ML20211B196

Insp Repts 50-266/97-17 & 50-301/97-17 on 970304-0805. Violations Noted.Major Areas Inspected:Operations & Maint

ML20211B196
Person / Time
Site:	Point Beach
Issue date:	09/17/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20211B177	List: ML20211B170 ML20211B190 ML20211B196
References
50-266-97-17, 50-301-97-17, NUDOCS 9709250107
Download: ML20211B196 (9)

See also: IR 05000266/1997017

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U.S. NUCLEAR REGULATORY COMMISSION

REGION Jll

Docket Nos: 50-266,50-301

License Nos: DPR-24, DPR 27

Report No: 50-266/97017(DRP); 50-301/97017(DRP)

Licensee: Wisconsin Electric Power Company, WEPCO

Facility: Point Beech Nuclear Plant, Units 1 & 2

Location: 6612 Nuclear Road

Two Rivers, WI 542419516

Dates: March 4 through August 5,1997

Inspector M. Kunowski, Project Engineer

Approved by: J. W. McCormick Barger, Chief

Reactor Projects Branch 7

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9709250107 970917

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EXECUTIVE SUMMARY

Point Beach Nuclear Plant, Units 1 & 2

NRC Inspection Report 50-266/97017(DRP); 50-301/97017(DRP)

This inspection reviewed an apparent inaccurate statement made to the NRC regarding the

capability to cross-connect the Units 1 and 2 component cooling water (CCW) systems. The

statement was made while the licensee was requesting a Notice of Enforcement Discretion

during repairs of a service water pump and a Unit 1 CCW pump.

Operations

e A violation of 10 CFR 50.9(a) was identified for providing inaccurate information on the

status of the CCW cross connect capability on February 19 and 20,1997, during the

request for the Notice of Enforcement Discretion (Section 02.1).

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Maintenance f

e A violation of 10 CFR 50, Appendix B, Criterion XI, " Test Control," was identified for the

failure to test the CCW pump discharge and suction cross connect valves to demonstrate ,

the valves would perform satisfactorily (Section M8.1).

e A non-cited violation of Technical Specification 15.3.3.C was identified for the failure to

provide two operable CCW pumps to Unit 1 on February 26,1995 (Section M8.1).

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Report Details

Summary of Plant Status

During this inshetion period, Unit 1 was in cold shutdown because the licensee decided to

voluntarily shut down following an outage to repair two cooling water pumps. Unit 2 weS in cold

shutdown due to a refueling outage, including replacing the steam generators, and to address

performance issues.

, l. Operations

02 Operational Status of Facilities and Equipment

O2.1 Capability to Cross Connect CCW Systems

a. Backoround and inspection Scope (71707)

As discussed in Inspection Report 50-266/97003(DRP); 50-301/97003(DRP), a Notice of

Enforcement Discretion (NOED) was orally issued to the licensee on Wednesday,

February 19,1997, from specific Technical Specification (TS) requirements related to the

inoperability of a Train "A" service water (SW) pump, P-32A, and the Unit 1 Train "A"

component cooling water (CCW) pump,1P-11 A. A fc mal written request for the NOED

was documented in a letter to the NRC, received late in the afternoon of February 20,

1997. One of the eight compensatory actions that the licensee offered in the oral request

on February 19 and in the written request on February 20 was that the Units 1 and 2

CCW systems had the capability to be cross-connected.

The CCW systems for the two Units were designed to be cross-connected by opening the

CCW pump suction valve (CC-722A) and discharge cross connect valve (CC-722B) as

described in the abnormal operating procedures and as shown in Figure 9.3-3, from the

Final Safety Analysis Report (FSAR). The cross-connect capability was designed to

expedite cooldown of a Unit and to provide single failure protection upon inoperability of

one of the three CCW pumps required by TS 15.3.3.C for two-Unit operation. The system-

could also be cross-connected through the CCW heat exchanger cross-connect valves.  !

However, the latter method was not discussed within the context of the NOED and was

not described in station procedures. It is shown in FSAR Figure 9.3-3.

In the moming of Thursday, February 20, a former senior reactor operator (SRO) and shift

superintendent raised a concern at the routine plant meeting (6:45 a.m.) that the CCW

pump cross-connect valves had been closed with force several years ago and may not

operate properly. The plant manager, who attended the meeting, requested that the

individual document the concem in a condition report (CR). After the meeting, the ex-

SRO received some additional anecdotal information from a current SRO on the same

issue. This additionalinformation was factored into the subsequent CR This potential

problem was not discussed in the NOED request sent to the NRC later that afternoon nor

was it discussed in telephone conversations between Region lit and the licensee that day

because the plant manager felt there may not be a problem with the valves based on his

experience with the type of valve in question.- Further, the Plant Manager desired that the

concern be evaluated through the established CR system. He was also aware that a

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resident inspector was in attendance at the meeting when the concern was raised and

believed that the NRC was aware of the issue.

