Text

Insp Rept 50-266/99-04 on 990105-0222.One Violations of NRC Requirements Occurred & Being Treated as non-cited Violation.Major Areas Inspected:Operations,Maint & Engineering
	ML20204D831
Person / Time
Site:	Point Beach
Issue date:	03/12/1999
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	;
Shared Package
ML20204D820	List: ML20204D816; ML20204D831;
References
	50-266-99-04, 50-266-99-4, NUDOCS 9903240293
	Download: ML20204D831 (25)
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U.S. NUCLEAR REGULATORY COMMISS!ON

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Docket No: 50-266

License No: DPR-24

Report No: 50-266/99004(DRP)

Licensee: Wisconsin Electric Power Company

Facility: Point Beach Nuclear Plant, Unit 1

Location: 6610 Nuclear Road

Two Rivers, WI 54241

Dates: January 5 through February 22,1999

Inspectors: F. Brown, Senior Resident inspector

P. Simpson, Resident inspector

' Approved by: R. Lanksbury, Chief -

Reactor Projects Branch 5

Division of Reactor Projects

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TABLE OF CONTENTS

Page No. 1

Execu tive Summary . . . .. . . . . . .. . . .. .... . . . . . .. . . ... . . . . . .. . .. . . . . . . ... ........... .. .. .. ..... . . ... . . 1

1.0 Loss of Flow Path for Safety injection (SI) Pumps Minimum Flow Lines ... .... ... . 3

1.1 Identification of the issue on January 5,1999 .. . ... ....... . . ...... ..... . .. 3

1.2 . Licensee Response and issuance of a Notice of Enforcement Discretion ... 4

1.3. Review of Licensee Documentation . . ...... .. . . . . .. . .. . 5

2.0 Conduct of Operations Associated with the Unit 1 Downpower . .. .. . . . . ............ 6

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'3.0 Recovery of Full SI System Operability and Other Short-Term Actions . . .... . . . . . 7

3.1. Actions to Recover SI System Normal Flow Paths . . .. . .... . . . . 7

3.2 Other Short-Term Corrective Actions .. . .... ... . . .. .. . .. .. . .. 8

4.0 Refueling Water Storage Tank (RWST) Line Freeze Protection Circuit Failure . 10

4.1 Heat Trace and Pipe Design .. .. . ... ... . .... .. . .... ... .... . .. .... . . . . 10

4.2 History of Word Order 9819891 for the Failed Heat Trace Circuit .. . . 11

4.3 Maintenance and Testing of the Facade Freeze Protection System . ... ,. 12 -

5.0 Safety Function of the St Minimum Flow Path ... .. . .. . . . .. . . .. . . .. . . . 13 i

6.0 Follow-up Assessment of the Ice Plug in the RWST Inlet Line . . ... .. . . . . . . . . 14

- 7.0 Prior Licensee Cold Weather-Related Corrective Actions ....... ... . ... .... ....... .. 16

8.0 Corrective Actions identified During This inspection .. .. . . .. . ... . . 18 1

9.0 - Miscellaneous issues . . ... .... ... ... . . . . . . .. . .. .. ... ... .......... . . .. .... . . . . 18 ,

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Exit Meeting S u m m ary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . .. . 19

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EXECUTIVE SUMMARY

! Point Beach Nuclear Plant, Unit 1

l NRC Inspection Report 50-266/99004(DRP)

This special inspection was conducted following the identification that a safety-related flow path

for the safety injection system was blocked with ice.

Operations

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Plant operators failed to respond appropriately to an alarm for L temperature on an I

exposed length of safety-related pipe (RWST inlet line). Actions taken included writing

a routine priority work order and defeating the temperature recorder and alarm for the

affected pipe. Because the work order did not specify the safety-related function of the

affected pipe, the licensee's maintenance, production planning, and management i

organizations failed to initiate prompt corrective actions until the NRC questioned I

system operability. The ineffective corrective actions for this condition adverse to quality I

were considered to be an apparent violation. (Section 4.2)

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. The inspectors identified that a failed heat trace circuit on the Unit 1 RWST inlet line had l

the potentia l to affect safety injection (SI) system operability under the cold outdoor ;

temperatures being experienced at the plant. The licensee followed-up on the

int.pectors' concern and identified that the SI pump minimum flow path was blocked by ,

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ice. The licensee declared both trains of Si and both trains of containment spray l

inoperable, and commenced a unit shutdown in accordance with the Technical

Specifications. (Section 1.1)

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. Operators reduced Unit 1 power by approximately 80 percent without significant

problem. All regulatory requirements and most licensee expectations for the conduct of

operations were met. (Section 2.0)

. The inspectors identified that an alarm was not associated with the pipe cited in the l

facade freeze protection procedure for the given alarm. The licensee found several

more errors after the inspectors questioned the accuracy of the procedure. The

inspectors concluded that the licensee had failed to maintain the procedure current

following modification work. This failure was considered to be a non-cited violation of ,

plant Technical Specifications. The licensee's failure to identify the procedure and

alarm inconsistency also reflected poorly on the thoroughness of the immediate

corrective actions following the Si line freeze-up identified 3 days earlier. (Section 3.2)

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The operations department procedure for placing the facade freeze protection system

into service and operating it did not specify minimum material condition requirements.

(Section 4.3)

. Out-of-service heat trace elements were only documented by work order. A formal

assessment of the impact of the degraded condition, such as by the formal operability

, determination program, was not required by plant procedures. (Section 4.3)

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The licensee had experienced equipment challenges from inadequate cold weather

preparations and freeze protection system failures from 1994 to the most recent

inspection period. The licensee took appropriate, timely corrective actions for each

l individual problem. However, not until late December 1998, had the licensee identified

l the need to perform a root cause evaluation of the continuing equipment problems with J

! the facade freeze protection system. The inspectors concluded that the licensee's l

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corrective actions had been adequate, but had not been broad enough in scope to

prevent the January 5,1999, event. (Section 7.0)

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The licensee's intermediate-term corrective actions for the frozen SI minimum flow path' )

! were appropriate. Long-term corrective actions had not been identified at the end of the ]

inspection. (Section 8.0)

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Maintenance l

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Significant weaknesses were identified in the facade freeze protection system ,

maintenance program and its implementation. (Section 4.3) l

Enaineerina

The licensee's technical evaluations which supported a Notice of Enforcement

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Discretion for continued operation of the facility with the frozen SI system line were

thorough and accurate. One weakness was noted with the licensee's safety evaluation,

but the validity of the evaluation's conclusion was not affected. All commitments

associated with the requested discretion were satisfied. (Section 1.3)

The common Si system minimum flow path was protected from freezing by a nonsafety-

related heat trace circuit susceptible to a single failure. The licensee did not have

controlled drawings or installation records for the facade freeze protection heat trace

system. This made assessing the potentialimpact of faulty or failed heat trace elements

difficult. (Section 4.1)

The SI pump minimum flow function was required to prevent pump failure during a

limited set of small- to intermediate-size RCS pipe failures. The licensee performed

simulator runs which indicated that operator actions would prevent the core from

becoming uncovered during a small-break loss-of-coolant accident, even if both SI

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pumps failed. However, the simulated failure mechanism provided earlier warning of a

problem with Si than would have occurred in the plant as a result of the frozen line.

