IR 05000266/1990003
| ML20011E704 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 02/02/1990 |
| From: | Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20011E702 | List: |
| References | |
| 50-266-90-03-EC, 50-266-90-3-EC, 50-301-90-03, 50-301-90-3, NUDOCS 9002220250 | |
| Download: ML20011E704 (17) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
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Report Nos. 50-266/90003(DRP);50-301/90003(DRP)
Docket Nos. 50-266; 50-301 License Nos. OPR-24; DPR-27 Licensee: Wisconsin' Electric Company 231 West Michigan Milwaukee, WI 53201 i
Facility Name: Point Beach Nuclear Plant Units 1 and 2 Meeting At: Region III Office, Glen Ellyn, Illinois j
Meeting Conducted: January 16, 1990 Type of Meeting: Enforcement Conference Telephone Conference Date: January 22, 1990 Inspectors:
C. L. Vanderniet
J. Gadzala
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Approved By:
R. C. Knop, Chief Reactor Projects Branch 3 2-2-70 Date
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Meeting Summary Meeting on January 16, 1990, and the telephone conference on January 22, 1990, (Report Nos. 50-266/90003(DRP); 50-301/90003(DRP)
Matters Discussed: Design of the DC distribution system, identification of the original design deficiency, noncompliance with the single failure criteria, the quality assurance program, failure to take prompt corrective action to remedy the identified design deficiency, control of open items, and
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additional examples of untimely corrective actions. Analysis and disposition of the apparent violations.will be presented in subsequent communications, 9002220200 900206 PDR ADOCK 0500
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DETAILS 1.
Attendees of Enforcement Conference on January 16. 1990 a.
Wisconsin Electric Power Company j
C. W. Fay, Vice President, Nuclear Power J. J. Zach, Plant Manager, PBNP R. Newton, General Superintendent, NSEAS G. Krieser, General Superintendent, Quality Assurance
G. Frieling, Superintendent, Nuclear Systems
P. J. Katers, Senior Project Engineer Electrical C. W. Krause, Senior Project Engineer, Licensing
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Nuclear Regulatory Commission j
A. B. Davis, Regional Administrator-W. L. Forney, Deputy Director, Division of Reactor Projects J. A. Grobe, Director of Enforcement
R. C. Knop, Chief, Reactor Projects, Branch 3
R. W. Cooper, Chief Engineering Branch I. N. Jackiw, Chief, Reactor Projects, Section 3A C. L. Vanderniet, Senior Resident Inspector, PBNP W. H. Swenson, NRR, Project Manager J. Gadzala, Resident Inspector, PBNP A.Dunlopl,ProjectEngineer,RIII C. H. Wei Enforcement Specialist D. S. Butler, Reactor Engineer
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F. L. Brush, Reactor Engineer
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1. T. Yin, Reactor Inspector 2.
Personnel' Involved in the Telephone Conference on January 22. 1990 a.
Wisconsin Electric Power Company J. J. Zach, Plant Manager, PBNP
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R. Newton, General Superintendent, NSEAS G. Krieser, General Superintendent, Quality Assurance C. W. Krause, Senior Project Engineer, Licensing G. Maxwell, General Superintendent, Operations
~J. Antony, Onsite Quality Assurance b.
Nuclear Regulatory Commission R. C. Knop, Chief, Reactor Projects, Branch 3 i
I. N. Jackiw, Chief, Reactor Projects, Section 3A C. L. Vanderniet, Senior Resident Inspector, PBNP J. Gadzala, Resident Inspector, PBNP A. Dunlop, Project Engineer, RIII C. H. Weil, Enforcement Specialist
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Enforcement Conference As a result of proposed violations of NRC requirements, en Enforcenent Conference was held in the NRC Region III Office on January 16, 1990.
The preliminary findings, which were the bases for the two proposed violations documented in Inspection Report 266/89033; 301/89033, were transmitted to the licensee by letter dated January 12, 1990. The attendees at the enforcement conference are noted in paragraph 1 above.
