IR 05000266/1993012
| ML20058C981 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 11/23/1993 |
| From: | Wright G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Link R WISCONSIN ELECTRIC POWER CO. |
| References | |
| NUDOCS 9312030012 | |
| Download: ML20058C981 (2) | |
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"[ a a t G o,o e
UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION Ill o
S 799 ROOSEVELT ROAD 5+
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"f GLEN ELLYN. ILLINOIS 60137-5927
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NOV r. ; 1993
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Docket No. 50-266 Docket No. 50-301
Wisconsin Electric Power Company
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ATTN: Mr. Robert Vice President i
Nuclear Power 231 West Michigan-P379
Milwaukee, WI 53201
Dear Mr. Link:
SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORTS NO. 50-266/93012(DRS);
50-301/93012(DRS))
This will acknowledge receipt of your letter dated November 4,1993, in response to our letter dated October 6,1993, transmitting a Notice of Violation associated with Inspection Reports No. 50-266/93012(DRS) and No. 50-l 301/93012(DRS).
These reports summarized the results of the service water
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system operational performance inspection at your Point Beach Nuclear Power i
Plant, Units 1 and 2.
We have reviewed your corrective actions and have no further questions at this time. These corrective actions will be examined
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during future inspections.
Sinc.erely,
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, H' %k (Geof rey f. Wright, Chief Engineering Branch See Attached Distribution 9312030012 931123 '
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Wisconsin Electric Power Company
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Distribution
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G. J. Maxfield,
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Plant Manager
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l cc w/ltr dtd 11/04/93:
OC/LFDCB Resident Inspector, RIII
Virgil Kanable, Chief
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Boiler Section
Ms. Cheryl L. Parrino Public Service Commission of Wisconsin
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State Liaison Officer J. E. Dyer, NRR
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A. G. Hansen, NRR D. P. Norkin, NRR R. A. Hasse, RIII M. W. Hodges, RI
A. F. Gibson, RII S. J. Collins, RIV K. E. Perkins, Jr., RV
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kVisctn1stn Electnc POWER COMPANY
231 w ucrom Po b 2046 Mawasee wi 5320b2046 (m)2212x5
VPNPD-93-194 NRC-93-123 I
November 4, 1993 Document Control Desk U.S. NUCLEAR REGULATORY COMMISSION Mail Station F1-137 Washington, DC 20555 Gentlemen:
DOCKETS 50-266 AND 50-301 RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORTS 50-266/93012(DRS); 50-301/93012(DRS)
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POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2
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In a letter from Mr. W. L.
Forney dated October 6, 1993, the Nuclear Regulatory Commission forwarded to Wisconsin Electric Power Company, licensee for Point Beach Nuclear Plant, the results of the service water system operational performance inspection (SWSOPI).
The SWSOPI was conducted by Mr. Rolf A. Westberg and other NRC
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representatives from August 2-through September 3, 1993.
This
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inspection report included a Notice of Violation (NOV) which
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described a violation of 10 CFR 50, Appendix B, Criterion V,
" Instructions, Procedures, and Drawings."
We have reviewed this NOV and, pursuant to the provisions of 10 CFR 2.201, have prepared a written response of explanation l
concerning the identified violation.
Our written response is included as an attachment to this letter.
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i 10 CFR 50, Appendix B, Criterion V, requires that activities
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affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances
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and shall be accomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been
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satisfactorily accomplished.
Point Beach Nuclear Plant Procedure (PBNP) 3.4.21, " Voluntary Entry into an LCO," Revision 0, dated January 15, 1993, requires, in
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part, that contingency actions or plans that will mitigate the potential consequence of the equipment being unavailable shall be g,. r Wa n
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Document Control Desk November 4, 1993 Page 2
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part of the considerations for activities requiring entry into a Limiting Condition for Operation (LCO).
Contingencies shall.be
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addressed in the controlling work document.
This violation is based upon a lack of' documented, quantitative acceptance criteria for establishing. leak tightness and a perceived lack of contingency actions to mitigate the potential' consequence.
of having several service water pumps unavailable when an LCO was
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entered to replace service water system Valve SW-9 on July 13,
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1993.