(Section 5.0)

The licensee concluded that the normal minimum flow path for the SI pumps was

unavailable for an indeterminate period of time due to the frozen RWST inlet line.

l Based on tests performed after this event, the licensee concluded that sufficient flow

would have been established through failed low pressure boundary valves to have

assured the safety-related function of the SI pumps during any previously analyzed

accident scenario. However, the design and licensing basis does not credit the

. structural failure of low pressure system boundary valves to ensure that an emergency

core cooling system function is operable. (Section 6.0)

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Report Details

1.0 Loss of Flow Path for Safety Inlection (SI) Pumos Minimum Flow Lines

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1.1 Identification of the issue on Januarv 5.1999

During the licensee's morning management meeting, one of the topics discussed was a i

problem with one channel of the Unit 1 "A" steam generator (SG) pressure reactor

protection system logic. The instrument line for a transmitter had frozen, and the {

channel had become inoperable. Material distributed at this meeting included a list of

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" Priority Equipment." This list identified open work orders for conditions which the

operations department determined had the potential to affect operation of the plant, and

for which assistance from other departments was requested. The inspectors reviewed

this list, paying particular attention to potential cold weather issues. The inspectors

noted that work order (WO) 9819891 was on the priority equipment list. In describing

the condition that needed to be addressed, the WO stated that the freeze protection

alarm system had indicated a low temperature for the Unit 1 "RWST [ refueling water ,

storage tank) Inlet Line," that the alarm system temperature monitoring point had been l

placed in bypass (would no longer alarm), and that the heat trace for this line was "non-

function (al)." The repair completion date identified for this item was April 19,1999. The

inspectors were concerned because the common minimum flow line for the two Unit 1

safety injection (SI) pumps returned to the Unit 1 RWST through a line labeled as the

"RWST inlet line." This section of pipe was located in the unheated facade, an area

between the reactor containment and the primary auxiliary building (PAB) where the

RWST was located.

After the morning meeting, the inspectors walked-down the Unit 1 SI system to

determine whether the line identified on WO 9819891 affected the SI pump minimum

flow function. The inspectors determined, based upon the system walk-down and the

WO tag hanging on the facade freeze protection alarm panel, that the line affected by

the non-functional heat trace was part of the common flow-path for the minimum flow

function of the two Unit 1 SI pumps. Using a controlled copy of the Si piping diagram

and a copy of the priority equipment list, ;he inspectors described to the assistant

operations manager their concern that WO 9819891 appeared to indicate that a section

of pipe with a safety-related flow function was located in an area currently exposed to

sub-zero degrees Fahrenheit (*F) temperatures without operational freeze protection

and with the temperature alarm function in bypass. The inspectors questioned how this

condition had been evaluated for operability ramifications, and what the current basis

was for considering the SI minimum flow function to be operable. The inspectors'

discussion with the assistant operations manager was completed at approximately

10:45 a.m., Central Standard Time. The assistant operations manager then promptly

engaged the assistance of the shift technical advisor to evaluate the inspectors'

concerns.

l At approximately 12:00 noon, the assistant operations manager informed the inspectors

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that the plant staff had confirmed that at least a portion of the common minimum flow

line from the Unit 1 SI pumps to the RWST was without operable freeze protection.

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Operators were preparing to test the flow path to determine whether the SI pump

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minimum flow function was operable. After two attempts to pass flow through the

RWST inlet line were unsuccessful, the licensee concluded at 12:40 p.m. that the line

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was blocked. Both trains of SI were declared inoperable because the support function

of ensuring minimum cooling flow through the pumps during the initial stages of some

small-break loss-of-cooling accidents (LOCAs) was not available. The licensee also 1

identified that both Unit 1 containment spray pumps used the plugged RWST return line.

At 12:40 p.m., the licensee declared both SI pumps and both containment spray pumps ,

inoperrble. In accordance with Technical Specification (T/S) 15.3.0.B.1, the licensee

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was required to initiate actions within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to have the plant in hot shutdown within '

7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months after declaring the SI pumps and containment spray pumps inoperable. At

approximately 1: 20 p.m., the operations manager informed the inspectors that actions 1

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had been initiated to place the unit in hot shutdown, and that the shutdown would

commence at 2:00 p.m.

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Conclusions

The inspectors identified that a failed heat trace circuit on the Unit 1 RWST inlet line had

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the potential to affect safety injection system operability under the cold outdoor )

temperatures being experienced at the plant. The licensee followed-up on the l

inspectors' concern and identified that the Si pump minimum flow path was blocked by l

ice. The licensee declared both trains of Si and both trains of containment spray i

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inoperable, and commenced a unit shutdown in accordance with the Technical

Specifications.

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1.2 Licensee Response and Issuance of a Notice of Enforcement Discretion (NOED)

While operators prepared to shut down Unit 1, the licensee evaluated alternate methods

of establishing a minimum flow path for at leas. one of the SI pumps. The licensee

quickly concluded that there was reasonable assurance that the containment spray

pumps would perform their safety function with the blocked RWST return line, but these

pumps could not be declared operable until a written operability determination (OD) was

developed, reviewed, and approved as required by plant procedures. At approximately ,

1:40 p.m., the licensee concluded that the plugged Si and containment spray pump

minimum flow path placed the plant in a condition outside of its design basis. A 1-hour

report was made at 2:12 p.m., pursuant to 10 CFR 50.72(b)(1)(ii)(B).

During preparation for the plant shutdown, the licensee staff was informed by the

Wisconsin Electric electrical distribution control center that the local grid was heavily

loaded because of the increased electrical power demand due to the extreme cold

weather in the service area. The start of the plant shutdown was delayed from 2:00 to

3:00 p.m. while grid stability was evaluated. A unit shutdown was then commenced at

3:06 p.m. Inspector observations of shutdown activities are discussed in Paragraph 2.0 !

below. A 1-hour report for the T/S-required shutdown was made at 3:15 p.m., pursuant

to 10 CFR 50.72(b)(1)(i)(A).

In parallel with the shutdown, the licensee identified an alternate minimum flow path,

involving the SI system full flow test line, which could be used to return one Si pump to

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an operable status. The licensee concluded that physical system alignments and tests

could be completed prior to the expiration of the T/S 15.3.0.B.1-required time for placing

the plant in hot shutdown (7:40 p.m. based on the time of identification of

12:40 p.m. and the 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months specified in the T/S). However, the licensee determined that

the written ODs, emergency operating procedure (EOP) changes, and supporting

10 CFR 50.59 safety evaluation (SE) required by plant procedures could not be

completed within the specified time to shutdown.

At 4:30 p.m., the licensee initiated a conference call with NRC Region lli and the Office

of Nuclear Reactor Regulation to request an NOED for a one-time,6-hour extension of

the shutdown provisions of T/S 15.3.0.B.1. The basis for this request was the licensee's

desire to avoid the plant transient associated with a shutdown of the plant. Additionally, l

the licensee informed the NRC staff that replacement of the plant's power output was l

not a certainty given the cold weather and system loads. Wisconsin Electric had l

entered a grid pow ondition of " Yellow" at the time the Unit 1 downpower was started. l

The licensee statec uat there was little increase in risk associated with the requested !

