ML20112A719
| ML20112A719 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 05/17/1996 |
| From: | Link B WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| VPNPD-96-031, VPNPD-96-31, NUDOCS 9605210484 | |
| Download: ML20112A719 (7) | |
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Wisconsin Elecinc POWER COMPANY l
231 W Michgon. PO Box 2046. Milwaukee, WI 53201-2046 (414)221 2345 VPNPD 96-031 May 17,1996 l
Document Control Desk US NUCLEAR REGULATORY COMMISSION Washington, DC 20555 l
Gentlemen:
DOCKETS 50-266 AND 50-301 REPLY TO A NOTICE OF VIOLATION 1
INSPECTION REPORT 50-266/96002(DRPt 50-301/96002(DRP)
POINT BEACH NUCLEAR PLANT. UNITS 1 AND 2 By letter dated April 17,1996, signed by Mr. W. L. Axelson, the NRC forwarded to Wisconsin Electric, Integrated Inspection Report Nos. 50-266/96002; 50-301/96002. The inspection covered the period from January 9,1996, through March 1,1996. Enclosed with the inspection report was a Notice of Violation i
documenting three indivLlual v.olations of NRC requirements.
Pursuant to the requirements of 10 CFR 2.201, we are responding to each of the violations. Attached is our response which includes: (1) the reason for the violation, or if contested, the basis for disputing the violation; (2) corrective action taken and the results achieved; (3) corrective action to be taken to avoid further violations; and (4) the date when full compliance will be achieved.
If you have any questions or desire additional information, please contact us.
Sincerely,
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Bob Link Vice President Nuclear Power Attachment ec: NRC Regional Administrator l
NRC Residentinspector i
9605210484 960517 l
PDR ADOCK 05000266 I
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RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-266/96002 (DRP); 50-301/96002(DRP)
WISCONSIN ELECTRIC POWER COMPANY POINT BEACil NUCLEAR PLANT, UNITS 1 AND 2 DOCKETS 50 266 AND 50-301 LICENSE NOS. DPR-24 AND DPR-27 During a routine safety inspection performed by Messrs. T. Kobetz, A. McMurtray and others of your staff covering the period January 9,1996, through March 1,1996, three separate violations of NRC requirements were identified. Each of the violations were classified as a Severity Level IV. Inspection Report 50-266/96002 (DRP); 50-301/96002 (DRP) and the Notice of Violation (Notice) transmitted to
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Wisconsin Electric on April 17,1996, provide details regarding each violation.
i In accordance with the instructions provided in the Notice, our reply to the alleged violation includes:
(1) the reason for the violation, or if contested, the basis for disputing the violation; (2) corrective action taken; (3) corrective action to taken to avoid fmther violations; and (4) the date when full compliance will be achieved.
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i VIOLATION:
10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality shall be prescribed by procedures appropriate to the circumstances and shall be accomplished in accordance with these procedures.
NP 8.4.8, Revision 1, " Requirements for Scaffold near Safety-Related Equipment," Step 4.6, states "The construction sequence of all scaffold installations that will require more than one shift, and are not worked to completion, shall be reviewed for the potential to impact safety related equipment. If necessary, interim means of restraint shall be provided. The interim restraints shall be inspected by engineering or the contractor liaison engineer."
Contrary to. the above, scaffold had not been properly secured or restrained during construction over the 2P-'2C charging pump in excess of one shift.
This is a Severity Level IV violation (Supplement I).
Resoonse to Violation:
- Contrary to NP 8.4.8, " Requirements for Scaffolding Near Safety-Related Equipment," scaffold planks were not properly secured to the scaffolding in the 2P-2C charging pump cubicle prior to the end of the work shift. Charging Pump 2P-2C was in operation while the scaffolding was installed in the cubicle.
NP 8.4.8 requires scaffolding to be inspected prior to the end of the shift if the equipment is in service and the scaffolding is not complete. The inspection is intended to ensure that the condition of the j
scaffolding is such that it is structurally sound and does not create the potential to adversely affect operating equipment. The scaffolding in the charging pump cubicle was inspected. However, the inspection did not identify that the planks were not tied down as required. As a result, the scaffolding over the charging pump was in an unacceptable condition for approximately two days.
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We agree that this violation has been appropriately characterized.
l (1) Reason for Violation:
This event is attributed to the inexperience of the work group and supervisor installing the scaffolding. The group and supervisor were trained in 1995 on the proper method of constructing scaffolding. The group and supervisor also received just-in-time training prior to the construction of the scaffolding in the 2P-2C charging pump cubicle. However, this was the first non-training scaffolding job for the work group. A contributing factor in this event was that the workers were pulled off of the scaffolding construction prior to completion to support snow removal at the station.
(2) Corrective Action Taken:
Subsequent to being made aware of this condition, the planks were appropriately secured in accordance with procedural requirements.
