ML20097G738
| ML20097G738 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 06/15/1992 |
| From: | Link B WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-92-064, CON-NRC-92-64 VPNPD-92-217, NUDOCS 9206170267 | |
| Download: ML20097G738 (4) | |
Text
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Wisconsin Electnc FDNER COMPANY ni w M,&gn Po bw 2m huno W mi id 'd R2'~ Dd!'
VPHPD-92-217 NRC-92-064 June 15, 1992 jl U.
S.
NUCLEAR REGULATORY COMMISSION Document Control Desk Mail Station P1-137 Washington, D.
C.
20555 Gentlement DOCKETS 50-266 AND 50-301 RESPO!ME TO NOTICE OF VIOLATION INSPECJION RF2 ORT 50-766/92009(DRPl.L 50-301/92009(DITl a
l POINT BEACH NUCLEAR PLANT. UNITS 1 AND 2 i
Your letter dated May 15, 1992, transmitted a Notice of Violation which was supported by the findings documented in Inspection Report 50-266/92009(DRP); 50-3 01/92 009 (DRP).
The Notice of Violation cited two examples of failure to conform with the requirements of 10 CFR 50, Appendix B, Criterion V.
This criterion requires that activities affecting quality be prescribed in documented procedures, instructions, and drawings appropriate to the situation.
The first cited example occurred on April 29, 1992, during preparations for hydrostatic testing of a portion of the Residual llcat Removal (RHR) System.
The hydrostatic test was being performed as part of the acceptance testing for a modification performed during the most recent refueling outage for our Point Beach Nuclear Plant, Unit 1.
This modification installed test lines capable of passing full flow from the RHR pumps and was performed to address concerns with operating the pumps on recirculation at reduced flow and to allow more meaningful testing of the pumps.
During the lineup of the system, prior.to filling the piping, a vent valve was inadvertently left open.
When the RilR pump suction and discharge valves were. opened to fill the piping with water, the water. began discharging.from the open vent valve into the containment spray pump room in the Primary Auxiliary Building.
Approximately 200 gallons of water were discharged.
The spill resulted in approximately 600 square feet of floor near the safety injection and containment spray pumps becoming contaminated.
No personnel contaminations occurred.
}
NRC Documumont Control Desk Juno 15, 1992 Page 2 The RHR suction and dischargo valves, which had boon opened from the control room to fill the RHR piping, voro immediately closed when water was reported discharging from the vont line.
The hydrostatic test was suspended to assoas the incident and take correctivo action.
The valvo lineup utilized during the test was reviewed for accuracy.
This review identified the vont valvo which had boon inadvertently left open during the filling process.
To ensure the complotonoss of tho valvo lineup during the completion of tho.tosting process, a detailed valvo lineup check list was developed to establish the test boundarios; the valvo linoup was performod; and the test completed without further incident.
During our review of this event, wo datormined that the change to the design of the test line modification to include this vont valve was mado during installation of the modification utilizing the Engineering Chango Roquest (ECR) process.
This process is controlled by Quality Assuranco Proceduro QP 3-4, "Enginooring Change Roquests."
This proceduro prosently requires identification of drawings that require updato but does not require update prior to the performance of post-modification testing.
PDNP 3.2.5, "Pressuro Test Program," currently does not require that a formal valvo lineup shoot be used while establishing the boundarios for a pressure tost.
The procedure suggests that a sketch be prepared defining the extent of the pressure test and boundary.
The operators used a=separato marked-up sketch during the valvo lineup which they had updated to reflect this vont path.
The controlled drawing in the control room had also been updated to include the vent path.
- However, the informal sketch in the hydrostatic test package did not reflect the new vont valvo.
A revision to PDNP 3.2.5 is being written to require that a formal valvo lineup be prepared and utilized, along with the appropriate verification, when performing system lineups for pressure tests.
Requirements will 'also be established to ensure that the test boundarios are shown on appropriate-plant documents rather than on informal sketches.
