ML20092C847
| ML20092C847 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 02/05/1992 |
| From: | Zach J WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-92-019, CON-NRC-92-19 VPNPD-92-066, VPNPD-92-66, NUDOCS 9202120131 | |
| Download: ML20092C847 (10) | |
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Wisconson Electnc
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I VPNPD-92-066 10 CFR 2.201
!!RC-92-019 CERTillED_.M&lla
-February 5, 1992 t
Director Office of Enforcement U. S. NUCIIAR REGUIATORY COMMISSION Mail station P1-137 Washington, D. C.
20555 i
Attentions _ Document Control Dock i
Gentioment
-DQCRETS BO-266 AllD 50-301 REFLV =TO NOTICE OF VIOLATIOl{
11UiEECTION REPOETs so-266/910st.f>o-3cl/91025 POINT BEACH NUCLEAR, PIANT. UNIT 3 1 AND 2 In.a lettor_ dated January 10, 1992, from Hr. A.
Dort Davis, tho Nuolear Regulatory Commission forwarded to Wisconsin Electric Power Company, licensee for the Point Beach Nuclear Plant, a i
-Notice of Violation and Propomd Imposition of civil Ponalty (Notice).
The Notice described violations identified during the' special.-inspection conducted at: Point Beach Nuclear Plant from
. October 1 to November 1, 1901.-
Wo have reviewed this Notice and, pursuant to the provisions of 10-CFR 2.201, hava prepared a written statement of explanation 10oncerning theseLviolations as an-attachmont to this lotter.
Wo
' g-have also enclosed.a check payablo to the Troasurer of the United
' States:in the amount of $150,000 for payment of thel civil a.
penalties imposed by the Notico.
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NR'c Office of Enforcement February 5, 1992 Page 2 We believe this statomtent and the actions described are fully responsive to the cor.corno identified in the January 10, 1992, letter.
Should you have any questions concerning our activitios or proposed actions in this regard, please lot us know.
Sincerely, l
e c.
J JaghsJ.
Zach Vice. President' Nuclear Power Enclosures (Check 907144) copios to NRC Regional Administrator, Region III NRC Resident Inspector Subscribed and sworn to before me this 4h day of 2 d w.._,,, 1992.
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.A~ g, ".-c uc Q me Notary Public, State of Wisconsin My Commission expires.D. 5 D O
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l REPLY TO NOTICF, OF VIOLATION AND PROPOSED IMPOSIT!ON OF CIVIL PENALTIE8 Wiscondin Electrio Pow *,: s.smpany Point Beach Nuclear el
.nita 1 and 2 Dockets 50-266 and 50
-l During an inspection conducted from October 1 to November 1, 1991, at the Point Beach Nuclour Plant, two violations of HRC requirements woro identified.
The Notice of '*iolation (transmittal of January 10, 1992) identified two violations.
We agros that the everts and circumstances described in those violations have boon correctly charactorized.
We also agroo that the factors involving the discovery and corrective actiono concerning those violations have boon correctly applied in the escalation or mitigation of the associated civil penalties.
I.A. Violations Associated with_HSIV Renorting "10 CPR 50. 72 (b) (2) requires, in part, that the liconsoo notify the NRC as soon as practical and in all casos within four hours of the occurrence of any event or condition that alone could have provented the fulfillmont of the safety function ot a system that is nooded to mitigato the consequences of an accident.
"10 CPR 50.73 (a) (2) requiros, in part, that the licensoo submit a Licenseo Event Report within 30 days after the discovery of any event or condition that could alono have provented the fulfillment of the safety function of a system that is nooded to mitigato the consequences of an accident.
"Soction 14.2.5.1 of the Point Beach Safety Analysis Report (SAR) states that the fast acting steam line isolation valves are designed to close in loss than five seconds with low steam flow.
" Contrary to the above, the licensoo failed to adhere to these reporting requirements an.ovidenced by the following examplos:
"1.
On September 29, 1991, at 9:30 a.m.,-Unit 2 main steam stop valves /MSIVs No. 2MS-2017 and 2MS 2018 failed to closo under low stoca flow conditions during reactor shutdown for major fuel roloading, and the licensoo did not notify the NRC until the afternoon of September 30, 1991, a period in excess of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> as required by 10 CFR 50.72 (b) (2).
