ML20199F587
| ML20199F587 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 11/14/1997 |
| From: | Cayia A WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-266-97-16, 50-301-97-16, NUDOCS 9711240270 | |
| Download: ML20199F587 (12) | |
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- e WISCONSIN Electnc POWER COMPANY Point Bevoch Nuc.'ecw Ptont.
(920)755-2321 6610 tesclear Rd., Two Rtvers, VA 5424 i NPL 97-0735 -
10 CFR 2.201 November 14,1997
- Document Control Desk 11 S. NUCLEAR REGULATORY COMMISSION Mail Station PI 137 Washingtc1, DC 20555 Ladies / Gentlemen:
DOCKETS 5%266 AND 50-301 ILEPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT NOS. 50-266/97016 AND 50-301/97016 l'OLNT IIEACll NUCLEAR PLANT. UNITS 1 AND 2 in a letter from Mr. John A. Grobe dated October 17,1997, the Nuclear Regulatory Commissica forwarded the results of an inspection conducted by your staff at our Point Beach Nuclear Plant uom iusy 27 through September 8,1997. This inspection report included a Notice of Violation which identified four violations of NRC requirements.
We have reviewed the Notice of Violation and, pursuant to the provisions of 10 CFR 2.201, have prepared a written response to the violation as requested by your letter of October 171097. Our written response is included as an attachment to this letter.
We believe'that the attached reply is resporave to the Notice of Violation and fulfills the requirements
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identitied in your October 17,1997 letter.
New commitments that have not been previously docketed are identified by italics.
If you have any questions or require additional information regarding this response, please contact me.
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Attachment to NPL 97-073:i -
Page1 DOCKETS 50-266 AND 50-301 REPIN TO A NOTICE OF VIOI,ATION NRC INSPECTION REPORTS 50-266/97016 AND 50-301/97016 POINT HEACil NUCl. EAR PI, ANT UNITS 1 AND 2 During an NRC inspection conducted from July 2*, through September 8,1997, four violations of NRC requirements was identified. Inspection Reports 50-266/97016 and 50-301/97016 and the Notice of Violation (Notice) transmitted to Wisconsin Electric on October 17,1997, provide
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details regarding the violation.
in accordance with the instructions provided in the Notice, our reply to the violation includes:
. (1) the reason for the violation, or if contested, the basic for disputing the violation; (2) the corrective action taken and the results achieved; (3) corrective action to be taken to avoid furGier violations; and (4) the date when full compliance w,il be achieved.
Molation 1:
"10 CFR Part 50, Appendix B, Criterion B, " Corrective Action," requires in part, that conditions adverse to quality are promptly corrected.
Contrary to the above, in the four examples given below conditions adverse to quality were not promptly corrected:
a.
In August 1997, the licensee identified that procedures for testing of valve ISI-852A had not been revised by viay 17,1997, to correct a previous violation of NRC requirements, b.
On July 8,1997, the NRC inspectors identified that the Operations Notebook in the main control room had not been updated by June 30,1997, to include the requirements for initiating temporary changes to operations procedure, This action was necessary to correct a previous violation of NRC requirements.
c.
On July 28,1997, the licensee identified that reactor coolant pump maintenance l.
procedures had not been revised by May 9,1997, to correct a previous violation of NRC requirements, d.
On July 29,1997, the licensee identified that a Licensee Event Report had rr t been submitted for a condition identified on May 15,1997, that alone could have prevented the fulfillmerit of the safety ftmetion of structures or systems that are needed to remove residual heat.
This is a Severity Level I" violation (Supplement 1)."
Attachment to NPL 97 0735 Page 2 Hrainn_ fur Viohtilun Ia:
We concur with the violation as characterized in the inspection report. We wish, however, to provide additional details associated with the violation to ensure completeness of the record.
CortcIlluuhtions Takers LER 266/97-005a was submitted to the NRC on February _14,1997. This licensee report provided detp% whereby on January 16,1997, the iicensee had ides riicd that low head safety injection core deluge valve ISI-852A had not been tested in accordance with the inservice test program as described by Technical Specification 16.4.5.II.A.I. Corrective actions described by the LER included stroke testing of the valve on January 17,1997, and verifying its operability.
