ML20127B725
| ML20127B725 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 01/07/1993 |
| From: | Link B WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-93-001, CON-NRC-93-1 VPNPD-93-002, VPNPD-93-2, NUDOCS 9301130087 | |
| Download: ML20127B725 (8) | |
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Wisconsin VElecinc
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POWER COMPAfiY wnvarp m ura w ouan3m mmw 23s VPHPD 002 NRC 001 January 7, 1993 Document Control Desk U.S.
NUCLEAR REGULATORY COMMISSION Mail Station Pl-137 Washington, DC 20555 Gentlemen:
DOCKET 50-301 RESPONSE TO NOTICE OF VIOLATION POINT BEACH NUCLEAR PLANT. UNIT 2 In a letter from Mr. A.
Bert Davis dated December 8, 1992, the Nuclear Regulatory Commission forwarded to Wisconsin Electric Power Company, licensee for the Point Beach Nuclear Plant, a. Notice of Violation (Notice) and Proposed Imposition of Civil Penalty in the amount of $75,000.
The Notice resulted from events documented in a routine safety inspection for the period August 24 through October 12, 1992.
The Notice describes a violation of Point Beach Nuclear Plant Technical Specification Section 15.3.3, " Emergency Core Cooling System, Auxiliary Cooling Systems, Air Recirculation Fan Coolers, and Containment Spray," Specification A.1.g; and 10 CFR 50, Appendix B, Criterion V,
" Instructions, Procedures:and Drawings."
We have reviewed this. Notice and, pursuant to the provisions of
.10 CFR 2.201, are enclosing e written. response of explanation _of the identified violation including actions taken, or being taken, to correct and. prevent recurrence of similar events.
We have also enclosed a-check payable to the Treasurer'of the United States in the amount of $75,000 for payment of the civil penalty imposed by the Notico.
The violation identified in the Notice pertains to inadequate'-
procedural control of a safety system modification which resulted in the system _being unable'to perform its function in certain post-accident modes of operation.
This is in violation.of the Technical Specifications.
On. September 18,:1992, during performance testing
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of_the,PBNP-Unit 2 Train A' containment spray pump, the pump;was rendered inoperable due.to a foam rubber plug becoming lodged in the impeller suction.
An. incident' investigation-team formed to pfif 416?g.'I^O1'b_0087930107r~~vb5 f f' I
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1 Document control Desk January 7, 1993 Page 2 determine the origin of the plug concluded that the plug had originated in aEsection of piping between the residual heat removal (RHR) pump discharge and the suctions of the containment spray and safety injection pumps and had been moved into the containment spray pump suction during performance of system leak checks.
In this locction, the plug could have caused the failure:of the safety injection or containment spray pumps if operated with their suctions aligned-to the RHR pump discharge.
The foam rubber plug was most likely placed in the line during modifications performed to Train A of the RHR system.to install test lines capable of passing full pump flow.
The modifications were performed during the Unit 2 fall 1991 refueling outage.
Therefore, the plug was in the piping for nearly one year prior to being discovered.
This is in violation of Technical Specification 15.3.3.A.1.g, since the PBNP Unit 2 reactor was made critical following the fall 1991 outage with a portion of the piping inoperable.
Procedures controlling the modification process were inadequate to prevent this occurrence and were therefore in violation of 10 CFR 50, Appendix B,-Criterion V.
Corrective actions have been taken to improve controls related to foreign material intrusion during system maintenance and modifications.
Action is also being taken to assess and improve our control of contractors during system maintenance and modifications.
We believe that the attached reply is responsive to the concerns and fulfills the requirements in your December 8, 1992, letter.. If you have any questions or require additional information regarding-this response, please contact us.
sincerely,
-Bob Link Vice President Nuclear Power TGM/jg Enclosure.(Check No. 983339) cc:
Regional Administrator, NRC Region III' NRC' Resident Inspector
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REPLY TO NOTICE OF VIOLATION WISCONSIN ELECTRIC POWER COMPANY POINT BEACH NUCLEAR PLANT, UNIT 2 DOCKET 50-301 LICENSE NUMBER DPR-27 During the routine safety inspection conducted at our Point Beach Nuclear Plant from August 24, 1992, through October 12, 1992, violations of NRC requirements were identified.-
The identified violation, with two parts, was classified as a severity Level III.
Inspection Reports 50-266/92018(DRP) and 50-301/92018(DRP) dated October 30,-1992, and the Notice of Violation and Proposed Imposition of Civil Penalty (Notice) dated December 8,'1992, correctly provide the details associated with the event.
We agree that the event and circumstances described in the Notice are appropriately characterized.
In accordance with the instructions provided with the Notice, our reply to the violation includes:
(1) the reason for the violation, (2) corrective action taken, (3) corrective action taken to avoid further violations, and (4) the date when full compliance will be achieved.
VIOLATION A.