NOED because the physical plant changes required to exit the T/S 15.3.0.B.1 action ,

statement would be completed prior to the expiration of the allowed outage time and l

associated shutdown action statement. The additional 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months would be required to !

complete, review, and approve required paperwork. The licensee explained the

proposed alternate Si system minimum flow path for one Si pump, and the technical <

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basis for considering the containment spray pumps to be operable. At 6:20 p.m., the

NRC notified the plant that the requested NOED had been granted consistent with the

guidance of NRC Manual Chapter 9900, " Technical Guidance, Operations - Notice of i

Enforcement Discretion."

The basis for considering containment spray operable was the physical configuration of l

the pumps and the recirculation through the system chemical addition piping. The

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licensee also determined that the pumps' discharge valves would open prior to the

pumps' receiving a start signal, consequently, the pumps would not be subjected to a

shutoff head flow condition.

At 6:32 p.m., the licensee established the alternate minimum flow path for the "B" train

SI pump. Crew briefings on the abnormal SI system configurations commenced at

8:30 p.m. for the on-shift crew, and continued at each oncoming shift turnover meeting.

At 12:26 a.m on January 6,1999, the licensee completed the development, review, and

approval of ODO, EOP changes, and an SE for the existing configuration of the two Si

pumps. The "B" train SI pump and the two containment spray pumps were declared

operable but degraded, and T/S 15.3.0.B.1 was exited prior to the time allowed by the

NOED extension. The unit remained in a 72-hour limiting condition for operation for the

inoperable "A" train Si pump in accordance with T/S 15.3.3.A.2.b.

1.3 Review of Licensee Documentation

The inspectors reviewed the licensee's OD, SE, and NOED written request for accuracy

and technical adequacy. The inspectors determined that all three were complete,

a curate, and without major flaws. One issue was identified with the written SE.

Sr 'cifically, when evaluating the use of tha full flow test line as an alternate SI pump

minimum flow bypass line, the licensee acknowledged that portions of the line were not

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I classified as safety-related. The SE concluded that this did not impact the use of this ;

l alternate flow path because the applicable pipe and components had originally been ;

l- purchased and installed to equivalent standards as the safety-related portions of the SI 1

system. The pipe and components were being controlled as Seismic Class 1,

" Augmented Quality." The SE did not address whether the system had been modified,

through either design changes or through parts replacement, in a manner which

affected its ability to function under accident conditions during the period when

safety-related quality control program elements were not being implemented. The

inspectors considered the failure to address this issue a weakness, but concluded that it

did not invalidate the findings of the SE. This conclusion was based on the very limited

number of active and passive components in the applicable portion of the system, and

the low probability of the failure (based upon their nature) of any of these items.

The inspectors reviewed the work plan used to establish the altemate SI pum? minimum

flow path. The work plan was adequate to achieve the desired results. The inspectors

reviewed shift logs and turnover notes, and verified that required briefings were

performed to ensure that operating crews were aware of the alternate Si minimum flow

bypass configuration. Based on these reviews, the inspectors concluded that the

licensee satisfied the commitments referenced in the NOED.

Conclusions !

The licensee's technical evaluations which supported the continued operation of the

facility with the frozen SI system line were thorough and accurate. One weakness was j

noted with the licensee's safety entuation, but the validity of the evaluation's

conclusions were not affected. All commitments associated with the NOED were

satisfied.

2.0 Conduct of Operations Associated with the Unit 1 Downoower

The control room crew referred to Operating Procedure 3A, " Normal Power Operation to

Low Power Operation," Revision 43, to commence the Unit 1 shutdown. The licensee

terminated the shutdown at approximately 20 percent power once the NOED was

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granted. The inspectors noted that the Unit 1 shutdown was conducted and controlled

well, as evidenced by the use of pre-job briefs, formal communications, and self-

checking. The operating supervisor (a senior reactor operator) in charge of the reactor

shutdown evolution displayed good command and control of the activities.

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A change of shift occurred during the shutdown. The off-going control room crew

placed the plant in a stable configuration prior to conducting a turnover with the

oncoming crew. The inspectors observed the operators exchange detailed equipment

status information and perform a control board walkdown prior to assuming the shift. In

addition, the oncoming operating supervisor conducted a brief with the oncoming control

(reactor) operators covering precautions, limitations, and reactivity control. The j

!- inspectors concluded that the change of control room crews was conducted smoothly j

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i and effectively.

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At the point in the shutdown evolution when a SG feedwater pump needed to be

secured, the control room crew decided to secure the "A" pump. As discussed in

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( Section 01.2 of Inspection Report (IR) 50-266/98019(DRP); 50 301/98019(DRP), the

l "A" pump had experienced a bearing failure on November 14,1998. As part of its return !

j to service following repairs, temporary procedure changes and a temporary modification

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to the "A" pump discharge valve had to be made. During the January 5,1999, Unit 1 ,

shutdown, operators thought those changes were necessary on a one-time b_. .s in I

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. order for engineering staff to gather pump start data. However, during the return to full

l power on January 6,1999, operators learned that in order to restart the "A" SG

feedwater pump, the temporary procedure changes and the temporary modification to

the "A" pump discharge valve needed to be implemented. This resulted in a delay of 1

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2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months while support personnel recreated, approved, and implemented the temporary l

l procedure changes and the temporary modification. The inspectors concluded that l

l ineffective communications occurred between the operations and engineering

departments regarding operational requirements for the "A" SG feedwater pump, l

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resulting in en unnecessary distraction to the control room crew.

The inspectors observed during the shutdown that the duty shi't superintendent (the

lead senior reactor operator) and the duty operating supervisor were both heavily

involved with developing and implementing compensatory measures for the plugged

l RWST inlet line. Attachment 1 of Operations Manual 1.1," Conduct of Plant

Operations," Revision 1.1, tasked the duty shift superintendent with providing a." big

picture" overview cf shift and plant activities and the duty operating supervisor with

providing oversight of control room activities. Industry events have shown the value of

having a senior reactor operator (SRO) who is not directly involved with ongoing j

activities providing an independent overview of critical plant evolutions such as a time l

constrained reactor shutdown. While no actual safety impact resulted in this case, the

inspectors were concerned that although industry experience had been integrated into

the station conduct of operations procedure, the licensee did not provide an

independent overview in the control room.

The inspectors discussed these observations with the operations manager. The

operations manager acknowledged them and planned to address them with the

operations department staff.

Conclusions

Operators reduced Unit 1 power by approximately 80 percent without significant

problem. All regulatory requirements and most licensee expectations for the conduct of

operations were met.

i 3.0 Recovery of Full SI System Operability and Other Short-Term Actions

3.1 Actions to Recover SI System Normal Flow Paths

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The licensoe isolated the two Si pumps from the pump minimum flow line using manual

valves when the alternate minimum flow path was established at 6:32 p.m. on

January 5,1999. This was done, in part, to prevent over-pressurization of portions of

the RWST inlet line which would not normally be exposed to Si system pressure, but

which could be because of the plugged RWST intet line. External heating of the blocked

RWST inlet line was commenced at approximately 2:00 p.m. using a space heater. This

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heater was located to direct heat on the outside of the pipe lagging at the base of the

vedical run of the RWST inlet line. At approximately 10:30 p.m., an electric weld

machine was used to establish a high current (between 200 and 300 amperes (amps)),

low voltage electrical circuit through a portion of the vertical section of the RWST fill line.

