ML20199F136
| ML20199F136 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 12/22/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20199F126 | List: |
| References | |
| 50-266-97-21, 50-301-97-21, NUDOCS 9802030069 | |
| Download: ML20199F136 (27) | |
See also: IR 05000266/1997021
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U.S. NUCLEAR REGULATORY COMMISSION
REGION lli
Docket Nos.: 50 266, 50 301
Report No: 50-266/97021(DRP): 50 301/97021(DRP)
Licensee: Wisconsin Electric Power Company
Facility: Point Beach Nuclear Plant, Units 1 & 2
Location: 6612 Nuclear Road
Two Rivers, WI 54241 9516
Dates: October 21 through November 30,1997
Inspectors: F, Brown, Senior Resident inspector
A. McMurtray, Senior Resident inspector
P. Louden, Resident Inspector
Approved by: J. W. McCormick Barger, Chief
Reactor Projects Branch 7
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9902030069 971222
PDR ADOCK 05000266
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EXECUTIVE SUMMARY
Point Beach Nuclear Plant, Units 1 and 2
NRC Inspection Report No. 50 266/97021(DRP); 50-301/97021(DRP)
This inspection included aspects of licensee operations, engineering, maintenance, and
plant support. The report covt,rs a 6 week inspection period by the resident inspectors.
Operations
- Good command and control, deliberate conduct of operations, and good procedure
adherence were observed during the shutdown of Unit 2 and the startup of Unit 1.
(Section 01.1)
- The facility was operated in a safe manner with a strong safety focus and generally
conservative operational decisions. Two notable examples were the decision to
promptly shut down Unit 2 when reactor protection instrumentation test problems
could not be resolved within the allowed time and the decision to delay the startup of
Unit 1 while a nuclear instrument detector was repaired. (Section 01.2)
- Prior to unit restart, the inspectors determined that Unit 1 containment cleanliness
was sufficient to prevent immediate safety concerns; however, the inspectors
identified several items, including loose electrical tape, which should not have been
present. (Section 02.1)
- The licensee had taken adequate measures to ensure those safety systems
susceptible to freezing during the winter months were protected. Also, the licensee
had taken acceptable actions in addressing concerns with the facade freeze
protection system discussed in a previous inspection report. (Section 02.2) 4
The licensee identified and corrected three examples of the use of inappropriate
procedures. The need for numerous other procedure changes was identified by
operators prior to the use of inappropriate procedures. Despite these problems with
procedure development and review, the inspectors considered the use of procedures
in Operations to be good. This strong performance was based, in part, on
Operations Department initiatives to ensure that all required procedures were
performed as written, to ensure that activities requiring procedures were performed
using procedures rather than work plans, and to provide mentors who reinforced the
need for procedural control of activities affecting quality. (Section 03.1)
- Most component cooling water (CCW) syntem normal, abnormal and emergency
operating procedures were considered appropriate, but the inspectors identified a
weakness with the failure of the emergency operating procedure to provide positive
isolation of nonsafety related CCW flow paths during the containment sump
recirculation phase of accident mitigation. This procedure weakness was considered
one aspect of a iest control violation. (Section 03.2)
Operator knowledge of the CCW system and its operation was good Reactor
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operators were familiar with the CCW system status and the cause for CCW system
annunciators. (Sections 04 & 05)
- The quality assurance organization's identification and documentation of findings
improved significantly as the result of self critical program level arsessments
performed by the licensee. A self assessment performed by Quality Assurance
during this report period noted improvement in some areas but identified the need for
improvement in other areas. The inspectors considered the improvements and the
thorought.ess of the current self assessment to be positives. New performance
indicators for corrective action backlogs were implemented, but prioritization of
condition reports within each organization's backlog was of concern to plant
management and the inspectors. (Section 07.1, applicable to all functional areas)
- The licensee committed to develop an Annual Plan which prioritized high-level
improvement initiatives and commitments to the NRC. This will provide a means for
licensee management to track the status of the improvement initiatives. (Section X2,
applicable to all functional areas)
Maintenance
No problems were noted during observations of maintenance and surveillance
activities involving the Unit 1 feedwater isolation feature and the auxiliary feedwater,
safety injection, and residual heat removal systems. (Section M1.1)
- An inadequately controlled modification performed in December 1996 defeated the
Unit 1 containment upper hatch interlock system. This caused a Technical
Specification violation when the required compensatory actions were not
implemented. No instances were identified where containment integrity had been
degraded during the interlock system inoperability. (Section M2.1)
Maintenance supervision effectively responded to problems with maintenance
procedures for the CCW pump and motor repairs, inadequacies in the work scoping
process and insufficient lead time following procedure development con'ributed to
the procedure problems. (Section M3.1)
Enaineerina
- The inspectors independently identified that CCW system testing had not
demonstrated the system's ability to provide its safety-related function when
instrument inaccuracies and potential accident condition system lineups were
considered. The inspectors also determined that four licensee operability
determinations for these problems generated between December 1996 and
November 1997, were inadequate. The licensee developed an adequate operability
determination after the inspectors brought this issue to the attention of plant
management. Two violations were identified. (Section E1.1)
A system engineer identified the potential for an unreviewed safety question if a test
of spare ventilation equipment, committed to in a Licensee Event Report, was
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performed at power. This identification was the result of a comprehensive and .
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thorough review of the proposed test by the system engineer. (Section E2.1)
Plant Support
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The radiological housekeeping within the P mary Auxiliary Building was good.
(Section R1)
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8tport Details
Summarv of Plant Status
Unit 2 was at full power and Unit 1 was in an extended outage at the start of the inspection
perled. Tw: unit operation was precluded due to previously identified concems with the
auxiliary feedwater system. Unit 2 was shutdown on November 15,1997, after the licensee
identified that complete testing of reactor protection system instrumentation and control
circuitry had not been completed as required by T/Ss. Unit i startup was underway at the
end of the Inspection period.
