ML20217J964
| ML20217J964 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 08/11/1997 |
| From: | Steinhardt C WISCONSIN PUBLIC SERVICE CORP. |
| To: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| CON-NRC-97-83 50-305-97-02, 50-305-97-2, NUDOCS 9708150093 | |
| Download: ML20217J964 (11) | |
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- WPSC (414143341598 mECOPIER 1414) 433-5544 NRC-97-83 MONSW PUSUC BERV6CE CORPORATk 000 North Adams
- P.O Box 19002 e Green Bay, W1543o7 9002 August 11,1997 10 CFR 2.201 Mr. James Lieberman Director, Office of Enforcement U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 I;idies/ Gentlemen:
Docket 50-305 Operating License DPR-43 Kewaunce Nuclear Power Plant Reply _to Notice ofNiolation . Inspection. Report 50-305/97002
Reference:
Letter from A.11. Beach (NRC) to M. L. Marchi (WPSC) dated July 11,1997 (Notice of Violation and Proposed Imposition of Civil Penalty).
In the reference, the Nuclear Regulatory Commission (NRC) provided Wisconsin Public Service Corporation (WPSC) with a Notice of Violation and proposed imposition of civil penalty based on the results of the NRC inspection activities conducted January 6 through January 31,1997 and a predecisional enforcement conference conducted on April 17,1997.
During the inspection, the NRC identified one Severity Level III violation. The violation was cited ;
due to a failure to maintain acceptance criteria for both the residual heat removal and auxiliary ,
feedwater flow tests consistent with plant accident analyses assumptions and a failure to use an adequate methodology to calculate instrument accuracy for inservice testing measurements. This
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is contrary to 10 CFR 50, Appendix B, Criterion XI, " Test Control."
Attached is our response to the notice. Although ot'- ~. view of the violation showed that at no time was plant safety challenged, WPSC understan, the significance and, as discussed in the attachment, is taking extensive corrective actions. If you should have any questions with regard to this response, please contact me or a membcr of my staff.
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Mr. James Lieberman August 11-1997 i Page 2 l 1
1 As WPSC does not contest this violation, a check in the amount of $50,000 for payment of the civil penalty is also enclosed.
Sincerely, NW Cu W
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Clark R. Steinhardt Senior Vice President Nuclear Power ,
DCL Attach, cc: US NRC Senior Resident inspector US NRC Region ill US NRC D<wument Control Desk Subscribed and Sworn to Before Me This.//11 Day ofj#fitSt1997 ddswb- AW.
otary Public, State of Wisconsin My Commission Expires:
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ATTACHMENT 1 Letter from C. R. Steinhardt (WPSC)
To James Lieberman Director, Office of Enforcement (NRC)
Dated August 11,1997 Re: Reply to Notice of Violation, Inspection Report 97-002 G8NLC N GfR!PSLU.EARiWPFIL13tLIC\NRONOV97028 WFD 6.
q Mr. James Lieberman August 11,1997 Attachment 1, Page 1 NRC Notice ofNiolation97:002-005 (305/97002-02) 10 CFR 50, Appendix B, Crite: ion XI " Test Control" requires, in part, that a test program shall be established to assure that all testing required to demonstrate that systems wiu 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.
Technical Specification 4.2.a.2 required inservice testing (IST) of ASME Code Class 1,2, and 3 pumps and valves in accordance with Section XI of the ASME Boiler and Pressure Code and applicable Addenda as required by 10 CFR 50.55a(f).10 CFR 50.55a and the licensee's IST plan specified Section XI aJdenda through 1988 and editions through 1989 and referenced ASME 1988.
- a. Contrary to the above, from the origination of the inservice test program until January 1997, acceptance criteria in the Residual licat Removal (RIIR) pump surveillance tcst procedures were not within the pump performance requirements of the plant accident analysis.
- b. Contrary to the above, from the origination of the inservice test program until January 1997, acceptance criteria in :he Auxiliary Feedwater (AFW) pump surveillance test procedures were not within the pump performance requirements of the plant accident analysis,
- c. Contrary to the above, from the origination of the inservice test program until January 1997, the methodology used to calculate instrument accuracy for inservice test measurements was inadequate to meet 2% accuracy required by the ASME Code ASME/ ANSI OMa-1688,
" Operation and Maintenance of Nuclear Power Plants," Part 6, Section 4.6,
" Instrumentation "
WPSC Response Wisconsin Public Service Corporation (WPSC) does not contest this violation or the civil penalty.
WPSC's assessment of the identified deficiencies concluded that: 1) the Inservice Test (IST) procedures did not specify acceptance criteria that would have ensured the pumps met Updated Safe'y Analysis Report (USAR) assumptions and,2) based on manufacturer's data, some of the instrumentation used in IST testing did not meet code requirements for accuracy and range. The causes of the deficiencies in the testing program are primarily attributed to inadequate technical and management support of the IST program. Testing performed during the recent refueling GDNUCI N \GRmfMNUCl. EAR)WPf t!J1LJON9CNOV9702B WPD .
