ML20138Q537
| ML20138Q537 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 03/03/1997 |
| From: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Patulski S WISCONSIN ELECTRIC POWER CO. |
| References | |
| EA-97-089, EA-97-89, NOED-97-3-001, NOED-97-3-1, NUDOCS 9703060423 | |
| Download: ML20138Q537 (6) | |
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ij March 3, 1997 h
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Mr. S. A. Petuiski, Site Vice President Point Beach Nuclear Plant 6610 Nuclear Road l
Two Rivers, Wisconsin 54241
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SUBJECT:
NOTICE OF ENFORCEMENT DISCRETION FOR WISCONSIN ELECTRIC l
POWER COMPANY, REGARDING POINT BEACH NUCLEAR PLANT, UNIT 1 l
(EA 97-089, NOED NO. 97-3-001) l
Dear Mr. Patuiski:
By letter dated February 20,1997, Point Beach staff requested that the NRC exercise discretion not to enforce compliance with the actions required in Technical Specifications (TSs) 15.3.3.C.2 and 15.3.3.D.2 to allow Point Beach Unit 1 to remain in a hot shutdown condition. TS 15.3.3.C.2 requires that during power operation, an inoperable component cooling water (CCW) pump must be restored to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If this cannot be satisfied, the reactor shall be placed in the hot shutdown condition. If the pump cannot be restored to an operable status within an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the reactor shall be placed in cold shutdown.
TS 15.3.3.D.2 requires that during power operation, an inoperable service water (SW) pump must be restored to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If this cannot be satisfied, both reactors shall be placed in the hot shutdown condition within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in cold shutdown within the following 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
Because of the inoperability of a SW pump and a Unit 1 CCW pump which would have required Unit 1 to have been in cold shutdown by 3:58 a.m. and 4:00 p.m. (CST) on February 20,1997, respectively, Point Beach staff requested enforcement discretion to allow Unit 1 to remain in hot shutdown until 12:00 p.m. (CST) on February 21,1997.
This request was to allow time to return the inoperable CCW pump to service. If the CCW pump was returned to service prior to returning the SW pump to service or if the enforcement discretion time ran out prior to retuming the CCW pump to service, Unit 1 would then be taken to cold shutdown within 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> of returning the CCW pump to service or 12:00 p.m. (CST) on February 21,1997, whichever came first.
The February 20,1997, letter documented information previously discussed by Point Beach management with the NRC in telephone conversations during the afternoon and evening (between approximately 4:00 p.m. and 7:00 p.m.) of February 19,1997. Point Beach mana9ement stated during those conversations that Point Beach Unit 1 was in hot shutdown in accordance with TSs, due to inoperability of both a SW and CCW pump.
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9703060423 970303 PDR ADOCK 05000266 P
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S. Patulski i Further, your staff requested that a Notice of Enforcement Discretion (NOED) be issued pursuant to the NRC's policy regarding exercise of discretion for an operating facility, set out in Section Vll.C of the " General Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600. You requested that the NOED be effective immediately and remain in force until 12:00 p.m. (CST) on February 21, 1997, as described above.
The rationale for requesting the NOED was based on the belief that maintaining Unit 1 above cold shutdown temperatures, pending repairs of the CCW pump, would reduce shutdown risk and provide an overall safety benefit. Should the plant be taken to cold shutdown, your staff indicated that the two required redundant means available for decay heat removal during the time the NOED was requested were a loop of the residual heat removal (RHR) system and forced circulation via a loop of the reactor coolant system (RCS) and its steam generator. Loss of the remaining CCW pump would have resulted in the loss of both of these means of decay heat removal. Should this occur during cold shutdown, the RCS would be water solid and an uncontrolled heat up of the RCS would have to occur before controlled, natural circulation cooling via the Geam generators could be established. This condition could result in a pressure excursion challenging the power operated relief valves used as low temperature overpressure protection (LTOP). Should loss of the remaining CCW pump occur while remaining in hot shutdown with RCS pressure controlled by the pressurizer bubble, operators could more effectively establish immediate natural circulation cooling via the steam generators without the initial uncontrolled plant heat up under RCS water solid conditions.
Your staff also discussed that station voltage was subject to greater variation because,in addition to Unit 1 being out of service, both Point Beach Unit 2 and Kewaunee Nuclear Plant were in refueling outages. Your staff was concerned that the available RCS pump might trip on low voltage as a result of the pump's load increasing because of the increased density of cooler water, potentially reducing station bus voltage to the RCS pump's undervoltage setpoint.
Further, Point Beach staff pointed out that by staying above cold shutdown temperatures, safety systems, including safety injection, safety injection accumulators, and the steam driven auxiliary feedwater pump, would be available to mitigate the consequences of an accident.
As compensatory measures, your staff (1) performed evaluations that reportedly demonstrated that the five remaining SW pumps were capab!e of cooling required loads, (2) verified that non-essential service water loads were isolated and tagged, (3) reviewed procedures and walked down systems to assure the capability to cross connect the Unit 1 and Unit 2 CCW systems, and (4) tested the gas turbine-generator (G-05).
We considered the site grid voltage stability issue and the rationale for requesting not to place Unit 1 in cold shutdown under the circumstences described above. In addition, we considered the compensatory measures taken to ensure that the available SW pumps could perform the intended functions, and that the operable Unit 2 CCW system was available to cross connect with the Unit 1 CCW system if the remaining Unit 1 CCW pump should fail.
