ML19347B587

LER 80-011/03L-0:on 800926,found That,Aug 1977-Sept 1980, Containment Spray Sys Spray Additive Valves Were Tested Per ASME Program Requirements Instead of Per Tech Specs.Caused by Administrative Error Re NRC 770926 Ltr

ML19347B587
Person / Time
Site:	Point Beach
Issue date:	10/06/1980
From:	Fay C WISCONSIN ELECTRIC POWER CO.
To:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19347B584	List: ML19347B583 ML19347B587
References
LER-80-011-03L, LER-80-11-3L, NUDOCS 8010150384
Download: ML19347B587 (3)

Text

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CONTROL OLOCK l l l l l l lh (PLEASE PRINT OR TYPE ALL REQUIRED INFORMATIONI b l t 4i l1 W l ILICENSEE 1

lPlB l H l }14 l@l15 0 l 0 l - l 0 LICENSE CODE l 0 l 0NUMeER l 01 O l - l 01 O is l@l 26 4 lLaCENSE 1 11 lTYPE l l 1a0l@lb7 C lA r dal@

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60 61 DOCK ET NUMBE R 68 63 EVENT OATE 74 75 REPCRT DATE 80 EVENT DESCRIPTION AND PROBABLE CONSEQUENCES h t o 1211 From Auaust 1977 throuch September 1980 the Containment Soray System sorav additive I

{ o la l ] valves were tested with satisfactory results at cold shutdown intervals in accordancaj I, ! . l l with Licensee's ASME Section_XI Inservice Inscection and Testing Program. Spray l 10 t s t I additive valves are recuired by Tech Specs,15.4.5.II.B.2 , to be tested on a l 10 !6 I I monthly interval . There were no adverse consequences resulting from this event. l lo ( 2 l l Point Beach Unit 2 is also affected by this event. l 10181 I l 7 s9 80 DE CODE SUSC E COMPONENT CODE SU8 CODE SU E lol9l 'l Sl Bl@ l Al@ l B l@ IV l A lL IV lE lS l@ IF l@ lD l@

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40 44 4; CAUSE DESCRIPTION AND CORRECTIVE ACTIONS h IiiO I l Administrative error in interoretation and imolementation of NRC letter dated I i i 1 August 26, 1977 which required Inservice Inscection and Testing in accordance with I i, ,,, i most restrictive of proposed ASME Section XI Program and Tech Specs. Spray l gl additive valves in both units were tested on 9-26-80 and will be tested monthly l gi until final NRC approval and issue of 2-17-77 Tech Spec Request. l 7 8 9 80 SA S  % POWER OTHER STATUS ISCO RY OlSCOVERY DESCRIPTION ITITI lE l@ l 0 l 7 I 5 l@l" NA l l A l@l Evaluation of ASME Section XI Program l

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ATTACHMENT TO LICENSEE EVENT REPORT 80-Oll/03L Wisconsin Electric Power Company Point Beach Nuclear Plant Units 1 and 2 Docket Nos. 50-266 and 50-301 The Point Beach Nuclear Plant, Units 1 and 2, Technical Specifications, at item 15.4.5.II.B.2, state that, "the spray additive valves shall be tested as follows. With the pumps shut down and the refueling water storage tank outlet valves closed, each valve will be opened and closed by operator action monthly."

Licensee was aware that testing of the spray additive valves in strict compliance with this specificatioh as written resulted in putting the containment spray system out-of-service during the duration of the test. On February 17, 1977, licensee submitted a Technical Specification change request to the NRC to establish compliance with 10 CFR Section 50.55a paragraph (g) (5) . This regulation requires that all nuclear power facilities meet, to the extent practicable, the inservice inspection and testing requirements of Section XI of the ASME Boiler and Pressure Vessel Code for safety class components. In additional guidance, received with a NRC letter dated November 22, 1976, licensee was cautioned to exerclse care in planning these ASME Section XI testing programs ,

to ensure that no test will be conducted while the plant is in an operating mode that would make it. vulnerable to a test error or a test failure, or which would have a potentially adverse impact on plant safety. In developing the Point Beach Nuclear Plant Unit 1 ASME Section XI inspection and testing program, which was submitted on May 20, 1977, we classified testing of the spray additive valves at a cold shut-down interval. Testing only at cold shut-down would eliminate any potential impact on plant safety during the duration of the test. Accordingl1, in the February 17, 1977 Technical Specification change request we proposed deleting the existing 15.4.5.II.B.2 specification and testing these valves and other safety class component in accordance with the ASME Section XI program.

On August 26, 1977 we received a letter from the NRC which directed that we implement the proposed ASME Section XI

' inservice inspection and testing program except where the .

current Technical Specifications are more restrictive. We were, therefore, required to create a hybrid inspection and testing program to comply with both the existing Technical Specifications and the proposed ASME Section XI inservice inspection and testing program until the Commission staff completed its review and approval of the ASME Section XI program. In developing this modified program to combine the most restrictive of these two sets of requirements, licensee commenced testing of the spray additive valves on a cold shut-down instead of a monthly testing interval.

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This misinterpretation of the more restrictive testing requirement was discovered by licensee as a result of our current investigation into the adequacy of the pump and valve testing program in accordance with Section XI of the ASME Code. Since the NRC has not as yet approved the February 17, 1977 Technical Specification change request which proposed deletion of specifi-cation 15.4.5.II.B.2, licensee on September 26, 1980 resumed testing of the spray additive valves on a monthly interval basis.

Since testing of these valves in accordance with the specification as written would result in securing both trains of containment spray for the duration of the test, we have resumed testing using a procedure approved by the Manager's Supervisory Staff which results in only The securing the chemical remainder of the spray additive portion of the spray system.

system remains fully functional during the test. An interim modification to our license amendments application to delete the procedural portien of specification 15.4. 5. II.B . 2 was submitted to the NRC for approval on September 29, 1980.

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