ML20205N422
| ML20205N422 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 04/12/1999 |
| From: | Lanksbury R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Reddemann M WISCONSIN ELECTRIC POWER CO. |
| References | |
| EA-99-002, EA-99-2, NUDOCS 9904160271 | |
| Download: ML20205N422 (41) | |
Text
April 12, 1999 EA 99-002 Mr. M. E. Reddemann Site Vice President Point Beach Nuclear Plant 6610 Nuclear Road Two Rivers, WI 54241
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SUBJECT:
PREDECISIONAL ENFORCEMENT CONFERENCE HANDOUTS
Dear Mr. Reddemann:
1 On March 26,1999, NRC Region lli and Headquarters personnel met with you, Mr. M. Sellman, and other m3mbers of the Po nt Beach staff, to discuss an apparent violation conceming operator response to a low temperature alarm for tha minimum flow recirculation line for the Unit 1 safety injection system. The attachments to this letter contain the handout provided to the NRC by Wisconsin Electric during the meeting, a copy of the proposed apparent violation, and the agenda for that meeting. As discussed at the conference, the apparent violation is subject to further review and may be changed prior to any resulting enforcement action. You wiil be notified by separate correspondence of the resalts of our deliberation on this matter. l In accordance with Section 2.790 of the NRC's " Rules and Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the attachments will be placed in NRC's Public !
Document Room. j l
Sincerely,
/s/ Roger D. Lanksbury Roger D. Lanksbury, Chief Reactor Projects Branch 5 Docket Nos. 50-266: 50-301 License Nos. DPR-24; DPR-27 Attachments: 1. Wisconsin Electric handout
- 2. Proposed apparent violation
- 3. Conference Apanda See Attached Distribution DOCUMENT NAME: G \FOIN'.confhan1.wpd To receive a copy of this document. Indicate in the bom "C" = Copy without attachmentlenclosure *E* = Copy with attachment / enclosure v = w copy OFFICE Rlll 6 Rill h Rill Rlli NAVE Kun9wskdh Lanksbur3@h E _
DATE 04f,l/99 04/1/99 OFFICIAL RECORD COPY
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9904160271 99o412 l PDR G
ADOCK 05000266 pg
POINT BEACH PREDECISIONAL ENFORCEMENT CONFERENCE FROZEN SAFETY INJECTION RECIRC MIN FLOW LINE, UNIT 1 FRIDAY, MARCH 26,1999,9:00-12:00 (CST)
AGENDA NRC Regional Administrator Opening Comments Jim Dyer DRP Background and Comments Marc Dapas Wisconsin Electric Introduction Mike Sellman I Event Overview Rick Mende Safety Consequences / Operability Tom Kendall NN3R Classification Tom Kendall l Operations Actions and Expectations John Anderson Corrective Actions Mark Reddemann Enforcement Perspective Vito Kaminskas Wisconsin Electric Conclusion Mike Sellman .
1 NRC Caucus Jim Dyer I DRP Concluding Remarks Marc Dapas Regional Administrator Concluding Remarks Jim Dyer Questions from the Public and Media Jim Dyer, et al. !
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I M. Reddemann !
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cc w/encts: R. Grigg, President and Chief l Operating Officer, WEPCO M. Sellman, Senior Vice President, Chief Nuclear Officer R. Mende, Plant Manager J. O'Neill, Jr., Shaw, Pittman, Potts & Trowbridge K. Duveneck, Town Chairman l l
Town of Two Creeks B. Burks, P.E., Director Bureau of Field Operations J. Mettner, Chairman, Wisconsin Public Service Commission S. Jenkins, Electric Division Wisconsin Public Service Commission State Liaison Officer Distribution:
CAC (E-Mail)
RPC (E-Ma;l)
Project Mgr., NRR w/encls J. Caldwell, Rlli w/encls B. Clayton, Rlli w/encls SRI Point Beach w/encls DRP w/encls DRS (2) w/encls Rlli PRR w/en s PUBLIC w/encls h
Docket File w/encls GREENS I !
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l l 1 The apparent violation discussed at this predecisional enforcement conference is subject to further review and is subject to change prior to any resulting enforcement action
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10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Action," requires, in part, that measures shall be l established to assure that conditions adverse to quality are l promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined.