(3) Corrective Action Taken to Avoid Similar Violations:
NP 8.4.8 has been reviewed by maintenance management. NP 8.4.8 contains adequate guidance and direction for the construction of scaffolding near safety related equipment.
The Manager-Maintenance discussed this event with the work group supervisor. The importance of properly constructing scaffolding was stressed, as was the unacceptability in leaving scaffolding in
. an unfinished condition. This event was reviewed with the work group and the significance of the event was stressed.
This procedure had undergone a major revision at the end of 1994 in response to several scaffolding problems. Based on a review of the station condition reports following the revision, the procedural changes have been successful in reducing the number of scaffolding problems. In addition, the work group secured the planks and constructed scaffolding in the 2P-2B charging pump cubicle without any problems or violations.
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(4) Date when Full Compliance will be Achieved:
Based on our reviews, we believe this situation to be an isolated occurrence. We are in full compliance.
I VIOLATION:
10 CFR 50.71, Paragraph (e)(4), requires the information included in the Final Safety Analysis Report l
(FSAR) contain the latest material developed and be updated annually or 6 months after each refueling outage. The revisions must reflect all changes up to a maximum of 6 months prior to the date of filing.
Contrary to the above, the FSAR updates have not reflected the following existing plant conditions as described in the FSAR:
Minimum service water flow to the containment accident fan coolers is 920 gpm in lieu of 1000 gpm as stated in Section 6.3.2 of the FSAR.
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i The actual operating average coolant temperature of both Units is 570*F in lieu of 573.9 F as j
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specified in Table 14-2, of the FSAR.
An analysis and a FSAR change increased the design service water temperature to 75 F; however, this temperature has not been updated in all sections of the FSAR for systems using service water i
cooling.
l l-These conditions existed a minimum of six months prior to the previous FSAR update.
l This is a Severity Level IV violation (Supplement I) l Response to Violation:
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The apparent inconsistencies referenced in the violation are related to the interpretation of the l
information, as well as the overall detail related to system and component design and operation l
presented in the FSAR. It has been our practice to maintain the original scope and content of the j-FSAR'when incorporating changes as required by the regulations. We believe this approach is acceptable and recognizes that the Design and Licensing Basis for PBNP are documented in numerous sources, including but not limited to the License (including Technical Specifications); the updated Final 1
Safety Analysis Report; commitments made in Licensee Event Reports, Notice of Violation responses l-and other documents, necessary for compliance to NRC Rules and Regulations; Safety Evaluations prepared by NRC staff as well as pursuant to 10 CFR 50.59; as well as documents being developed l
to document the PBNP Design Bases.
l We have provided annual updates to the FSAR, which we believed to be complete, since the inception of 10 CFR 50.71 (e). The FSAR continues to ensure that the proper evaluations are performed in accordance with Commission regulations for changes to the Point Beach Nuclear Plant.
l With the exception of the cited example related to operating Tm, we agree that this siolation is l
appropriately characterized. Table 14-2 documents the nominal inputs to the non LOCA licensing basis transients at PBNP. While the Tm input to the analyses remains 573.9 F, evaluations have been performed to show that the analyses at 573.9 F remain bounding for an operating Tm of 570 F. This j
table is not meant to document nominal operating parameters.
(1) Reason for the Violation:
The apparent inconsistencies documented in the violation are a result of the interpretation of the information related to system and component design and operation presented in the Point Beach FS AR. Information, particularly numbers, are a mix of design input assumptions, equipment nameplate data, and operational parameters. Because of this, dependent on the interpretation of the reviewer, a change may not be initiated as a result of an evaluation perfonned to show the acceptability of alternate configurations. In the case of the service water flow rate to the L
containment fan coolers, it was recognized that the flow was only one input to the design basis heat removal rate. Since the design heat removal rate is input to the safety analyses and therefore the acceptance criteria for the evaluation, the 1,000 gpm stated in the FSAR was interpreted as a j
nominal number and not changes as a result of the evaluation.
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(2) Corrective Action Taken:
The cited discrepancies are being resolved with the next annual update. Proposed revisions have been incorporated into a draft update and are being reviewed in accordance with our procedures.
Notwithstanding our belief that Table 14-2 is accurate, this update includes a note to Tables 14-1 and 14-2 to indicate that normal operating Tm is 570*F.
This update will be provided as required by 10 CFR 50.71 (e) (4) in June 1996.
(3) Corrective Action Taken to Prevent Further Violations:
We have reviewed our procedures for updating the FSAR and for preparation of evaluations pursuant to 10 CFR 50.59. Both clearly document the need to properly evaluate potential changes to the FSAR as well as identify specific proposed changes to our Licensing group for incorporation into the update. The update procedure also accurately reflects regulatory requirements for the update. We will continue to emphasize the importance of the FSAR to the operation of PBNP, and the need to ensure it's accuracy with all nuclear power personnel.. We are also directing personnel to report identified discrepancies via our Condition Report process so that trending and corrective action can be performed.
