NPL-97-0050, Responds to NRC Re Violations Noted in Insp Repts 50-266/96-03 & 50-301/96-03.Corrective Actions:Issued Temporary Change to AOP 0.0 Re Battery Chargers & Will Incorporate Temporary Change to Permanent Procedure Rev

Responds to NRC Re Violations Noted in Insp Repts 50-266/96-03 & 50-301/96-03.Corrective Actions:Issued Temporary Change to AOP 0.0 Re Battery Chargers & Will Incorporate Temporary Change to Permanent Procedure Rev

ML20135D212
Person / Time
Site:	Point Beach
Issue date:	02/24/1997
From:	Dante Johnson WISCONSIN ELECTRIC POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NPL-97-0050, NPL-97-50, NUDOCS 9703050130
Download: ML20135D212 (4)

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Wisconsin Electnc POWER COMPANY 231 W Michigan, PO Box 2046. Mdwoukee. WI 53201-2046 (414)221-2345 NPL 97-0050 rebruary 24,1997 Document Control Desk U.S. NUCLEAR REGULATORY COMMISSION Mail Station PI-137 Washington, DC 20555 Ladies / Gentlemen:

DOCKETS 50-266 AND 50-301 REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-266/96303(OLh50-301/96303(OD POINT BEACH NUCLEAR PL ANT. UNITS 1 AND 2 13y letter dated January 23,1997, the NRC forwarded to Wisconsin Electric Power Company NRC Inspection Report Nos. 50-266/96303(OL); 50-301/96303(OL). The reports forwarded the results ofinspections concluded on November 27,1996, oflicense examinations and related operator training. activities at the Point Beach Nuclear Plant.

Enclosed with the inspection reports was a Notice of Violation related to a plant procedure that aligned the Vital DC Electrical System to a configuration for which it was not designed.

Pursuant to the requirement of 10 CFR 2.201, we are responding to this violation. Attached is our response which includes: (1) the reason for violation, or if contested, the basis for disputing the violation; (2) the corrective action taken and the results achieved; (3) corrective action to be taken to avoid further violations; and (4) the date when full compliance will be achieved.

As requested in the letter transmitting the inspection and related Notice, we have included a discussien of our corrective actions regarding the 125 VDC Electrical Distribution System training weaknesses and the perfonnance weaknesses identified in the Inspection Report. We believe this is responsive to the Notice and your concerns. Please contact us ifyou have any questions or desire additional information.

Sincerely,

/

.E Do 'laa . Johnson h'{)

Manager - Regulatory Services & Licensing 9703050130 970224 GDA/ec PDR ADOCK 05000266 0 PDR y Attachments: A. Reply to Notice of Violation B. Corrective Actions Related to 125 VDC Training Weaknesses cc:. NRC Regional Administrator, Region !!! Subcribed and sworn before me on NRC Resident Inspector this Mtlday of J& 1997.

NRC Project Manager 41.fousA Nt & notcv Notary PublicVState of Wisconsin My commision expires 5

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ATTACHMENT A 1

REPLY TO NOTICE OF VIOLATION  :

INSPECTION REPORT NOS. 50-266/96303(OL); 50-301/96303(OL)

WISCONSIN ELECTRIC POWER COMPANY POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 DOCKETS 50-266 AND 50-301 LICENSE NOS. DPR-24 AND DPR-27 During an inspection of NRC-administered license examinations and related training, one violation of NRC requirements was identified. The violation was classified as Severity Level IV, Inspection Reports 50-l 266/96303(OL); 50-30I/96303(OL) and the Notice of Violation (Notice) transmitted to Wisconsin Electric on

January 23,1997, provide the details of the violation.

I in accordance with the instructions provided in the Notice, our reply to the violation includes: (1) the reason for l violation, or if contested, the basis for disputing the violation; (2) the corrective action taken and the results achieved; (3) corrective action to be taken to avoid further violations; and (4) the date when full compliance will be achieved.

VIOLATION:

l 10 CFR 50, Appendix B, Criterion V requires that activities affecting quality shall be prescribed by procedures I appropriate to the circumstances and shall be accomplished in acccrdance with these procedures. Procedures shall include appro;date quantitative or qualitative acceptance criteria for determining that important activities have been accomplished satisfactorily.

i Abnormal Operating Procedure (AOP) 0.0," Vital DC System Malfunction", Revision 9, Attachment B,"DC

, Distribution Panel Power Supplies", aligned 125 VDC battery chargers D-107 and D-108 to DC buses D03 and D04 i

respectively without the related battery also connected.

Contrary to the procedure, battery chargers D-107 and D-108 would not function properly if aligned to a DC bus without a battery also connected due to their design..

This is a severity Level IV violation (Supplement I).

Resnonse to Violation:

Reason for the Violation:

llistorically, the capability of the installed battery chargers to provide quality VDC power without a connected battery has been questioned, but not rigorously resolved. In the late 1980's, plant engineers understood that the connected battery provided an important filter for the battery charger output. At that time, testing and evaluation indicated that the PBNP battery chargers could provide VDC power of suitable quality, but cognizant engineers and training personnel reserved some degree of uncertainty, Most recently, pant engineers have conducted a test that conclusively determined that PBNP battery chargers provided inadequate power quality without a connected battery.  !