Contrary to the above, as of January 5,1999, measures were not established to promptly correct or determine the l cause of a sigMficant condition adverse to quality associated with the common minimum flow line for the Unit 1 safety injection pumps. Specifically on December 22, !
1998, the licensee identified that a temperature recorder i for a section of the minimum flow line, located in an area exposed to extreme low temperatures, was indicating near l freezing temperature. Corrective action did not commence until January 5,1999 when, subsequent to questions by the NRC, a section of the minimum flow line was found plugged with ice. This resulted in the declaration that both safety injection pumps were inoperable because the minimum flow was not available. This was a significant condition adverse to quality because the minimum flow l line prevents pump failure by ensuring adequate cooling of the pumps during a limited range of small to intermediate size reactor coolant system pipe failures.
The apparent violation discussed at this predecisional enforcement conference is subject to further review and is subject to change prior to any resulting enforcement action l _
PBNP Pre-Decisional Enforcement Conference March 26,1999 Agenda Introduction Mike Sellman Safety Consequences / Operability Tom Kendall
- Event Overview Rick Mende Operations Actions and Expectations John Anderson Corrective Actions Mark Reddemann NNSR Classification Tom Kendall
- Enforcement Perspective Vito Kaminskas
- Conclusion Mike Sellman 3/25/1999 Shdei l
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Introduction 1
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Mike Sellman 1
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i V25/lW) Shde 3 l
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i Introduction 1
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On December 22, Freeze protection alarm received on RWST return line l
- On January 5, Sr. Resident reviewed priority equipment list and asked if SI recirc line was operable l
i l - Attempt to pass flow through the line was unsuccessful l
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- As a result, both SI pumps declared inoperable
- Subsequent testing proved the SI system operable l
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I Introduction
- Why did this occur?
Erroneous diagnosis resulting in low work order priority
- Single S1 recirc line with one heat trace circuit
Introduction
- Based upon evaluation and testing the SI system was operable but degraded Potential safety consequences were negligible j l
Robust corrective actions to change the physical plant are in process
- Corrective actions go beyer.o the physical plant j e, , su,s ;
Introduction Questions / Issues to be Addressed:
- 2. Discuss Operator performance and their decision making process. q
- 3. Discuss the corrective actions in thee, in progress and planned. 1
- 4. What was the process used to classify (lie freeze protection system as NNSR and to establish the maintenance and operational controls?
- 5. How are failures evaluated for effect on safety related components / systems? 3,,3,,
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I Introduction Summarv A matter of misdiagnosis; not a failure to take prompt corrective action
~ Broad corrective actions:
- Case study presentation to employees
- Robs
- plant modifications
- Ca. for organizational change No need for escalated enforcement:
- Committed to fundamental change
- Negligible safety consequence l
- Robust plant modification l l
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l Safety Consequences / Operability Tom Kendall V25/lWN Shh 9 Initial Operability Determination J Entered TS Action Statement for SI pumps being inoperable Requested and received NOED Promptly performed an Orierability Determination per GL 91-18
- Si pumps inoperable pending establishment of a confirmed recirculation path e , . . s: ..,, o ,
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I Subsequent Investigation Subsequent Operability Based on Testing and Analysis Used Only to Evaluate SI Support Function Capability and Safety Consequences System Restored to Previous Conditiori
- Not Intended to Justify Future Operability
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Safety injection System l - -
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RWST IIc.k y
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Recire. Line isolation Valves From CSPs WHUTs 5 CVCS 5 From SFPI P 33 D 2', r
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SI Pump Data Shutoff Head: ~1460 psi
- 8 Stage centrifugal pumps 700 Hp Motors 700 gpm at 1118 psig
.V25/lirN Slide 13 ,
Accidents & Transients That Credit SI Loss of Coolant Accidents (LOCAs)
- Rod Ejection Accident
. Steam Generator Tube Ruptures (SGTRs)
Secondary Function: Reactivity Control
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i Operability Concerns Limited to small break events that
-Initially keep RCS pressure above SI pump Shutoff Head
- Require High Head Injection to prevent core damage LOCA smaller than ~2" diameter SGTRs 3/23/17M Shde 15 l
Diaphragm Valve h
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L Diaphragm Valve Data Safety Related 2" Class 150 Saunders Pattern Rated for 200 psig service at 200 oF Leak tested at 325 psig for 1 minute by manufacturer.
