IR 05000266/1997005

Insp Repts 50-266/97-05 & 50-301/97-05 on 970208-0314.No Violations Noted.Major Areas Inspected:Insp to Review Use of Manual Operator Action in Place of Automatic Operation of Train a of MDAFW Sys During Accident

ML20140C575
Person / Time
Site:	Point Beach
Issue date:	04/03/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20140C561	List: IR 05000266/1997005 ML20140C557
References
50-266-97-05, 50-266-97-5, 50-301-97-05, 50-301-97-5, NUDOCS 9704170130
Download: ML20140C575 (8)

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}- U.S. NUCLEAR REGULATORY COMMISSION

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REGION lli

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Docket No , 50-301

License No DPR-24, DPR 27

4 Report N /97005(DRP), 50-301/97005(DRP)

Licensee: Wisconsin Electric Power Company, WEPCo ,

Facility: Point Beach Nuclear Plant, Units 1 & 2 Location: 6612 Nuclear Road Two Rivers, WI 54241-9516 Dates: February 8 through March 14,1997 Inspectors: A. McMurtray, Senior Resident inspector C. Keller, Resident inspector Approved by: J. W. McCormick-Barger, Team Leader Point Beach Oversight Team 9704170130 970403 PDR ADOCK 05000266 e PDR L, .

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EXECUTIVE SUMMARY l

l Point Beach Nuclear Plant, Units 1 & 2

!. NRC Inspection Report 50-266/97005, 50-301/97005

This special inspection was conducted to review the use, since April 1996, of manual operator action in place of the automatic operation of train A of the motor-driven auxiliary feedwater (MDAFW) system during an acciden The licensee had substituted manual' operator action for automatic auxiliary feedwater i control to compensate for the tendency of the MDAFW motor breaker to trip on

overcurrent when a lightly loaded emergency generator diesel was supplying the electrical !

power to the motor. The operator action was determined by the inspectors to be an 1- unreviewed safety question and an apparent violation of 10 CFR 50.59 was identified for ;

changing the operation of the MDAFW system without prior NRC approva '

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i f BADert Detalla 4 .

b L 1. Operations

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j 02 Operational Statue of Facilities and Equipment 02.1 Train A Motor-Driven Auxiliary Feedwater (A MDAFW) Svstem Oneration

!' Insnection Scone (71707) I l

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The inspectors reviewed the licensee's use of manual operator action to prevent the l A MDAFW pump motor breaker from tripping on overcurrent during an accident.

l Observations and Findinas I

!_ l l On April 17,1996, the breaker for the A MDAFW pump motor (P-38A) tripped on I i

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overcurrent during a Unit 1 safety iniecti<m will loss of offsite power surveillanc The licensee determined that the overcurrent condition was due to high electrical !

! frequency from the lightly loaded emergency diesel generator which was' running i j with speed droop set in the mechanical governor. For corrective action, the

licensee revised emergency operating procedures (EOPs) to implement operator i

action during an accident to adjust valve AF-4012, the P-38A discharge pressure !

! control valve, to limit auxiliary feedwater flow to 200 gallons per minute, thereby (

j preventing a trip of the breaker on overcurren ]

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On April 18,1996, the licensee issued safety evaluation report (SER)96-023 which l addressed the compensatory action of stationing a dedicated operator at AF-4012 j to prevent tripping P-38A. The SER concluded that this action did not involve a i change to the technical specifications nor an unreviewed safety question (USQ).

On April 25,1996, the licensee issued SER 96-028 which proceduralized operator action for AF-4012 in the EOPs and removed the dedicated operator. This SER also concluded that operator action to adjust AF-4012 did not involve a change to the technical specifications nor a US On April 22,1996, Unit 1 went critical after a refueling outage and the requirement in technical specification 15.3.4.A.2 to have two operable motor-driven auxiliary feedwater pumps and one operable turbine-driven auxiliary feedwater pump was applicabl On February 6,1997, the licensee initiated Condition Report (CR)97-415,

" Conclusions Within SER 96-028, Overfrequency of P-38A and Release of Dedicated Operator for AF-4012 Discharge Flow, May Be inappropriate" after questions were raised by Duke Engineering, a licensee contractor, during review of Unit 2 restart commitments. On March 4,1997, the licensee determined that release of the dedicated operator allowed by SER 96-028 was inappropriate. The licensee noted this determination in CR 97-708, " Inappropriate Release of

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Dedicated Operator for P-38A Under a Safety Evaluation" and reestablished the l

dedicated operator for AF-4012 via a prompt operability determination. No

! additional SERs were issued for this condition since SER 96-028.