The purpose of the enforcement conference was to discuss the findings regarding the two proposed violations, one violation identified a failure to meet single failure criteria for the DC Electrical Distribution system (266/89033-02; 301301/89033-02), and the other violation identified a failure to take prompt corrective actions (266/89033-01; 301/89033-01).
Regional management and the resident staff presented a brief overview of both proposed violations covering the main points of the related findings. Regional management also conveyed NRC concerns as a result of the proposed violations and their related inspection findings and additional findings based on in progress inspection findings.
The licensee acknowledged the violations and presented what they considered to be mitigating factors for the proposed violations, and several corrective actions.
Issue was taken with the proposed violation regarding failure to take corrective actions. The licensee stated that the initial audit finding identified in the violation was very narrow in scope. Specifically, it did not identify the violation of single failure criteria that resulted in the request for discretionary enforcement. The licensee further maintained that because of their thorough evaluation of that audit finding they were able to identify the existence of the original design flaw in the DC Electrical Distribution system. Once the design flaw was identified, the licensee felt prompt corrective actions were taken to correct the flawed design.
The NRC stated that the proposed violation for the failure to take prompt corrective actions did not take issue with the actions taken once the flawed design was identified.
The issue regards the length of time it took the licensee to complete the evaluation of the original audit finding. Further, had the evaluation been completed in a more timely manner, the flawed design could have been discovered more than a year earlier which demonstrated the failure to take corrective action. The HRC also cited previous examples of problems with the licensee's corrective actions and discussed findings of an ongoing inspection as
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further evidence of problems with the enrrective act-lon program.
The licensee continued by exalaining the scope and purpose of a contracted electrical distri>ution analysis project that is part of their further corrective actions. This analysis appears to be of sufficient
scope to ensure no similar electrical design flaws exist at the facility.
A presentation was also given by the licensee on the control of open items, changes, and improvements. During the presentation, discussions
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ensued about the findings of an ongoing inspection that indicated
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problems existed in the prioritization and escalation of open items.
The licensee acknowledged that these weaknesses existed and described how
they intended to r:orrect them, including establishing an ad hoc committee i
to review the problems.
j At the conclusion of the enforcement conference, regional management
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decided to pursue further evaluation of the ongoing inspection of the
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Quality Assurance (QA) weaknesses.
It was also decided that if the QA
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weaknesses had a direct bearing on the proposed violation for failure to
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take prompt corrective actions, the licensee would be contacted for a further conference.
After further NRC inspection (Inspection Report 50-266/89032; I
50-301/89032), it was determined that further discussions with the
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licensee were necessary.
Through communication with the licensee it was
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determined that a teleconference would be sufficient. The teleconference was held on January 22, 1990.
During the teleconference, the NRC presented its findings regarding the QA program weaknesses and how these findings related to the original
proposed corrective action violation. The licensee acknowledged the existence of the weaknesses but still contested the original audit finding being used as the basis for the proposed violation.
Based on the original facts and the additional inspection findings, the
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NRC is considering escalated enforcement action for the identified
violations.
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Attachment:
i Licensee Presentation Slides
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Wisconsin Electric Power Presentation i
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NRC Enforcement Conference January 16, 1990 1:0 0 P.M.
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Subject:
DC Distribution Design Deficiency
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A.
Introduction
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B.
Technical Presentation
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DC System Breaker Event History 2.
DC System Breaker Corrective Actions f
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Electrical Distribution System
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Analysis Project
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Management Tools And Systems Currently
In Use Within The Nuclear Power Dept.
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Recent Experience Of Safety
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Significant items l
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Actions in Progress
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Future Management System Considerations E.
Inpui From Others (INP0, NRC, Utillties)
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F.
Closing Comments
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f DC SYSTEM BREAKER ADEQUACY
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ORIGINAL PLANT DESIGN l
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INSTALLATION OF
NEW DC SYSTEMS l
EPM CALCULATION P0325-154 l
NRC APPENDlX R
AUDIT
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WESTEC SSFl AUDIT DIESEL GENERATORS
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LETTER FROM WEST.