3C5/19W Shde 17 Diaphragm Valve Testing
- Testing performed at Curtiss Wright Flow Corporation's Target Rock test facility.
. Testing met 10 CFR 50 Appendix B QA requirements.
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Test Configuration mgn Pressure Air Bank water volume Press. Press. Temp. Press.
Xducer Kducer Xducer Xducer Upstream Stop Calibrated Valve being Downstream Valve Throttle Valve Tested Stop Vaive y 5/tW9 Slide 14 l
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t Sg. m:.i Test Configuration W **7g ,
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. Chnqig(g$; Test Results
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ET . _ s .'y 3/?5/1999 Shde 21 Test Results Valves start leaking at ~500 psig Leakage is immediate with no discernable time delay Leakage phenomenon is consistent and repeatable Valves behave like variable orifices or relief valves Valve diaphragms showed time-dependent .
degradation (i. e. flow increased with constant pressure). ,,,,, ,_
System Modeling Modeled SI systen, as a network of orifices Used lower of two test results 1
Used IST data to quantify flow restriction '
from rest of system wan, s,.n Calculated Flows SI pumps running: 1 2 I Flow per pump (gpm): 88 78 Line press. (psig): 541 748 Flow per valve (gpm): 29 52 l
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l Plant Operating Experience Manufacturer originally recommended 70 gpm Have run pumps extensively at ~110 gpm for IST surveillances Average run time was 46 minutes Langest run time was 189 minutes Pump performance and vibrations all acceptable, no indication of degradation from low How operation.
3/25/1999 Slide 25 I
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SI Pump Operability Temperature rise would have been minimal
(~18 deg F vs. ~12 deg F)
Pumps had sufficient NPSH to ensure stable operation Pumps were available and fully functional for extended operation at ~78 gpm.
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- Collateral Issues l
External Leakage j -Internal Flooding: Manageable
-Wetting of Equipment: Acceptable
- Radiological' Consequences: No release P
Internal Leakage: Minimal Loss ofInventory: Acceptable
.1/25/1999 Shde 27 Simulator Runs )
3 scenarios: 1 SBLOCA,2 SGTRs W/O SI Pumps 2 Operating Crews Each scenario correctly diagnosed and addressed
- None resulted in core uncovery All successfully terminated using existing Emergency Operating Procedures l
r Summary of Safety Consequence
Overall SI system was operable but degraded Leakage would have had negligible impact on equipment important to safety Internal flooding would have been addressed by existing procedures
- Release to PAB would have been minimal No off-site release Health and Safety of the public not impacted 3/25/1999 ShJe 29 c:Ut.ee s w,lr u,
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Event Overview Rick Mende l
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3/25/1W9 Shde 31 l
Event Overview l
- Circuit opened April,1998
- Apparent cause: age related failure e Performance monitoring and trending not conducted
- Service life not established, therefore, no replacement j scheduled I
- I Amperage Measurement PM not performed as scheduled (5/1.198); PM deferred due to planned freeze protection
, circuit upgrades - No formal PM deferral justification process !
- Extensive modification < ar.d repairs completed on freeze ,
protection system during summer and fall
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Event Overview
- Cold weather preparation process not well integrated
- Deferred PM not completed prior to onset of cold weather December 18,1998
+ Amperage readings taken per a routine PM Acceptance criteria waived due to ongoing modifications (rebaselining was being performed on the system)
. No Work Order issued for the subject freeze protection circuit
. No formal interface between Maintenance and Engineering for review of PM information after test 3/23/1994 Shde 33 Event Overview December 22,1998
- Outdoor temperature drops below 0 *F
. Heat tracing alarm occurs at 35 "F (0625)
. Design - Single heat tracing circuit to heat recire line
. Operator Dispatched, verified circuit energized, inspected pipmg
- Procedure: 01-106 did not require immediate taking of
. amperage; pipe temperature was not established
. Based upon heated RWST, some circuit overlap, probable thermocouple problem, and system engineer concurrence, crew concluded line would not freeze.
