ML20005G175
| ML20005G175 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 01/12/1990 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-90-004, CON-NRC-90-4 VPNPD-90-026, VPNPD-90-26, NUDOCS 9001180246 | |
| Download: ML20005G175 (12) | |
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KWER COMPANY l 234 w McNoon/P.O. Ibx 2046.houkee.W 53201 (414)2212345 =
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' January 12, 1990 6A1 q
-UE S.. NUCLEAR REGULATORY COMMISSION l
I DocumentJControl: Desk LMail: Station.P1-137.
J JWashington, D.JC.: '20555:
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- Gentlemen:
'N DOCKETS 50-266 AND'50-301 REPLY TOrNOTICE'OF~ VIOLATION'
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.bf" INSPECTION' REPORT' 50-266/89030(DRP);
50-301/89030(DRP)'
- POINT BEACH ~ NUCLEAR PLANT. UNITS 1 AND 2 U
LThistletterlis$in response,to a Notice of Violation enclosed with xyoursletter oH f. December 1 3,-.1 9 8 9.
The Notice of Violation is
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'L associated ~with:a routine l safety' inspection conducted'by Messrs.
'O C.
It.1 Vandernieti and J. Gadzala"during_the period October 16
-i ithroughiNovemberH30,u1989.;'The'results'of that inspection
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- werefreported:inLInspection Report'50-266/89030(DRP);
M 50-301/8903 0 (DRP)..
The violations identified in the inspection report and described
'in the~ Notice,of Violation; involve (1) failure to meet Technical i'
Specifications requirements regarding' operability of auxiliary feedwater-flow: rate instrumentation ~and (2)" failure to comply u*
Lwith~ Administrative Procedure PBNP 3.4.1,
" Ignition Control",
' which requires that a' fully charged, suitably sized fire extinguisher be'provided at a work site. involving hot work.
i Wisconsin Electric agrees that the conditions described in the inspection' report-have been properly classified as two Severity on JM Level'IV. violations.
Our discussions on each of the violations, including the apparent cause, corrective actions taken, actions ataken'to prevent recurrence, and date when full compliance was
. achieved are provided in the attachments to this letter.
'9001190246 900112
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--January ~12, j l990-
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.Very truly-yours, I
e C. W; Fay.
i-Vice-President' l
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-Nuclear Power e
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' Attachments Copies:to1NRC: Regional ~ Administrator,. Region.III
'NRC Resident Inspector i
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J' jx ATTACHMENT 1 I'
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ATTACHMENT 1 O
REPLY TO' NOTICE'OF VIOLATION DOCKET NO. 50-266 POINT BEACH NUCLEAR PLANT h; <-
VIOLATION-NUMBER 266/89030-04 DESCRIPTION OF THE VIOLATION:
Techni' cal Specification Table -15.'3.5 requires one channel of auxiliaryffeedwater.to be operable during reactor operations,
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i DCS 3.1.3,
" Technical Specification Interpretation, Auxiliary Feedwater Flow Rate," broadens the interpretation to include-one channel of each of. the' installed groups 'of feedwater flow Lindication.
1 Contrary'to'the above, on November 20, 1989, the licensee discovered that Unit-1 AFW flow transmitters 1FT 4036 and 1FT.4037'were isolated.
These flow transmitters provide AFW flow-indication in'the control room.
A review of the event found that the. transmitters were isolated for three days.
This is a violation of Technical' Specifications (TS) Table 15.3.5-5.
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La ATT CHMENT 1--
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DISCUSSION:
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i On' November-17, 1989, Unit 2~was in a shutdown-condition for its
. annual ~ refueling and maintenance outage m al Unit 1 was. at 100%
normal' power. operation.with the auxiliary feedwater system in a o
standby; condition.
In' preparation forLa tubesheet crevice flush of the Unit 2 steam generators,.an I&C technician was assigned to, isolate the instrumentation' identified in Attachment C of RP-6A, " Steam Generator Crevice Flush (Vacuum Mode)."
Included among that instrumentation are two flow transmitters, FT-4036 and FT-4037,
-that. provide the control room with direct indications of the total. auxiliary feedwater flow to steam generators A and B,
.respectively.
