps, by means of more refined internal review schedules and deadlines, to provide our submittals to the NRC on a more timely basis so that your staff has more ample opportunity to review our requests prior to the scheduled completion date.
Thank you for the detailed and candid discussions during the appraisal review on July 18.
Very truly yours,
.h
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y (f60 de C. W..ay Vice President Nuclear Power Copy to Resident Inspector l
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