HMA BREAKERS i
l PRELIMINARY EVALUATION OF SSFl AUDIT FINDING i
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CORRECTIVE ACTION FOR AUDIT FINDING f
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REQUEST TO RETAIN CONSULTANT CONTRACT PLACED WITH IMPELL
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NRC INSPECTION MR.
l.T. YIN
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NRC FOLLOWUP INSPECTION
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REQUEST TO WESTINGHOUSE FOR DETAILED
BREAKER INFORMATION
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ADDITIONAL DISCUSSIONS WITH WESTINGHOUSE AND BECHTEL
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PBNP STAFF MEETING AND RESULTING
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CORRECTIVE ACTIONS
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DC SYSTEM BREAKER ADEQUACY
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CORRECTIVE ACTIONS
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PRELIMINARY EVALUATION OF AUDIT FINDING
CONTRACT TO IMPELL REQUEST TO WESTINGHOUSE FOR DETAILED INFORMATION j
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NOV. 7,19 89 STAFF MEETING AND i
RESULTING IMMEDIATE ACTIONS
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EVALUATION OF NECCESSARY LONG TERM
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CORRECTIVE ACTIONS BY JULY 1,1990
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COMPLETION OF OVERALL PROTECTION AND COORDINATION STUDY BY IMPELL l
DECEMBER.
31,1990
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REVISIDN: 0
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DATE:
1/22/88
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INSPECTION DBSERVATION
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AREA:
Electrical
INSPECTOR:
G. W. Morris ISSUE-l DC distribution bus short circuit exceeds main breaker U.L. rating.
REQUIREMENT:
Electrical protective devices should be applied within their U.L. rating.
The available short circuit current should be restricted to below the breaker rating.
DISCUS $10N:
The original 8echtel analysis, assembled for a 1985 presentation, did not agree with the plant existing equipment. The EPM analysis performed in 1987 identified the short circuit current at the Westinghouse DC Switchboard (D01) as 13.900 A, and the Square D DC Switchboard (D03) as 15,700 A.
These
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short circuit currents are greater than the interrupting ratings of the
incoming breakers to the sw'tchboards as follows:
EXAMPLES:
s-Westinghouse HMA circuit breaker is U.L. rated at 10,000 A, 250 Y.
Square D MAL' circuit breaker is U.L. rated at 14,000 A, 250 V.
COMMENT AS TO SAFETY SIGNIFICANCE:
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It appears th'at the 1987 EPM analysis reversed the capabilities of the_ data such that switchboard Doll)should experience the higher short circuit.-
Westinghouse has been contacted and has verbally stated that they have internal test data that can demonstrate that the HMA breaker could interrupt 20,000 A.
Details of this test have been requested from Westinghouse, but has not yet been supplied.
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RCS/EP(88) 055
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ha : NUCLEAR SERVICES INTEGRATION DIVISION
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- 4 :Febraary 17, 1988 8A5 INTE'(RUPTING CAPABILITY OF HMA BREAKERS
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'Vince Burke Wisconsin Point Beach M Site Service Manager Point Beach Units 1 and 2 cc:
Ed Somers Mike DeStefano in response to your question about tha interrupting capability of the HMA molded case circuit breakers, the interrupting capability at 250 VDC is 20,000 amps.
Beaver has tested the breakers to 111s and will stead behind 20,000 amps. The U.L. however only requires the breakers to have 10,000 amp interrupting capability at 250 VDC, and the U.L. will therefert only endorse 10,000 amps.
This letter is in response tp Mr. Bob Shore's question.
If you have any othei questions, please let me know.
Sharon Oelrich RCS Engineering Programs
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ELECTRICAL DISTRIBUTION SYSTEM
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ANALYSIS PROJECT
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IMPELL CORPORATION 1.
SCOPE:
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LOSS OF DC STUDY I
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LOADING STUDY C.
CAPACITY STUDY
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PROTECTION AND SELECTIVE i
COORDINATION STUDY E.
VOLTAGE LEVEL STUDY lI.
PURPOSE A.
TO CREATE AN ELECTRICAL DIST SYS,
DATABASE AND ANALYSIS CAPABILITY l
TO SUPPORT INITIAL AND FUTURE EVALUATIONS OF SYSTEM ADEQUACY B.