On Friday, February 21, sometime between 6:45 a.m. and shortly after 10 a.m., the plant

manager read the CR written by the ex-SRO and noted that it characterized the problem

in stronger terms than those expressed the day before at the plant morning meeting.

Around 8:00 a.m., one of the resident inspectors also read a copy of the condition report

and subsequently voiced a concern about the operability of the cross-connect function to

Region lil management. At a 1:00 p.m. plant manager's staff meeting, at which the same

resident inspector was present, the plant manager stated that he planned to inform

Region 111 at a scheduled 2:00 p.m. telephone call of the concern with the CCW cross-

connect capability as expressed in the CR. During the 2:00 p.m. telephone call, Region

111 mariagement asked the plant manager about the CR. The plant manager then

described the concem.

In a letter dated March 3,1997, the NRC documented the issuance of the NOED on

February 19. In that letter, the NRC stated that information provided on February 19 and

20 may have been misleading because the ability to cross-connect the CCW systems

was questionable due tr poor cross-connect valve material condition, referring to the

concern of the ex-SRO. The NRC referred this potential failure to provide complete and

accurate information to the NRC Office of Investigations (01) for further review. On

March 4, the CCW pump discharge cross-snnect valve failed to open during a test to

specifically open and close the valve; the suction cross-connect valve opened and closed

as designed (discussed in Inspection Report 54266/97003(DRP); 50-301/97003(DRP)).

Also, on March 4, and on March 5, Ol interviewed personnel at Point Beach regarding

l their knowledge of the status of the cross-connect capability on February 19 and 20.

The scope re f this inspection was to review the transcripts from the Ol interviews, the

regulatorv requirements, the current licensing basis in the FSAR, and other licensee

informat;on to assess the appropriate enforcement action. The results of the inspection

are discussed below and in Section M8.1.

b. Observations and Findinas

10 CFR 50.9(b) specifies a notification period of 2 days for information that has a

"significant implication for public health and safety..." Region lit personnel were informed

by the licensee of the potential problem with the cross-connect valves about 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after

the plant manager read the CR on February 21,1997, and less than 1% days after the

issue was raised orally on February 20. However, while the capability to use the CCW

pump cross-connect valves was considered material by Region ill in issuing the NOED,

the unavailability due to the stuck discharge valve was not considered to hold sig.iificant

implication for public health and safety, and thus was not reportable under this regulation.

Notwithstanding the lack of a need to report the potentialinoperable cross-connect

because of the absence of significant implication for public health and safety,

10 CFR 50.9(b) also specifies that the 2-day reporting requirement is not applicable to

information which is already required to be provided to the Commission by other reporting

requirements. The inoperable cross-connect was properly reported in Licensee Event

Report (LER)97-013 on April 3.1997, under 10 CFR 50.73(a)(2)(ii)(B), "Any event or

condition that resulted in the nuclear power plant being in a condition that was outside the

design basis of the plant."

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Further, as discussed above, the plant manager did not inform Region lll management on

February 20 of the potential problem with the cross-connect valves because he believed, '

based on personal experience with that type of valve, that a large of amount of force was

sometimes needed to close those valves but would not necessarily render the valves

incapable of being opened again. In addition, earlier, in late 1996, no concerns about

valve operability were raised by current operators when the abnormal operating

procedure to open the cross-connect valves were written and provided to all of the

current operators. The plant manager also expressed at the morning meeting on

February 20 that he wanted the concern processed through the condition reporting

system. This was done to emphasize to plant staff his expectation that concerns and

potential problems were run through the system so that they can receive proper

evaluation and disposition.

The plant manager did not notify the Region immediately on February 21, once he read

the CR that described the problem as more severe than the initial portrayal on

February 20, because as he stated at the 1:00 p.m. meeting with his staff, he intended to

notify Region Ill at the previously scheduled 2.00 p.m. telephone call. Also, the presence

of an NRC resident inspector at the moming meeting on February 20 when the concern

was first raised and the knowledge that the NRC resident inspectors received copies of

all CRs also factored into the plant manager's decision to not notify NRC Region 111

management until the scheduled telephone call on February 21.

Although the reporting requirement of 10 CFR 50.9(b) was not applicable to this issue,

the inspectors identified a violation of 10 CFR 50.9(a). In the oral NOED request made to

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Region ill on February 19 and in the written NOED request received on February 20, the

l Plant Manager provided inaccurate information in that the Point Beach plant did not have

l the capability to cross-connect CCW systems of the two Units because of the inoperable

pump discharge cross connect valve. The Plant Manager was unaware of the operating

problems with these valves at the time the oral statement was made. The failure to

provide complete and accurate information to the NRC on February 19 and 20,1997, was

j a violation of 10 CFR 50.9(a), which requires in part, that information provided to the NRC

be complete and accurate in all material respects (VIO 50-266/97017-01(DRP);

50-301/97017-01(DRP)).

c. Conclusions

The licensee unwittingly provided inaccurate information about the capability to cross-

connect CCW systems of the two Units. A violation of 10 CFR 50.9(a) was identified.