At 10:34 p.m., a 58-gallon per minute (gpm) flow was established through the RWST fill

line using a normal RWST recirculation flow path and the refueling water recirculation

pump, P-33.

The licensee declared the "A" train SI pump and system operable at 9:08 p.m. on

January 6, following completion of an engineering assessment that there was no

freezing or thawing-related damage to the RWST inlet line, realignment of the "A" train

manual isolation for the normal minimum flow line, and performance of an Si pump test

run with flow to the RWST, With the "A" SI pump and both containment spray pumps

fully operable, and the "B" SI pump operable but degraded (with the alternate minimum

flow path), the licensee exited the T/S 15.3.3.A.2.b 72-hour action statement. At

11:01 p.m. on January 9, the licensee completed valve manipulations and testing

necessary to return the "B" SI pump to a fully operable condition using its normal

minimum flow path. This activity had been sequenced to the completion of repair and

modification work on electrical buses affecting the emergency power supply for the

redundant ("A" train) Si equipment.

3.2 Other Short-Te rm Corrective Actions

On January 8, the licensee documented in Condition Report (CR) 99-0076 that two

facade freeze protection system recorder points indicated temperatures below freezing

and that a low current to the associated heat tracing existed. The control room crew, in

screening the CR, used Operating Instruction (OI) 106, " Facade Freeze Protection

System Operation," Revision 11, to associate the recorder points with a circuit

description. It was necessary to use 01106 since the freeze protection system

component labels only provided a circuit number and not a physical description of the

equipment protected. Using Ol 106, the licensee identified that one of the affected

circuits was for the Unit 1 turbine-driven auxiliary feedwater (AFW) pump (1P-29) steam

supply from the "B" SG. The operators checked the steam trap in the affected 1P-29

steam supply line and noted that it had a large differential temperature which they

interpreted as meaning the line upstream was not frozen. On this basis, the CR

screener concluded that AFW pump 1P-29 was operable but requested that an OD be

performed to address the low heat tracing current.

The inspectors reviewed CR 99-0076 on' January 9 and questioned how the facade

freeze prota>ction system related to the steam supply for 1P-29. The inspectors walked

down the accessible portions of the 1P-29 steam supply from the "B" SG and could not

-find any heat tracing associated with those lines. The inspectors did locate a line in the

Unit 1 facade connected to a temperature element and a heat tracing circuit labeled with

designators that matched those in question. The inspectors informed the control room

crew that it appeared that 01106 inaccurately described the defective circuit

documented on CR 99-0076. The control room crew informed the system engineer

performing the CR 99-0076 OD of the inspectors' observations.

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The inspectors met with management from the operations and engineering departments

later that day to discuss the inspectors' field observations and express concem about j

( the accuracy of Ol 106 and the lack of apparent licensee action to evaluate the extent of

the inaccuracy. This was of concem because the licensee was using Ol 106 to identify

' which plant systems were affected by freeze protection circuits that were not working ,

properly. The licensee acknowledged the inspectors' concerns. '

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- The licensee promptly compared the freeze protection circuits described in 01106 to the

l actual field configuration. Many circuits were found to be improperly described. The

j licensee corrected Ol 106 to eliminate the errors or to indicate that the circuit would

I have to be walked down if it alarmed. One error identified was that the circuit Ol 106

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had described as the 1P-29 steam supply from the "B" SG was actually the Unit 1 "B"

SG relief valve stack drains and "B" SG main steam isolation valve steam trap bypass to

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l Pie licensee had classified Ol 106 as a procedure required by T/S 15.6.8. The

j .nspectors were told by several plant staff, including supervisory personnel, that Ol 106

w's known to be out-of-date and to contain potentially inaccurate information. A partial

caut;e for this condition was that some of the facade freeze protection circuits had been ;

modifad prior to the onset of winter weather, but the modification package close-out

work had not been completed. Because there were no final drawings to use in updating ;

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the operating procedure, plant engineering and operational staff had accepted that the

questionable procedure would continue to be used. The failure to maintain a required ;

l procedure current following system modification was a non-repetitive Severity Level IV i

j violation of T/S 15.6.8 which has been entered into the licensee's corrective action 4

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j program (condition report 99-0075) and is being treated as a Non-Cited Violation,

l consistent with the NRC Enforcement Policy (NCV 266/99004-01(DRP)). Corrective

t

actions taken for this condition included a prompt change to 01106 to correct some

known errors and to flag circuits of questionable accuracy, an intermediate-term .

, commitment to accurately characterize all facade freeze protection circuits and to l

update 01106 accordingly, and a long-term commitment to ensure that operating

, procedures were updated prior to the release of any modified system for operation.

! Conclusions

[ l

i The inspectors identified that an alarm was not associated with the pipe cited in the j

i facade freeze protection procedure for the given alarm. The licensee found several j

' '

more errors after the inspectors questioned the accuracy of the procedure. The

! inspectors concluded that the licensee had failed to maintain the procedure current

following modification work. This failure was considered to be a non-cited violation of

plant Technical Specifications. The licensee's failure to identify the procedure and

.' alarm inconsistency also reflected poorly on the thoroughness of the immediate

corrective actions following the Si line freeze-up identified three days earlier.

4'

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4.0 RWST Une Freeze Protection Circuit Failure

4.1 Heat Trace and Pioe Desian

l

l The. facade freeze protection system was one of three heat tracing systems installed at !

!

the facility. The facade freeze protection system and the boric acid heat trace system

(located inside the PAB) each monitored temperatures on various components and had

alarm panels in the PAB (although alarm coverage was not comprehensive in that some

circuits were not monitored). The third system provided protection for portions of the

primary chemical and volurm control system gas strippers and the radiological waste

processing systems located in the facade. This system had no alarm capability. j

The RWST inlet line located in the facade was a nominal 2-inch diameter, schedule 10,

stainless steel pipe. The line left the PAB approximately 1 foot below the floor of the

6.5- foot elevation (plant designation). The pipe ran horizontally for approximately ;

5 feet, then ran vertically up the external side of the RWST wall. This vertical length of l

!

pipe was approximately 75 feet long. The pipe turned and entered the RWST near the

top of the tank. The tank was heated (to approximately 50*F) and insulated. The

vertical run of the RWST inlet line was approximately 1 foot from the tank, and was i

supported by two uninsulated pipe supports attached to the RWST. The fill line was

insulated with asbestos lagging.

Two heat trace circuits were installed on the RWST inlet line. Each circuit was carried in

a piece of conduit which entered the inlet line insulation approximately half way up the

vertical length of pipe. Each heat trace circuit had a thermocouple-type temperature ,

probe installed on the pipe, under the insulation, somewhere along the length of the j

heat trace. There were no controlled drawings or installation notes to indicate where the ;

heat trace was routed under the insulation on the inlet line, or where the thermocouples

were physically located. The pipe insulation had not yet been removed at the

completion of the inspection because of the need to establish appropriate asbestos

controls and the desire to minimize heat loss from the pipe.

The failed section of heat trace was designated as 1-FF-1-228, with the associated

thermocouple being designated as point 133 on the facade freeze protection alarm

panel in the PAB. The other heat trace circuit was designated as 1-FF-1-07A, with the

associated thermocouple being designated as point 126 on the alarm pan 61.