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Event Overview l December 22,1998 (cont.) ,
- WO written - Believed line would not freeze
- WO review in Work Control Center; assigned default priority ,
- Nomenclature did not prompt recognition of WO significance
. Generic facade freeze protection issues placed on priority equipment list
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3/25/lW9 Slide 35 Event Overview December 28,1998
= CR written leading to assignment of root cause evaluation on {
I fagade freeze protection issues December 30,1998
- Plant managemeia requests unique identification of failed freeze protection circuits on priority equipment list in place of generic fagade freeze protection issues u ca, su +
Event Overview December 31,1998
. WO for the specific circuit placed on the priority equipment .
list; no status change but priority raised to 5 and WO assigned to the next workweek for this system
- Process for setting Operations priorities not well defined and ]
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maintenance did not modify work efforts due to low pricrity 1 January 5,1999
- NRC Resident reviews priority equipment list; questions .
"RWST inlet 'me" status (~ 10:45)
- Operatar walks down piping and circuit (~12:00) 3C$/1999 Shde 37, Event Overview
- FIN Team installs heater and Operations attempts to verify line not frozen by running recirculation pump. (12:35)
. No flow occurs - Line Frozen (1235)
- Safety Injection and Containment Spray pumps declared inoperable (1240)
- Determination made that system outside design basis (1340) 10 CFR 50.72 notification (outside design basis) (1415)
. Commenced Load Reduction at 307c per hr. (1506)
= 50.72 notification for TS required shutdown (1515) u s+m sua, ,
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l Event Overview e Requested Enforcement Discretion + 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (1630) l l
- Started 'B' SI Pump to establish alternate recirculation flow path alignment (1800) l
- 'B' SI pump functional with 110 GPM alternate recire now path established (1816) l l e Received Verbal NOED and stopped load decrease at ~25%
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- Operability Determination completed for CS and Si pumps with throttled full flow recire line (after 50.59)(2230)
I M5/19W ShJe 39 Event Overview l
- Heat applied to mini-recirc line (2230)
- Established flow (58 gpm) thru mini-recirc line (2234)
January 6,1999 I
50.59 approved for 'B' SI pump alternate recirculation alignment (0026) (still in 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LCO)
- Successful test of 'A' SI pump through mini-recirculation line (2108) i january 9,1999 l
- Both Si pumps in normallineup (2301)(Exit LCO) e i .. , s u,. .. .
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i Event Overview Summary l . Misdiagnosis on December 22,1998 - WO Issued
. WO priority was raised on December 31,1998
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- Rediagnosis results in Frozen Line discovered January 5
- Plant shutdown begun and NOED requested
- Alternate recirculation' established
- NOED granted and shutdown curtailed
- Mini-recire line restored; SI system returned to full operability e Both SI pumps in normal lineup (Exit LCO) ;
3/23/1999 Shde 41 l
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Operations Actions and Expectations John Anderson 3/25/1999 Shde 4)
Initial Operations Response
- IT-13. "RWST inlet" in alarm (low temperature)
- Operator dispatched to facade e Verified circuit energized and inspected piping
- Verified that the related circuits on the recire line were functioning m ,,, s u. u l
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I Initial Operations Response
. RWST is heated, therefore, some heat transfer to the connected recirc line (also insulated)
- Other circuit on this line was functioning l
. Heat tracing circuit believed to be overlapped
- Previous experience showed failed thermocouple as a typical failure e System Engineer concurred with the reasoning
- Concluded line would not freeze m - si.e i
Initial Operations Response e Procedure 01-106 actions completed as crew believed i applicable l I
e Crew concluded line would not freeze -- probable faulty thermocouple
. Line was not drained or fluid circulated
. Work order for circuit written (although this specific WO was low priority); also, general note on faqade freeze protection was added to priority equipment list
- Subsequent raanagement review of priority equipment list resulted in specific FFP circuits being placed on the priority equipment list y e ,, u w o,
Follow-up Operations Response
. Operators performed plant walkdown looking for additional cold-weather vulnerabilities
. System engineers reviewed each systet coid-weather issues (be' yond just faqade freeze ; ;oiection)
- Operations and Engineering reviewed 01-106 anil issued changes to reflect recent work on the freeu protection system and strengthen operations alarm response V25/1999 Shde 47 Lessons Learned i
Adverse events create opportunities to fundamentally question ourselves Crew is the final barrier SRO is the focal point of crew success or failure as a barrier against adverse events The role and responsibility of the SRO as " chief nuclear safety officer" on-site during his watch has been clearly established
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i Operations Corrective Actions
- Ops. Manager held all-hands SRO meetings to discuss this event and reinforce expectations
- Continuing series of Shift Superintendent meetings to evaluate progress
- Each SS is reporting his and the crew's effectiveness in specific Conduct of Operations areas focussing on the role of the SRO 3/25/1999 Shde 49 Operatio:is Corrective Actions Shift Superintendents have begun mentoring other crews' performance Ops Manager is using weekly Operating Experience training sessions to focus on this and other events with
'similar precursors !
