ML20091F853
| ML20091F853 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 12/03/1991 |
| From: | Zach J WISCONSIN ELECTRIC POWER CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| CON-NRC-91-138 VPNPD-91-421, NUDOCS 9112090409 | |
| Download: ML20091F853 (4) | |
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.o-L Wisconsin Electnc POWER COMPANY 231 W Micmyrt oo im 20e Wem W 53201 (4'4)22' 2345 P?!?'.lY [ b.
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NRC-91-138 lv December 3, 1991
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- f d[Itth1HAd~7 Mr. A.
Bert Davis. Regional Administrator Region III U.
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NUCLEAR REGULATORY COMMISSION 799 Roosevelt Road Glen Ellyn, Illinois 60137 Gentlemen:
DOCKETS 50-266 AND 50-301 RIE STEAM ISOLATION VALVE _
OPERABILITY CONSIDERATIONE EQINT BEACH NUCLEAR PLANT, UNITS 1 AND 2
? he purpose of this letter is to provide our follow-up to the Wisconsin Electric /NRC Enforcement Conference held at the NRC Region III offices in Glen.Ellyn, Illinois, on November 22, 1991, regarding the failures of the Main Steam Isolation Valves (MSIVs) at Point Beach Nuclear Plant, Unit 2.
At the Enforcement Conference, we concurred that certain mistakes and errors in judgment may have occurred in the maintenance, testing, coirective action, documentation, and reporting of MSIV problems and failures.
We believe that the root cause of these occurrences was a mind-set specific to the operability of the MSIVs.
In the early.1970's, we experienced several incidents of sudden MSIV closure as we approached 100% power.
We determined at that time that the valve discs were susceptible to " wiping-in" due to high steam flow, and the 2MS-2017 MSIV was modified to include a larger air operator to hold the valve open against the steam flow.
We also performed other modificatione to the valves to minimize the probability of inadvertent closure.
Given these problems and the nature of the valve design, a be. lief persisted that, even if the valves failed to fully shut at no or low flow, the valves would shut with any significant steam flow.
Although we believe this mind-set wac unique to the MSIVs, we recognize a potential need to improve the scope and implementation of several existing programs as they apply to all of our safety-related systems and equipment.
Many of these
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Mr.*A.
Bert Davis December 3, 1991 Page 2 management processes were initiated in the last year or so and are becoming more effective as they mature.
These existing programs include the Condition Reporting System with its associated operability and reportability determinations; corrective maintenance reporting and documentation; preventive maintenance programs; root cause analyses and correction of significant or repetitive equipment problems; operating experience review; and surveillance testing.
We intend to increase management attention to these programs by evaluating them for adequacy, making changes as necessary; and by enhancing the training of our personnel on their implementation, emphasizing the vital importance of communicating equipment problems to management.
Specific actions that we will take to imorove the above existing programs are listed below.
We expect to complete Items 1, 2,
4, 5, and 7 by February 1992 and Items 3 and 6 approximately one year later.
We will provide an updated schedule and discuss our methodology and preliminary findings during the February 1992 meeting prooosed in i.ur November 4, 1991, letter.
1.
We will request a Techruc.1 Specification change to add the MSIVs and Non-Return Sb.m Ialves (NRSVs) to Section 15.3,
" Limiting Conditions for operation," and to clarify Section 15.4.7 regarding surveillance testing of the MSIVs.
2.
To help determine whether we have any chronic or repetitive problems with any other safety-related equipment, a written Operator and Maintenance Worker Survey will be conducted seeking this information from an operational or maintenance perspective.
Follow-up interviews and/or focus group discussions will be conducted as necessary.
3.
We will initiate a systematic review of operating and machinery b# story of safety-related equipment; the review will cover he last five years.
This will include records such as Lictnsee Event Reports, Significant Operating Event Reports, Non-Conformance Reports, Maintenance Work Requests, and Nuclear Plant Reliability Data System Reports.
We will use the results of Item 2 to focus this review.
4.
An INPO Operating Experience Assist Visit requested earlier thic year has been scheduled for December 1991.
We intend to seek the INPO staff's advice on identification of root cause techniques to incorporate into both our corrective maintenance and operating experience review programs.
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_ _ _ _ _ _ _ _ _ - _ _ _ J
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- ' Mr A. Bert: Davis =
December 3, 1993 Page-3 5.
Wo.will conduct a review of the assurptions in our FSAR accident analyses against the Limiting Conditions for Operation-(LCO) Section and the Surveillance Section of the Point Deach Technical Specifications to determine if additional equipment-LCOs or surveillances should be added.
We wi?1 submit Technical Specification Change Requests to make the appropriate revisions resulting from this review.
-Mr. R. K. Hanneman will be our liaison person-in regard to Technical Specification matters.
IfJyou wish to designate a
_particular individual.with whom he should discuss these matters, please let us know.
6.-
The" equipment required in the assumptions of our FSAR accident analyses will be compared to the mainte. nance call-up_ system to ensure that our preventive maintenance program covers this' equipment.
7.._To help ensure that' equipment problemc.are promptly
' evaluated for reportability and operability, we will revise the Maintenance.Hork Request defect tag to initiate concurrent reportability-and operability determinations.
In the interim,1 we:will issue an' operations Night Order to Lalert the-operating crews to this' issue.
_There'are three additional items that we would like to clarify and commit to:-
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We_now understand that for any-condition where a single.MSIV would'not have performed its safety-function if called upon, a: report will_be made to the NRC in.accordance with 10 CFR 50.72 and-10 CFR 50.73.-
2..
If a safety-related component or1 system does not meet its surveillance testing req'tirements or is not' capable of performing its safety = function as_ analyzed in the FSAR, Lwhether identified in.the performance;of a srecific surveillance" test _or otherwise,.that compor.ent will be
, considered inoperable,~unlessLit can be otherwise shown_that thc safety function can be satisfied.
'3.
Until the-NRC Region'III.RegionalLAdministrator and_
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-Wisconsin Electric agree otherwise, in cases where a safety-n-
related-component:or system is-inoperable and there is-no governing.LCO in the. Technical Specifications, we will notify-the_ Resident-Inspector or.the NRC Headquarters Duty
-Officer within four hours.
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Mr.'A.
Bert Davis I
December 3, 1991 Page 4 As noted previously, we intend to schedule a meeting with you and ycar staff in February 1992.
The purpose of the meeting will be to provido an update on our modification plans for the PSIVs and NRSVs and an update on the evaluations conducted and enhancements planned for the above administrative programs.
We want to emphasize that we intend to continue to take conservative actions in the operation of the Point Beach units to protect the public health and safety beyond minimal actions required by the Technical Specifications and to keep the NRC informed of these actions.
We believe the above commitments will ensure the continued safe operation of both units at Point Beach, while we continue to evaluate further long-term corrective actions and program enhancements.
Very truly yours, j.
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. " ' ' /s 6-c Zeb Jages J.
Vice President Nuclear Power Copics to NRC Document Control Desk NRC Resident Inspector
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