The licensee thought, based on experience with similar heat trace circuits and the

available indication, that one heat trace circuit ran upward on the vertical RWST inlet

line from the point the conduit entered the lagging, and the other circuit ran downward.

This configuration would not provide any overlap in the heat trace function. Therefore, if

a single circuit failed, the other circuit would not provide direct heating of the entire pipe

run.

Conclusions

The common SI system minimum flow path was protected from freezing by a heat trace

circuit susceptible to a single failure. The licensee did not have controlled drawings or

l

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10

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1

i

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1

r installation records for the facade freeze protection heat trace system. This made

assessing the potentialimpact of faulty or failed heat trace elements difficult. I

4.2 History of WO 9819891 for the Failed Heat Trace Circuit !

I

A PAB auxiliary operator reported that facade freeze protection system point 133 was in )

l alarm (indicated temperature of 35'F or less) on December 22,1998. Ambient

temperatures were below O'F at the time. Several other alarms were also received,

including one on the Unit 1 SG blowdown line flow indicators. This latter iesue was ,

recognized to be a challenge to the continued operation of Unit 1. Operating l

Instruction 100, Section 4.3, " Alarm Response," provided instructions for dealing with

points in alarm. The actions taken by the auxiliary operator included placing point 133 in )

bypass (this removed the alarm and record keeping functions of the alarm panel from '

service for this heat trace element), and informing the control room of the condition.

The operator did not take any of the compensatory actions described in 1

Paragraph 4.3.12 of 01106. This paragraph stated that circulating system fluids

through the pipe or adding heat lamps should be " considered."

One of the onshift reactor operators (ROs) was an acknowledged expert on the facade

freeze protection system. He recognized that the Si pump minimum flow function was

associated with the RWST inlet line; however, he did not consider the alarm to represent

an immediate safety concern. The operators told the inspectors that this conclusion was

based on the operable 1-FF-1-07A heat element, heat conduction because of the

proximity of the pipe to the heated RWST, and the fact that there was no known history

of this line freezing. The RO initiated WO tag 144850 for the alarming point and then

. discussed the alarm condition and the WO tag with the duty shift supervisor (DSS). The l

DSS was also familiar with the Si pump minimum flow function associated with the

RWST inlet line; however, the DSS also failed to annotate the WO tag as being a high

priority item affecting plant safety equipment, and to direct that a CR and OD be l

initiated. The WO tag was then routed in a routine manner to the work control center i

SRO, who was also responsible for assessing the impact of the observed condition on l

equipment operability, for determining whether a CR should be written, and for l

assigning a priority or verifying the initial priority given to the WO. The WO was I

assigned a priority of "6" (routine woik).

As a result of the freeze protection problems being experienced on December 22,1998,

the RO most familiar with the system and the system engineer (who had been assigned

responsibility for the system on December 21,1998) performed a walk-down of large

portions of the system. Although they were reported to have specifically looked at the

I

RWST inlet line, neither individual identified any need to reassess the priority assigned

to WO 9819891 or to initiate a written operability review.

On December 22, a general note regarding the need to perform facade freeze

protection system corrective maintenance in a prompt manner was added to the " Priority

Equipment" list by the operations department. This note remained on the list through

December 29. On that date, plant work control and maintenance personnel requested

that the operations department provide more detail on the issue referenced in the note

so that the issue could be effectively addressed. An on-shift DSS added two equipment

, identifiers, one of which was for 1FF-1-22B (the RWST inlet line heat trace), to the

l

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l priority equipment list distributed on the morning of December 30. The DSS selected

the term "non-function (al) heat trace" to describe the condition for 1FF-1-228. He later

stated that this term was arbitrary, in that he was not aware of any details other than the

alarm condition stated on the original WO tag (and hence in the subsequently developed

electronic WO file). The priority equipment list of December 31 included the equipment

designator and the WO number for the RWST inlet line heat tracing. The lists for

January 1,4, and 5,1999, included the equipment designator, the WO number, the

description (referenced in Paragraph 1.1 of this report), the new priority of "5"

(mandatory work), and the proposed completion date of April 19,1999. A status code

"10," indicating validation of the work and finalization of the prioritization, but no work

planning activities initiated, was also listed. The work priority had been upgraded from

"6" to "5" when the item was specifically identified on the priority equipment list;

however, having the WO on the list did not accelerate the completion of the corrective

maintenance for the failed heat trace circuit.

On December 22, the licensee was aware that a temperature recorder for a section of

safety-related pipe, located in an area exposed to extreme low temperatures, was

indicating near freezing temperatures. The only substantive action taken between

December 22,1998, and January 5,1999, (when the NRC recognized the potential

significance of the condition and questioned Si system operability) was to remove the

temperature recorder associated with the pipe from service. The licensee's failure to

promptly address the low temperature on the safety-related pipe, a condition adverse to

quality, was an apparent violation of 10 CFR Part 50, Appendix B, Criterion XVI,

" Corrective Action," which requires that measures be established to assure that

conditions adverse to quality are promptly identified and corrected (Escalated

Enforcement Itam (EEI) 266/99004-02(DRP)).

Conclusions

Plant operators failed to respond appropriately to an alarm for low temperature on an

exposed length of safety-related pipe. Actions taken included writing a routine priority

work order and defeating the temperature recorder and alarm for the affected pipe.

Because the work order did not specify the safety-related functica of the affected pipe,

the licensee's' maintenance, production planning, and management organizations failed

to initiate prompt corrective actions until the NRC questioned system operability. The

ineffective corrective actions for this condition adverse to quality were considered to be

a violation of 10 CFR Part 50, Appendix B, Criterion XVI.

4.3 Maintenance and Testino of the Facade Freeze Protection System

The licensee repaired the facade freeze protection system once it failed, instead of

performing preventive maintenance to prevent failure of the system. The maintenance

department had a planned diagnostic work procedure ("Callup E-A") which required

amperage checks for all facade freeze protection circuits. The scheduled completion

date for this "callup" work activity of May 18,1998, would likely have allowed time for

.

correction of any identified deficiencies prior to the onset of cold weather. On August 2,

I the WO for Callup E-A was annotated by an engineer with " Defer performance of this

W.O. until the revised callup E-A check list is issued." The "callup" work activity was not

initiated until around December 16 and the breaker and thermostat circuit containing the

12

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1FF-1-228 heat trace were tested around December 18. A current of 4.5 amps was

measured for the circuit test.' The design value listed for this circuit was 8.4 amps, but

no acceptance criteria were provided in the callup WO package. The electricians who !

performed the "callup" work activity initiated individual WOs to fix the circuits with 0 amp i

readings, but since this circuit read greater than zero amps, no action had been taken

,

'

as of January 13,1999. The WO for Callup E-A was still open at that time (not all

circuits had been tested, and some circuits could not be identified with certainty), and

the electricians interviewed by the licensee's. event assessment team stated that all

anomalous readings would have eventually been provided to engineering personnel for

evaluation. The most recent completion of Callup E-A prior to the winter of 1998 was

l ~ September 24,1997. The licensee stated that the electrical circuit containing the

L 1FF-1-228 heat trace was functional, with an indicated current of 8 amps.

l Operations Department Periodic Check 49, Part 4, " Auxiliary Buildings Miscellaneous

( and Facades," Revision 10, (a non-nuclear type procedure) and Ol 106 (a procedure

l required by T/S) provided instructions for placing the facade freeze protection system in

service. These procedures had been completed on October 5,1998. The system

'

check-out and operating procedures did not contain any tests or checks which would

identify the passive failure (that is, breakers not opened on a short circuit current) of a

section of heat trace. The licensee expected a work order to be written for any non-

functional equipment, as indicated by observable failures, and the DSS to be informed

so that an appropriate priority could be established for corrective maintenance. There

were no minimum material condition (system operability) requirements for placing the .

facade freeze protection system in operation.