Inspection Focus
During this inspection period, the inspectors integrated a vertical slice review of the
component cooling water (CCW) system into the routine inspection of the Operations,
Engineering, and Maintenance functional areas,
l. Operations
01 Conduct of Operations
01.1 Shutdown and Startuo Activities
a. Insoection Scope (Inspection Procedure (IP) 71707)
The inspectors observed the T/S-required shutdown of Unit 2 on November 15,
1997, and the startup of Unit 1 which began November 21,1997, and was
completed November 30,1997.
b. Observations and Findinas
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Shutdown of Unit 2
During a review of NRC Generic Lette- N 01," Testing of Safety Related Logic
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Circuits," licensee engineering staff k wiled that multiple permissive logic circuitry
had not been tested in accordance v - T/S requirements. Technical Specification
Table 15.4.11 Item 45 identifies these permissives and the required f4quency of
testing (every refueling outage). The engineering review identified that these
combination logic tests had not been performed and a Condition Report (CR) 97-
3786, dated November 14,1997, was written.
A 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> delay was allowed by T/Ss to accomplish the missed surveillance, but the
licensee determined that an acceptable procedure likely could not be written,
approved, and implemented within the 24-hour time limit Consequently, the
Ucensee decided at 11:30 a.m. on November 15 to shut down the unit.
Once the decision was made to shut down, the T/S action statement of Table 15.3.5-
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2 went into effect, requiring the unit to be in Hot Shutdown within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The
licensee subsequently provided an event notification to the NRC Operations Office at
1:25 p.m. in accordance with 10 CFR 50.72(b)(1)(1)(A) and (b)(2)(iii)(A).
The inspectors observed the Manager's Supervisory Staff (onsite review committee)
meetings which led to the decision to shut down Unit 2, and noted that senior plant
management consistently queried plant staff to ensure that they were not pressing
too hard for a desired result and being too production focused. The inspectors
concluded that the decision to shutdown Unit 2 was conservative and appropriate for
the situation.
The inspecturs observed control room activities during the shutdown of the Unit 2
reactor. The shutdown was methodically conducted, and control room command
and control was adequate. Ono delay in the direct shutting down of the unit
occurred during the testing of the Unit 2 main steam isolation valves (MSIVs).
Operations elected to perform the non required test to gather information for
engineering trending. During the shutdown, just prior to starting the test, a control
(reactor) operator noted that an initial condition for the test was that the reactor be
between 2 percent and 5 percent power. The reactor at the time was at about 1.5
percent. Operations department supervision decided to increase reactor power to
within the band indicated in the procedure and continue with the test. Other minor
delays occurred during the testing of the 'A' MSIV. The result of these test
decisions led to the reactor reacning hot shutdown status at 7:00 p.m. on November
15,1997,30 minutes prior to the required limit and 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> later th:n had the testing
not been conducted.
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Startuo of Unit 1
The inspectors performed extensive control room observations during the startup of
Unit 1. Good use of procedures and good command and control were noted. No
negative observations were identified.
c. Conclusions
Good command and control, deliberate conduct of operations, and good procedure
adherence were observed during the shutdown of Unit 2 and the startup of Unit 1.
01.2 Safety Focus in Operational Decision Makina
a. Inspection Scope
The inspectors monitored operation of the facility to assess whether an appropriate
safety focus was maintained.
b. Observations and Findinai
The inspectors observed an appropriate safety focus in the operation of the facility,
most notably in the decision to promptly shut down Unit 2 when it was determined
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that the instrumentation test problems discussed in Section 01.1 could not be
resolved, within the allowed time, to plant management's satisfaction. The deelslon
to delay startup while an intermediate range nuclear instrumentation detector was
repaired was another example of conservative decision making, in that the T/3
allowed startup with only one operable detector.
Four examples of operational decisions which were not consistent with the normally
strong safety focus were noted by the inspectors. None of these decisions had a
direct impact on the safe operation of the facility. Multiple equipment failures or
human errors would have been required while these decisions were in effect for
there to have been an impact on the safe operation of the facility,
The first decision was to perform the MSIV maintenance diagnostic test during a T/S
required shutdown, which resulted in the unit remaining critical approximately an
hour longer than necessary (as discussed in Section 01.1). Following this
shutdown, the operations manager directed that a new procedure be written to
ensure that T/S required shutdowns were not delayed by the performance of optional
testing.
The second decision involved restart of Unit 1 with an inoperable upper containment
personnel hatch interlock. While allowed by the T/Ss, this decision resulted in
reliance on manual action rather than automatic action to prevent defeat of the
personnel hatch should use of the hatch be required during an emergency. A new
procedure was written to help ensure proper operation of the hatch.
The third decision involved performing repairs to Unit 1 control room annunciators.
Shortly before pressurizing and heating up the plant, plant staff identified that an
outage of annunciator panel 10-03 would be required to repair a degraded resistor.
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The outage removed 122 annunciator windows from service. The required repair
could have been performed prior to exiting cold shutdown conditions, but it was nnt.
The licensee established appropriate administrative controls for the annunciator
outage. The inspectors observed the outage, which lasted approximately 1% hours,-
and did not note any performance problems.
The fourth decision involved relying on an analysis to demonstrate Unit 1 CCW
system operability rather than performing a test to confirm proper system alignment
and operation. This issue is discussed in more detail in E1.1.
b. Conclusions
The facility was operated in a safe mannei with a strong safety focus and generally
conservative operational decisions.
02 Operational Status of Facilities and Equipment
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a. Inspection Scope
The inspectors performed a walkdown of the Unit 1 containment. This walkdown
was performed after licensee management's containment walkdown but prior to final
containment closeout.
b. Observations and Findinat
The inspectors verified that equipment stored in containment was appropriately
secured. The general cleanliness of the containment was considered to be
acceptable in that no immediate or direct challenges to safety related systems or
components were observed; however, the inspectors found and removed several
pieces of loose tape, a broken stay tie, an aerosol can cap, a radiological posting, a
bottle of leak detection fluid, and some other miscellaneous trash. The total volume
and surface area of the removed items was insignificant compared to the available
surface area of the emergency core cooling system sump recirculation strainers.