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v, hir. James Lieberman August 11,1997 Attachment 1, Page 2 i outage and reviews of historical data, applying appropriate adjt.stments for instrument accuracy, revealed that all pumps monitored by the IST program were operating such that safety analysis acceptance criteria continued to be met and nuclear safety was not challenged.
Reason For Violation The deficiencies identified in the IST Program were caused by a failure to recognize the significance of the discrepancies between; the IST procedures acceptance criteria and USAR assumptions, and test instrument accuracy and code requirements. Contributing factors included an unclear division of responsibility within the program, limited management and technical support for the program, and inadequate turnovers between past program owners.
The acceptance criteria in the IST procedures, at the time of the violation, were based on AShiE/ ANSI Oht-6 requirements. AShtE/ ANSI Ohi-6 req *es an acceptance of +/- 10% of an established reference value for centrifugal pumps and + 10% / -7% for vertical line shaft pumps.
The reference values were determined in accordance with Section XI / Ohi-6 requirements. The IST program was originally established per AShf E Section XI to monitor the performance of a specific pump or valve. The code did not require a comparison of the test results to USAR assumptions. As IST evolved and became a means of proving operability of a component, the need to perform a comparison of the test procedure acceptance criteria to the plant's accident analysis was not recognized.
The potential for discrepancies between the IST procedure acceptance criteria and USAR assumptions was first identified in October 1995. This was identified as a result of the evaluation performed to develop new reference values for the B Safety Injection pump following repairs.
This discrepancy was captured in Kewaunee's corrective action program as incident Report No.95-215. One of the corrective actions proposed for this incident report was:
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Mr. James Lieberman August 11,1997 Attachment 1 Page 3 To ensure that all cident analysis assumptions are maintained by the current surveillance acceptance criteria, an evaluation for each pump in the IST plan should be performed.
A low priority was inappropriately placed on this evaluation because of the good maintenance history and stable performance of the pumps. Pre-op testing of the pumps was relied upon for verifying compliance with US AR assumptions, and since there was little indication of degradation, the pumps were assumed to be performing acceptably. No in-depth assessment was performed to ensure the procedure acceptance criteria were consistent with USAR assumptions. Ilowever, as updated accident analyses were performed, a conscious effort was made to ensure they reflected actual pump performance. This was done for both Small Break LOCA and Large Break LOCA.
Following the SSOPI in January 1997, an evaluation of each pump in the IST plan was performed.
The evaluation included a review of: USAR, Technical Specifications, and Design Basis assumptions for the pump, instrumentation used to measure pump performance, and past pump performance data. The evaluations found that all pumps, with the exception of the AFW pumps, met existing USAR and Technical Specification assumptions. The review of the AFW pumps indicated that a revision to safety analysis accidents dependent on AFW flow was necessary due to measured flow being less than expected. The revised accident analysis showed that all USAR acceptance criteria continued to be met at the lower AFW flow rate.
A review of the applicable procedures found that the acceptance criteria for a majority of the IST procedures could have allowed pump degradation beyond what was assumed in USAR analyses.
KNPP's IST Plan for the first two ten year intervals was written per ASME Section XI. The test instrument accuracy requirements in Section XI did not clearly indicate whether the 2% accuracy was for a component or for the loop. The interpretation taken by the then IST Program owner was that 2% was a component accuracy. In 1994 KNPP began the third ten year interval. The IST G8NUCl N \GROUPtNt! CLEAR 1WPFILFSUCNRONOV9?CJB WPD
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Mr. James Lieberman August 11,1997 Attachment 1, Page 4 plan for this interval was written per ash 1E/ ANSI Oht-6 (pumps) and Oht-10 (valves). The guidance in Oht-6 clearly states that the 2% accuracy is for the instrument loop.
The concern with the accuracy of the instruments used for Inservice Testing and Code requirements was Drst identified in 1993 during an internal Safety System Functional Inspection (SSFI) of the residual heat removal system. An internal Request for Information (RI) was initiated concerning the accuracy of the instrumentation used in testing the RIIR pumps. This RI was resolved by using local pressure indication instead of control board indication. KAP-0139 (Kewaunee Assessment Program), written on July 25, 1996, requested a review of the IST instrumentation to ensure it met Code requirements. As the KAP dealt with instrument accuracy, it was felt that it would be best addressed by the Setpoir.t Prcgram. At the time this KAP was written the Setpoint Program was focusing on safety related setpoint calculations, the instrument review was to have been done following completion of the higher priority calculations.
During the SSOPI, the concern with instrument accuracy was raised by the inspectors. A concentrated elfort was made by the plant staff to quamify the error for the instrumentation used for IST. This effort found that, when as-found instrument calibration results were used, all loops with the exception of the measurement of service water flow, met the 2% accuracy requirement.