An interdisciplinary team is performing a detailed review of Chapter 9, " Auxiliary and Emergency Systems." This chapter contains information on service water, component cooling water, spent fuel pool cooling, and other support systems. This effort is expected to result in an update to this chapter and related information in other parts of the FSAR by August 1996. The team has been directed to question and appropriately characterize any number related to system design and operation. We also expect the team to provide input on any needed update process changes. We will use the results of this review as an input to assessing the overall condition of the FSAR and need for a more comprehensive review and update effort.
We recognize that improvements can be made in the identification and timeliness of making changes to the FSAR. A process improvement team is being formed to assess our present practices and investigate industry practices. Recommendations for improvement and implementation of appropriate changes will be made by September 1996. This will ensure that appropriate changes are captured in the next routine update to the NRC.
(4) Date when Full Complic.nce will be Achieved:
The revisions to our process to be completed by September 1996, will ensure future updates are performed in full compliance with the Commission's regulations.
VIOLATION:
10 CFR 50 Appendix B, Criterion XVI, " Corrective Actions," requires that measures shall be established to assure that conditions adverse to quality (such as failures, malfunctions, deficiencies,
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deviations, defective material and equipment) and nonconformances are promptly identified and j
corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
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Contrary to the above, the licensee failed to take adequate corrective action for deficiencies identified in 1993 regarding performance testing on the spent fuel pool heat exchangers.
This is a Severity Level IV violation (Supplement 1)
Response to Violation:
Based on the additional discussion in the inspection report regarding assessment of SFP heat exchanger capabilities, we believe timeliness of permanent corrective action implementation for the identified testing deficiencies is the issue that needs to be addressed. However, as discussed below, interim actions was taken to ensure the operability of the spent fuel pool heat exchangers which were not discussed in the Inspection Report.
The inspection report narrative implies that our planned actions for collecting acceptable performance l
data were technically inadequate. Our selected option ofinstalling more accurate instrumentation was based on avoiding the need to place the SFP cooling system into an unusual test configuration.
Improved instrumentation would have allowed operators to routinely gather accurate performance data without having to adjust valves, change pump combinations, and raise SFP liquid temperature higher than normal.
The inspection report fails to mention that radiographs of the SFP heat exchangers were taken in January of 1994 in order to assess their internal condition. Based on experience with service water supplied equipment, gross fouling and sitting is the expected degradation mode. The radiographs revealed no evidence of gross fouling or sitting. This information was factored into the overall urgency of the issue.
(1) Reason for Violation:
The cause for the lack of timeliness associated with this violation was lack of recognition of the importance of the assessment being performed.
He test was designated as a "PC" or periodic call-up. This is the least significant classification of operational surveillance. Operations Manual Procedure, OM 4.2.3, regarding call-ups states, "The purpose of periodic call-ups is to initiate tests, checks, and simple tasks that are periodically completed per manufacturers' reconunendations and/or plant experience."
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he purpose statement of PC 56.3 does not specifically mention implementation of GL 89-03 programmatic guidance or with operability determinations of safety related equipment. GL 89-03 is i
listed only as a reference in PC 56.3.
Two of the engineers responsible for PC 56.3 data review during the period April,1994, through January,1996, as well as for response to action items from the 1993 SWSOPI, were hired in June l
1993. Neither had direct experience with the response to GL 89-13 or with the 1993 SWSOPI.
j Additionally, neither had previous nuclear power experience.
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r (2) Corrective Action Taken:
The procedure, has been revised such that sufficient heat load is placed on the spent fuel pool heat exchangers to ensure meaningful results are obtained and instrument inaccuracies are less likely to influence results. Specifically, the spent fuel pool cooling system is reconfigured to increase liquid temperature prior to data gathering, thereby providing a heat load for removal. The revised test was conducted on May 11,1996. The Spent Fuel Pool Cooling System heat exchangers were determined capable of removing the required heat load. No significant degradation was detected.
(3) Corrective Action Taken to Prevent further Violations:
i The procedure used to evaluate the SFP heat exchangers has been reclassified as an IT (insenice j
test). Reclassification elevates the importance of this test, thereby ensuring appropriate attention is given to it. The " Purpose" section of Procedure OM 4.2, " Inservice Tests," states, "To provide guidance for the performance of periodic inservice testing of safety-related equipment as required in
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Technical Specifications and ASME codes referenced below..."
i The responsibility for scheduling the testing has been assaned to the Plant Performance Engineering l
group. This reassignment will ensure ownership and respoasibility for test performance, data i
evaluation and follow-up corrective actions.
(4) Date when Full Compliance will be Achieved:
We are presently in full compliance.
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