These failures alone could have provented the fulfillment of a safety function of a system nooded to mitigate the consequences of accidents described in the SAR.
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e Roply to NOV page 2 i
"2.
On August 16, 1987; September 24, 19891 and October 6, 1990; Unit 2 MS3V ' '
2MS-2017 failed to fully closo under low steam flow conditions during reactor l
shutdown, and the licensoo did not notify the NRC as i
soon as practical or within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> as required by 10 CFR 50.y2 (b) (2), and the licensos did not submit a 4
Writton r< port within 30 days after discovery as i
required Ly 10 CFR 50.73 (a) (2).
Those HSly failures alono could have provented the fulfillmont of a safety i
function noodod to mitigate the consequences of accidents described in the SAR."
EliGI911E Wo acknowledge that the circumstances identified in this violation are accurato and agroo that our failure to provido propor or timely reporting constitutos a violation of the NRC regulations.
The reason for this violation was our porception, baned on_the early operating experiences with the MSIVs during high steam flow conditions (which woro discussed in some detail during the Enforcomont Conference), that the failure of an MSIV to close-under low steam flow during a plant shutdown was not a significant safety concern.
We believed that during a postulated steam lino rupturo downstream of the valvo, the steam pressure and high steam flow would act to swiftly shut and seat tho MSIVs.
Wo further did not considor a failuro of the MSIV to fully closo during a unit shutdown to be a significant safety concern if the valvo was tested and proven to be operable before any subsequent power operation.
We acknowledge that those interpretations woro not conservative and did not moet the intent of the regulations.
We assure you, however, that those interpretations developed because of an operating-oxperieneo-based mind-set and not because of any deliberato disregard for plant safety or the NRC regulations.
As a result of this violation, a number of correctivo actions have bean completed or_have boon proposed to avoid further violations of this nature.
The following correctivo actions were discussed at the Enforcement Conference and have previously boon documented in our lotter to Mr. Davis dated December 3, 1991.
1.
For any condition where a single MSIV would not havo performed its safety function if called upon, wo have committed to report to the NRC in accordance with 10 CFR 50.72 and 50.73.
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4 Reply to NOV page 3 2.
If any safety-related componont or system does not moet its surveillance testing requiromonts or is not capable of performing its safety function as analyzed in thn FSAR, we will considor that component inoperable unloos it can be otherwise shown that the safety function can be satisficd.
3.
In those cases whore a safety-related component or system is inoperable and thoro is no governing bCo in the Technical Specifications, wo are committed to i
notify the Resident Inspector or the NRC Headquartors Duty officer in four hours.
We will continue this extra report until the Region III Administrator datorminos otherwise.
In the past year to oightoon months, we have initiated soveral management processes, including the condition Reporting System with its associated operability and reportability determinations, which are expected, as the processos mature, to becomo more effective in~1dentifying situations of this typu and avoiding similar violations.
Wo are increasing management attention to i
the programs-by evaluating them for adoquacy, adopting changes an necessary, and enhancing the training of our personnel on the implementation of the programs.
As a result of this incident, wo have taken the following additional steps which are intended to ensure that equipment problems are identified and promptly evaluated for reportability and operability:
1.
In order to datormine whether we have any chronic or repetitive problems-with other safety-rolated
-equipment, we are conducting a written operator and Maintenance Worker. Survey cooking information from thoso plant porsonnel as to whether situations nimilar to those experienced with the MSIVs exist anywhere oise in the plant.
The survoy has been distributed and will' be collected and summarized by February 14, 1992.
Follow-up interviews and/or focus group discussions will be conducted as necessary.
2.
We are revising the Maintenance Work Request defect tag to initiato concurrent reportability and operability dotorminations.
This revision will be completed by February 28, 1992.
3.
We havo issued an operations Night order and Standing i
order to reemphasize to the operating crews the importance of communicating equipment problems to management.