Ilowever, if manufacturer's data was used, several of the instruments did not meet the requirement. Generally, whenever a control room indicator was used, the total instrument loop accuracy, based cu manufacturer's data, exceeded 2%. The review cf the IST instrumentation was expanded to also evaluate the Code required instrument range. In cases where the instrumentation used in the IST procedures did not satisfy the Code accuracy and range requirements, the IST instrumentation review provided: the identification of alternate instruments, a plant physical change to install new instrumentation, the use of test gauges, or a relief request.
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ie Mr. James Lieberman August 11,1997 -
Attachment 1, Page 5 CorrectiveActions The following actions are being taken to sp cifically improve and strengthen the IST Program:
- 1) IST procedures are being revised to use more accurate instrumentation that satisfy code requirements and to include acceptance criteria consistent with USAR assumptions.
- 2) The IST Licensing Basis Document will be revised to include the basis for the pump acceptance criteria.
- 3) Instrumentation used by the IST Program will be identified in the Instrument & Control procedures used for calibration, so any problems will be brought to the attention of the Operations Department.
- 4) A Code Relief Request to allow use of RilR and AFW suction pressure gauges that do not meet OM-6 range requirements has been submitted.
- 5) IST training has been provided to personnel involved with the program as weh as other plant staff to ensure adequate support exists.
- 6) An independent, performance based audit using either contrsctors or personnel from another plant will be performed on the IST Program.
The following broader corrective actions are ts.g taken as a result of the root cause evaluation:
1: The backlog of unresolved work was reviewed to determine if any other operability concerns existed.
- 2) A KAP was initiated to improve the interface between vendors doing analytical work and KNPP Engineering and between the WPSC Nuclear Fuels Group (non-LOCA analysis) and KNPP Engineering. The improved interface will help ensure consistency between USAR and analytical input assumptions.
- 3) A long term plan will be developed to ensure the appropriate resources remain available to support the IST Program.
- 4) Work Management systems will continue to be improved to ensure significant issues are identified and resources are allocated to address them.
- 5) Division of responsibility within the IST program will bc (.larified.
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- Mr. James Lieberman August 11,1997 Attachment 1, Page 6 Compliance Schedule IST Program Corrective Actions
- 1) To comply with Code requirements, the IST test for a pump must be run with both the old and new instrumentation prior to making a change. This ensures that potential degradation in the pump is not masked by the change in instr:nnentation. To ensure Code compliance WPSC is first temporarily changing each of the IST procedures to use both the old and new instrumentation. Once the new instrumentation is shown to be acceptable the procedure will be permanently changed. The temporary changes are being done prior to the scheduled performance of the test. The permanent change will be done prior to the subsequent performance of the test. As some tests are only run once per cycle, this action will not be completed until the next scheduled refueling.
- 2) The changes in the IST Licensing Basis Document are scheduled to be complete by September 1997.
- 3) The changes in the I&C procedu.res used for calibration of the IST instrumentation are scheduled to be complete by September 1997.
- 4) The approved Code Relief Request, IST-RR-28, was received July 7,1997 and will be incorporated into the IST plan.
- 5) The IST Refresher Training was completed May 22,1997. The training included an overview of the applicable codes and standards, design and testing requirements, testing methods, relief valve testing, and the Kewaunee IST Program.
- 6) An independent, performance based audit has been tentatively scheduled for the first quarter of 1998. Early 1998 was chosen as it will allow the effectiveness of the listed corrective actions to be measured.
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Mr. James Lieberman August II,1997 Attachment 1, Page 7 Root Cause Evaluation Corrective Actions
- 1) The work backlog review has been completed. No immediate operability issues were found, llowever, items that could be considered as untimely corrective actions or inadequate administrative controls were found. These items were identified to the affected process owners for correction. None of the identified problems affect the operability of safety-related equipment. The lessons learned will be compiled and reviewed. The lessons learned review should be completed by September 1997.
- 2) A QA code has been established requiring a WPSC review of the input assumptions for analysis that could affect the USAR. This QA code will be added to purchase orders for safety-related analyses. This action is complete. The WPSC Fuels Group is compiling the accident analysis innut assumptions. A formal table of the assumptions should be completed and issued by December 1997.
- 3) The IST training described in IST Corrective Action 5 was the first step in ensuring resources are available. The IST Program Owner will begin working with the trained staff, getting them involved in the IST program. This action should be completed by December 1997.
- 4) The lessons learned from the work backlog review (Corrective Action 1) will be used to improve the Engineering work management process. A ranking scheme that categorizes a task based on whether it is necessary for safe operation, required by regulation, improves plant performance, or is discretionary has been developed. All Engineering tasks are now being categorized. Improvement in the Work Management system is expected to be continuous.
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Mr. James Lieberman August 11,1997 Attachment 1, Page 8
- 5) llistorical weakness in the division of responsibility in the IST program was corrected in 1994 by assigning overall responsibility to the Shift Technical Advisors. The division of responsibility within the program is defined in Nuclear Administrative Directive (NAD) 1.24. Inservice Test Program. NAD 1.24 was issued August 16, 1994.
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