The inspectors also noted two pieces of modular reflective insulation unsecured
within the *B" reactor coolant pump (RCP) cubicle, a spare valve protector for a
portable nitrogen bottle, and about twenty pieces of electrical tape dangling from
electrica: conductors on the containment polar crane. The inspectors informed the
licensee of these observations, and the observed items were subsequently removea
from the containment by licensee staff .nrior to final containment closeoui. The
electrical tape removed from the polar crane was characterized as being quite old
and degraded.
c. Conclusistni
The inspectors determined that Unit 1 containment cleanliness was sufficient to
prevent immediate 6afety concems; however, the inspectors identified several items,
including loose electrical tape, which should not have been present.
02.2 Cold Weather Preparations
a. insoection Scoco flP 71714)
The inspectors reviewed the implementation of the licensee's cold weather
preparations and freeze protection program for safety-related systems.
b. Observations ansi Findinos
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The inspectors reviewed the licensee's completed surveillances for cold weather
preparations and performed independent verification checks of selected cold weather
protection equipment. No problems were identified.
During a previous inspection ' Inspection Report No. 50-266/97003(DRP);
50 301/97003(DRP)), the inspectors identified concerns with the material condition of
the facade freeze protection system and with work orders not receiving the
appropriate priority to ensure completion before the onset of cold weather. An
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additional concern involved the uncontrolled use of heat lamps in the facades to
alleviate freeze protection circuitry problems in heat traced lines.
The inspectors reviewed the licensee's response to these concerns and noted that a
facade freeze protection improvement initiative was started in June of 1997. The
maintenance backlog reduction group was given the task to address the freeze
protection circuitry problems. The major problem involved the functional quality of
the existing heat tracing coils. To address this problem, new heat tracing wiring and
leads were installed on much of the facade piping. At the conclusion of the
inspection period, about 90 percent of the new heat tracing had been installed in the
facade systems requiring heat tracing. The remaining 10 percent was scheduled to
be completed within the next few weeks. The inspectors concluded that the licensee
had made acceptable efforts to restore the facade freeze protection system to a
reliable functioning status.
During this inspection, no heat lamps were in place within the facades and
operations department management implemented the use of the station's temporary
information tag or temporary modification programs as the formal means to track
heat lamp usage. Also during this inspection period, an NRC Maintenance Rule
Inspection Team identified the failure to consider the facade freeze
protection system to be within the scope of the Maintenance Rule (see
Inspection Report No. 50 266/97025(DRS); 50 301/97025(DRS)).
c. Conclusions
The licensee had ta'Kon adequate measure to ensure that safety systems susceptible
to freezing were protected during the wir ter months. Actions taken to address
previous concerns with facade freeze protection system were also acceptable.
03 Operations Procedures and Documentation
03.1 Use of Procedures in the Operations Department
a. Ln.ipection
n Scoce
The inspectors monitoled the facility's control and use of proceduret to ensure
compliance with NRC regulations and the T/Ss, and to ensure that activities affecting
quality were appropriately planned and executed.
b. Observations and Findinas_
The inspectors observed good use of procedures by operators in the control room
and in the plant. Procedures which could not be performed as written were
corrected prior to performance of work: however, the large number of required
procedure changes was indicative of the poor past practices regarding procedure
development and use.
Proactive lmorovements in Ooerations Procedures and Usagg
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The inspectors discussed the improved procedure usage with tne operations
manager who informed the inspectors of two initiatives within the operations
department. The inspectors considered these initiatives to be significant. The first
initiative involved the reclassification of all operations procedures as ' Continuous
Use." This classification dealt with a reported mind set among operators that non.
continuous use procedures did not need to be performed as written. The inspectors
discussed this mind set with the Regulatory Services and Licensing Manager, who
acknowledged that the failure to perform any required procedure as written, unless
authorized by 10 CFR 50.54(x), was inconsistent with NRC requirements ar.d the
licensee's Nuclear Power Business Unit, Procedure 1.1.2, *Procedurs Use and
Adherence." The second initiative involved the conversion of all repetitive use
operations work plans to procedures. This initiative reduced the possibility that a
work plan would be used to perform activities that the T/Ss required in be
procedurally controlled. The inspectors will monitor the effectiveness of these
operations department initiatives and the use of procedures by other departments
under the previously opened inspection follow up item (IFI) 50 266/97020-02(DRP);
50 301/97020-02(DRP).
The inspectors also observed positive examples of another operations department
significant initiative. The experienced contractors mentoring operators in the control
room were observed to coach plant staff to ensure that activities affecting quality,
such as troubleshooting a failed control rod drive logic card, were planned and
controlled using approved procedures.
, inadeauste Procedure Reviews
An operator initiated CR 97 3877 on November 17,1997, to document an
inadequacy in Surveillance Procedure TS 30," Low Head Safety injection Check
Valve Leakage Test (Cold Shutdown)," Revision 16. Specifically, the procedure
directed that containment isolation valves be opened, while containment integrity was
in effect, without establishing the appropriate compensatory control of having a
dedicated operator stationed at the valve. Another operator initiated CR 97-3870 on
November 23,1997, to document an inadequacy with In service Test (IT) 300,
- Feedwater Leakage Check Test Line Valve," Revision 10. This procedure also
directed that a containment isolation valve be opened without specifying the use of a
dedicated operator. On both of these occasions, the involved operators identified the
procedure errors after the valves were opened but before T/S containment integrity
requirements were violated. Work was stopped, the containment isolation valves
were shut, and the procedures were corrected.
The low temperature overpressure protection (LTOP) system actuated on October
23,1997, when operators started the Unit 1 "A" RCP using Operating Procedure
(OP) 4A, * Filling and Venting Reactor Coolent System,' Revision 44, and OP 48,
" Reactor Coolant Pump Operation," Revision 33. This RCP start was unusual in that
it was part of a fill-and vent evolution but the primary system was solid with little
entrained gas. The operating crew anticipated rapid pressure swings when the
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) pump was started, so the control operator made large and rapid changes to the
chcmical and volume control system (CVCS) letdown and charging controls.
Because of the lack of entrained gas in the primary system, the system induced
pressure transient was insignificant. The manipulation of the CVCS controls resulted
in en overfilling transient which was terminated by the operator's actions and the
LTOP a:tuation. The October 23,1997, LTOP event was the second time that a
RCP had been started during fill and venting of a solid, de-gassed primary system.
