ML20118C096

Responds to NRC 920904 Ltr Re Violation Noted in Safety Insp Repts 50-206/92-15 & 50-301/92-15 on 920629-0823.Corrective Actions:Procedure Pbnp 4.13, Equipment Isolation.... & Form SEC-79, Escort...Authorization... Being Revised

ML20118C096
Person / Time
Site:	Point Beach
Issue date:	10/02/1992
From:	Link B WISCONSIN ELECTRIC POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-92-113 VPNPD-92-319, NUDOCS 9210090247
Download: ML20118C096 (6)

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NRC-92-113 October 2, 1992 Document Control Desk U.S. HUCLEAR REGULATORY COMMISSION Mail Station P1-137 Washington, DC 20555 Gentlernen :

QOCKETS 50-266 AND 50-301 BESPONSE TO,1LQTICE OF VIOLATION POINT DEACH NUCLEAR PLANT.-UNITS 1 AND 2 In a letter from Mr. Robert L. Greger dated September 4, 1992, the Nuclear Regulatory Commission forwarded to Wisconsin Electric Power _ Company, licensee for_the Point Beach Nuclear Plant, the results of the routine safety inspection conducted by Messrs.

K. R. Jury and J. Gadza.la from June 29 through August 23, 1992. i This inspection report included a Notice of Violation (Notice).

The Notice describes a violation of Point Beach Nuclear Plant Technical Specification 15.6.8, " Plant Operating Procedures,"

Section--15.6.8.1.- -

We have reviewed this Notice and, pursuant-to the provisions of 10 CFR 2.201, have prepared a written response'of explanation  !

concerning the identified violation. Our written response is ,

included as an attachment to this letter.  !

The violation identified in the Notice pertains to procedural requirements for returning equipment, that-has been-isolated, back to service._ Technical Specification 15.6.8.1 requires that the plant be operated and maintained-in accordance with approved L

procedures. Our procedure, PBNP 4.13, _" Equipment Isolation _  ;

Procedure," Step 6.2.3, requires that equipment not be returned to

=uervice - until the danger (equipment isolation)1 tag location sheet.

authorizes the return of the equipment to the operations group.- In addition, Step 6.4 of'the procedure requires that-the positioning

'of equipment identified on the danger tag location sheet be- ,

performed by a qualifled individual.- The. identified violation occurred on. July 24, 1992',_When a battery cable for the-auxiliary-diesel (G501) _ was reconnected to the battery prior to the-danger h[)()l)- .Q

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I Document Control Desk October 5, 1992 Page 2 t39 location rheet authorizing this equipment to be returned to service. The reconnection was completed by a contractor employee who was not qualified to perform this task.

This violation characterizes a contractor employee's failure to conform to the PB!IP equipment isolati n procedure. An event invectigation team had previously been chartered to review the circumstances of an event which occurred on June 10, 1992, which r,imilarly is believed to have involved a contractor's violation of PbitP 4.13. Based on the evaluation performed by the event _

investigation team for the June 10, 1992, event and an ad-hoc interdiccip)inary group formed to review the July 24, 1992, event identified in the 110tice, corrective actions have been taken or are planned to be taken to respond to the identified deficiencies.

Thece corrective actions are intended to implement enhanced management controls and practices to ensure conformance to PB!1P 4.13. ,

We believe that the attached reply is responsive to the concerno and fulfills the regnirements identified in your September 4, 1992, letter. If you have any questions or require additional infor-mation regarding this renponse, please contact us.

Sincerely, e" -r fe'. .. ~) ))

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Bo',b Link Vice President fluclear Power 14FB/jy Enclosure cc: Regional Administrator, 11RC Region 1'1 IIRC Resident Inspector

REPLY TO NOTICE OF VIOLATION WISCOllSIN ELECTRIC POWER CO!4PANY POI!1T BEACH NUCLEAR PIJd1T, UNITS 1 A!1D 2 DOCKETS 50-266 AND 50-301 LICENSE NOS. DPR-24 AND DPR-27 During the routine cafety incpection conducted at our Point Beach Nuclear Plant from June 29 through August 23, 1992, one violation of 11RC requirements was identified. The identified violation was classified as a Severity Level IV. Inspection Report llumbers 50-266/92015(DRP) and 50-301/92015(DRP) and the flotice of Violation (flotice) transmitted to Wisconsin Electric on September ., 1992, provide details regarding the violation. We -

agree that the event and circumstances described in the Fotice are accurately characterized.

In accordance with the instructions provided in the flotice, our reply to the alleged violation includes: (1) the reason for the violation; (2) corrective action taken; (3) corrective action taken to avoid further violations; and (4) the date when full compliance will be achieved.

VLOLATION

" Technical Specification 15.6.8.1 requires that the plant be operated and maintained in accordance with approved procedures.

Procedure PBNP 4.13, Equipment Isolation Procedure, Stop 6.2.3, -

requires that equipment not be returned to service until the danger tag location sheet authorizes the return of the equipment to the operations group. Step 6.4, reouires that positioning a component per the danger tag location cheet shall be performed by a qualified red tagger."

" Contrary to the above, on July 24, a battery cabic on the G-501 auxiliary diesel was reconnected to the battery prior to the danger tag location sheet authorizing the return to service of the equipment to the operations group. Also the person who reconnected the cable was not a qualified red tagger."