As discussed in the attached reply, we agree that we-did not
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have documented quantitative acceptance criteria for leakage and,
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although a contingency action was in place, it was inadequately
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documented in the controlling work plan.
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Please contact us if you have any questions or require additional information regarding this response.
Sincerely,
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Bob ank Vice President Nuclear Power
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i Attachment l
cc:
NRC Resident Inspector NRC Regional Administrator
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RESPONSE TO NOTICE OF VIOLATION 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 INSPECTION REPORT NOS. 50-2 66 / 93 012 (DRS) ; 50-3 01/ 93 012 (DRS)
During a service water system operational performance inspection (SWSOPI) conducted by Mr. Rolf A. Westberg and other NRC representatives from August 2 through September 3, 1993, one violation of NRC requirements was identified.
The identified violation was classified as Severity Level IV.
Inspection Report
Nos. 50-266/93012(DRS) and 50-301/93012(DRS) and the Notice of
Violation (NOV) transmitted to Wisconsin Electric on October 6,
1993, provide details regarding the violation.
In accordance with the instructions provided in the NOV,
our
reply to the alleged violation includes:
(1) the reason for the
violation; (2) corrective action taken and results achieved; (3)
corrective action to be taken to avoid further violations; and
(4) the date when full compliance will be achieved.
VIOLATION
10 CFR 50, Appendix B, Criterion V,
requires that activities
affecting quality shall be prescribed by documented instructions,
procedures, or drawings, of a type appropriate to the
circumstances and shall be accomplished in accordance with these
instructions, procedures, or drawings.
Instructions, procedures,
or drawings shall include appropriate quantitative or qualitative
acceptance criteria for determining that important activities
have been satisfactorily accomplished.
Point Beach Nuclear Plant Procedure (PBNP) 3.4.21,
" Voluntary
Entry into an LCO," Revision 0,
dated January 15, 1993, requires
that contingency actions or plans that will mitigate the
potential consequence of the equipment being unavailable shall be
part of the considerations for activities requiring entry into a
Limiting Condition for Operation (LCO).
Contingencies shall be
addressed in the controlling work document.
Contrary to the above, when an LCO was voluntarily entered on
July 13, 1993, to replace service water system Valve SW-9 under
Maintenance Work Request (MWR) 932809, the controlling work
document did not provide:
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Quantitative acceptance criteria for establishing leak
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tightness of the boundary valves.
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Contingency actions to mitigate the potential consequence of
having service water pumps A,
B,
and C unavailable.
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RESPONSE TO VIOLATION
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1.
REASON FOR VIOLATION
Maintenance on Valve SW-9 commenced on July 13, 1993.
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sump pump was placed in the body.of Valve SW-32C to prevent
water from accumulating in the work area.
Safety Evaluation Report (SER)93-050 stated Valve SW-9
would be removed after an adequate degree of leak tightness
was achieved which would be within the capability of the
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sump pump and not enough to effect service water
operability.
The sump pump. capacity was actually found to
be approximately 100 gpm which was much lower than initially
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anticipated during the development of the SER.
Therefore,
the sump pump capacity was inadequate to remove the service
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water entering Valve SW-32C.
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Service water system operability was determined prior to
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removing Valve SW-9 from the header.
With all isolatinn
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valves closed, Valve SW-9 was opened to simulate its removal
from the header while the service water header leakage was
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monitored at the open check valve.
The auxiliary operator
(AO), who was stationed in the pump house, verified with the
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control room that the service water system had adequate
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pressure to supply all non-isolated parts of the service
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water header.
The south header pressure was found to be in
excess of 50 psig and was determined by the duty shift
superintendent (DSS) to be adequate to supply all required
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loads.
Abnormal operating procedure AOP-9A, " Service Water System
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Malfunction," dated June 17, 1993, recommends maintaining
header pressure above 50 psig to avoid cavitation in the
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service water pumps.
However, cavitation was'not a concern
because the pumps were discharging to the north header which
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had a significantly higher pressure than the south header.
The maintenance mechanics were also confident that they
could replace Valve SW-9 in the existing conditionc.