Conclusions I

l

Significant weaknesses were identified in the facade freeze protection system

maintenance program and its implementation. The operations department procedure

for placing the facade freeze protection system into service and operating it did not

specify minimum material condition requirements. Out-of-service heat trace elements

were only documented by work order. A formal assessment of the impact of the

degraded condition, such as by the formal operability determination program, was not j

required.

5.0 Safety Function of the SI Minimum Flow Path ,

l

Point Beach's safety-related emergency core cooling systems consisted of two

intermediate-head safety injection trains, two accumulators, and two low-head residual

. heat removal trains. The licensee was committed to being capable of handling any size l

reactor coolant system (RCS) pipe break. For some range of small-to-intermediate pipe - l

break sizes (the range was not specified in the plant's design or licensing bases), there

would be a period of time between the automatic start of the SI pumps and the

depressurization of the RCS to below the Si pump shutoff head. During this period of

time, the only flow through the SI pumps would be through the minimum flow

- recirculation line to the RWST. This minimum flow ensured adequate cooling of the

pumps. The absence of cooling flow would lead to binding within the pump, or seal l

failure, in a short period of time. The licensee's SI pumps could operate indefinitely with

. 225 gpm of recirculation flow. At 70 gpm of flow, the pump vendor certified that the

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SI pumps would remain fully operable for 15 minutes. At no-flow conditions, the

licensee's SI pumps, which were close-toleranco, multi-stage, high horsepower pumps,

could failin less than 2 minutes.

1

The ice plug in the RWST inlet line had no direct impact on the operation of the plant. j

The plug would have had safety consequence during a certain range of LOCAs that '

involved a slow depressurization of the RCS. If the time it took to depressurize from

1800 pounds per square inch - gauge (psig) (the time of pump start) to below 1500 psig

(approximate start of injection) had exceeded approximately 2 minutes (assuming no )

alternate minimum flow path), both Si pumps would likely have failed catastrophically.

Assuming no operator action, this would have delayed the start of injection until the RCS

reached approximately 700 psig, at which time the accumulator outlet check valves

would have opened. This condition would be outside the plant's design basis, in that the

licensee's accident analysis assumed that at least one SI pump was always operable.

Following the event, the licensee performed unannounced simulator drills for three

separate crews where the SI pumps were both rendered inoperable. In each case, the

i crew took action to lower RCS pressure manually so that the accumulators could inject.

The licensee informed the inspectors that the core was not uncovered during any of the

simulations. However, the inspectors noted that the method of failing the pumps in the

simulator provided earlier warning to the operators of system failure than would have

occurred if failure had resulted from the frozen Si line.

Conclusions

1

The Si pump minimum flow function was required to prevent pump failure dunng a i

limited set of small- to intermediate-size RCS pipe failures. The licensee performed

simulator runs which indicated that operator actions would prevent the core from

becoming uncovered during a small-break loss-of-coolant accident, even if both S1

'

pumps failed. However, the simulated failure mechanism provided earlier warning of a

problem with Si than would have occurred in the plant as a result of the frozen line.

6.0 Follow-up Assessment of the Ice Plua in the RWST Inlet Line

The licensee demonstrated that the flow path through the RWST inlet line was operable

on December 12,1998, during performance of activities per in-service Test

Procedure 01 "High Head Safety injection Pumps and Valves (Quarterly), Unit 1." The

next scheduled date for performing this test was March 10,1999. No other scheduled

activities that could have established flow through the RWST inlet line were identified in

the licensee's planning system.

The licensee concluded that flow through the RWST inlet line was blocked on the

morning of January 5,1999, when the low-head (approximately 120 psig) P-33 pump

could not establish recirculation flow to the RWST. There were no data available to the

inspectors which indicated the location or thickness of the ice plug. The licensee

evaluated the temperatures recorded at point 126 (the operating heat trace on the

RWST inlet line), at point 133 before it was placed in bypass on December 22,1998,

and ambient air temperatures recorded in the station logs. From this evaluation, the

licensee determined that the pipe temperature at point 133 dropped below freezing on

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l

. three occasions. The first was for a period of about 2 days starting on December 22. l

The second was fora period of about 3 days starting on December 30. The third and

final period began on January 5,1999, and ended that evening. This evaluation was of

limited use in bounding the potential periods of pipe freezing because the licensee could

i

not determine how closely the temperature at point 133 reflected the temperature at the

l point in the pipe at which the ice plug actually formed.

Based on an engineering assessment, the licensee concluded that an ice plug of 2 pipe

i diameters (approximately 4 inches) would effectively block flow in the pipe at the shutoff

head of the Si pumps. An orifice installed in the SI pump minimum flow bypass lines off

of each pump (before they joined) normally maintained pressure in the downstream pipe l

i at values below 150 psig. Shutoff head pressure of the SI pumps was approximately )

l 1500 psig. The existence of the ice plug would have eliminated the pressure drop l

through the orifice, and would have resulted in pressurizing the entire minimum flow j

path to pump shutoff head pressure. The licensee calculated that the stainless steel :

'

'

pipe in the RWST inlet line would not have failed at SI shutoff head pressure. Based on

this assessment, the minimum flow function was considered inoperable.

i

The inspectors questioned whether the closed isolation valves which normally isolate the

Si minimum flow bypass flow path from other systems connected to the RWST inlet line

would have withstood the SI shutoff head pressure. The licensee concluded that SI

pump shutoff head pressure would have caused the failure of pressure boundary l

! diaphragms in three normally closed isolation valves on the RWST inlet line. The I

licensee performed tests which indicated that sufficient flow would have been created I

through these failed diaphragms such that the SI pumps would not have failed during a i

small- to intermediate-break LOCA. The licensee further concluded that the loss of I

water from the RWST through the failed valvos would have had no adverse impact on

the RWST inventory for a small-break LOCA. The licensee therefore concluded that the

SI system remained operable, but degradediwhile the RWST inlet line was frozen. The

calculations and test results supporting the licensee's operability determination were

reviewed by the inspectors. No problems were identified; however, the inspectors noted

that the design and licensing basis does not credit the structural failure of low presture .

system boundary valves to ensure that an emergency core cooling system function is l

operable.

Conclusions ,

.The licensee concluded that the normal minimum flow path for the Si pumps was

unavailable for an indeterminate period of time due to the frozen RWST inlet line.

