ML20236S974
| ML20236S974 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 11/19/1987 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| CON-NRC-87-115 VPNPD-87-508, NUDOCS 8711300212 | |
| Download: ML20236S974 (7) | |
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J Wisconsin iom coumr 231 W. MICHIGAN, P.O. BOX 2046, MILWAUKEE, WI S3201 (414) 221-2345 i
VPNPD-87-508 10 CFR 2.201 NRC-87-115 November 19, 1987 U. 5; NUCLEAR REGULATORY COMMISSION i
Document Control Desk l
Washington, D.
C.
20555 Gentlemen:
l DOCKET 50-301 REPLY TO NOTICE OF VIOLATION 50-301/87016(DRP)
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POINT BEACH NUCLEAR PLANT, UNIT 2 I
This is in response to your letter dated October 29, 1987, regarding the Notice of Violation determined as a result of a i
special' safety inspection conducted by your inspector during the period August 19 through 28, 1987, at Point Beach Nuclear Plant and the subsequent enforcement conference between J.
C.
Paperiello of NRC and C. W.
Fay of Wisconsin Electric.
The attachment to this letter addresses the violation, as described in Sections A and B of the Notice, to include defining the action taken to date, actions planned for the d
immediate future, and continuing actions that will be implemented to ensure that Technical Specifications will be adhered to and timely and appropriate reporting of events will take place.
Very truly yours, t,ld l
(fil! t}/
C. W.
Fay Vice President Nuclear Power Attachment Copies to NRC Regional Administrator, Region III NRC Resident Inspector 9711300212 871119 0
PDR ADOCK 05000301 0
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1 November 19, 1987' WISCONSIN ELECTRIC POWER COMPANY'S REPLY TO NOTICE OF VIOLATION 50-301/87016
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POINT BEACH NUCLEAR PLANT, UNIT 2 Docket 50-301 DISCUSSION ~
~ 1. D DESCRIPTION OF VIOLATION AND IMMEDIATE CORRECTIVE ACTION During the day of August 17, 1987,' Unit 2 was.in the' hot shutdown condition following a trip which occurred on' August 16 (see LER 87-002).. The main steam isolation valves (MSIVs) were shut manually'after the trip to facilitate repairs;to three low-pressure turbine rupture discs which. ruptured during the transient following the trip..Following. repairs to the rupture discs and 3
verification of valve operability, the MSIVs were'left Later in the morning of August 17, it was decided open.
to have maintenance. personnel inspect the internals of the turbine and a moisture separator reheater.. For reasons of personnel' safety during the inspections, the MSIVs were closed, and a " red tag" series was initiated to tag them i
in the closed' position.
The tag series provided for tagging the instrument air isolation valve to each MSIV and the DC control power breakers in the control room which supply the instrument air isolation valve supply and vent solenoids.
After the inspection and maintenance work was completed, the reactor was released for criticality..By approximately 2138 hours0.0247 days <br />0.594 hours <br />0.00354 weeks <br />8.13509e-4 months <br /> on August 17, 1987, the reactor was critical with the MSIVs remaining closed.
Between 2138 hours0.0247 days <br />0.594 hours <br />0.00354 weeks <br />8.13509e-4 months <br /> and 2230 hours0.0258 days <br />0.619 hours <br />0.00369 weeks <br />8.48515e-4 months <br />, it was intended that the MSIVs be returned to service by clearing the tagout series.
Two of the tags in the tagout series were inadvertently not removed, but the tagout series was assumed to be cleared.
These tags required the circuit breakers which supply DC control power to the MSIV trip solenoid valves to be in the open position.
Without DC control power, the MSIVs can be opened, but are not capable of being closed with either an automatic or manual signal.
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i REPLY TO NOTICE OF VTOLATION NO. 50-301/87016 November 19, 1987 Page 2 l
At about 2230 hours0.0258 days <br />0.619 hours <br />0.00369 weeks <br />8.48515e-4 months <br /> OP-1C, " Low Power Operation to Normal Operation" was started.
The first step in the initial j
conditions of that procedure requires that the applicable i
portions of OP-13A, " Secondary System Startup and Shutdown" l
be completed.
OP-13A has a step that requires the MSIVs to be opened and cycled, thereby verifying the valves' operation.
Since the MSIVs had been cycled earlier prior to the l
maintenance inspections, operations personnel decided that l
the OP-13A requirement to cycle the MSIVs had already been met.
The cycling was therefore not performed and the failure to completely clear the tagout series was not I
identified at that time.
At approximately 2305 hours0.0267 days <br />0.64 hours <br />0.00381 weeks <br />8.770525e-4 months <br />,
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when the MSIVs were opened, it was not known,that the trip j
circuits for the MSIVs were functionally inoperable because j
the control power breakers were open.
Sometime between 1
0330 and 0400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> on August 18, 1987, during the continu-l ation of OP-lC, Operations personnel discovered the red j
tags on the DC control power supply circuit breakers for l
the MSIV trip solenoid alves.