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S. Patuiski l We concluded that remaining above cold shutdown temperatures for a limited time to allow repair of the inoperable CCW pump would reduce shutdown risk by avoiding a potential uncontrolled RCS heatup should the remaining CCW pump fail during repair of the inoperable pump while in cold shutdown. Based on this, the NOED was granted at j
approximately 6:30 p.m. (CST) on February 19,1997, under Criteria 2 of Part 9900, NUREG-1600, to reduce shutdown risk by avoiding placing Unit 1 in a condition l
inappropriate for the means of decay neat removal that were available, in that it would not provide an overall safety benefit.
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On February 21,1997, at 2:00 p.m. (CST), after the NOED had been granted, your staff notified the NRC that it was unlikely that the CCW pump would be restored to servico prior to 12:00 p.m. on February 21,1997, the deadline for the NOED. This was due to leakage from the seal housing gasket of the Unit 2 CCW pump newly installed in place of l
the inoperable Unit 1 CCW pump. Your staff requested a 36-hour extension of the NOED based on the same rationale provided in your February 20,1997, letter.
We again considered the existing site grid voltage stability issue and the rationale for 5
2 requesting not to place Unit 1 in cold shutdown. We also discussed with your staff the l
compensatory measure concerning the availability of the cross-cormect with the Unit 2
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CCW system should the remaining Unit 1 CCW pump fail. We learned that the information i
Point Beach staff provided on February 19,1997, may have been misleading because the j
ability to cross connect the CCW systems was questionable due to poor cross-connect l
valve materiel condition. We have referred this potential failure to provide complete and accurate information to the NRC Office of Investigations for further review.
Based on the above considerations and discussions, we concluded grid voltage was more stable during weekends and the Unit 2 CCW cross-connect to Unit 1 was possibly not j
available. As a result, we dec! ned the request for a 36-hour extension of the NOED. We informed your staff of this decision around 7:10 p.m. (CST), on Friday, February 21.
Subsequently, the CCW pump was retumed to service and Unit 1 entered cold shutdown j
on Saturday, February 22, around 5:00 a.m.
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On the basis of our evaluation of the requests, we concluded that an NOED was warranted l
for the time frame described in the February 20,1997, letter, because we were clearly l
satisfied that this action involved minimal or no safety impact and had no adverse l
radiological impact on public health and safety. Therefore, we exercised discretion not to l
enforce compliance with TSs 15.3.3.C.2 and 15.3.3.D.2 from February 19,6:30 p.m.
(CST), until February 21,12:00 p.m. The request for the 36-hour extension of this NOED j
was denied.
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S. Patuiski This letter documents our telephone conversations during the afternoon and evening (between approximately 4:00 p.m. and 7:00 p.m.) of February 19,1997, when we orally i
issued the NOED, and during the afternoon and evening (between approximately 2:00 p.m.
j and 7:10 p.m.) of February 21,1997, when we denied the request for a 36-hour extension of the NOED. As stated in the Enforcement Policy, action will normally be taken, to the extent that violations were involved, for the root cause that led to the noncompliance for which this NOED was necessary.
Sincerely, 4
/s/A. Bill Beach A. Bill Beach Regional Administrator i
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Docket No. 50-266 Docket No. 50-301 4
cc:
R. R. Grigg, President and Chief i
Operating Officer, WEPCO A. J. Cayia, Plant Manager Virgil Kanable, Chief, Boiler Section Cheryl L. Parrino, Chairman Wisconsin Public Service Comm.
State Liaison Officer 1
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pistribution:
Docket File i
SRI Point Beach A. B. Beach, Rill Rlli Enf. Coordinator W. L. Axelson, Rlli Project Manager, NRR DRP RlliPRR DRS (3)
PUBLIC TSS PDill-3 R/F J. Caldwell, Rlli G. Hill (2 cys)
J. Lieberman, OE S. Collins /F. Miraglia, NRR E. Adensam, NRR C. Grimes, NRR G. Marcus, NRR ACRS DEDR & DRPE TA R. Zimmerman, NRR W. Long, NRR A. Thadani, NRR J. Roe, NRR J. Goldberg, OGC EMail - NOED TGD-DOCUMENT NAME:A:\\NE97-3-001.wp5
- See previous concurrence g r.e.s.. c.,y.e sni. e.e-.t. i.aie.t. in sn. no. -c - c.,, wit % t.it.en/..ei c - c.,y. ism.it.en/ ci n-0FFICE RIII C
RIII C
RIII A/
C-RIdl NAME KundskI/bs JMcB/AN/A1 G[otkdaldwell Adhach
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DATE 2/2 7/97 2/A7/97 2/M/97 2/E/97 0FFICIAL RECORD CDPY
a S. A. Patulski This letter documents our telephone conversations during the afternoon and evening (between approximately 4:00 p.m. and 7:00 p.m.) of February 19,1997, when we orally issued this NOED, and during the afternoon and evening (between approximately 2:00 p.m. and 7:10 p.m.) of February 21,1997, when we denied your request for a 36-hour extension of the NOED. However, as stated in the Enforcement Policy, action will normally be taken, to the extent that violations were involved, for the root cause that led to the noncompliance for which this NOED was necessary.
Sincerely, A. Bill Beach Regional Administrator Docket No. 50-266 Docket No. 50-301 cc w/ encl:
R. R. Grigg, President and Chief Operating Officer, WEPCO A. J. Cayia, Plant Manager Virgil Kanable, Chief, Boiler Section Cheryl L. Parrino, Chairman Wisconsin Public Service Commission State Liaison Officer (See attached continued distribution)
Document: P:\\NE97-3-001.wp5 To receive a copy of this document, indicate in the box "C" = Copy without attachlenci "E" = Copy with attach /enci "N" = No copy OFFICE Rill C
Rill C-Rlli, y Rlli NAME Kunowski hA f -
McBffAN/A Gh:aldwell Beach DATE 02/Y,/97 02/497 02dI97 02/ /97 OFFICIAL RECORD COPY
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