11. Maintenance

M8 Miscellaneous Maintenance Issues (92909)

M8.1 (C!osed) LERs 50-266/97-013: 50-301/97-013 and 50-266/97-013-01: 50-301/97-013-01:

Component cooling water system not in accordance with plant design basis. LER 97-013

was written to report the inability to cross-connect the CCW systems, via the pump

discharge and suction valves (CC-7228 and CC-722A), because CC-722B was found to

be stuck closed on March 4,1997. The inspectors determined from discussions with

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plant personnel that these valves had not been tested in the past several years (the date

of the last test was unknown) to verify that they would open to allow cross-connection of

the Units 1 and 2 CCW systems and that the valves were not in any operational test

program. The failure to test the'CCW pump discharge and suction cross-connect valves

was a violation of 10 CFR 50, Appendix B, Criterion XI, " Test Control," which requires, in

part; that a test program be established to assure that all testing required to demonstrate

that structure, systems, and components will perform satisfactorily in service is identified

and performed in accordance with written test procedures which incorporate the

requirements and acceptance limits contained in applicable design documents. The test

program shall include operational tests (VIO 50-266/97017-02(DRP);

50-301/97017-02(DRP)). The licensee had abnormal operating procedure (AOP)-9B,

' Component Cooling System Malfunction," that provided instructions on using the pump

cross connect valves, but had no procedure for testing the valves and had not tested the

valves.

LER 97-013 was subsequently revised and LER 97-013-01 was submitted on May 30,

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1997, to document an occurrence on February 26,1995, when the licensee

l. inappropriately took credit for the assumed cross connect capability to satisfy the then-

l extant TS 15.3.3.C requirement for Unit 1 (as an operating Unit) to have two operable

CCW pumps assigned to it At the time, with Unit 2 shutdown, Unit 1 operating at

100 percent, and one of the two Unit 1 CCW pumps out-of-service for seal replacement,

the licensee used an operable Unit 2 CCW pump to satisfy the two pump requirement for

Unit 1. The licensee identified the violation as part of corrective actions for the

determination on March 4,1997, that the pump discharge cross-connect valve was

inoperable. The violation was corrected when the inoperable Unit 1 pump was returned

to service. The failure to have two operable CCW pumps assigned to Unit 1 on

February 26,1995, was a violation of TS 15.3.3.C; however, this non-repetitive, licensee-

identified and corrected violation is being treated as a Non Cited Violation (NCV),

consistent with Section Vll.B.1 of the NRC Enforcement Policy

(NCV 50-266/97017-03(DRP); 50-301/97017-03(DRP)). In August 1997, TS 15.3.3.C

was revised to eliminate the dependence on cross-connecting the CCW systems and

eliminating the need to routinely test the valves.

V. Manaaement Meetings

X1 Exit Meeting Summary

The inspectors presented the inspection results to members of licensee management at the

. conclusion of the inspection on August 5,1997. The licensee acknowledged the findings

presented.

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PARTIAL LIST OF PERSONS CONTACTED

peensee

Wisconsin Electric Power Company (WEPCo)

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S. A. Patulski, Site Vice President

A. J. Cayia, Plant Manager

D. F. Johnson, Regulatory Services and Licensing Manager

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J. G. Schweitzer, Manager, Site Engineering

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INSPECTION PROCEDURES USED

IP 71707: Plant Operations

IP 92909: Followup Maintenance

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ITEMS OPENED AND CLOSED

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Opened ^

50 266/97017 01; 50 301/97017 01 VIO - Inaccurate information provided regarding CCW -;

cross connect capability.

50 266/97017 02; 50 301/97017 02 VIO- CCW pump cross connect valves not tested.

50-266/97017 03; 50 301/97017 03 NCV TS requirement for two operable CCW pumps not

met.

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Closed '

50 266/97-013; 50-301/97 013 and LER Component cooling watet system not in

50-?66/97 013 01; 50 301/97 013 01 accordance with plant design basis.

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LIST OF ACRONYMS USED

CFR Code of Federal Regulations

CCW Component Cooling Water

CR- Condition Report

DRP Division of Reactor Projects

EA Enforcement Action

FSAR Final Safety Analysis Report

IP inspection Procedure

IR Inspection Report

LER Licensee Event Report

NCV Non Cited Violation

NOED- Notice of Enforcement Discretion

NRC Nuclear Regulatory Commission

01 - Office of Investigations

PDR Public Document Room

SRO Senior Reactor Operator

SW Service Water

TS Technical Specification

VIO - Violation

WEPCo Wisconsin Electric Power Company

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