TO ESTABLISH AND DOCUMENT ACCEPTANCE CRITERIA i
C.
TO CONDUCT INITIAL EVALUATIONS OF
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DISTRIBUTION SYSTEM ADEQUACY
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l CONTROL OF OPEX ITEMS
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CHANGES AND IMPROVEMENTS i
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Monthly Open Item Status Report (MOISR)
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Quarterly Open Item Status Report (QOISR)
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Quality Trending Program (QTP) Report
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Evaluation of all Nonconformance Reports (NCR) and Audit Finding
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Reports (AFR) for potential safety significance
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Use of the Corrective Action Request for generic issues j
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(Quality Fivcedure l'6-1)
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Improved NCR process (Quality Frucedure 15-1)
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Increased personnel awareness and sensitivity i
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Initiation of NCRs for AFRs having safety significance (interim)
Initiation of an Action Request System (Quality. Procedure 16-4)
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Operating Experience Review Program (Quality Procedure 16-3)
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CONTROL OF OPEN ITEMS
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RECENT EXPERIENCE i.
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All NCRs are reviewed for potential safety significance
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including reportability and operability review
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359 NCRs initiated in 1989 m
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119 determined.to have potential safety significance
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Examples (see next sheet)
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All AFRs reviewed for potential safety significance
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As a result of recent vertical slice audit of containment
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systems six AFRs determined to have potential safety
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significance l
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Four NCRs written to address these issues j
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Containment trusses / spray ring header
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Spray additive to containment spray (spray PH/
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Containment isolation issues
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Seismic adequacy of CIV installation
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Action Request process (Quality Procedure 16-4) requires l
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1989 CASE STUDIES
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PROMPT RESOLUTION OF SAFETY SIGNIFICANT ISSUES 1.
DIESEL LOADING WITH DA TRANSFER PUMPS 2.
ALL AFW AFTER STEAM LINE BREAK 1000 GPM 3.
UPPER BEARINGS IN SW PUMPS 4.
HIGH RAD BARRIER DOWN PZR 5.
NBFD AND BFD RELAY CONTACTS 6.
CONTAINMENT (RECIRCULATION SWITCHOVER) EOP-1.4 (LER)
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PORVs 2 SECONDS OPENING ON LTOP (LER)
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SI ACCUMULATOR LEVEL INDICATORS (LER)
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MAKEUP FOR 3/8" HOLE IN RCS 10.
REPLACE SUDDEN PRESSURE RELAY 2X01B (LER)
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G01 AND G02 EXHAUST STACKS (RED PHONE)
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FAST-ACTING VALVES AFTER SI 13.
825C AND 20,000 PPM IN BASTS 14.
CONTAINMENT SPRAY AND TRUSSES (FROM VERTICAL SLICE)
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CONTAINMENT ACCIDENT PAN CAPACITY 17.
GRAVOPLY PLACARDS IN CONTAINMENT 18.
RCCA R71 INSTALLATION WITH CRACK (LETTER TO NRC)
19.
BAST LEVELS (RED PHONE)
CONCLUSION:
EXAMPLES DEMONSTRATE THAT IN-PLACE MANAGEMENT SYSTEMS HAVE IDENTIFIED AND CORRECTED (OR SCHEDULED FOR CORRECTION) SAFETY SIGNIFICANT ISSUES.
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CONTROL OF OPEN ITEMS
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Establish an ad hoc task team to prioritize and assist in
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close-out of old open items n
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Consolidate various open item databases j
Develop a procedure for performing Justifications for Continued
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Operation (JCO)
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Improve access and availability of open item information f
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Implement procedure changes for evaluating vendor i
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technical information
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Reconstitute design basis information (long-term program
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which will be responsive to numerous open items)
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COXTROL OF OPEX ITEMS ACTIONS. BEING CONSIDERED n
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Review-existing procedures and integrate as necessary to assure proper prioritization of safety significant items i
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Review present tracking systems and revise as necessary
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Revise audit procedure to more fully describe the process of j
m; evaluating the potential safety significance of AFRs
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Review other utility programs for controlhng opan items
Request INPO assistance j
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Solicit NRC suggestions-l
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