This licensee-identified condition was reviewed during your inspection, as documented via inspection Reports 50-266/96019 and 50-301/96019. In our response dated h1 arch 31,1997, to the enclosed Notice of Violation on this issue (Violation 2), we stated that we would revise the associated inservice test procedures (IT-750/755) to ensure that 1&2SI-852A&B are clearly identined within the purpose statement of the procedure and that stroke times are recorded in order to fulfill Section XI testing requirements.
We acknowledge that we did not complete this corrective action commitment ns documented in our letter dated Nlarch 31,1997. During review of this issue, we recognized that the subject inservice test procedures require the use of a modined residnal heat removal (RllR) lineup. We had recently identified this lineup as an unreviewed safety question (USQ) an I had canceled the associated Technical Specification interpretation as well as the insersice test procedures. We reported the discovery of this USQ to the NRC via Licensee Event Report 266/97-019-00 dated Niay 2,1997.
On October 1,1997, we subsequently submitted a letter to the NRC that previded a supplementary description of our commitment regarding inservice testing of the safety injection vMves during cold shutdown conditions. As noted in our letter of October 1,1997, new inservice test procedures IT-03B (Unit 1) and IT-u4B (Unit 2), "LilSI Valve Exercise Test in Cold Shutdown," were issued on August 15,1997. The letter also notes that the Unit 2 core deluge valves had been tested in accordance with their normal Technical Specification test (TS-31) to satisfy inservice testing requirements for the past Unit 2 refueling outage.
Ihtte_Enli Compliaate Will be Achieved:
Full compliance with NRC requirements was achieved on August 15,1997, with issuance of the new in.,ervice test procedure, IT-03B and IT-04B described above.
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Aitachment to NPL 97-0735 Page 3 Reasun. fur _YJula11nn 1.b:
L We concur with the violation as characteri:.ed in the inspection report. Corrective action to address a previous violation of NRC requirements regarding initiating temporary changes was not ccapleted by June 30,1997,in accordance with our commitment.
Corrective Actions laktB:
1.
An Operations Notebook entry was made on August l1,1997, to address the violation cited in Inspection Reports 50-266/96012 and 50-301/96012.
2.
Operations has dedicated additional resources to the corrective action program and to improve program oversight. As a result of the increased attention, there i3 reasonable assurance corrective action commitments made by Operations will be completed as required.
Dutclull Conmliance Will beAchieved; Fu;l complianco svas achieved on August 11,1997, when the Operations Notebook entry
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regarding initiation of temporary changa was made.
Reason for Violation 1,n The violation, as characterized in the inspection report does not appear to reflect the actual situation regarding the reactor coolant pump routine maintenance procedure commitment. There were three actions required by our response to the Notice of Violation contained in hispection Reports 50-266/96012 and 50-30lN6012 regarding changes to the RMP 9002 series of reactor coolant pump maintenance procedures. These thtee changes were to (1) Include appropriate tag series information; (2) require all steps to be perlormed in the indicated order; and (3) require an evolution coordinator to be assigned.
Our response to the Notice of Violation seated that the procedure revisions would be completed prior to the next use which will occur dunng the next unit refueling outage, currently scheduled to commence on May 9,1997. The commitment was predicated on a refueling outage use rather than a specific commitment date.
1 he Notice of Violation correctly states that the licensee initiated condition report CR 97-2302 to document the fact that several of the procedures had been needed to address the Unit 2 reactor coolant pump seal leakage experienced during Unit 2 restart. It should be noted, however, that the danger tagging steps and required tagouts had been included in the permanent procedure revisions prior to use of these procedures in July 1997.
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Attachinent to NPL 97-0735 Page 4 Correente Actions Taken:
1.
Work was stopped on the Unit 2 reactor coolant pump seal repair until appmpriate temperary changes to the afTected procedurcs could be made.
2.
On October 1,1997, we submitted a clarification letter to the NRC regarding this commitment. In our clarification letter we stated that while we believed we had met the intent of our origin.I commitment which had been focused toward ensuring the procedures were revised prior to the next Unit I refueling outage, we felt it prudent to establish a firm commitment date for permanent revision of the five applicable reactor coolant pump routine maintenance procedures.