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Corrective Actions Mark Reddemann 3/25/l999 Shde 51 Corrective Actions Root Cause Evaluation performed by 6 member team Corrective Actions (CAs) were identified for improvements in four major areas:
- Design j
- Configuration Management l
- Programmatic / Procedural l
- Organizational CAs are specific to the event but also very broad Over 60 CAs have been identified to date Over one-half of these have been completed, remaining ao in prog m , , , . , , , s ,, ,, c
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Corrective Actions Completed Ul Safety Injection and Containment Spray returned to full operability Additional heat trace installed on Ul SI recire line 1
Faqade Freeze placed in Maintenance Rule (a)(1) status and system j performance criteria established I Performed detailed review of engineering data obtained during the PM i
- Numerous heat trace circuits investigated and several repaired a Formalized and improved approach for use of the priority equipment list a Process established for review, justification and approval of PM I
deferrals Maintenance Guide prepared for expeditious thawing of frozen lines V25/1999 Shde 53 Corrective Actions Completed (cont)
- Detailed walkdown of fagade freeze protection circuits and associated configuration updates (Master Data Book)
Alarm response procedure updated to reflect current system configuration, additional response guidance provided !
Engineering review of cold weather preparations required
- FSAR change has been processed to reflect need for recirculation l line for operability of SI system Si pump performance under minimum flow conditions was evaluated Expectations for Operating Experience evaluations communicated in Engineering Support Personnel training
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Corrective Actions i
Near Term A tions 5 in Progress
- Review fagade piping that is not heat traced Determine service life and establish an appropriate replacement schedule for heat tracing
- Identify other safety related systems whose operability could be affected by non-safety relatcu systems (5 found)
- Train operators on lessons learned related to SI and faqade freeze protection V25/Pm Shde 55 Corrective Actions Near Term Actions in Progress (cont.)
- Case study being given to all personnel on organizational lessons learned
- Improving assignment of WO priorities through training of ;
operations, maintenance, and engineering personnel f
= Improving monitoring of heat trace circuit performance parameters
- Implementing system performance, monitoring and trending for faqade freeze protection Evaluating other non-safety support systems to ensure adequate performance and trending
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Corrective Actions Lone Term Actions in Procress
- Evaluate and implement a robust, permanent solution to fagade freeze issues
- Enhance our cold weather bill to schedule, coordinate and verify preparations a
Complete development of as-built drawings for heat trace circuits Develop detailed expectations for reinforcement of a questioning attitude
- Reevaluate IN 98-002 and selected scope of INPO O&MRs 3/25/19W Shde 57 i
Corrective Actions i Future Actions Determine the cause of heat trace circuit failure.
