ML20063M792

Responds to NRC Re Violations Noted in IE Insp Rept 50-305/82-10.Corrective Actions:Revised Maint Work Request Procedures Implemented

ML20063M792
Person / Time
Site:	Kewaunee
Issue date:	09/01/1982
From:	Giesler C WISCONSIN PUBLIC SERVICE CORP.
To:	Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20063M791	List: ML20063M792
References
CON-NRC-82-154 NUDOCS 8209160121
Download: ML20063M792 (4)

Text

_____________.-- ____________________________ _______ ______

NRC-82-154 WISCONSIN PUBLIC SERVICE CORPORATION P.O. Box 1200, Green Bay, Wisconsin 54305 September 1, 1982 Mr. R. L. Spessard, Director Division of Project and Resident Programs U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Dear Mr. Spessard:

Docket 50-305 Operating License DPR-43 IE Inspection Report No. 50-305/82-10 The subject report was issued following a routine inspection conducted by Mr.

R. L. Nelson on June 1-30, 1982, of activities at the Kewaunee Nuclear Power Plant. One item was identified as non-compliance and cited by this report.

The attachment to this letter provides our response to this item.

Very truly yours, C. W. Giesler Vice President - Nuclear Power js Attach.

cc - Mr. Robert Nelson, U.S. NRC Subscribed and Sworn to Before Me This 1st Day of September 1982

/ J/

L ais ) f'sK Notary Public, State of Wisconsin My Commission Expires:

March 24, 1985 8209160121 820913 PDR ADOCK 05000305 O PDR SEP 3 E82

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j' Mr. R. L. Spessard September 1, 1982 A TTACll!!1.'n Response to IE Inspection Report 82-10 Item of Non-Compliance l

. Technical Specification 6.8.1 states, " Written Procedures and admini-I strative policies shall be established, implemented and maintained that meet the requirements and recommendations of Section 5.1 and 5.3 of ANSI .

i N18.7-1972." ..." Administrative Control Directive 5.4 (Work Request),

Section 5.4, states, in part, "The maintenance or I&C Group Supervisor i

plans when the maintenance action is to be donc noting priority, comple-tion required date, and collating in order of importance."

1 Contrary to the above, neither the maintenance nor 16C Group Supervisor planned maintenance action on a Maintenance Work Request concerning heat tracing on a boric acid flow path in that they failed to note the priority and completion required date and collate in order of importance. The MWR i

was in effect th roughout the 42-day maintenance outage. This lack of planning resulted in the plant entering into a Technical Specification Limiting Condition for Operation upon return to operation from the outage.

Response

The Maintenance Work Request (MWR) was written because of continual low alarms from the trendscan monitor point, not because of an actual failure observed with the boric acid heat tracing circuits. At the time the MWR was written applicability of the trendscan monitor alarm was question-abic as evidenced by several such Work Requests that were generated on L

r .  !

Mr. R. L. Spessard September 1, 1982 .

the alarm circuits. Questionable applicability is due to the fact that trendscan monitor points come off different thermocouples than the temperature controlling monitor points. Thus, the thermocouple monitoring any particular circuit may be located in a colder region of piping than the control point and may continually give low alarms as the control circuitry oscillates through its control band. When a situation like this is discovered, corrective action is taken to relocate the controlling monitor point to the colder portion of the affected pipe, whenever it is practicable to do so. At the time the MWR was written controller operation and trendscan points were checked and verified operable. The MWR was set aside because it was determined that the trendscan monitoring point and the heat tracing circuit control point were not properly placed. Relocation of the thermocouples requires taking the circuitry and process line completely out of service. Since the plant was operating at the time and a shutdown was required to work on the circuit in question, the MWR was set aside for refueling. As mentioned in the non-compliance, through an oversight this MWR was not completed during the refueling outage and a subsequent failure of one train of heat tracing in that circuitry caused a loss of one path of Boric Acid to the reactor.

Investigation revealed that the botic acid line freeze-up upon return to power operation from the outage was caused by a failure of one train of heat tracing tape combined with the removal of some insulation on that section of line. Upon discovery, the affected section of piping was flushed out, and the old heat trace tape was replaced and tested in accordance with approved maintenance procedures.

Since the time that the MWR was written a design change has been completed on the trendscan alarm inputs which has eliminated a large number of non-applicable alarms. In addition, a person from the maintenance group is responsible to note the priority, collate the MWR's associated with heat tracing in order of importance, and track completion of heat tracing MWR's.

L . __ _

, . 'Mr. R. 1,. Spessard ,,

September 1, 1982 Operahi1ity Check For safety-related circuits, when a valid, non-explainable trendscan low temperature alarm point is below 145 F, or when a Train A failure alarm is received, the shift supervisors are instructed to perform the following:

- Write a Maintenance Work Request

- Call in an electrician to perform a current reading on both Train A and B circuits to ensure operability

- Monitor heat tracing circuit temperatures to ensure that Train B is operating per design In the event of a train failure, the inoperable train must be returned to service within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> as per T.S. 3.2.c.3.

if a low temperature alarm is received and no failures are found:

- Current readings will be taken every 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to ensure both trains operable dutil the problem has been corrected and the temperature returns to above 145 F.

These actions are currently in place at the Kewaunee Plant.