ML20247G008
| ML20247G008 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 07/21/1989 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-89-086, CON-NRC-89-86 VPNPD-89-401, NUDOCS 8907270301 | |
| Download: ML20247G008 (3) | |
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Wisconsin Electnc eowra coursur 231 W. MICHIGAN, P.O. BOX 2046, MILWAUKEE,WI S3201 (414)221-2345 i <
1 VPNPD-89-401 NRC-89-086 July.21, 1989.
U. S. NUCLEAR REGULATORY COMMISSION Document Control Desk Mail Station P1-137 Washington, D. C.
20555 Gentlemen:
DOCKETS 50-266 AND 50-301 REPLY TO NOTICE OF VIOLATION 50-266/89015;50-301/89014 POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 t
.On June' 26, 1989,- we received a Notice of Violation as outlined in Inspection Report 50-266/89015 for Unit: 1 and 50-301/89014 for Unit 2.
Attachment I outlines the-corrective actions to be taken and the time at which full compliance will be achieved.
We accept your classification'of the procedural issues described in your report as a Level IV violation.
If you have-any questions regarding our response, please contact us.
l Very truly yours,
/
6' Obu C. W.
ay Vice President Nuclear Power Attachment Copies to NRC Regional Administrator, Region III NRC Resident Inspector 8907270301. 890721 h
PDR ADOCK 05000266 Q
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J Attachment I REPLY TO NOTICE OF VIOLATION POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 DOCKETS 50-266 AND 50-301 DESCRIPTION OF EXAMPLE A:
On Mt7 1, 1989, during the installation, verification, and removal of red tags, a modified list of " Qualified Red Taggers" was used to select the names of personnel to perform the red tag process.
This list is maintained by the Operations Group as part of Standing Order PBNP 4.12.2, " Qualified Red Taggers."
As an attachment to the standing order, it can be inferred that the list should only be revised using a procedure revision form.
On May 1 the list being used in the control room was one with pen-and-ink changes, but without the use of a procedure revision form.
Although the red taggers listed on the revised i
list were qualified in accordance with the qualification program, the procedure revision requirement provisions were not used.
CORRECTIVE ACTION We agree the violation occurred as stated.
The " Qualified Red Taggers" list is referenced in Step 4.4, PBNP 4.13, " Equipment l
Isolation Procedure."
The actual list is part of Standing Order PBNP 4.12.2.
Standing Order PBNP 4.12.2 is a non-nuclear
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safety-related (NNSR) document under the control of the Operations Superintendent.
PBNP 2.1.1, " Classification, Review and Approval of Procedures," states that a non-nuclear safety-related document affecting two or more groups (like the l
standing order) is to be revised with the approval of the Manager.
In this case the red taggers list includes qualified I
personnel from more than one work group.
a.
PBNP 2.1.1 will be changed to more clearly specify when another review / approval process for NNSR procedures is appropriate.
This will be changed by September 7, 1989.
b.
In addition, the qualified red taggers list will be removed from the Standing Order and be directly controlled by the Superintendent - Operations by September 7, 1989.
c.
Step 4.4 of PBNP 4.13, " Equipment Isolation Procedure",
will be changed to eliminate the reference to the Standing Order by December 1, 1989.
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Attachment I Page 2 DESC.'.RIPTION OF ' EKAMPLE B.
' During the performance of the post-installation testing'of the ATWS Mitigation System Actuation Circuitry (AMSAC) on May.5, 1989, the auxiliary feedwater system was actuated due to a sensed low steam generator level during a refueling operation.
The controlling procedure (ICP 11.422, " Initial Checkout and Test of AMSAC, MWR 85-213, Unit 1") clearly required the introduction of an artificial level signal into the steam generator level channels if the steam generator. level was expected to be lowered below the set point.
Then the level reduction would not result in an auxiliary feedwater actuation.
Nonetheless, corumunications between the.per onnel performing the testing.of AMSAC and the control room personnel was incomplete, and an artificial level signal was only installed on one steam generator ("B").
During the testing evolution, the "A" steam generator level was also reduced below the auxiliary feedwater initiation set point, resulting in auxiliary feedwater initiation.
LER 89-006-00 for Unit 1 documents this event.
' CORRECTIVE ACTION We agree the violation occurred as described..The error was cognitive, and the involved parties were counseled.
An evaluation of the procedure controlling the work for this testing on Unit'2 will be conducted.
If it is believed that a revision'will reduce the probability of the occurrence of a similar event, the procedure will be revised.
We believe we are now in full compliance.
Any appropriate changes in the procedure for this test will be complete prior to the Unit 2 AMSAC testing.
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