If other than age related, evaluate the extent of the
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as'-found condition i 1
- Quality Assurance organization will review effectiveness of cold weather preparations next j
' summer / fall l
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1 Non-safety Related Classification I
Tom Kendall 3/25/1999 Shde 59 l
Non-safety Related Classification Safety Related classificauan applies to systems that must remain functional during and following design basis events to ensure:
Integrity of reactor coolant pressure boundary Capability to shut down the reactor and maintain it in a safe shutdown condition Capability to prevent or mitigate the consequences of an accident that could result in potential release in excess of Part 100 guidelines J
Non-safety Related Classification
- Freeze protection system not part of the pressure boundary
- Function is to prevent freezing of the borated water in the RWST and associated piping. (FSAR Sec 6.2)
- Need for the borated water source described in safety analysis (FS AR Sec 14)
- If freeze protection becomes inoperable, alternate means of ensuring line is operable at:: available (monitoring, Dowing)
V15/1999 Shde 68 Non-safety Related Classification
- Operability of the freeze protection system is monitored each shift l (Aux-Building Shift Log) l
- Control room noti 6ed if any discrepancies found l
- Low temperature alarm also received in the control room.
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I Non-safety Related Classification
- A failed circuit would not render the line inoperable immediately due to the thermal mass and insulation.
Orderly placement of the unit in safe shutdown could be completed prior to a system being inoperable due to freezing. f
+ Tile system is properly classified.
3/25/tw9 Shde 63 Support System Operability How are support system failures evaluated for ;
effect on safety related components / systems? l
- In each case an initial Operability Determination is .
made by the Senior Reactor Operator on shift. l
- Engineering may be consulted to assist in this evaluation.
. . The procedure describing that a formal OD be performed
. for a degraded component that supports a safety related system will be enhanced.
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l Enforcement Perspective Vito Kaminskas 3/25/1999 Shde 65 Enforcement Perspective
. Severity of the violation
. Application of factors to consides for determining the amount of a civil penalty that may be assessed
. Any other application of the Enforcement Policy to this case c:wn, sw+
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Enforcement Perspective Severity of the Violation l
Prompt and aggressive response to NRC question was appropnate
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- Operating Crews demonstrated on the simulator, using Emergency Operating Procedures, that if Si failed to function .
during an accident, the reactor was maintained in a safe l condition
- A matter of misdiagnosis, not a failure to take prompt corrective action Ifealth and safety of the public was not impacted Escalated enforcement is not warranted , , , , , , , ,
Enforcement Perspective Application of Factors That the NRC Considers in Accordance With Section VI.B.2 Past Performance
- Date of Freeze Protection alarm 12/22/98
- Date of events leading to last SL 111 Violations all predate 12/22/96 ,
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Last SL Ill Violation greater than two years ago l
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Enforcement Perspective Identification Credit Low temperature alarm revealed deficiency Dec 22,1998 Freeze protection WO written and general note on fagade freeze protection placed on priority equipment list on Dec 22
= Event Misdiagnosis: Our analysis concluded that the line would'not freeze Sr. Resident questioned operability after reviewing the priority equipment list Operations promptly re-reviewed original diagnosis and discovered that the line would not pass flow
- WE should be given credit for the re-evaluation that led to discovery of the frozen line 3/25/1999 Shde 69 Enforcement Perspective Prompt and comprehensive corrective actions i
1 Operations determined Si recire line to be blocked
- WE declared the SI system inoperable
- Notified NRC under 10 CFR 50.72 Staned a Unit shutdown
- Requested and was granted NOED to delay TS shutdown
- Restored 'B' Train SI to operation using 50.59 Removed blockage from SI mini-recire line Restored 'A' Train SI to operation
+ Formed Root Cause Evaluation Team to detcrmine why this event occurred v s,., sa :,,
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l Enforcement Perspective 4 Corrective Actions (cont.)
Developed case study and are in the process of reviewing the study with all employees as to why the event happened This event is being used as an opportunity to improve the organization WE should be given credit for prompt and comprehensive corrective actions msn9* swe71 Enforcement Perspective Section VII - Exercise of Discretion l
- Event was misdiagnosed
+ O'nce diagnosed, event was promptly corrected e SI system remained operable
. licalth and safety of the public was not impacted l .
. Therefore, escalated enforcement is not warranted
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i Conclusion i
Mike Sellman l
3/25/19'8 Shde 73 Conclusion Matter of misdiagnosis; not a failure to take prompt corrective action
- Broad corrective actions ,
- Case study presentation to employees
- Robust plant modifications l - Catalyst for organizational change No need for escalated enforcement:
- Committed to fundamental change
- Negligible safety consequence
- Robust plant modification
- /2 8/ PnJ Shde 74
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