Also contributing to the violation, the battery's function to filter the battery charger output and the associated limit on battery charger operation without a connected battery were not well documented. Historically, plant personnel have not considered a formal method for recording the aforementioned functions and limits. Therefore, Abnormal Operating Procedure (AOP) 0.0 was developed without acknowledging the limits of battery charger operation without a connected battery.

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Since 1992, the PBNP Design Basis Document (DBD) program has provided a formal repository for the functions and limits on equipment. The 125 VDC System DBD addresses battery charger and battery functions. Although the DBD did not capture the battery charger limits or battery function described herein, it is the appropriate document to record these functions for future reference.

Corrective Action Taken:

As stated in the inspection repon, the licensee took corrective action and issued a temporary procedure change to AOP 0.0 the same day that the NRC identified the issue. A caution was added to indicate that battery chargers D-107, D-? 08, and D-109 could not be aligned to a DC bus independent of a battery. Also, an operability determination concluded that these battery chargers were capable of performing their safety-related functions and were operable.

The operability determination concluded that the D-107, D-108, and D-109 battery chargers are operable as long as they are physically connected to a station battery (even ifit is declared "out-of-service"). The determination also concluded that, if one of the chargers was aligned to a DC bus without a connected battery, it would be r.ecessary to declare both the charger and the bus inoperable, ar.d the appropriate Technical Specification shutdown requirements would have to be entered.

Also, an entry was mac' in the Operations Notebook to ensure that operators were clear on the system requirements of D-107 and D-108. Finally, testing subsequent to the violation has canfirmed that the subject battery chargers are not capable of providing adequate power capacity and quality when a battery is not connected to the respective DC bus. This test demonstrated that the actions taken to date have been appropriate. As stated in the inspection report, the prompt corrective actions for the procedure deficiencies were considered adequate.

l A design basis document (DBD)" Potential Open item" has been initiated to ensure that the aforementioned battery <

function and battery charger limitations are identified in the next revision of the 125 VDC System DBD.

Corrective action to be taken to avoid further violations:

The temporary change to AOP 0.0 will be incorporated into a permanent procedure revision by April 18,1997.

Appropriate training will be provided when this procedure is revised A clarupcation to the TechnicalSpecipcation Bases (TS 15.3.7) will be evaluatedpursuant to 10 CFR 50.59. Ifthe changes do not represent an unreviewedsafety question or a change to the specipcations, we will submit the revised TechnicalSpecipcation pages by Afay 1,1997. Ifthe changes do represent an unreviewed safety question or a change to the specifications, we willsubmit a license amendment request by Afay 1,1997. Thepurpose ofthe clartpcation will be to remove any ambiguity that TechnicalSpecipcations allow aligning the 125 VDC system outside its design capabilities.

Date When Full Compliance Will Be Achieved:

We believe that, we will be in full compliance when the Technical Specification Bases (TS 15.3.7) are issued with the appropriate clarifications. Although we plan to submit any changes by May 1,1997, we expect that approval of a license amendment, if required, could postpone full compliance until September 30,1997.

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ATTACliMENT B CORRECTIVE ACTIONS RELATED TO 125 VDC TRAINING WEAKNESSES The cover letter to the inspection report requested the following:

" Include in your response the corrective actions regarding the 125 VDC Electrical Distribution System training weaknesses and the performance weaknesses demonstrated on the Administrative Job Performance Measure Tasks.

The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements." _

Performance Weaknesses in Administrative Job Performance Measure (JPM) Tasks The inspection report states:

"Two applicants failed the examination due to unsatisfactory performance while two other applicants demonstrated weaknesses on the Administrative JPM tasks administered.

Additionally, unsatisfactory performance was demonstrated by at least one applicant on five of the six difTerent Administrative JPM tasks administered which included: completing portions of the criticality checklist; proper method to independently verify valve position; and determination of Main Turbine loading limitations.

The demonstrated weaknesses illustrated an apparent lack of attention to detail, lack of procedural knowledge, and a failure to follow procedures for the Administrative JPM tasks administered. The applicants' inability to perform the 6 Admini .trative JPM tasks administered on this examination was considered a weakness."

Reply:

Weaknesses in the administrative procedure training and compliance have been previously identified by the NRC at the September 12,1996 Predecisional Enforcement Conference. In response, the Operations group has initiated an upgrade to the operations manual and associated administrative proceduns. The upgrade focuses on the following administrative areas which affect daily operation of the plant: (1) Ope ations Manual expectations, (2) Control Room conduct, (3) logkeeping, and (4) work control / configuration management. In addition, our initial training program and the long-range training program are being revised to incorporate more emphasis on administrative procedures.

Trainiw Weaknesses in Administrative JPM Tasks The inspection report states:

" Operator training regarding the operating limitations and differences between the 125 VDC system battery chargers was considered a weakness."

Reply:

As discussed in the reply to the Notice of Violation, we performed a test and conttrmed that battery chargers D107,

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D108, and D109 would not provide adequate DC power without a connected battery. Accordingly, a temporary procedure change to abnormal operating procedure AOP 0.0 was issued to ensure that these particular battery chargers are not aligned to a Vital DC bus without a connected battery. As described in the reply to the Notice of Violation, the temporary change to AOP 0.0 will be incorporated into a permanent procedure revision by April 18, 1997. Appropriate training will be provided when this procedure is revised.