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Reply to NOV Page 4 j
Wo expect to report to you on the progross of those additional correctivo actions during a scheduled mooting with the NRC Regional representativos on Pobruary 24, 1992, i
I.B. ViolationsjAggggiated with MSIV Tettlng "10 CPR Part 50, Appendix B, critorion XI, Test Control, requires, in part, a test program be established to assuro that all testing required to demonstrate that systems and components will porform satisfactorily in service is identified and performed in accordanco with written test proceduros which incorporato the requirements and acceptanco limits contained in applicable design documents, that tort program shall include operational tests of systems and components during nucioar power plant operation, and tno test results shall be documented and ovaluated to assure that tout requiromonts have boon satisfied.
" Technical Specification 15.4.7 requires that the main steam stop valvos (alternatively known as the main steam isolation valvos, or MSIVs) shall be tested under low steam flow conditions during reactor shutdowns for major fuel reloading.
Closure tino of five seconds or loss shall be verified.
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" Contrary to the above, as of September 29, 1991, Point Beach Procedure IT-280/205, "In-Servico Testing of Main Steam Stop Valves," did not demonstrate that the main steam stop valvos (MSIVs) would perform satisfactorily in service duo to pro-conditioning of the valves by other proceduros.
Specifically, Point Doach Proceduro No. OP-13D, "Socondary System Shutdown," Revision 1, dated March 30, 1989, paragraph 4.7 directed _ closure of the MSIVs without measuring the closure _timo and Point Beach Proceduro Ho, OP-13A, " Secondary System Start-up," Revision 40, dated October 3,-1990, paragraph 4.5.5 directed the operator to cyclo the MSIV prior to performing the Technical Specification survoillance test that measures valvo closure time."-
RESPONSI We agroo with the conclusion of this violation that cycling the MSIVs during OP-13A prior to conducting the surveillance test may sorvo te procondition the valvos and, therefore, detracts from the ability of the survoillance test to demonstrate that the MSIVs would-pe
- form satisfactorily when placed in service.
We f-L l
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e Reply to NOV page 5 believe, however, that the portion of Proceduro OP-13D which directs closure of the HSIVs during a secondary nystem shutdown without measuring the closure timo should not be considered as I
preconditioning of the valvo.
We hope to discuss this matter with the NRC staff at our mooting on February 24 and will adhore to any agreemont developed at that j
timo rogarding this issue.
This violation occurrod becauso plant start-up procodures for the i
testing of thoso HSIVs originally required tho operators to conduct the Technical specification survoillance tost by cycling i
the valves.
Later, when a specific test procedure was developed to document this survoillance test,- the cycling of the HSIVs was i
not removed from proceduro OP-13A.
Our corrective-moasures to assure thoro was no operability questions because of testing mothodology included additional testing of both the Unit 2 and Unit 1 HsIVs during the months of October and November 1991.
Those tests woro reported to you in our letters dated October 8 and November 4, 1991, and during the Enforcement Conference.
The Unit 1 valvos woro successfully tested on October 5 and October 26, 1991.
For the latter outago, the tests were conducted both before and after the cleaning and refurbishment of the valvo operators.
As vo have previously reported,-the valves met the acceptanco critoria of the more rigorous surveillance test.
The Unit 2 valvon were successfully surveillance tested during the unit start-up in November 1992.
We have also committed to a mid-cycle test of the Unit 2 valvos in February or March 1992.
This mid-cycle tost, as indood all the'recent tests of the MSIVs mentioned abovo, will not includo any cycling of the valves prior to measuring the valvo closure time.
Since operating Proceduro OP-13A have boon revised to
-romove the valvo cycling stops prior to the Technical specification survoillance test, our program is now in compliance with the regulation.
II.
Violation Associated with corrective Actions "10 CFR Part 50, Appendix B, Critorion XVI, Corrective Action, requires, in_part, that measures be established to assure that conditions adverso to quality, such as failurus and malfunctions, are promptly identified and corrected.
In the case of significant conditions adverso to quality, the measures shall also assure that the cause of the condition is determined, correctivo action is taken to precludo repetition, and the cause of the condition and the correctivo action are documented and reported to appropriato l
levels of management.
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Reply to NOV Pago 6
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l "Soction 14.2.5.1 of the Point Beach Safety Analysis Report
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statos that the fast acting steam lino isolation valves are i
designed to closo in loss than 5 seconds with low steam flow.