- Corrective Actions in be Taken to Avoid Recurrence As stated in our letter of October 1,1997 letter, all corrective actions, including issuance of permanent revisions to the applicable procedures will be completed by December 19,1997.
llate Full Compliance Will be Achieved Full compliance with our commitment, as clarified in our October 1,1997 letter, wiP be achieved by December 19,1997.
Reason for Violation 1.d We agree that we have not submitted several licensee event reports (LERs) within the time requirements specified by 10 CFR 50.73. The example cited concerned the reactor coolant pump rotor stand not being seismically qualified. Thh was the second I.ER which we did not submit within the 30-day submittal requirement. This second event occurred prior to completion of our corrective actions commitments associated with the first event. While we revised NP 5.3.1,
" Condition Reportiag System," prior to the commitment date, in retrospect, we realize we should have revised this procedure in a more timely manner.
Correctile Actions Taken:
Afler the second instance, we reviewed the condition.eporting database to ensure that we did not have additional problems in this area. During thn review, we discovered a third situation where a condition was repMable and an action item to issue a licensee event report was not initiated.
This event is documented on condition report CR 97-2320. We have since submitted L.ER 266/96-016-00.
- Attachment to NPL 97-0735 s
Page 5 Additionally, we have reevaluated the issue o missing licensee event reporting requirements.
r We realize that the procedure change previously implemented was not suflicient to preclude recurrence of the problem. Therefore we have developed additional corrective actions, as delineated below, to prevent recurrence.
Grrrtlire Actions to be Taken to Prevent Iltnttnicn 1.
Regulatory reportability training will be provided to the matrixed corrective action program permnnel by March 31,1998.
2.
By December 31,1997, we will reinforce the requirement that condition reports are provided to Regulatory Services & Licensing for input into the reportability determination process.
3.
We will audit our condition report files for the past two years to ensure the electronic copy accurately reflects the originally submitted condition report. This will be completed by December 31,1997, lhis_Dtil Complilutte Will be Achieved:
Full compliance with N'RC requirements will be achieved by March 31,1993.
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" Technical Specification 15.3.1.A.3.b requirce, in part, that both residual heat removal (RilR) loops be operable when the reactor coolant temperature is less than 140 degrees Fahrenheit ( F) except when the reactor vessel head is removed and the refueling cavity hooded or to meet surveillance requirements.
Contrary to the above, a Uni
- 2 RilR loop was inoperable on two occasions with the reactor coolant temperature below 140 F and the reactor vessel head installed. Specifically:
On July 29,1997, the "B" RilR loop was made inoperable when a leak from a crack in a a.
section of one-inch diameter, component coolant water pipe to the "B" RI1R heat exchanger was isolated to facilitate repair.
b.
On August 6,1997, the "A" RllR loop became inoperable as a result of excessive mechanical seal leakage on the "A" RI-IR pump (2P-10A).
This is a Severity Level IV violation (Supplement 1)."
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Attachment to NPL 97-0735 '
Page 6 r
Henson for VLqlations 2.a & b:
We concur with Violations 2.a and 2.b as characterized in the inspection repon.
LER 301/97-004 00 submitted to the NRC on August 28,1997 addressed Violation 2.a LER 301/97-005-00 submitted to the NRC on August 28,1997, addressed Violation 2.b The PBNP Technical Specifications governing decay heat removal operations, presently do not provide for the inoperability of a single decay heat removal train when reactor coolant system-
_ temperature is less than 140 F.
Corrective Actions Takeni Corrective actions specific to the two events are addressed in the respective' licensee event -
reports.
i Additionally, the PBNP Technical Specifications have been compared with the Improved
- Standard Technical Specifications for Westinghouse reactors in NUREG 1431 and Technical Specifications for similar units to determine appropriate allowances for decay heat removal train inoperability when reactor coolant system temperature is less than 140*F. This review also looked at conditions necessary to provide for acceptable coordination between Specifhatiorn governing residual heat removal, component cooling water and decay heat removal provisions.
Currective Actions to be Taken to Prevent Recurrence:
An amendment request is being developed to incorporate appropriate requirements consistent uith NUREG 1431 into the PBNP Technical Specifications. Wepresently expect to submit this amendment request to the PBNP Technical Specifications in January 1998.
Date Full Comnliance Will be Achieved:
We will be in full compliance for this violation upon issuance oflicense amendments that provide appropriate operability and action requirements for the affected systems.
