ML20073J907
| ML20073J907 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 02/09/1994 |
| From: | Link B WISCONSIN ELECTRIC POWER CO. |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| CON-NRC-94-012, CON-NRC-94-12 VPNPD-94-018, VPNPD-94-18, NUDOCS 9410070184 | |
| Download: ML20073J907 (5) | |
Text
Wed Oct 05 14: 24: 20 1994 Pace 2 NIMS I
\\ Electnc POWER COMPNlv Pon' Beon Na7 Pmt 66'O Nuew od Ne pwi w u.x (414 W 2321 VPNPD-94-018 NRC-94-012 February 9, 1994 Mr. John Martin Regicnal Administrator U.S.
NUCLEAR REGULATORY COMMISSION, REGION III 801 Warronville Road Lisle, IL 60532-4351
Dear Mr. Martin:
DOCKETS 50-266 AND 50-301 RIOUEST FOR ENPORCEMENT DISCRETION LIMITING CONDITIONS FOR OPERATION POINT BEb_C.H NUCLEAR PLANT Uji1TS 1 AND 2 The purpose of this letter is to document the basis for a request from Wisconsin Electric Power Ccepany, licensee for Point Ecach Nuclear Plant, for enforcement discretion.
This request for enforcement discretion is made pursuant to the guidelines of Section VIII of the enforcerent policy (10 CPR Part 2, Apperdix C),
as rodified in the March 17, 1993, Federal Feaister Notice (58 FR 14308).
REOUTREME!TT FOR WHICE ENFORCEMENT DISCRETION IS PEOUESTED The Limiting Condition for Operation (LCO) defined by PBNP Technical Specification Section 15.3.7, " Auxiliary Electrical Systems," Specification B.l.g allows one emergency diesel generator (EDG) to be inoperable for a period not to exceed 7 days provided the other EDG is tested daily to ensure operability and the engineered safety features associated with the EDG are operable.
The failure of the operable EDO places both PBNP units into Technical Specification Section 15.3.0, " General Considerations,"
Specification A, which requires tho operating units to be placed into hot shutdown within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
Enforcement Discretion was requested to allow sufficient tine to return EDG G01 or G02 to a fully operable condition and should this action not be successful, to allow time for the orderly and sequential shutdown of both units.
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3 Mr. John Martin February 9, 1994 Page 2 i
CIRCUMSTANCES SURROUNDING THE SITUATION On February 7, 1994, at 0339 hours0.00392 days <br />0.0942 hours <br />5.605159e-4 weeks <br />1.289895e-4 months <br /> CST, EDG G02, the Train B EDG,
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was voluntarily removed from service fer its annual maintenance 1
outage as required by PBNP Technical Specification 15.4.6. A.4.
This required placing both PBNP units into the LCO defined in Specification 15.3.7.B.1.g which permits one EDG to be inoperable fer up to seven days provided the operable EDG is tested daily and the engincorod safety features associated with the operable EDG are operable.
On February 8, 1994, at 2204 hours0.0255 days <br />0.612 hours <br />0.00364 weeks <br />8.38622e-4 months <br /> CSI, ECG G01 was declared inoperable due to VAR fluctuations observed on the generator output during load testing of G01.
The declaration of G01 inoperability, with G02 out of service, required that both units be placed in het shutdown within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> (by 0104 hours0.0012 days <br />0.0289 hours <br />1.719577e-4 weeks <br />3.9572e-5 months <br /> on February 9, 1994) as required by Specification 15.3.0.A.
At 2208 hours0.0256 days <br />0.613 hours <br />0.00365 weeks <br />8.40144e-4 months <br />, shutdown cf both PENP Units cornenced.
An Unusual Event was declared at 2207 hours0.0255 days <br />0.613 hours <br />0.00365 weeks <br />8.397635e-4 months <br /> in accordance with our Energency Plan due to loss of safeguards equipment requiring plant shutdown.
Notification of State and Local Agency was completed on February 8 at 2219 hours0.0257 days <br />0.616 hours <br />0.00367 weeks <br />8.443295e-4 months <br />.