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. A subsecor't review of data from the first time evolution, in September 1997,
indicateu that an LTOP actJallon had nearly occurred on that occaslon. Procedure
OP 4B I;ad been changed on August 2,1997, to cover stav. . 4 RCPs in the
condtions cescribed above, but this change had not established controls or
cor.Wed cautions for the operato,s to prevent the LTOP actuation. Planned
corre.;tive action 6 for the latest event includes additional crew training and revision of
the procedures.
The inspectors concluded that the inadequate procedures described above were not
indicative of a repetitive problem because of the large number of new procedures
and revised procedures which were implemented during this inspection period. The
licensee identified and corrected, non-repetitive inadequacies in IT 300, TS 30, and
OP 48 are considered to be examples of a non-citeo violation
(NCV 5F266/97021-01(DRP); 50 301/9702101(DRP)). In recent insoection periods,
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the insp;,ctors had noted that operators were being relied upon to catch procedure
errors which should have been corrected during procedure preparation and review.
The events described above indicate the risk associated with continued reliance on
operators to catch procedure problems. The effectiveness of the initiatives to
improve procedures and procedure reviews so that less burden is placed on
opMators will be monitored under the previously opened IFl 50 266/97020-02(DRP);
50-301/97020 02(DRP),
c. Conclusions
The licensee identified and corrected three examples of the use of inappropriate
procedures. The need for numerous other procedure changes was identified by
operators prior to the use of the procedures. Despite these problems with procedure
development and review, the inspectors considered the use of procedures in
operations to be good. This strong performance was based, in part, on operations
department initiatives to clarify that all required procedures were to be performed as
written, to ensure that activities requiring procedures were performed using
procedures rather than work plans, and to provide mentors who reinforced the need
for procedural control of activities affecting quality.
03.2 Comoonent Coolina Water Procedures
a, bsDection ScoDe
The inspectors reviewed normal, abnormal, and emergency operating procedures
for the CCW system.
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b. Observations and Findinos
The inspectors reviewed OP 6A, * Operation of Component Cooling System,"
Revision 21, and Check List 6A, * Component Cooling, Unit 1,* Revision 22, and did
not identify any signincant issues. The inspectors also reviewed Abnormal Operating
Procedure (AOP) 98, Unit 1,' Component Cooling System Malfunction," Revision 9,
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and only identified one potential concern. Specifically, Step 6 directed that the CCW
surge tank vent valve, CC.17, be opened if the CCW surge tank level was trending
lower. Valve CC.17 must be closed (closed system outside of containment) to
maintain containment integrity because there are not two containment isolation
valves in the CCW system. The inspectors were concerned that operators
implementing AOP 9B could overlook the impact of opening CC.17 under the stress
of responding to a CCW system failure. The inspectors detennined that this issue
did not make AOP 9B inadequate, but discussed the concern with the procedure and
tho basic system configuration limitations which affected the procedure, with licensee
tranagement.
The inspectors reviewed Emergency Operating Procedure (EOP) 0.0, *Redlagnosis,"
Revision 5, and EOP 1.3, " Transfer to Containment Sump Recirculation," Revision
15 to determine whether the CCW system was adequately described and controlled.
The inspectors did not identify any concerns with EOP 0.0. However, the inspectors
identified that Step 9, * Establish Desired Component Cooling Lineup," of EOP 1.3 did
not establish the same system lineup described in the operability determination (OD)
for CR 96-416 (see Section E1.1). Specifically, the inspectors identified that the
CVCS seal water heat exchanger and the waste gas compressors were not isolated
by EOP 1.3 but were not considered as flow paths in the OD. The site system
engineers wrote CR 97 3754 and an associated OD to document and address this
inspector-identified issue (Section E1.1). The inspectors also identified that EOP
1.3, Step 9e, directed that CCW flow to the CVCS non-regenerative heat exchanger
be isolated by closing valve 1(2)CC 130 using its pneumatic actuator controller
1(2)HC 130. The inspectors noted that 1(2)CC-130 was a fall-open butterfly valve
and that its pneumatic actuPor was nonsafety related. The inspectors also noted
that there was no direct control board indication of the position status of 1(2)CC-130
or direct indication of CCW flow through the CVCS non regenerative heat exchanger.
The only available indication for an operator to use in determining whether use of the
pneumatic actuator had achieved the desired results was the CCW system total flow
indicator. The inspectors noted that no quantitative value for flow change as a result
of successful closure of 1(2)CC 130 under accident conditions was available to the
operators, and flow changes in the CCW system from completion of Steps 9c
(placing a residual heat removal (RHR) heat exchanger in service), 9d (isolating
CCW loads in containment), and paraiset performance by an auxiliary building
operator of iso!ating a boric acid evaporator (Attachment A of EOP 1.3) could mask
the effect of Step 9e. Additionally, if the nonsafety related actuator were to fall open
after completion of Step 9e, there would be no direct indication of CCW system flow
diversion from safety related loads.
The inspectors reviewed the CCW system test procedures and ODs, and concluded
that the effect of CCW flow diversion through the non regenerative heat exchangers
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was not evaluated or bounded, and had the potential to directly affect the mitigation
of a design basis loss of coolant accident. The non regenerative heat exchanger
Isolation valve,1(2)CC 7408, was used during performance of CCW system tests to
serve the function covered by EOP 13, Step 9e. The weaknesses in controlling _
CCW system configuration during accident conditions was a contributing aspect of
the test control inadequacies described in Section E1.1.
c. Csnelusions
Most CCW system normal, abnormal and emergency operating procedures were
considered appropriate,- but the inspectors identified weaknesses associated with the
failure of the EOP to provide for positive isolation of nonsafety related CCW flow
paths during the containment sump recirculation phase of accident mitigation.
04 Operator Knowledge and Performance
The inspectors interviewed several licensed and non licensed operators regarding
the function, design, component makeup, and system interrelationships of the CCW
system. All opemtors interviewed displayed a solid fundamental understanding of
the system and its overall purposes. Control room operators were familiar with the
cause of alllit CCW system annunciators and accurately explained all system
Indications discussed with the inspectors.