A
conversation was held with the duty operating supervisor
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(DOS), the AO, the engineering supervisor, two engineers
(including the responsible engineer), a maintenance
supervisor, and maintenance mechanics to discuss the
qualitative aspects of the leakage and determine if the job
should proceed.
It was agreed that the job should continue
since:
(1) the leakage was within the quantity considered
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in the development of Special Maintenance Procedure (SMP)
1136, " Isolating and Replacing'SW-9;"
(2) the control room
stated the service water system had adequate pressure; and
(3) the mechanics could perform their work in the existing
conditions.
The replacement of Valve SW-9 could have been stopped at any
time by the responsible engineer (also designated as the
evolution coordinator), who was assigned in accordance with
PBNP 3.4.19 " Infrequently Performed. Tests or Evolutions."
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The evolution coordinator is responsible for the activity
over its entire duration and has the authority to abort the
evolution at any time if needed.
An acceptable leak rate
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criterion could not be established prior to commencing the
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evolution because working _ conditions for maintenance
mechanics had to be determined after visibly observing the
existing leakage.
Also, Calculation N-93-035 specified a
maximum lake temperature'of 74*F minus l'F for every 500 gpm
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of leakage from the service water header to provide adequate
cooling to service water system loads.
A maximum lake
temperature of 70*F was specified in accordance with
Justification for Continued Operation (JCO)93-001 and the
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inlet lake temperature was monitored throughout the
evolution.
Since the estimated leakage during the evolution
was approximately 500-1000 gpm (for a calculated maximum
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lake temperature of 72*F) and the maximum lake water
temperature recorded on July 13, 1993, was 51*F, the
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conclusions of SER 93-050 were valid and an unreviewed
safety question did not exist.
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Our planned contingency action to restore the A,
B,
and C
service water pumps to service was to use blind flanges to
close the pipe in the location of the removed valve (if this
would be the most efficient method) and restore the pumps to
service via the strainer bypass line.
This action was
discussed with the procedure originator during procedure
development but the approved procedure lacked this guidance.
The final procedure did have a requirement to maintain blind
flanges available.
However, the procedure-did not provide
adequate guidance on the use of the blind flanges as a
contingency action for restoring the south service water
pumps to service in an emergency as suggested in SER 93-050.
We agree with the examples cited in the NOV.
Although we
methodically evaluated the effect and amount of leakage
associated with the removal of Valve SW-9, we did not
include quantitative acceptance criteria in the procedure.
In addition, PBNP 3.4.21 clearly states that the controlling
work document shall have contingencies stated'in them for
voluntary LCO entries.
Although we had a contingency action
in place, it was inadequately documented in the procedure.
2.
CORRECTIVE ACTION TAKEN
This NOV is based on NRC review of the procedure used during
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replacement of Valve SW-9.
We believe the procedure was
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adequato to safely complete the evolution cnd no unreviewed
safety question existed.
Therefore, no immediate corrective
actions were taken.
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3.
COFRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER VIOLATIONS
Revision 1 of " Writer's Guide for Electrical and Mechanical
Procedures," issued on March 26, 1993, provides guidance for
the inclusion of acceptance criteria in e'ectrical and
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mechanical maintenance procedures.
Similarly, Revision 0 of
" Writer's Guide for Instrumentation and Control Procedares,"
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issued on January 15, 1993, provides guidance for the
inclusion of acceptance criteria in instrumentation and
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control procedures.
We have reviewed the writer's guides
and believe the guides contain sufficient guidance for
including acceptance criteria in associated procedures.
Although we considered this guidance, we failed to
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adequately reflect it in the procedure.
Therefore, we
believe no further corrective actions are required to
address the lack of acceptance criteria in the controlling
work document.
Regarding the lack of documented contingency actions in the
controlling work document, we will revise Form PBF-9133,
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" Voluntary Entry into a Limited Condition For Operation," to
add questions specifically addressing plant conditions and
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contingencies.
4.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
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We believe we are presently in full compliance with NRC
requirements.
However, we will revise Form PBF-9133 by
March 31, 1994, to create an additional barrier to prevent
the situation described above from reoccurring.
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