An ENS notification was made to the NRC Operations Centor on February 8 at 2257 hours0.0261 days <br />0.627 hours <br />0.00373 weeks <br />8.587885e-4 months <br /> CST.
Efforts to troubleshoot and repair G01 were initiated immediately in parallel with efforts to recover G02 from its annual maintenance cutage.
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At 2320 hours0.0269 days <br />0.644 hours <br />0.00384 weeks <br />8.8276e-4 months <br /> CST, the power reducticn was suspended with the approval of NRC Region III personnel pending completion of our 1
request for enforcement discretion.
PBNP Unit 1 power was held at 864 and Unit 2 at 85% during this time.
Upon declaring EDG G01 inoperable, innediate action was taken to detcraine the cause of the VAR fluctuations.
We determined that the voltage fluctuations were caused by the shorting of a cable assembly within the generator.
The cable which connects the exciter brushes came in contact with a rotating collector bus bar carrying current from the brushes to the generator coils.
The damaged cable and bus bar on EDG G01 were replaced with identical parts from G02 which was out of service for maintenance.
This repair was cor.pleted, EDG GL, load tested satisfactorily and G01 declared operable at 0244 hours0.00282 days <br />0.0678 hours <br />4.034392e-4 weeks <br />9.2842e-5 months <br /> CST on February 9, 1994, at which time enforcement discretion was no longer required.
Wed Oct 05 14: 24:30 1994
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Mr. John Martin February 9, 1994 Page 3 Both PBNP units were subsequently returned to 100% power.
G02 remains out of service.
Both units continue in the seven-day LOO in Specification 15.3.7.B.I.g for one EDG inoperable.
COMPENSATORY ACTIONS Cembastion Turbine Generator (C05), our qualified alternate AC scurce can be used to supply power to both the Train A and Train B safeguards buses if a loss of offsite power occurred during the duration of the enforcement discretion.
G05 was successfully lead tested on February 7, 1994.
No work er testing that could adversely affect the operability of G05 was performed during the
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duration of the enforcement dlscretion.
We requested special consideration from our system control center to minimize requests for changes to the loading of the PBNP units, as wel'. as te minimize any foreseeable perturbations on the 345 kV grid.
All four 345 kV lines to FBNP were operable.
All work, testing and surveillance which could result in a trancient on one or both PBNP Units or could affect safeguards equipment was suspended for the duration of the enforcement discretion.
SAFL'TY SIGNIFICANCE AND POTENTIAL CONSEOUENCES Continued operation of both units for the duraticn of this enforcement discretion in excess of the 3-hour action time required by specification 15.3.0.A did not result in an increased risk to the health and safety of the public and plant personnel.
The shutdown of both units within the 3-hour action tire limit of Specification 15.3.0 places the units through sinultaneous transients, placing unnocessary burden on the operating crew, and therefore increases the probability of initiating an event which could challenge the engineered safety features of the reacter protection system.
Sequential shutdown of the units allows norral and orderly shutdown of each unit, minimizes the effects of the shutdown transients on the units and the burden on the cperating crew.
During the time that both units are operating at power, should a loss of of fsite power occur and both EDGs fall resulting in a station blackout, the conbustion turbine (G05) is operable and available to provide power to the required safe shutdown loads.
In addition, both units are near normal operating temperatures which allows use of the steam generators and auxiliary feedwater systen for the renoval of decay heat.
If the units are in cold shutdown, i
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Wed Oct 05 14*24:30 1994 Paeo 5 l
Mr. John Martin February 9, 1994 Page 4 a loss of decay heat renoval capability by the residual heat renoval system would occur until the required shutdown loads are repowered from G05.
i JUSTIFICATION FOR THE DURATION OF THE ENFORCEMENT DTSCRETION We requested to hold in abeyance the required shutdown to allow repairs and return of G01 to an operable condition.
Also, we requested an additional seven hours to place the first unit in hot shutdown and 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> to place the second unit in hot shutdown.