For the flushing process, a 20-inch vacuum.is
.. drawn:on the steam generators to facilitate boiling at less than 200*F.
Because of-uncertainty as to how the transmitters would hold 1up to a 20-inch vacuum, the procedure calls for their isolation.as a precautionary measure.
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- ATTACHMENT 1
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f RP-6A identifies the two-transmitters as.FT-4036 and FT-4037 and does not include the unit identifier.
Only the tags on the e
actual > instruments themselves make any distinction between the
,two= units:
The alphanumeric identifiers associated with Unit 1 are prefixed with numeral "1" and those that are associated with Unit ~2'are prefixed with the numeral "2."- -Thus, 1-FT-4036 and 1 FT-4037 idehtify the actual transmitters for Unit 1 and the transmitters for Unit 2 are identified by tags that read 2 FT-4036 i
and 2:FT-4037.- Both pairs of the Unit 1 and the Unit 2 l
transmitters are. physically located in the primary auxiliary i
building (PAB).
The procedure in question, RP-6A, identifies the L
El. 26! of the PAB as tlle location of the transmitters; but in L
fact,'only the flow transmitters for Unit 1 (1 FT-4036 and i
1 FT-4037) are on the El. 26' while 2 FT-4036 and 2 FT-4037 are actually on the El. 8' of-the PAB.
N I t about 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br /> on November 17, 1989, an I&C technician A
-inadvertently isolated 1 FT-4036 and 1 FT-4037.
In the process of restoring the procedure-referenced instrumentation to service,
.other I&C technicians discovered that 2 FT-4036 and 2 FT-4037 had never been isolated.
Subsequent investigation revealed the extent of the error and upon discovery on November 20, 1989, at approximately 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br />, 1 FT-4036 and 1 FT-4037 were expeditiously restored to service.
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' ATTACHMENT 11<
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APPARENT CAUSE OF VIOLATION:
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.TheEcircumstances surrounding this violation were reported in g
1-2 Licensee: Event: Report (LER)150-266/89-010-00 enclosed with our.
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letter of December 19,-1989.
The LER stated:
The cause of-this event is the direct result of'an f
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. error in'an approved procedure together with a-personnel cognitive error...The procedure directed e
the technician'to the flow-: transmitters located on Lthe El.,26' -[.-.
. of the primary Auxiliary Building-x rather than'to their actual' location on El. 8'.]
Although.the technician was aware of_the need to isolate-the Unit 2 transmitters,Rhe'was'under the mistaken' impression.that the transmitters to the El."26of the PAB were common to both units and 4
. verified.only the.last faur characters of the 4'-
alphanumericLidentifiers.
The flow transmitters at'the discharge of:the motor-driven auxiliary feedwater pumps are common instruments to both
' units.-
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-CORRECTIVE ACTIONS:
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'.When the error.was-discovered, the Unit 1 auxiliary feedwater i
flow' transmitters (1 FT-4036 and 1 FT-4037)-were immediately valved L
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- back into servi ce.
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- ATTACHMENT 1 LPage-5; i
ACTIONS TAKEN-TO PREVENT-RECURRENCE:
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ALrevision to procedure RP-6A, " Steam Generator Crevice Flush
.(Vacuum Mode)" has been" initiated.
The procedure revision will correct the error which resulted'in this violation.
The location i
of:the. Unit 2 auxiliary'feedwater flow transmitters (2 FT-4036 and
- 2
- FT-4037) will' be correctly identified as being on the El. 8' of
.the-PAB.
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- This-procedure change will be made prior to its next use during 1
the Unit 1 refueling outage in the spring of 1990.
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Inl addition, with regard to the personnel cognitive error, the ztechnician' involved in the event has been counseled by the PBNP
- superintendent'of Instrumentation and Control.
That counseling l
t stressed the importance of verifying unit identifiers when isolating or' returning instrumentation to service.
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l-The PBNP Training group will perform a Training Needs Analysis l'
(TNA) in regard.to the event and will revise training materials and/or conduct training if deemed necessary as a result of that analysis.
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ATTACHMENT:1
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- DATE WHEN FULL COMPLIANCE WAS ACHIEVED
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ff-Fullicompliance was achieved'when the Unit 1~ auxiliary feedwater f;
flow transmitters (lift-4036 and 1 FT-4037) were valved back into
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, service.