Violation 3:
s "10 CFR Part 50, Appendix B, Criterion XI, " Test Control," requires, in part that a test program be established to assure that all testing required to demonstrate that structures, systems, and
- components will perform satisfactorily in-service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in the applicable design documents.
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Attachment to NPL 97-0735 Page 7 a.
Contrary to the above, as of August 12,1997, the NRC identified that the licensee failed to ensure that acceptance criteria for inservice testing of the Unit 2 charging pumps were incorporated into Inservice Test procedure, IT 22, Revision 5, " Charging Pumps and Valves (Quanerly) Unit 2."
b.
Contrary to the above, on September 3,1997, the NRC identified that Routine Maintenance Procedure 9046-1, " Station Battery," Revision 22, a written procedure which included testing to demonstu e that safety-related components would perform satisfactorily in-service, did not incorponite acceptance limits from design documents for cell voltage or specific gravity.
This is a Severity Leve! IV violation (Supplement 1).
IkasmtAr Violation 3.a:
The violation, as characterized in the inspection report, states that acceptance criteria must be incorporated into the applicable procedures. The violation implies that this must be the inser~ ice test procedures, however, regulatory requirements do not specifically state this. At PBNP, the acceptance criteria are maintained separate from the testing procedures by incorporation into a stand alone document that is governed by an administrative procedure. We acknowledge, hc wever, that control of the inservice test program acceptance criteria was not in accordance with the intent of either ASME Section XI or 10 CFR 50 Appendix B, Criterion VI," Document Control" and that changes to acceptance criteria were not being adequately controlled.
The acceptance criteria for the Point Beach Nuclear Plant inservice testing (IST) program is maintained in the "lST Acceptance Criteria Binder." Administrative controls governing this activity are contained in OM 4.2.2, " Inservice Tests." Per the administrative procedure, two independent reviews must be perfbrmed prior to an acceptance criteria change being implemented. The reviews are perfonned by the IST coordinator or designated alternate and by the Operations Engineer or designated alterm,te. OM 4.2.2 specifies that the new acceptance criteria be manually checked to comply with the appropriate edi ion of ASME Section XI, t
verified to be within the current licensing basis, and checked against manufacturer component information,if available. The handwritten acceptance criteria for the Unit 2 charging pumps identified in this violation were post-maintenance operability testing criteria and not Section XI inservice testing criteria. The post-maintenance operability criteria developed were more restrictive than the Code-required action limits. This change did not alter current reference values; it assured that the charging pumps would be returned to service in an operable status.
As noted above, we agree that a violation of NRC requirements occurred, but this violation relates to inadequate administrative controls associated with maintenance of the IST Acceptance Criteria Bindet, and not with inclusion of acceptance citeria into applicable inservice testing procedures.
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Attachment to NPL 97-0735 Page 8 Cumsth e Aet3Dna hken' As discussed with the NRC during a public meeting held on September 12,1997, we have ensured that appropriate administrative and document controls are applied to the IST Acceptance Criteria Ilinder. We have classified the document as a " controlled reference document" in accordance with cdministrative procedure NP 1.1.6, " Controlled Reference Documents." This action was completed on September 17,1997, when the revised IST Acceptance Criteria Ilinder was issued via the newly established administrative controls. This will also ensure that any temporary or permanent changes made to the document are appropriately implemented in accordance with other efTective administrative controls and that 10 CFR 50.59/72.48 issues are taken into consideration during the change process.
natefulLCumpliance Will be Achined; Full compliance wi*h Nk" requirements was achieved on September 17,1997.
Reason for Violatlun1b We concur with the violation as characterized in the inspection report, but wish to amphry the discussion on station battery testing. Tl e routine maintenance procedure for the safety related station batteries contains limits to identify cells whose voltage and specific gravity are outside of the normal expected range. T1.ese limit; are based upon the battery manufacturer's listed normal ranges. For cells whose voltages or spe:ific gravities do not meet the established limits, the 125 V de system engineer is procedura'.ly required to review the cell data and detemiine whether corrective actions are required to ensure call operability.