05 Operator Training and Qualifications
The inspectors reviewed Training Handbook 10,9," Primary Systems Descriptions:
Component Cooling System," Revision 4, and found it to be informative and
accurate. Some of the non licensed operators stated during interviews with the
inspectors that
improvements could be made regarding the depth of training they receive on system
interrelationships following initial operator qualifications.
07 Quality Assurance in Operations
07.1 Imorovements In the Licensee Quality Assurance Function (IP 40500)
a. Insoection Scope
The inspectors performed reviews of some licensee Quality Assurance (QA)
organization uudits, assessments, and CRs to determine the effectiveness of the QA
function,
b. Obseivations and Findinas
The licensee conducted three program-level assessments of the Point Beach QA
organization and function during the last 18 months. The most recent was
completed in April 1997, and two of the three assessments were conducted by
outside contractors. The assessments were critical of the organizational and
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functional performance, and consequently major organizational, personnel, and
staffing changes were implemented. The inspectors noted significant improvement
in the number and quality of QA findings following these changes. The most
important QA findings were classified as QA Program Significant issues, and were
tracked as separate high level priorities within the licensee work and improvement
prioritization process.
In addition, the QA orgnizetion performed a self assessment, S A 9719, dated
November 20,1997, of their performance in implementing corrective actions from the
program level assessments. This self assessment involved the participation of two
CA managers from other nuclear power plants. The self assessment acknowledged
the improvements noted by the inspectors, and also identified opportunities for
continued improvement, including better training and qualification of OA staff, more
consistent initiation of CRs, and more time for preparation for performance of audits.
One additional issue in "1e self assessment was that the QA Program Significant
Issues list was one of ma,iy priority lists in the prioritization process, and that this
fact led to uncertainty on the part of line managers as to relative significance (see
also Section X2 for discussion of work prioritization issues).
Another positive action observed during this report period was the development of
performance indicators for corrective action backlogs in the line organizations. This
action was undertaken to help focus management attention on the CR process. One
issue that was of concern to the inspectors was the lack of a programmatic process
for assigning work priorities within the CR backlog. Plant management had directed
individual line managers to ensure that CRs were worked in the order of safety
significance, but no process existed to evaluate performance in this stea,
c. Conclusions
Performance of the QA organization's identification and documentation of findings
improved significantly as the '. ssult of self critical, program-level assessments
performed by the licensee. A self assessment performed by QA during this report
period noted improvement but identified additional areas for improvement. The
inspectors considered the improvements and the thoroughness of the current self.
assessment to be positives.
New performance indicators for corrective action backlogs were implemented, but
prioritization of CRs within each organization's backlog was of concern to plant
management.
08 Miscellaneous Operations issues
08.1 [Qlgsed) IFl 50 266/97003-01(DRP): 50 301/97003-01(DRP): Miscellaneous
concerns regarding the facade freeze protection system. The inspectors' follow-up
review of these matters is discussed in Section O2.2 of this report. The inspectors'
original concerns were determined to be adequately addressed.
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OS.2 (Closed) Ucensee [ *nt Report (LER) 50 266/95005-00: Manual Reactor Trip
During Startup Physics Testing. On April 15,1995, control rod F-12 dropped into the
Unit 1 core during low power physics testing. Unit 1 was critical below the point of
adding heat at the time. During troubleshooting on April 16,1995, a second control
rod, E 11, dropped part way into the core when the control operator withdrew rods in
control bank A. When the second rod entered the core, the reactor went subcritical.
The duty shift superAor ordered the reactor manually tripped.
The licensee dete. ad that rod E 11 dropped because fuses pulled to facilitate
troubleshooting actN, des on rod F 12 were common to movable gripper coils of both
rods. After the manual reactor trip, troubleshooting activities on the F 12 rod
determined that the rod had dropped due to the failure of its stationary gripper coll.
The licensee initiated CR 95 255 for this event and performed Root Cause
Evaluation 9510 since human performance factors contributed to the partial drop of
E 11. The root cause evaluation determined that there was a miscommunication
between the instrument and control engineer coordinating F 12 troubleshooting
activities and the reactor engineer and control operator for Unit 1. The root cause
evaluation also determined that inadequate shift tumover and pre job briefs
contributed to this event.
The licensee replaced the failed stationary gripper coil stack and successfully tested
it prior to the subsequent restart of Unit 1. The licensee had an off site laboratory
analyze the failure mechanism of the failed stack. The laboratory determined that
the primary contributor to the coil failure was high temperv ' hat resulted from the
failure of a control rod drive motor shroud fan damper.1 censee repaired the
damper and shroud temperatures remained normal during Unit 1 operation.
Secondary contributors to the coil failure were aging and moisture / boric acid
intrusion. The licensee subsequently inspected the stationary gripper coil stacks for
Unit 1 and Unit 2. No problems were identified.
The inspectors reviewed the root cause evaluation, the CR, the laboratory report,
and F 12 troubleshooting, and coil stack replacement work plans. The inspectors
had no concerns with any of these activities. The inspectors also noted that recent
improvements in communications during reactivity maneuvers, shift tumovers, and
pre job briefs should prevent this event from occurring again. The inspectors had no
additional concerns with this issue.
II. Maintenance
M1 Conduct of Maintenance
M1.1 Te9s and Surveillances
NRC Inspection Procedures 62707 & 61726 were used in the inspection of plant
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maintenance and surveillance activities, The inspectors observed and reviewed
selected ponions of the following tests:
- In service Test Procedure 10A," Test of dectrically Driven Auxiliary Feed
Pumps and Valves With Flow to Unit 1 Steam Generators (Quarterly)?
Revision 1, conducted on November 26,1997.
- TS Test 45 "Feedwater Isolation Test From a Safety injection Signal Unit 1,"
Revision 0, conducted on November 14,1997.
- In service Test Procedure 530A,' Leakage Reduction and Preventive
Maintenance Program Test of the Train A High Head Safety injection and
Residual Heat Removal Systems Unit 1," Revision 2, conducted on November
26,1997.
The work performed under these activities was professional and thorough.