This revision will bo incorporated into our current review and complete rewrite of PBNP 3.2.5.
This complete rewrito is.boing conducted in support of i
our upgrado to the Point Beach repair and replacement program as defined in ASME Section XI, " Rules for In-Service Inspection of Nuclear Power Plant Components;" Article IWX-4000, " Repair Procedures;" and IWX-2000, " Replacements."
The complete procedure rewrito, including this revision, will be issued by September 30, 1992.
NRC Documumont Control Desk June 15, 1992 Page 3 In addition to the revision to PDNP 3.2.5, we are evaluating our ECR and modification procedures to strengthen the controls and linkage between these procedures.
Wo will complete these evaluations and subsequent revisions to our Engineering Chango Request and modification proceddios by September 1, 1992.
Also, we will continuo to stress with our personnel tho importance of good, timely communications and the need to remain cognizant of the status of all ongoing evolutions.
This will be emphasized in continuing training.
When the described procedural revisions are completed addressing pressure test evolutions and the ECR process, we will be in full compliance to 10 CFR 50, Appendix B, Criterion V for this cited example.
The second cited example occurred on April 28, 1992.
This event occurred during the inspection of safeguards bus 1A06 when the wrong poter.tial transformer cubicle was entered.
Potential transformers, which sense bus voltage, for 4160V safeguards buses lA05 and 1A06 are located within the samo cubicle, 1A00-62, on bus 1A06 but behind separate doors.
The doors were uniquely identified with small labols.
The maintenance electrician and his supervisor, directed to inspect the potential transformer for bus 1A06, thought the cubicle contained only compononts associated with bus 1A06, which was doenergized.
The electrician failed to road the identifying labais and opened the door associated with tiA potential transformar for hus 1A05, which was energized.
Opening the door, which is interlocked with the undervoltage relays for the bus, resulted in the undervoltage relays for the safeguards bus IA05. sensing the bus as deenergized.
This caused diesel generator G01 to automatically start and bus 1A05 to deenergizo and'be reenergized by the diesel generator.
Normal power was rostored to the bus in approximately 10 minutes nd the diesel generator secured and placed-in standby.
Procedures for this evolution did not adequately describe the location and configuration of the cubicle.
This event and the corrective actions taken-aro described in detail in Licensee Event Report 266/92-003-00,_ dated May 27, 1992.
A Human Performance Enhancement System Evaluation (HPES) has boon performed and concluded the event was attributable primarily to human error.
This event was discussed with the individuals involved.
The consequences of the event will be included in future training sessions on operation and maintenance of switchgear.
4 l
I NRC Documument Control Desk June 15, 1992 i
5 Page 4 The Plant Manager issued a statement to plant and contractor personnel summarizing the event, its precursors,fand the importance of self-checking.
A caution statement has been added to Routine Maintenance Procedures (RMP) 29c, 29d, 29e, and 29f to_ alert personnel that opening a door to a potential transformer will result in deenergization of the associated bus.
The procedures will also indicate, where appropriate, that potential transformers for both A05 and A06 are located in close_ proximity to each_other.
The doors for the potential transformers for buses;A01, A02, A03, A04, A05, and A06 have been labeled to indicate that opening._the-door. will result in deenergizing.tlus bus.
Labels-have also been applied to the outside of cubicles 1A00-621and'2A00-71'to indicate train A and train B safeguards. components are located:
inside.
We believe that these actions have satisfactorily addressed'this-issue and will preclude a similar event in the future. -We are now in compliance with 10 CFR 50, Appendix B, Criterion V for; this cited example.
We agree that these events occurred as described in the Notice'of-Violation and accompanying Inspection Report.
The: events are appropriately characterized,.in the aggregate, as a' Severity Level IV violation.
Please contact us should--you_ require additionalLinformation or have questions regarding this response.
Sincerely, h
1 Bob Link Vice President Nuclear Power Copies to.NRC-Regional-Administrator,ERegionf1II-NRC Resident Inspector-1 m
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