" Contrary to the above, on August 26, 1987; September 24, 1909; and Octobor 6, 1990; Unit 2 MSIV 2MS-2017 failed to function as describod in Section 14.2.5.1 of the Safety Analysis Report, which is a significant condition adverso to i
quality, and the licensoo did not adequately determino the cause of the failure or take adoquato correctivo action to preclude repetition.
Specifically, on each of those occasions, the HSIV failed to close with low steam flow and the licensoo failed to dotormine the cause of the failure."
RESPONSE
l We acknowledge that the information in this citation is accurato and agroo With tho-observation that our correctivo actions to i
provent.rocurronco of the MSIV malfunctions were inadoquato.
The reason for this violation van our failuro to properly identify the root cause of the MSIV failuros.
In each of the throo valvo failures cited in this violation, valvo adjustments and/or maintenance was completed and the valvo satisfactorily tested prior to returning the unit to power.
The fset that those corrective actions were insufficient to provent recurrence of the valvo closure failures, and thus did not addrer.s the root cause of the valvo problems, is correct.
Our immediato corrective actions to return the Unit 2 MSIVs to an operable condition and to determine the cause of the recurring valvo failures have boon documented in our lottor dated November 4, 1991, and:the NRC's Novenber 15, 1991, Inspection Report.
We also discussed our findings with the NRC staff during the management mooting on November 1, 1991.
Briefly, those measures consisted of-cleaning and refurbishment of both MSIV valvo operators, replacement of valvo shafts and packing in both valves, and replacement of the MS-2017 shaft bushing.
The Unit-1 valve oporators_were also cleaned and refurbished during the October 26, 1991, unit outago.
On October 7,_1991, a Human Performanco Evaluation Systems L
' investigation of the September 29 incident was initiated.
This
' investigation focused on the history of operation of safety-related valvos and equipment and the practicos used by oporators during the conduct of procedures and tests.
The investigation also examined theLinterface and foodback betwoon operators and plant management.
Initial results of this investigation were l
4 Reply to NOV pago 7 shared with the NRC at the November 1, 1991, mana oment mooting.
Additional actions resulting from this investigat on woro also i
shared with you at the Enforcoment Conference and documented in i
our December 3, 1991, lottor.
Those includo the operator survey -
i montioned previously, our decision to initiato a systematic i
review covering the past fivo years of operating and machinery history of safety-related equipmont to uncover previously unidentified repotitivo problems, and the review of assumptions in our FSAR against the limiting conditions for operation and surveillanco requirements in the Technical Specifications and our preventive maintenanco program.
As described in our November 4, 1991, letter, we are closely monitoring the condition of the MSIVs in both units for any signs of conditions detrimontal to the valves or the operators loaks.
Any packing stoam leakago which we observe will be ovaluated to datormino the impacts of the leakage on the valvo and valvo operator.
Condensation will be addressed by diversion of the water away from the operators.
If packing adjustment is determined to be appropriato, the affected valvo will be subsequently tested for operability.
We are at this tino also planning additional hardware modifications to the MSIVs.
Those modifications woro discussed in our Supplements 1 LER 91-001-01 dated January 24, 1992.
They include replacement of the non-operator and of the MSIV valvo shaft packing box with a bearing cap which would require no packing.
At the operator and of the shaft, wo are planning to imploment the recommendation of the valve manufacturer to install an additional shaft support bearing.
This modification will provido additional support to the valvo shaft and reduce the amount of shaft bonding and uplift.
We believe this valvo shaft bonding and uplift contribute to the valvo packing leakage we have observed which, in turn, has contributed to the corrosion problems observed on the valve operator cylindor.
We are also planning to install a stronger spring in the valve operator cylinder which would provido a larger closing force on the valvo.
We will be contacting licensees having good root cause identification programs.
From those discussions, wo expect to identify.onhancements which may be mado_to our operating Experience Review Program which will contribute to prevent recurront equipment failures.
INPO has provided us with lesson plans and other information concerning-a training program for teaching root cause ovaluations.
As discussed above, we are planning to meet with the NRC staff on February 24,.1992, to summarize our progress towards resolution of the MSIV operability problems.
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. violations of NRC Regulations at the Point Beach Nuc. lear Plant Units 1 and 2.
RC068851
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