Technicians were experienced and knowledgeable of their assigned tasks. The work
packages were present at the job site and actively used by the technicians for all
work observed. System engineers were frequently observed monitoring job
progress.
M2 Maintenance and Material Condition of Facilities and Equipment
M2.1 . Containment Hatch Interlock inocerability
a. insoection Scope (IPs 62707 & 37551)
The inspectors reviewed the circumstances surrounding the licensee's identification
that a gear was missing from the Unit 1 containment upper personnel hatch interlock
mechanism. The inspectors also reviewed the results of the licensee's root cause
investigation into the matter,
b, Observatipns and Findinas
'
Maintenance workers identified that a gear was missing from the Unit 1 containment
upper hatch interlock mechanism while preparing to perform operational checks on
the hetch. Condition Report 97-3574 was written to address the defect and to note
that the absence of the gear inight defeat the interlock system. Licensee
management requested a root cause evaluation of the missing gear.
,
Licensee engineering staff verified through field tests that, with the gear missing, the
interlock system could be defeated if the normd lever manipulations for opening the
hatch doors were not followed. This condition was documented in CR 97-3756.
The licensee's root cause evaluation determined that the gear was removed on
December 28,1996, following an unsuccessful containment hatch leakage test. The
failure of the test was attributed to a bent remote operator shaft which was causing
damage to the quad ring seal. Removing the hatch interlock gear was intended to
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eliminate stresses on the seal ring caused by the bent shaft. Removal of the gear
was not recognized as being a temporary modification to the hatch interlock system;
therefore, the design control process was not used and the proper reviews and
approval of the gear removal were not obtained. The gear was removed under work
order 9614237. A station log entry referenced that the hatch was operable based on
a successful hatch leakage test performed following the removal of the gear. No
post maintenance testing of the hatch interleck was performed.
Unit 1 was at power between December 28,1990, and February 18,1997, with the
Unit 1 containment hatch interlock system inoperable. The failure to perform the
required compensatory actions was a Violation (VIO 50-266/97021-02(DRP);
50 301/97021-02(DRP)) of T/S 15.3.6.A.1.d.2. No instances were noted that
indicated that the containment ilitegrity for Unit 1 was degraded during this period,
c. Conclusions
The licensee inadvertently defeated the Unit 1 containment upper hatch interlock
system by removing a gear from the system without utilizing the appropriate design
control processes for work on safety related components. One T/S violation was
identified.
M2.2 Comoonent Cooling _ Water System Walkdowns and Material Con @gn
The inspectors conducted walkdowns 'the CCW system and saw no obvious
material condition problems. The inspectors also reviewed CRs for the CCW
system. Many of the CR's identified isolated problems or deficiencies. However,
one issue which was noted in several CRs was the unreliability of pressure
controllers and level transmitters in the system. The instruments had been
frequently found out of tolerance end presented calibration repeatability difficulties.
Another issue involved a several year old problem with fluctuations in the CCW
, surge tank level. There were several apnarent contributors to this level fluctuation,
but definitive corrective actions had not been taken. The inspectors concluded that
there was no safety consequence associated with the surge tank level fluctuations.
M2.3 Primarv Auxiliary Buildina (PAB) Boric Acid L.eaks
During tours of the PAB and the Unit 1 containment, the inspectors observed boric
acid build-up and numerous work order tags on several pieces of safety-related
equipment. Boric acid build-up was present on the mechanical seals for the safety
injection (SI) and RHR pumps and body-to-bonnet joints and packing for charging,
SI, and RHR valves. There were more work order tags and boric acid build up than
the inspectors had observed during previous tours of the PAB, but the inspectors
had no operability concerns. All observations were discussed with plant
management.
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M3 Maintenance Procedures and Documentation
M3.1 CCW Pumo Modification
a. Inspection Scope (IP 62707)
The inspectors reviewed the replacement of the Unit 1 CCW system *B" pump motor
and the overhaul of the pump impeller,
b. Observations and Findinas
The licensee pit.nned to replace the motor for the Unit 1 CCW *B* pump (due tc high
vibrations) with the spare pump motor maintained onsite to meet 10 CFR 50,
Appendix R requirements. Pump impeller overhauls were also planned to be
performed during the motor replacement.
After a couple of days of work, the job vlas stopped following requests by the job
leaders because the procedures being used were cumbersome to implement and
hard to follow. At one point prior to the work being stopped, maintenance workers
were referencing three procedures at one time. Maintenance management stopped
the work and immediately met with workers to more fully understand the problems
and establish a strategy to address the concerns prior to work recommencing.
The inspectors discussed the circumstances with maintenance personnel and
supervision and determined that the causes for the procedural problems leading to
the work stoppage included inadequate management guidance regarding the scope
of the work, and failure to provide enough lead time following procedural
development to allow for a thorough procedure review and walkdown.
,
Once the work was restarted, it was conducted smoothly and in a timely manner.
The inspectors noted that workers involved with the repairs exerdsed good craft
skills, housekeeping in the work area was tidy, and appropriate tools were used
during the repairs. However, there were inconsistencies in the manner by which
foreign material exclusion areas were established and controlled during the work
suggesting that the intent of the program and/or station procedures were not clearly
understood by the workforce.
c. Conclusions
The inspectors concluded that maintenance supervision effectively responded to
problems encountered by workers during the CCW pump and motor repairs.
Inadequacies in work scoping and insufficient lead time following procedure
devebpment caused the problems.
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E1 Conduct of Engineering
E1.1 CCW System Testina Inadecuacies
a. Inspection Scope UP 3755.)
The inspectors reviewed the CCW system test and surveillance procedures to
ensure that the system was tested in a manner which ensured that design basis
requirements would be met under postulated accident conditions and configurations.
b. Qblervations and Findinas
The inspectors found that identifying design bases requirements for the CCW system
was difficult. The T/Ss did not contain any quantitative requirements for the system.