Based on tests performed after this event, the licensee concluded that sufficient flow l

would have been established through failed low pressure boundary valves to have

assured the safety-related function of the SI pumps during any previously analyzed

accident scenario. However, the design and licensing basis does not credit the

structural failure of low pressure system boundary valves to ensure that an emergency

core cooling system function is operable.

i 15

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7.0 Prior Licensee Cold Weather-Related Corrective Actions

The inspectors reviewed the docket for recent cold weather problems at Point Beach.

The results of that review are listed below.

In IR 50-266/93018(DRP); 50-301/93018(DRP), issued on January 31,1994, the

licensee's preparations for cold weather were discussed. The licensee

experienced problems with SG blowdown flow sensing lines freezing, inadequate

main steam isolation valve solenoid-operator enclosure heating, and low

operating air pressures for several 345-kilovolt switchyard breakers. The

licensee corrected each problem.

in IR 50-266/96002(DRP); 50-301/96002(DRP), issued on April 17,1996,

problems with low operating air pressures for some 345-kilovolt switchyard

breakers during cold weather were discussed. The identical problem had been

discussed in IR 50-266/93018(DRP); 50-301/93018(DRP). The inspectors were

concerned that the air leaks introduced a common mode failure mechanism that

could affect offsite power availability. The licensee replaced the breakers with a

new type less susceptible to cold weather air leaks.

In IR 50-266/97003(DRP); 50-301/97003(DRP), issued on February 22,1997,

the licensee's cold weather preparations and implementation of the freeze

protection program were discussed. The inspectors concluded that the licensee

was adequately prepared for cold weather; however, the inspectors identified the

lack of a formal mechanism to identify heat lamp use in the facade, the lack of

an oversight individual for the cold weather / freeze protection program, and the

untimely resolution of facade freeze protection system deficiencies which created

operator workarounds.

In IR 50-266/97021(DRP); 50-301/97021(DRP), issued on December 22,1997,

the licensee's preparations for cold weather were discussed and independent

verification checks were performed of selected cold weather protection

equipment. The inspectors did not identify any problems. The inspectors

documented that the licensee had reduced the corrective maintenance backlog

for facade freeze protection system components and had been installing new

heat trace wiring to upgrade portions of the system.

On December 15,1997, the NRC completed an inspection of the licensee's

implementation of 10 CFR 50.65 as documented in IR 50-266/97025(DRS);

50-301/97025(DRS). The inspectors identified that the licensee had failed to

include the facade freeze protection system in the scope of the maintenance rule

and issued a severity level IV violation (VIO 50-266/97025-01(DRS);

' 50-301/97025-01(DRS)). In a follow-up inspection (IR 50-266/98022(DRS);

50-301/98022(DRS), the inspectors reviewed the licensee's corrective actions

and closed the violation. The inspectors concluded that the scoping deficiency

was properly corrected, portions of the facade freeze protection system were in

the program, and acceptable system performance criteria were established.

During the current inspection, the inspectors were told that the RWST inlet line

heat trace had been missed in the reclassification of the system. Subsequently,

16

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the licensee placed the entire facade freeze protection system into the

maintenance rule program, and planned to remove portions of the system only

after a case-by-case evaluation was performed.

On January 8,1998, the Unit 1 high voltage station auxiliary transformer isolated,

as documented in IR 50-266/97026(DRP); 50-301/97026(DRP). The licensee's

event investigation team determined that a short circuit in the bus ductwork

l occurred because of water-saturated and moisture-damaged insulation. The

i root cause of that condition was determined to be the failure of installed strip

heaters. A work order had been initiated in August 1996 to repair the strip

l heater supply breaker; however, it had been inappropriately classified and was

'

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still in the licensee's minor maintenance backlog as of January 8,1998. The

licensee implemented corrective actions to preclude recurrence, such as

reviewing the minor maintenance backlog Mr other inappropriately classified

work orders (none were identified) and conducting a periodic review of the

material condition of all strip heater breakers. The licensee subsequently

eliminated the minor maintenance program.

Documented in IR 50-266/98021(DRP); 50-301/98021(DRP), issued on

January 15,1999, are the results of the inspectors' walkdown of portions of the

plant subject to severe cold weather conditions and their review of cold weather ;

preparations. While no immediate safety issues were identified, the inspectors I

were concerned with the cold weather preparation program. Also, as a result of

equipment problems caused by severe cold weather, the licensee had identified

-deficiencies with the operation of the facade freeze protection system. Some

were repetitive from previous years. In response, the licensee entered the

deficiencies into the corrective action systr.n and in late December 1998, plant j

management directed that a root cause 2 valuation be conducted. The j

inspectors had decided to track the lic'. nsee's evaluation of the inspector-

identified issues and the corrective r,ctions for the . licensee-identified facade

freeze protection system deficienr..es as Inspection Followup Item !

(IFI) 50-266/98021-01(DRP); 50 301/98021-01(DRP).

The inspectors retrieved all of the cold weather-related CRs from the licensee's

corrective action database from January 1,1994, to January 5,1999. The inspectors

reviewed the conditions identified in the CRs, the licensee's corrective actions, and the

timeliness of the corrective actions. The CRs that the inspectors reviewed are listed in

the " List of Documents Reviewed" section at the end of this inspection report.

The licensee identified and documented via CRs a variety of cold weather related

concerns over the time period reviewed. In each case, the licensee developed and

implemented, in a timely manner, appropriate corrective action for the concerns

documented in each CR. Some instances of repeated problems previously identified in

CRs did occur, but these typically were prior to completion of planned corrective actions

to prevent reoccurrence. The inspectors did not identify any direct, specific precursors

for the January 5,1999, event from the corrective action database review. However,

l

while the licensee's corrective actions were appropriate for each CR, the actions were

I narrowly focused on resolving the specific concern identified in the associated CR.

.

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Conclusions

The licensee had experienced equipment challenges from inadequate cold weather

j preparations and freeze protection system failures from 1994 to the most recent

inspection period. The licensee took appropriate, timely corrective actions for each

-

individual problem; however, not until late December 1998, had the licensee identified

the need to perform a root cause evaluation of the continuing equipment problems with

the facade freeze protection system. The inspectors concluded that the corrective

actions had been adequate, but had not been broad enough in scope to prevent the

January 5,1999, event.

8.0 Corrective Actions identified Durina This Inspection

The inspectors reviewed the intermediate-term corrective actions being taken by the

licensee to address the material condition problems and design and procedural

problems with the facade freeze protection system. Many of these correctiva actions

were described in the licensee event report for the plugged RWST inlet line

(LER 50-266/99001-00). No significant shortcomings were identified. Plant

management was aggressive in its efforts to resolve many of the facade freeze

protection problems discussed in this report.

The licensee informed the inspectors that the Common Cause Event investigation Team

chartered to investigate this event would provide broad, long-term corrective action

recommendations to address any generic cold weather preparation or other

programmatic issues that it identified. The licensee indicated that any such corrective

actions would be provided in a supplement to the LER for this event.

9.0 Miscellaneous issues

(Closed) LER 50-266/99001-00: Safety injection recirculation line to RWST frozen. The

contents of the LER were substantially consistent with the findings of the inspectors. No

significant problems were noted with the corrective actions included in the LER. The

licensee stated that a supplemental LER will be issued to document the findings of its

event investigation team.