IEfiEO. BEE __T_O VI01ATlall

1. REASON FOR THE VIOLATIOil The event cited in the Notice of Violation occurred on July 24, 1992, during the ongoing overhaul of the gas turbine generator (GOS) installed at PBNP. Work on the gas turbine auxiliary power diesel (G501) was being supported by a contractor employee. The contractor ;mployee had not been authorized general plant access and, therefore, was required to be escorted. During performance of his assigned work, the contractor employee repla ed a power cable on the diesel starting battery. The cable had been danger tagged, in the

Reply to Not'.co of violation October 5, 1992 Page 2 disconnected condition, in accordance with PBNP 4.13,

" Equipment Isolation Procedure." PBNP 4.13, Step 6.4, requires that positioning a component per the danger tag location sheet be done by a person qualified as a danger tagger.

The contractor employee involved, noted the installed danger tag but did not understand that the tag precluded him from reattaching the cable on the battery. The contractor's understanding of the equipment isolation requirements was that he was prohibited from operating the auxiliary power diesel following the completion of the work, but did not prevent him from attaching the battery cable. A contributing factor to the failure of the contractor employee to completely understand the isolation requirements of this system was that a sufficiently thorough pre-job briefing had not been conducted prior to beginning the work activities.

t An additional contributing factor was identified as different

' training requirements dependent on the type of plant access required by a contractor. The contractne employee involved in this event was classified as a shcrc term visitor and was o authorized escort required access. The contractor employee '

was being encorted by a PBNP Security Officer. Short-term visitors, suct, as this contractor employee, are not normally granted unescorted access to PBNP and, therefore, do not receive general employee training (GET). GET would ha\e provided the contractor employee training on the equipment isolation system and procedural requirements which may have prevented the event. -

y 2. C_ORBECILYE _ ACTION TAKEN

.. In response to this violation, corrective actions were takt9 immediately following identification of the inappropriately installed battoiy cable. 11so, additional corroctive actions have been 'ompleted to date in response to this event to prevent recurrence of similm 22,nts.

A. IJnmediate Certective Action

- Work on the auxiliary power diesel had been completed when the condition was discovered by operations personnel tasked to remove the danger tags associated with the auxiliary powcr diesel. The tagout of the diesel was suosequently cleared by qualified operations personnel and the equipment configuration verified as correct.

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Reply to Notice of Violation l October 5, 1992 Page 3

- The contractor employee was counselled regarding equipment laolation requirements, the personal safety i implications of taking actions prohibited by the equipment isolation requirements, and the incorrectness of his actions based on this event

- The PDNP contractor liaison and manager-responsible for-the oversight of the gas turbine overhaul were counselled of their responsibility and obligation.to-brief contractor personnel regarding equipment isolation procedure requirements.

B. Additional Corrective Actions Taken To Date r

- An ad-hoc interdisciplinary group met on multiple occasions to discuss the event, determine the causes, and formulate corrective actions. The ad-hoc interdisciplinary group also met with the event investigation team which had been formed to review the equipment isolation procedural violation that occurred on June 10, 1992.

- Past occurrences of similar equipment isolation procedural violation events were reviewed to determine ,

if there is a commonality between the causes of these.

events. Causes identified included the' inadequacy of the pre-job briefings for escorted personnel-and the need to identify specifio guidelines for use in performing pre-job briefings. In addition, it was I identified that additional emphasis on the duties and l responsibilities of Wisconsit. Electric liaison j personnel dealing with contractors was needed.

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On September 30, 1992, the Plant Manager issued a memorandum to all Nuclear Power L,partment management personnel summarizing the violations'of theJequipmen. -

isolation procedure. The memorandum reinforces the l importance and requirements of conducting adequate pre- i job briefings and the requirements contained in PBNP 4.13, " Equipment Isolation ?rocedure." Specifically, the memorandum summarizes t.a' responsibilities of-supervisors and contractor liaisons as defined in PSNP 4.13, Step 5.5.

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e Reply to Hotice of Violation October 5, 1992 Page 4

3. C&OIWECTIVE /LQTJO!1 TO BE TAKEN TO PREVENT RECURRE1C_E Based on the reviews of equipment isolation procedure violation evento performed by the ad-hoc interdisciplinary group and the event investigation team, the following actions will be taken to preclude recurrence of similar events:

A. PB11P 4.13, " Equipment 1 solation Procedure," is being revised to clearly define the responsibilities of operations, maintenance, and engineering personnel involved with the equipment isolation procedure. This revision will include the requirement for the Wisconsin Electric contractor liaison, who is responsib]e for oversight of contractor work activities, to sign the equipment isolation tag record sheet. We plan to have these revisions to PB11P 4.13 completed by 11ovember 20, 1992.

B. 11uclear Power Department personnel with authorization to approve visitor access to the PBtJP site will be required to identify the necessary pre-job briefing requirements prior to authorizing contractor or visitor access to P B11P . This will be accomplished by enhancements tc, PE;d form PDF-7015, " Pre-Work Conference Checklist," and SEC-79, " Escort, Vehicle and Access Level Authorization and Control." The revisions to PBF-7015 and SEC-79 are scheduled to be completed by November 20, 1992.

4. DATE OF_ FULL CoMPLI Atty -

All corrective actions, identified above, which we believe will result in full compliance with Technical Specification 15.6.8.1 as it relates to proper implementation of equipment isolation requirements have been completed or will b3 completed by November 20, 1992.

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