The issue was reviewed further during the Operational Safety Team inspection )

i (OSTI) from December 1996 to February 1997 and left as an unresolved item (URI l No. 50-266(301)/96018-16) while the potential for an unreviewed safety question l j was evaluated by the NRC staff. On March 11,1997, in a conference call with the i

licensee, the NRC indicated that the use of operator action to maintain auxiliary

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feed flow following a loss of offsite power potentially was an unreviewed safety question in that the use of manual operator action could reasonably introduce the i possibility of increasing the consequences of an accident, may cause a different

] kind of accident, or may decrease the margin of safet '

, Section 10.2.2 (page 10.2-13) of the FSAR describes the design function of the A

MDAFW pump and the associated discharge valve as ensuring automatic delivery of

! auxiliary feedwater to the affected Unit's steam generator without operator action.

l In April 1996, the licensee revised several emergency operating procedures to direct !

! operators to adjust the P-38A discharge pressure control valve, AF-4012, as necessary to prevent the pump from tripping on overcurren l 10 CFR 50.59(a)(1) states that the holder of a license authorizing operation of a J

production or utilization facility may (i) make changes in the facility as described in

the safety analysis report, (ii) make changes in the procedures as described in the safety analysis report, and (iii) conduct tests or experiments not described in the

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safety analysis report, without prior Commission approval, unless the proposed ,

i change, test or experiment involves a change in the technical specifications j incorporated in the license or an unreviewed safety question. Based on NRC's

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determination of the existence of an unreviewed safety question, the inspectors j identified an apparent violation of 10 CFR 50.59 for the licensee's change of the j operation of the auxiliary feedwater system as described in the FSAR without prior j NRC approval (eel 50-266(301)/97005-01).

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! c. Conclusions

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The use of manual operator action to maintain the A MDAFW pump operable was

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an unreviewed safety question. Given this unreviewed safety question, an apparent violation of 10 CFR 50.59 was identified for the licensee's failure to obtain NRC approval of the change in the operation of the A MDAFW pump.

i 08 Miscellaneous Operations lasues 08.1 (Closed) Unresolved item No. 50-266(3011/96018-16: Review the use of manual operator action to maintain the A MDAFW pump operabl As discussed above in Section 02.1, the inspectors determined that the use of the operator involved an unreviewed safety question for which an apparent violation of

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10 CFR 50.59 was identified. Further licensee action on this issue will be tracked via apparent violation No. 50-266(301)/97005-0 V. Management Meetings

X1 Exit Meeting Summary

The inspectors presented the inspection results to licensee management at the l conclusion of the inspection on March 17,1997. The licensee acknowledged the '

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findings presented.

!' The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

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PARTIAL LIST OF PERSONS CONTACTED

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Licensee Wisconsin Electric Power Company (WEPCo)

A. J. Cayia, Plant Manager T. G. Staskal, Acting Operations Manager J. G. Schweitzer, Manager Site Engineering D. F. Johnson, Manager-Regulatory Services and Licensing T. C. Guay, Regulatory Services Manager

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INSPECTION PROCEDURES USED l

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l lP 71707 Plant Operations ITEMS OPENED, CLOSED, AND DISCUSSED

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50-266(301)/97005-01 EE: Apparent violation of 10 CFR 50.59 for change to the

. operation of the A MDAFW with an unreviewed safety l

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Closed I

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50-266(301)/96018-16 URI Use of manual operator action in place of automatic

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operation of the A MDAFW pump

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i LIST OF ACRONYMS USED AF Auxiliary Feedwater .

A MDAFW Train A Motor-Driven Auxiliary Feedwater CFR Code of Federal Regulations eel Escalated Enforcement item FSAP i Final Safety Analysis Report IP Inspection Procedure MDAFW Motor-Driven Auxiliary Feedwater  !

NRC Nuclear Regulatory Commission OSTI Operational Safety Team inspection -

PDR Public Document Room i SER Safety Evaluation Report '

URI Unresolved item WEPCo Wisconsin Electric Power Company

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