ML20246H190
| ML20246H190 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 08/21/1989 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-89-101 VPNPD-89-462, NUDOCS 8909010152 | |
| Download: ML20246H190 (4) | |
Text
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'e, UL Wisconsin Electnc POWER COMPANY 231 W MicNgan.Po Box 2046.Mdwookee,W153201 p14);21-2345 VPNPD-89-462 NRC-89-101
. August-21,.1989 U. S. NUCLEAR REGULATORY COMMISSION Document Control Desk Mail Station Pl-137 Washington, D.C.
20555 Gentlemen:
DOCKET NOS. 50-7.66 and 50-301 REPLY TO NOTICE OF VIOLATION
^ INSPECTION REPORTS. 50-266/89021'and 50-303/89020 POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2-On July 27, 1989, we received your letter dated July 21, 1989 which forwarded the results of the Enforcement Conference conducted on June ~2, 1989, reported as Inspection Reports Nos. 50-266/89021 (DRP)'
Land 50-301/89020 (DPR), together with a notice of violation. contains our written statement and explanation in reply to the notice.
For reasons discussed during the Enforcement
. Conference, we disagree with the characterization of the issues as Level IV violations.
Nonetheless, Attachment 1 includes a description of corrective actions taken or to be taken and when full compliance.will be achieved.
.Your letter requested that this response also describe what
-Wisconsin Electric now believes would constitute a satisfactory battery testing program and provide justification for those positions.
As you are aware, and as noted under the heading of future issues in the material we submitted during the enforcement conference, we are actively considering changes to our battery testing program.
By October 1, 1989, we will provide to you a detailed description, including our justification for the positions taken,.of a revised battery testing and capability verification
. program.
Upon your review and general concurrence with our proposed program, we would then submit a license amendment change application to incorporate this program into the Point Beach Technical Specification.
Please note that we will encounter no need for a periodic battery test of the existing station batteries during the remainder of 1989; therefore, we have adequate time available to resolve the performance testing issues.
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. August 21, 1989
- Page.2 If you have any questions regarding our response, please contact us.
Very,truly.yours, 7
.c f'M l C. W. Fay-Vice> President-
. Nuclear Power Attachment Copies to NRC Regional Administrator, Region III NRC Resident Inspector L x_:
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ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 DOCKETS 50-266 AND 50-301 h
DESCRIPTION OF ISSUE 1 l
. Technical Specification 15.4.6.B.4 states, in part, "Each battery shall be subjected to a load test at intervals recommended by the manufacturer but not exceeding five years."
In a letter dated July 6,
1988, under subtitle " Recommendations", the manufacturer stated, in part, "You have indicated that the next scheduled outage will be in October 1988 for Unit 2 (battery B).
At this time, the battery should be capacity tested as mentioned earlier in this evaluation."
A load test on Battery B was not conducted during the October 1988 Unit 2 outage.
CORRECTIVE ACTION PT.R-5 and PT.R-6 are the procedures used to meet the Technical Specification testing requirements for the DOS and D06 batteries, respectively.
PT.R-6, "No.
2 Battery (D06) Service Test", was performed on April 30, 1989. From the results of this test, it was concluded that station battery D06 was capable of performing its safety function.
We believe, therefore, that we were in full compliance with the testing recommendation at that time.
Subsequently, the adequacy of.this type of test was questioned.
To further verify station battery D06 capability to perform its safety function, station battery DOS was subjected to a discharge test that enveloped the calculated D06 load profile.
The results of this test indicated that station battery DOS was capable of performing its safety function and that, by similarity, station battery D06 would continue to be able to perform its safety function through the fall 1989 Unit 2 outage, at which time D06 will be replaced.
l In addition to the above-noted testing, the following additional corrective actions will be taken to avoid further violations of this nature:
a)
Proposed changes to the station battery testing program will be submitted for NRC review by October 1, 1989.
b)
Upon concurrence with our proposed battery testing program, a license amendment application will be submitted to incorporate the revised battery testing requirements into the Technical Specifications.
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l c)
The procedures used to meet battery testing Technical Specification. requirements will be changed to meet the new p
requirements.
These will be changed by May 15, 1991.
d)
The new D06 battery will be subjected to a service test that envelopes its load profile before placing D06 into i
service.
This test will be completed by November 31, 1989.
E DESCRIPTION OF ISSUE 2 This' issue was divided into two parts.
The first discussed a maintenance work request (MWR) that was issued to reinstall some wooden spacer /end pieces for a seismically rated battery rack.
The MWR was designated as QA scope and, therefore, according to plant procedures, required a QC inspection after installation.
Indications are that the QC inspection did occur but the documentation of that inspection is not clear.
PBNP 3.1.3,
" Maintenance Work Request Procedure" at the time of the completion of the work on the MWR allowed a single signature by the QC inspector qualir ?d work supervisor to also indicate the completion of the QC function.
It is not clear, however, whether the QC function has been actually completed by the supervisor if the only signature appears in the line supervisor slot.
Therefore the NRC inspector was unable to insure the completion of the QC function by review of the completed MWR form.
Tha second issue was an example of an identical situation of the lack of a signature designating the completion of the QC inspection of a QA scope MWR.
In this case the MWR required the replacement of some molded case breakers in safety related panels.
Here the MWR was designated as having QA scope and there was only the signature of the line supervisor in one signature line.
Here again, PBNP 3.1.3 allows the line supervisor to sign on one line designating the completion of the work and the QC inspection.
CORRECTIVE ACTION FOR ISSUE 2 l'
Our own QA group has identified the lack of two signatures as a possible deficiency in the procedure and auditability of the completed MWRs.
We therefore will revise PBNP 3.1.3 to require a signature for the completion of the work on the MWR and the completion of the QC inspection.
The same signature may appear on both lines; however, the assurance of the completion of the QC inspection will be on the completed MWR in the file for audit.
The revision to PBNP 3.1.3 addressing this issue will be completed by October 31, 1989.
We believe we have been in full compliance in respect to QC inspection of QA scope work.
As of October 31, 1989 this compliance will be easier to audit.
.