(Closed) IFl 50 266/98021-011DRP): 50-301/98021-01(DRP): Plant's cold weather

preparation program. The inspector concerns identified in this item will be tracked to

resolution using eel 50-266/99004-02(DRP).

1

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l TEMPERATURES AT POINT BEACH

l WHILE WORK ORDER 9819891 WAS OPEN

!

Date Shift 1 Shift 2 Shift 3

12/22/98 -0.5' F -1.2 * F 2.2*F

12/23/98 8 8 16

12/24/98 6 11 16

12/25/98 12.8 15.7 26.8

12/26/98' 28 11 17

12/27/98 24 29 31

12/28/98 15 14 33.7

12/29/98 36.5 28 12

12/30/98 0 -6 4

12/31/98 5 3 7

1/1/99 0 -1.6 13.5

1/2/99 19 22 21.8

1/3/99 22 14.5 18

1/4/99 9 5 7

1/5/99 -9.4 -14.1 4

All readings listed above were recorded in the licensee's " Safeguards Shift Log." Temperatures

were measured at the plant meteorological tower and may vary slightly from actual

temperatures in the facade area.

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 Februng 22,1999. The licensee acknowledged the findings

presented. The inspectors asked the licensee whether any materials examined during the

inspection should be considered proprietary. No proprietary information was identified.

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! PARTIAL LIST OF PERSONS CONTACTED

i

Licensee

J. G. Schweitzer, System Engineering Manager

J. R. Anderson, Operations Manager i

M. E. Reddemann, Site Vice President

R. G. Mende, Plant Manager

R. P. LaRhette, Manager - Quality Assurance j

i

INSPECTION PROCEDURES USED

IP 40500: Effectiveness of Licensee Controls in identifying, Resolving, and Preventing .

Problems

IP 71707: Plant Operations l

IP 71714: Cold Weather Preparations j

ITEMS OPENED, CLOSED, AND DISCUSSED

Ooened

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50-266/99004-01(DRP) NCV Failure to maintain a required pror,edure current

following installation of modificatlon work

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50-266/99004-02(DRP) eel Failure to address the low temperature of a safety-

related pipe

Closed l

50-266/99004-01(DRP) NCV Failure to maintain a required procedure current

following installation of modification work

50-266/99001-00 LER Safety injection recirculation line to RWST frozen

50-266/98021-01(DRP) IFl Plant's cold weather preparation program

50-301/98021-01(DRP)

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LIST OF ACRONYMS USED

l

amp Ampere

CFR Code of Federal Regulations -

CR Condition Report.-

DRP Division of Reactor Projects

DSS _ Duty Shift Supervisor l

l eel Escalated Enforcement item l

l EOP Emergency Operating Procedure '

'F. Degrees Fahrenheit-

gpm Gallons Per Minute

SG Steam Generator l

IFl Inspection Followup Item

IP Inspection Procedure

IR . inspection Report

LOCA Loss-of-Coolant Accident

NOED Notice of Enforcement Discretion

NRC Nuclear Regulatory Commission

OD Operability Determination

01 Operating Instruction

PAB Primary Auxiliary Building

psig Pounds Per Square Inch - Gauge

, RCS Reactor Coolant System

R.O Reactor Operator

RWST Refueling Water Storage Tank

SE . Safety Evaluation

SG Steam Generator

SI. Safety injection

SRO Senior Reactor Operator

T/S Technical Specification

URI Unresolved Item

VIO Violation

WO !

Work Order

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LIST OF DOCUMENTS REVIEWED

Cor.dition Reports

CR 94-011, " Air Leakage on 345 kilovolt Switchyard Breakers," dated January 21,1994

.

CR 94-012 " Unit 2 Seal Well Outlet Valve Failed to Close Electrically," dated

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January 20,1994

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CR 94-078, "G-01 Room Intake Louvers Blowing Open," dated February 23,1994

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CR 94-594 " Freeze Protection Circuits Appear incorrect on Drawings," dated

Novemt* ' 1994

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CR 94-595, " Steam Generator Blowdown Flow Indicator Enclosures and Sensing Lines ,

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i not Monitored for Freeze Protection," dated November 27,1994

CR 94-600, " Damaged Insulation on Facade Freeze Conductor," dated November 28, s

1994

a CR 95-011, " Unit 2 Steam Generator Blowdown Flow Indication Frozen," dated

January 4,1995

. CR 94-077, " Unit 1 Steam Generator Blowdown Flow Indicator Frozen," dated

February 13,1995

. CR 95-079, " Cold Weather Concerns in Emergency Diesel Generator Building," dated ,

February 11,1995 ;

CR 95-623, " Unit 1 Steam Generator Blowdown Tank Level Indicator and Tank Bypass

Valve Frozen in Cold Weather," dated December 9,1995

a CR 95-624, " Steam Generator Flow Indicators Freeze Up," dated December 10,1995

+- CR 94-627, " Tornado Dampers Forced Open by High Winds," dated December 9,1995

-

CR 96-030, " Steam Generator Blowdown Instrumentation Freezes," dated January 20, .

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1996

. : CR 96-1866, " Unit 2 Steam Generator Steam Header Blowdown Control Valve Slow to

Operate Due to its Heat Tracing Being De-energized," dated December 27,1996

.- CR 97-0158, " Steam Generator Blowdown Flow Indicator Frozen," dated January 17,

1997-

+- CR 97-0630, " Unit 1 Steam Generator Blowdown isolation Valve Frozen," dated

February 25,1997

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.- CR 97-2783, " Freeze Protection Wiring incorrectly Labeled," dated September 10,1997

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CR 97-2918, "Potentially Incorrect Quality Assurance Scoping," dated September 17,-

1997

- CR 97-2978, " Freeze Protection Circuit 1-FF-01-18A," dated September 20,1997

CR 97-3807, " Replacement of Facade Freeze Protection Systems Heat Traco Circuits," I

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dated November 18,1997

+

CR 97-3950, " Facade Freeze Protection Reorder Points / Circuits Bypassed," dated

December 3,1997

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CR 97-3995, " Potential for Containment Atmosphere Post-Accident Sample System to

Freeze Up," dated December 8,1997

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CR 98-0065, "No Status of Temporary Freeze Protection Provided," dated January 11,

.

1998

a CR 98-0070, "G-03 Room Louvers Not Working," dated January 11,1998

.

CR 98-1661, " Freeze Protection Systems Unnecessarily Left in Service During Warm

Weather," dated April 23,1998

- CR 98-4172, " Blowdown Level Transmitter Frozen Due to Facade Temperature," dated

December 28,1998 l

a CR 98-4192, " Steam Generator Blowdown Flow Indicators Frozen," dated December 22,

1998

-* CR 98-4207, "Lakeshore Trailer Complex Well House Pipes Froze," dated

December 23,1998

. CR 99-0019, " Gravity Louvers Allow Snow into G01/G02 Diesel Room," dated ,

- January 2,1999

! * CR 99-0031, " Unit 2 Steam Generator Blow Down Lines Froze Up," dated January 5, I

1999

CR 99-0036, " Unit 1 "B" Steam Generatar Pressure Sensing Line Frozen," dated

January 5, .1999

! Quality Condition Reports

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! * QCR 94-010, " Deficiencies Noted in RWST Level Transmitter Freeze Protection

Scheme," c%ted February 23,1994

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ML20204D831

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