ML20211B196
| 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: |
| 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:
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
ADOCK 05000266
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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
A violation of 10 CFR 50.9(a) was identified for providing inaccurate information on the
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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
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A violation of 10 CFR 50, Appendix B, Criterion XI, " Test Control," was identified for the
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failure to test the CCW pump discharge and suction cross connect valves to demonstrate
the valves would perform satisfactorily (Section M8.1).
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A non-cited violation of Technical Specification 15.3.3.C was identified for the failure to
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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
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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.
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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
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their knowledge of the status of the cross-connect capability on February 19 and 20.
The scope r f this inspection was to review the transcripts from the Ol interviews, the
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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,
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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
Region ill on February 19 and in the written NOED request received on February 20, the
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Plant Manager provided inaccurate information in that the Point Beach plant did not have
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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
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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,
1997, to document an occurrence on February 26,1995, when the licensee
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inappropriately took credit for the assumed cross connect capability to satisfy the then-
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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
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
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50 266/97017 01; 50 301/97017 01 VIO - Inaccurate information provided regarding CCW
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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
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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
Component Cooling Water
CR-
Condition Report
Division of Reactor Projects
Enforcement Action
Final Safety Analysis Report
IP
inspection Procedure
IR
Inspection Report
LER
Licensee Event Report
Non Cited Violation
NOED-
Notice of Enforcement Discretion
NRC
Nuclear Regulatory Commission
01 -
Office of Investigations
Public Document Room
Senior Reactor Operator
TS
Technical Specification
VIO -
Violation
WEPCo
Wisconsin Electric Power Company
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