The Final Safety Analysis Report (FSAR) provided adequate discussion of some
design bases information such as containment integrity considerations, but did not
list required flow rates for all safety related loads and did not reference critical
operational controls such as the need to throttic the CCW system outlet valves from
the RHR heat exchangers to prevent pump run out. The FSAR also provided only
one taference to design basis documents for the CCW system. The inspectors
reviewed two recent 10 CFR 50.59 r /aluations: Safety Evaluation 97-183 and Safety
Screening 97-1259-01. Neither e'.alu0 tion referenced CCW system current licensing
basis requirements other than the T/Ss and FSAR. The inspectors did not identify
any inadequacies in the two evaluations; however, the potential existed to miss
important considerations when modifying the system or system procedures.
The CCW system had only a single containment isolation valve on the return lines
from containment. To compensate for this, the system outside containment was
maintained as closed to the environment. This provided redundancy for the
contait. ment isolatinn function. The inspectors noted that some of the valves relied
upon for keeping the system closed outside of containment were known to have
small amounts of seat leakage, but the valves were not included in the periodic valve
leak check program, the leak rates were not quantified, and a bounding analysis of
acceptable leak rates was not developed. The licensee informed the inspectors that
this condition had been reviewed and found acceptable within the current licensing
basis (CLB). The inspectors will review the acceptability of classifying a system as
closed without performing boundary valve leak checks as an IFl (50-266/97021-
03(DRP); 50 301/9702103(DRP)).
The inspectors reviewed IT 12, " Component Cooling Water Pumps and Valves
(Quarterly)," Revision 12, to determine whether the ability of the CCW system to
meet its design bases requirements under accident conditions was adequate!y
demonstrated. Procedure IT 12 provided testing methodology which satisfied the in
service test requirements of TS 15.4.2; however, it did not demonstrate system
operability relative to safety-related flow and flow distribution. The system
engineering group referred the inspectors to Wisconsin Michigan Test Procedure
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(WMTP) 12.11,' Component Cooling System Flow Test," Revision 1, performed on
November 2,1989, and Point Beach Test Procedure (PBTP) 52, "Coi.vonent
Cooling Water System Flow Test - Unit 2,* Revision 0, performed on June 10,1997.
The inspectors detemuned that WMTP 12.11 did not test the CCW system in its
accident configuration and did not include provisions for considering instrument
inaccuracy in establishirg acceptance criteria. Procedure PBTP 52 also did not test
the CCW system in its accident configuration, and the specified acceptance criteria,
which included instrument inaccuracy, had not been satisfied. The licensee informed
the inspectors that there were no other applicable test procedures. The failure to
perform testing that demonstrated that the CCW system would satisfactorily perform
its safety-related function under accident conditions, was a violation
(50-266/97021-04(DRP); 50-301/97021-04(DRP)) of 10 CFR 50, Appendix B,
Criterion XI, " Test Control."
After identifying the testing problems discussed above, the inspectors reviewed the
licensee's record of CRs and ODs for the CCW system to determine whether
reasonable assurance of system operability existed. The inspectors found that CR
96-416 and an OD had been written on December 30,1996, which clarified design
basis flow requirements and relied on some of the test data from WMTP 12.11 to
demonstrate operability. This OD was inadequate in that, while relying on some test
data from WMTP 12.11, it ignored other data from WMTP 12.11 and did not consider
the impact of nonsafety-related loads which were not isolated under accident
conditions. CR 97-1863 had been written to document the tailure to obtain
acceptable test results during performance of PBTP 52. An OD associated with this
CR stated that sufficient margin existed to allow lowering the required acceptance
criteria. This OD wac inadequate in that action was not taken to develop revised
acceptance criteria or to change the CLB. On November 4,1997, the inspectors met
with licensee staff and provided specific concems with CCW system bst
methodology and the OD associated with CR 96-416.
On November 11,1997, a licensee engineer wrote CR 97-3754 to document
confirmation of the inspectors' finding that two nonsafety-related loads not
considered in the OD for CR 96-416 were left in service when following the steps of
EOP-1.3 (see Section O3.2). The OD for CR 97-3754 containec a corrective action
to revise EOP-1.3, prior to Unit 1 start-up, so that the CVCS seal heat exchanger
and waste gas compressor would be isolated during containment sump recirculation.
On November 25,1997, a system engineer wrote CR 97-3901 to document that
EOP-1.3 had not been revised prior to Unit 1 leaving cold shutdown in the start-up
process. The ODs for CRS 97-3754 and 97-3901 both failed to address the lack of
acceptable test results. On November 25,1997, the inspectors informed the plant
manager and the site vice president of their concerns with the adequacy of the
existing ODs for the CCW system. A new OD was completed on November 28,
1997, prior to Unit 1 going critical. This OD provided reasonable assurance that the
CCW system would perform its design safety functions by taking credit for seasonally
cool service water system temperatures. The failure to establish an adequate basis
for system operability between December 30,1996, and November 28,1997, was a
violation (50-266/97021-05(DRP); 50-301/97021-05(DRP)) of 10 CFR 50, Appendix
B, Criterion XVI, " Corrective Action."
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c. Conclusions
The inspectore concluded tnat CCW system testing had not demonstrated the
system's ability to provide its safety related function when instrument inaccuracies
and potential accident condition system lineups were considered. The inspectors
3!so determined that four ODs for these problems had been generated between
December 1996 and November 1997, but that these ODs were not E.1 equate. The
licensee developed an adequate OD after the inspectors brought this issue to the
attention of plant management.
E2.1 Positive System Enciaeer Performance
The licensee committed to test and maintain spare ventilation equipment in
LER 266/97-020-00. While preparing a safety evaluation for the required test, a
system engineer identified that an unreviewed safety question (USQ) would exist if
the test were performed with a unit at power. This issue was identified as the result
of a thorough review of references in the FSAR. The inspectors considered the
performance of the extensive research required to identify this potential USQ to be a
positive.
E4 Engineering Staff Knowledge and Performance
The inspectors found system engineers to be knowledgeable of their systems in
most cases. However, during the course of the CCW system inspection, the
inspectors requested information on the operation of valve 1(2)CC-130. During
subsequent discussion between the inspectors anO the system engineer for the CCW
system, the system engineer stated that valve 1(2)CC-130 was a fail-closed valve.