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Attachment to NPL 97-0735 Page 9 13y themselves, cell voltages and specific gravities p ovide little indication of available cell capacity, which is the determining factor for cell operability. However, trends of these parameters, along with the results of previous battery discharge tests are valuable in determining whether cell degradation is evident. By utilizing this method, degradation of cell capacity can be-predicted prior to cell parameters reaching extreme values at which operability would be seriously questioned. Discharge testing is the only sure method of determining the capacity of a cell. The safety related batteries at Point. Beach are tested every 18 months to verify that they can supply the energy required during the worct case emergency discharge.
Corrective Actions to be Taken to Prevent Recurrence:
1.
The existing battery maintenanceprocedure relics upon engineering involvement in determining station battery operability. To enable Operations personnel to independently make conservative decisions regarding battery operability, an evaluation will be performed by February 13,1998, to determine limits which would indicate reduced battery cell capacity.
2.
By May 15,1998, reduced battery cell capacity limits will be included in RMP 9046-1,
" Station Battery," along with current limits requiring system engineering review. The forma utilized in Standardized Technical Specifications will be used as guidancefor r
dete1 mining battery cell operability.
Date Full Compliance Will he Achieved:
Full compliance with NRC requirements will be achieved by May 15,1998, when revision to RMP C46-1 will be completed.
Violation 4:
" Technical Specification 15.6.11 states, in part, that a high radiation area with radiation levels such that a major portion of the body could receive in I hour a dose greater than 1000 millirem shall be provided with locked doors to prevent unauthorized entry.
Contrary to the above, on August 13,1997, the licensee identified that the lower equipment hatch a
to the Unit 2 containment, a high radiation area with localized radiation dose rates of up to approximately 1,100 millirem per hour at 30 centimeters from the radiation source, was not locked to prevent unauthorized entry.
This is a Severity Level IV violation (Supplement IV)."
Attachment to NPL 97-0735 o
Page 10 Reason for Violatinn h We concur with Violation 4 as characterized in the inspection report. Both of the Unit 2 containment outer doors were unlocked since early in October 1996 because all areas inside of containment were appropriately posted for the refueling and coincident steam generator replacement outage.
In mid-July 1997, a test was performed on the lower personnel air lock in preparation for establishing containment integrity prior to unit heatup and startup. To prevent use of the lower airlock, which would have required a retest of the airlock, the outer door was locked, even though it was not required to be locked for radiological control purposes.
The Health Physics sta% supervisor went on vacation on August 1,1997. While the supervisor was off-site, testing was performed on the upper personnel airlock. To provide for personnel ingress and egress during testing of the upper personnel airlock, the lower personnel airlock was unlocked.
% ten the Health Physics station superviser retumed to the site on August 12,1997, plans were initiated to remove Unit 2 containment imernal high radiation area postings for areas greater than 1000 mrem /hr as a critical approach on Unit 2 was planned for that evening. When areas within containm:nt are not posted, the containment outer airlock doors are required to be locked. The supervisor instructed personnel to remove the postings inside of the containment and to lock the upper personnel airlock door. He did not specifically instruct personnel to lock the lower airlock door since it had been locked when he had exited the site on August I and his review of turnover notes did not indicated that the lower airlock doors had been unlocked. The only document that specifically requires that both containment airlock outer doors are locked is Operations checklist CL-l A, " Criticality Checklist." It was during performance of this checklist that an operator discovered that the lower airlock door was not locked.
Investigation of this event determined that the cause of the event was attributable to the lack of an effective process within Health Physics for communication ofinformation regarding changes in radiological postings. A contributing factor was the lack of procedural guidance to ensure that the personnel airlock doors are locked when changes are made to containment internal postings of when a reactor unit's operating mode is changed.
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JAttachment to NPL 97 0735 -
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- i Corrective Actions Taken:
Ujion discovery that the lower Unit 2 containment airlock' door was unlocked, the door was immediately locked.
Corrective Actions to be Tm_ ken to Prevent Recurrence:-
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. 1.
A rmndardized Health Physics station supervisory shift turnover systern will be '
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im, cnented byJanuary 16,1998.
- 2..
- By January 16,1998, procedural guidance will be developed to control the radiological posting changes that are required w.'.w,; unit operating mode changes are made, llaic Full Comollance Will be Achieveth Full compliance with NRC requirements will be achieved by January 16,1998.
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