This occurred at;approximately 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br /> on
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~ November'20, 1989.
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ATTACHMENT 2.
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. Page'l-u ATTACHMENT 2 REPLY TO NOTICE OF VIOLATION DOCKET <NO. 50-301=
POINT BEACH NUCLEAR PLANT
. VIOLATION NUM*ER 301/89030-03 VIOLATION::
-Technical Specification 15.6.8.1Lrequires that'the plant be'
' operated!.and maintained in accordance'with' approved procedures.
Administrative procedure PBNP 3.4.1,
" Ignition-Control," requires that a fully charged, suitably sized fire extinguisher be provided at-a work site involved with hotwork.-
Contrary to the'above, on November 16, 1989, personnel were
, performing hotwork to remove-a circular staircase in the Unit 2 l containment area with no fire extinguisher present at the job site.
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- ATTACHMENT 2
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DISCUSSION:
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- k~1 On November 16, 1989,. Unit 2 was.in a refueling outage. -Work I
was beingl performed in the Unit 2 containment that involved
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An ignition
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welding andLgrinding.to removela spiral staircase.
icontrolLpermit had been issued for the job in accordance with'
" adminIs. r.trative: procedure PBNP 3.4.1,. "Igniti071 Control;
. Procedures,."Tand a fire watch of five individuals had been assigned.. The ignition control permit covered work on-El. 66',
El. 46' and El. 21.
- The' fire watch for the job was' comprised of one' individual. assigned to.each of the three elevations and
,two. roving watches.
In: addition to the 12 fire extinguishers mounted in containment for normal fire protection, three
< additional fire! extinguishers had been brought into containment
.specifically for this job.
The work and fire watch responsibilities were being' performed by personnel working under contract during
.the refueling / maintenance outage.
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-One member of the fire watch was interviewed by the resident l
H inspector. -Based upon.the results of his interview, it is apparent.that this member of the fire watch was not fully aware of his responsibilities, nor did he know the location of the nearest fire: extinguisher.
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ATTACHMENT'21
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1 Ourlinvestigation'of theievent involved = interviews with the 1
o contractor supervi'sor, members of hisi crew; the PBNP-fire protectionland safety' coordinator, and the.WE-contractor liaison j
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.engineert :The: fire watch person interviewed by-the resident x
' inspector.was-not available.to be~ interviewed during our r
4 investigation of'the: incident.
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L lthough this one' individual apparently did-not know the' location
' of the nearest fire extinguisher,.it is our -position, because
- four other persons wereLalso assigned;to the. fire-watch and' i
.because those members of the fire watch were-aware of their responsibilities and'the locations of' fire' extinguishing
- equipment,Lthat the-hotwork associated with the job was conducted-
-safely and in a. manner consistent with the intent of the PBNP g
' ignition ~ control procedure.
APPARENT CAUSE OF VIOLATION:
The' apparent cause of' the violation was failure of the job n,
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' supervisor to adequately brief one member of a five-man fire watch regarding his responsibilities and the location of fire extinguishers.
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" ATTACHMENT.2
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CORRECTIVE ACTIONS;.
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The auerrant member of the five-man fire watch was made aware ~of h
the location of a nearby fire extinguisher.
Our investigation L'
was.not'able.toidetermine if that awareness was achieved as a p
Y result'of' actions taken by the job supervisor or as a result of the worker's interview with the NRC inspector.
g ACTIONS TAKEN'TO PREVENT RECURRENCE:
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The..PBNP fire' protection'and safety coordinator routinely performs surveillance of work performed under the ignition control D
' procedure.- This surveillance involves interviews with persons assigne'd"to a fire ~ watch to assure that they are' aware 3of their responsibilities,'know the location'of fire extinguishing equipment'and are aware of nearby communications capabilities to report fires.to the control room.
This random surveillance program has been escalated effective January 5, 1990.
DATE WHEN-FULL COMPLIANCE WAS ACHIEVED:
Full compliance was achieved on November 16, 1989, shortly after the inspector's observations, when the aberrant member of the 1-fire watch was made aware of the location of the nearest fire y
extinguisher.
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