The inspectors questioned this conclusion based on field observation of the valve
actuator arrangement. Additionally, check list 6A contained a note which stated that
valve 1(2)CC-130 was gagged to prevent CCW pump run out should the valve fail.
ihe difference between a fail-open and fail-closed valve was also significant
because of potential CCW flow diversion under accident conditions (see Section
O3.2). The system engineer later informed the inspectors that valve 1(2)CC-130
was a fail-open. The system engineer wrote a CR which indicated that the vender
information for the valve was incorrect. The inspectors considered the system
engineer's lack of familiarity with the as-installed method of operation of the valve
actuator to be a weakness.
IV, Plant Support
R1 Radiological Protection and Chemistry (RP&C) Controls (IP 71750)
During the inspection period the inspectors frequently entered the PAB to conduct
housekeeping inspections and surveillances observations. Generally, radiological
housekeeping was good. However, during an inspection on November 25,1997, the
inspectors identified that a piece of drain tubing associated with Unit 1 Leakage
Reduction and Preventive Maintenance Program tests was dripping a small amount
of reactor coolant onto the floor of the #2 pipeway within the PAB. The inspectors
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informed operations and health physics personnel of the condition and it was
appropriately addressed,
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V. Manaaement Meetinas
X1 Exit Meeting Summary
The inspectors presented the inspection results to members of licensee management at the
conclusion of the inspection on December 2,1997. The licensee acknowledged the findings
presented.
The insoectors asked the licensee whether any materials examined during the inspection
, should be considered proprietary. No proprietary information was identified.
X2 Management Meeting Summary
A public meeting with the licensee was held on October 29,1997, in Manitowoc. Wisconsin.
Licensee senior management provided the NRC Point Beach Oversight Panel with the
current status of improvement initiatives. Individual managers described the review and
approval process for ensuring that Unit 1 was ready to be restarted. Planned improvements
in the work planning process were also discussed in detail. The NRC was also told that an
Operating Plan for 1998 was being developed. This plan will prioritize licensee initiatives
and commitments to the NRC, such as development of comprehensive current licensing
bases documents. It will also provide a means for licensee management to track the status
of the improvement initiatives. The NRC welcomed this initiative because the prioritization
tools in place, the QA Program Significant issues Listing, the Level 1 Report, the Plan for
Achievement of Operational Excellence, and the corrective action program Significant
Conditions Adverse to Quality allidentified appropriate information but did not appear to be
integrated.
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PARTIAL LIST OF PERSONS CONTACTED
. Wisconsin Electric Power Comoany
S. A.- Patuiski, Site Vice President
A. J. Cayla, Plant Manager
. R. G. Mende, Operations Manager
W. B. Fromm, Maintenance Manager
.J. G. Schweitzer, Site Engineering Manager
P. B. Tindall, Health Physics Manager
_
D. F. Johnson, Regulatory Services and Licensing Manager
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' INSPECTION PROCEDURES USED
IP 37551: Onsite Engineering
IP 40500: Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing
Problems
IP 61726: Surveillance Observations
IP 62707: Maintenance Observation
IP 71707: Plant Operations
IP 71714: Cold Weather Preparations
IP 71750: Plant Support Activities
ITEMS GPENED, CLOSED, AND DISCUSSED
Opened
50-266/97021-01(DRP) _
_
50-301/97021-01(DRP) NCV Procedural Inadequacies
50-266/97021-02(DRP)
50-301/97021-02(DRP) VIO Containment Hatch Interlock Inoperability
50-266/97021-03(DRP) '
50-301/97021-03(DRP) IFl Closed System Without Boundary Checks CCW
System
50-266/97021-04(DRP) _
50-301/97021-04(DRP)_ _ VIO Inadequate Testing of CCW System
50-266/97021-05(DRP)
50-301/97021-05(DRP) _VIO Inadequate Operability Determination for CCW
System
Closed
50-266/97021-01(DRP)
50-301/97021-01(DRP) NCV Procedural Inadequacies
50-266/97003 01(DRP)
50-301/97003-01(DRP) IFl Concems with Facade Freeze Protection
-50-266/95005 LER Manual Reactor Trip During Startup
Physics Testing
Discussed
50-266/97020-02(DRP) IFl Review of Procedure Adherence and
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Effectiveness
50-301/97020-02(DRP) IFl
LIST OF ACRONYMS USED IN POINT BEACH REPORTS
AC Alternating Current
AOP Abnormal Operating Procedure
ASME American Society of Mechanical Engineers
CCW - Component Cooling Water System
CFR - Code of Federal Regulations
CLUB Current Licensing Basis
CR Condition Report
CVCS Chemical and Volume Control System
ECCS Emergency Core Cooling System
EOP Emergency Operating Procedure
ESF Engineered Safety Feature
EP Emergency Planning
FAR Final Safety Analysis Report
IFl Inspection Follow-up item
IP inspection Procedure
IPE Individual Plant Evaluation
IR Inspection Report
ILRT Integrated Leak Rate Test
IT - In-service Test
LCO Limiting Condition for Operation
LER Licensee Event Report
LTOP Low Temperature Overpressure Protection
MSIV Main Steam Isolation Valve
MSS Manager's Supervisory Staff
NCV Non-Cited Violation -
NDE Non-Destructive Examination
NRC Nuclear Regulatory Commission
01 Operating Instruction
OM Operations Manual
OOS Out-of-Service
OP Operating Procedure
ORT Operations Refueling Test
PAB Primary Auxiliary Building
PASS Post-accident Sampling System
PBTP Point Beach Test Procedure
PDR Public Document Room
POD Prompt Operability Determination
QA Quality Assurance
RCP Reactor Coolant Pump
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RMP Routine Maintenance Procedure
RP. Radiation Protection
RWST - Refueling Water Storage Tank
SALP Systematic Assessment of Licensee Performance
SER Safety Evaluation Report
SFP Spent Fuel Pool
SI- Safety injection
TDAFW Turbine Driven Auxiliary Feedwater
-T/S -Technical Specification-
TS Technical Specification Test
URI Unresolved item
USQ Unreviewed Safety Question
VIO Violation
VNCR Control Room Ventilation
WMTP Wisconsin Michigan Test Procedure
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