" Technical Specification 15.3.3.A.1.g requires, in part, that a reactor shall not be made critical, except for-low tempera-ture physics tests, unless all valves and piping associated-with the safety injection system components that are required to function during accident. conditions are operable."
" Contrary to the above, on or about November 13,-1991, the Unit 2 reactor was made critical, not in connection with low.
temperature physics tests, while the piping associated with Train A of the containment recirculation mode of :safetyr injection, which is required to function during accident condition, was inoperable.
Specifically, a foreign material exclusion disk had been left in a section of the system.
piping leading to the suction of the Train A safety injection-pump."
B.
"10 CFR Part 50, Appendix B, Criterion V,
" Instructions, Procedures, and Drawings", requires, in part,'that activities affecting quality be prescribed by~ procedures of a. type' appropriate to the circumstances and.shall include
. appropriate quantitative or. qualitative acceptance criteria' for determining that important activities have been.
satisfactorily accomplished."
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" Contrary to the abova, on or about October 17, 1991, Procedure QAP-105-PB, " Cleanliness Inspection of Fluid Systems and Components," Revision 1, a procedure affecting quality; did not include appropriate guidance or acceptance criteria to ensure that debris was not left inside the safety injection and containment spray pump suction during perfor-mance of modification IWP 88-098."
BE.SPONSE TO VIOLATION 1.
REASON FOR THE VIOLATION The installation work procedure used during the modification process required the use of the contractor's cleanliness procedure, QAP-105-PB, " Cleanliness Inspection of Fluid Systems and Components," Revision 1.
This procedure was reviewed by WE personnel, but was interpreted differently by WE and contractor personnel.
Sign-offs required for system cleanliness checks, including checks for foreign material, were not specifically delineated from other cleanliness sign-offs related to actual performance of the work.
In addition, we had not established formal cleanliness guide-lines and controls to be used by contractor and WE personnel during the performance of system modifications.
This resulted in a cleanliness plug being left in the portion of the Train A RHR piping between the RHR pump discharge and the suctions of the safety injection and containment spray pump suctions following modifications to install new test lines for the RHR pumps.
The plug was most likely transported into the containment spray pump suction piping during an annual system leak check.
The plug was subsequently discovered during the performance of the quarterly inservice test of the containment spray pump.
2.
CORRECTIVE ACTION TAEEH I.
Immediate a.
The Duty Shift Superintendent (DSS) and Duty and Call Superintendent (DCS) made a determination that there was reasonable assurance that the containment spray system Train B, as well as the safety injection and RHR systems, remained operable following the discovery of the temporary plug.
This was based on their belief that no additional foreign material capable of causing a failure existed in these systems.
II. Short-Term The following actions were taken to investigate the cause of the pump failure and to verify the operability of the RHR, safety injection and containment spray pumps:
I
l a.
Containment Spray Pump P-14A was disassembled and a foam rubber plug was found in the impeller suction.
The plug was removed, and the pump reassembled.
A modified IT-545A, " Leakage Reductions and Preventive Maintenance Program Test of Containment Spray System, Unit 2," with flow through the RHR cross-connect line, and IT-06, " Containment Spray Pumps and Valves, Unit 2," were completed satisfactorily and the pump declared operable at 1923 on September 19, 1992.
b.
The Unit 2 Train B Containment Spray Pump P-14B was tested utilizing IT-06A on September 18, 1992.
The test was successful.
c.
Additional tests of Unit 2 Containment Spray Pumps P-14A and P-14B were performed on September 19 and 20, 1992, utilizing a modified test procedure IT-545A and IT-06, to test the ability of the pumps to develop full flow with water supplied to the pump suction from the RHR system.
The tests were completed satisfactorily.
d.
On September 20, 1992, Test IT-06 was completed on Unit 2 Containment Spray Pumps P-14A and P-14B.
The tests were completed satisfactorily, e.
A quorum of the Manager's Supervisory Staff (MSS) met on September 21, 1992, to review the event, the results of system testing, and to define additional necessary actions to ensure the operability of the containment spray, RHR and safety injection systems in both PBNP units.
The staff determined that there was reasonable assurance that failure of the Unit 2, Train A containment spray pump did not indicate a common-mode failure problem and that these other systems remained operable.
Similar modifications had been performed on the Unit i systems during the Unit 1 Spring 1992 refueling outage.
Additional controls were implemented in the Installation Work Plan (IWP) for this modification that were not included in the IWP for the Unit 2 modifications.
These controls included additional sign-offs by Wisconsin Electric personnel ensuring system cleanliness.
f.
The MSS prescribed a testing plan for the containment spray, RHR and safety injection systems in both units to provide additional assurance of the operability of these systems.
The following tests were conducted and results achieved:
Radiography was performed, on September 21, 1992, on a section of piping from the Unit 2 Train A RHR pump discharge to the Train A safety injection pump suction.
No foreign material was detected.
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1 On September 21 and 22, 1992, Unit 2 Safety Injection Pumps P-15A and P-15B were tested with water supplied to the pump suction from the RHR system.