We believe this time was sufficient to allow completion of G01 repairs and return to service testing, and to allcw an orderly and sequential shutdown of both PBNP units using normal shutdevn procedures and rates (15%/ hour) should these repairs not be successful.
STATE NOTIFICATION STATEMENT We notified the Public Service Ccanission of Wisconsin Electrical Division staff of the requested enforcement discretion at 0725 hours0.00839 days <br />0.201 hours <br />0.0012 weeks <br />2.758625e-4 months <br /> on February 9.
This will be followed by formal notification of appropriate State of Wisconsin officials by copy of this letter in accordance with 10 CFR 50.91(b).
SUMMARY
OF COMMUNICATIONS AND APPROVALS The NRC senior resident inspector was notified on February 8 at 2215 of the inoperability of both EDGs and of our intent to request enforcerent discretion.
In accordance with cur Energency Plan, State and local agencies were notified of the declaration of the Unusual Event on February 8 at 2219 CST.
They were notified of the Unusual Event termination at 0416 hours0.00481 days <br />0.116 hours <br />6.878307e-4 weeks <br />1.58288e-4 months <br /> on February 9, 1994, following the return of G01 to an operable condition.
The one-hour non-emergency event notification was made to the NRC Operations Center in accordance with 10 CFR 50.72 (i) (A), on February 8 at 2257 hours0.0261 days <br />0.627 hours <br />0.00373 weeks <br />8.587885e-4 months <br />.
A status update en the event was made to the NRC Operations Center on February 9 at 0034 hours3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br />.
The Operations Center was notified of the return of G01 to service en February 9 at 0253 hours0.00293 days <br />0.0703 hours <br />4.183201e-4 weeks <br />9.62665e-5 months <br />.
The PBNP Manager's Supervisory Staff (onsite nuclear safety reviev committee) convened and discussed this issue at approxinately 2300 hours0.0266 days <br />0.639 hours <br />0.0038 weeks <br />8.7515e-4 months <br /> CST on February 9, 1994; concurred with the decision to request this snforcement discretion; and concurred with the content of this request.
Page 6 Wed Oct 05 14:24:10 1994 Mr. John Martin February 9, 1994 Page 5 r
A telephone conference between the Nuclear Reactor Regulation (NRR) offices, NRC Region III, PBNP, and WE corporate offices was initiated and 2315 hours0.0268 days <br />0.643 hours <br />0.00383 weeks <br />8.808575e-4 months <br /> CST on February 8, 1994, to discuss this request fcr enforcement discretion.
it was At the beginning of our conference with RRC representatives,rampdown peinted out by the Managor-pBNP that as of 2208 hours0.0256 days <br />0.613 hours <br />0.00365 weeks <br />8.40144e-4 months <br /> CST,of both PEN Accordingly, it was accordance with normal shutdown procedures.
requested that the requirements of the LCo be cuspended for the This request was verbally duration of the telephone conference.
Mr. Robert Greger, on approved by your regional representative, Units 1 and 2 were subsequently held February 8 at 2320 hours0.0269 days <br />0.644 hours <br />0.00384 weeks <br />8.8276e-4 months <br /> CST.
at 86% and 85% power, respectively, fcr the duration of the enforcement discretien.
Verbal approval cf this enforcement discretion was granted on at 2356 hours0.0273 days <br />0.654 hours <br />0.0039 weeks <br />8.96458e-4 months <br /> CST by Mr. Robert Greger, holding in February 8, abeyance the shutdown of both PENP units until 08C0 hours CST onat which tine February 9,
- 1994, the unite would bo initiated if an EDG had not been restored to Three hours was granted for placing the first operable status. unit in a hot shutdown condition and additional 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> granted for placing the second unit in hot shutdevn.
If you have any questions or require additional information, please contact us.
Sincerely, Q
Bob Link Vice President Nuclear Power cc:
NRC Resident Inspector NRC Document Control Desk PSCW Anthony, Arneson, Becka, Krieser, Maxfield, Newton, Patulski, bec: Ulmer, Malanowski