The tests were completed satisfactorily.
On September 23 and 24, 1992, testing was performed on the Unit 1 Containment Spray Pumps P-14A and P-14B with water supplied to the pump suction using the Unit 1 RHR system.
The tests were completed satisfactorily.
i on September 24, 1992, testing was performed on e
the Unit 1 Safety Injection Pumps P-15A and P-15B-with water supplied to the pump suction using the Unit 1 RHR system.
The tests were completed satisfactorily.
g.
An incident investigation team was chartsred to investigate the event in order to determine the root cause.
The team completed its investigation and reported to the MSS on October 5, 1992.
The team could not conclusively identify the origin of the foreign material.
The foam rubber-plug was most likely placed into the piping during modifications performed during the Unit 2 fall refueling outage to install full flow test lines in the RHR, containment spray, and safety injection systems.
h.
Inspections were performed during the Unit 2 refueling outage, which ended on November 18, 1992, of portions of the Unit 2 containment spray, RHR, and safety injection systems to identify any additional foreign material in these systems.
The inspections included, to the extent practicable, the portions of the systems affected by the full flow test line modifications as well as piping dead legs land flow restrictions.
The inspections were performed using a combination of borescopic~ examinations and radiography of the potentially'affected piping.
sections.
Small amounts of foreign material discovered were removed from the systems where practicable.
All material that-could not be recovered-was evaluated prior to startup-and determined _to not-present an operability concern.
i.
The; interior of-the Unit 2 RWST was inspected using a remote. controlled minisub and video camera and by personnel entry.
Minor-debris was found.
The debris included small pieces of tape, herculite, metal and other material.
The debris was removed prior-to the end of the refueling outage.
The debris has been-determined to not be safety significant.
The MSS has-E concurred with this determination.
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Management has reinforced to engineers and supervisors the importance of foreign material controls and the need for specific instructions in the IWPs covering work for which they are responsible.
k.
Quality Assurance personnel reviewed all 1992 Unit 2 outage modification packages prior to installation specifically for system cleanliness concerns.
1.
Maintenance planners have been instructed to provide specific steps in work plans delineating the appropriate system and component cleanliness controls for the work.
Supervisors are required to ensure the requirements of the work plans are properly implemented and documented.
m.
The Manager-Maintenance stressed foreign material control during his refueling outage related weekly meetings with maintenance personnel.
3.
CORRECTIVE ACTION TO BE TAKEN TO PREVENT RECURRENCE I.
To address the root cause of foreign material introduction into a system during modification and maintenance, the incident investigation team recommended corrective actions in the areas of improved foreign material control and cleanliness inspections prior to system closing.
These recommendations have been evaluated and upgrades to our foreign material control procedures have-been implemented.--An upgraded procedure was issued on November 5, 1992, with full implementation completed by December 31, 1992.
This procedure will be required to be used by both WE and contractor personnel.
These upgrades include:
a.
Maintenance Instruction MI-32.4, " Guidelines For Exclusion of Foreign Material from Plant Systems,"
was replaced with PBNP Procedure 3.4.25, " Exclusion of Foreign Material fror Plant Components and Systems," to ensure that the procedural requirements are applied to all maintenance and modification work as appropriate.
b.
The above procedure includes foreign material control provisions based on the guidance in the preliminary draft of INPO Good Practice MA-315, " Exclusion of Foreign Materials."
II. The Quality Assurance Section will conduct an assessment of how Wisconsin Electric (WE) personnel control on-site contractors, with emphasis.placed on those contractors that are considered to be " prime" contractors on-site for
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,s-mechanical and' electrical inste.11ation and modification work on safety-related systems.
The assessment'will include:
a.
A review of how WE personnel interact, control, and monitor activities of contractors-including both the-contractor liaison and site QA oversight functions, b.
A comparison to how these activities are-performed at' other utilities in NRC Region III.
c.
An audit of the QA programs for the prime mechanical and electrical on-site contractor. organizations.
d.
An assessment of any overlaps or discrepancies between the'QA programmatic controls of these contractor organizations and the WE QA-program.-
The results of these activities will be presented-to department management will by March 1, 1993.. Written reports to management will follow within approximately 30 days.
III.
In order to validate the results of the assessment described above, a performance-based surveillance of various activities performed by on-site contractors will be conducted during the spring 1993 Unit i refueling outage.
Emphasis will be placed on. issues-and-discrepancies noted during the assessment to validate the recommendations from.the assessment-and to identify new issues that also need to be addressed.
This~ surveillance will be completed byfJune 1, 1993.
4.
DATE OF FULL COMPLIANCE Compliance was achieved with the full-implementation of the foreign material intrusion controls of PBNP 3.4.25 on.
December 31, 1992. ' Activities to address the on-site control of' contractor activities will continue, with expected implementation of'any. identified improvements by the end of-1993.-
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