After determining that the red tags should have been removed, since the tagout series was completed, the tags were removed and the breakers were i
closed, making the MSIV trip circuits operable and provid-j ing the immediate corrective action for the condition i
i described in Section A of the notice of violation.
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After this incident, a normal course of action at PBNP
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vould have resulted in the operator calling a duty and l
call superintendent so a 10 CFR 50.72 deportability l
evaluation could be performed.
10 CFR 50.72 deportability J
was not considered by the operator discovering the condition, and he therefore made no calls.
He did assume an LER would be required and he had a nonconformance report (NCR) on the event initiated.
The NCR was issued i
the afternoon of August 18, 1987.
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REPLY TO NOTICE OF VIOLATION NO. 50-301\\87016 November 19, 1987' Page 3
'The operator who found.the breakers open between 0330 and-0400 on' August /18 sent a written note to the' operator responsible for clearing the tagout series, who was not-scheduled for work until'1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br /> on August 18.-
Between 1500 and 2300 hour0.0266 days <br />0.639 hours <br />0.0038 weeks <br />8.7515e-4 months <br />s-on August 18,.the operator.who made the tag-removal error received.the note _and' generated the The NCR was sent'to a. responsible staff reviewer:in NCR.
the normal. plant mail, which was received,by the reviewer the afternoon;of August 19..
The NCR did not' clearly state:
that the.MSIVs were inoperable for the~ period of time that
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they were open with red--tags on the breakers.
A review'of L
_OP-13A led the_ reviewer, who thought that the breakers may have been closed instead of open, to conclude' mistakenly-that the-valvesLhad.been. cycled, which would1have meant they'were operable at the time.the. red tag problem was found.
The st.aff reviewer determined it was necessary to talk directly with the person who identified lthe situation.
The operator was still assigned to the 2300_to.
0700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br /> shift, southe staff reviewer decided to talk with him the morning _of August 20.
In the interim, the-Resident Inspector was informed of the circumstances and that an investigation was under way.
On August-20 the operators; involved in the incident were' interviewed,_and it was determined that,-in fact, the-breakers for the-control power were open and the MSIVs were inoperable with the reactor at 2% power.
The decision was then made to notify the NRC duty officer of a probable one-hour 10 CFR 50.72 report.
Subsequent calculations verified that, for-the conditions of the plant at the time, the plant was bounded by the design-basis.
The notification was the immediate corrective action taken for the condition describe'd in Section B of the notice of violation.
Following is a sequence of events 'for the event of August 16 through August 20, 1987.
1.1 SEQUENCE OF EVENTS Date Time Event 08-16-87 1855 Reactor trip due to lightning strike 08-16-87 1915 (approx.)
MSIVs shut for secondary side maintenance "B" MSIV shuts to within 1 in. of fully closed I
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j REPLY TO NOTICE OF VIOLATION'NO.- 50-301/87016 l
November 19, 1987
'Page 4 l
SEQUENCE OF' EVENTS (Cont'd)
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Date Time Event
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08-17-87 0515' MSIVs tested per'IT-285 to verify y
both MSIVs were operable, MSIVs-j left open 1
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Tag series written to isolate steam to the turbine hall 08-17-87 0830 (approx.)
Tag series reviewed and approved 08-17-87 0955 MSIVs shut 08-17-87 1100 (approx.)
MSIVs tagged shut
- Instrument air at the MSIV I
location (one tag for each MSIV)
- DC breakers in control room (one tag for each DC power source)_
08-17-87' 2138 Unit 2 reactor critical
- Tag series cleared except DC control power breaker tags left in place 08-17-87 2300 Pressure equalized across MSIVs and j
valves opened
- MSIV cycling considered not necessary due to testing at 0515 hours0.00596 days <br />0.143 hours <br />8.515212e-4 weeks <br />1.959575e-4 months <br /> 08-18-87 0158 Commenced turbine startup procedure 08-18-87 0530-0400 Discovered red tags and open power supply breakers with reactor criti-cal at approximately 2% power 08-18-87 0330-0400 Cleared DC control tag series for MSIV power, removed tags, and closed breakers 08-18-87 Swing shift Operations personnel prepare nonconformance report (NCR) for management review
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REPLY TO NOTICE OF VIOLATION NO. 50-301/87016 November 19, 1987 Page 5 SEQUENCE OF EVENT (Cont'd)
Date Time Event 08-19-87 Afternoon Responsible staff reviewer receives NCR and informs senior resident inspector of possible LER on Technical Specification viola-tion 08-20-87 0810 Reviewer interviews operations personnel and determines red phone report necessary.
Needs more information on deportability 08-20-87 Noon Red phone report made 2.0 REASONS FOR VIOLATIONS WE acknowledges that violations A and B did occur as described in the NRC Region III Inspection Report dated October 29, 1987.
The cause for these violations as determined by our investigation were:
2.1 The procedure for control of equipment isolation did not have enough specificity to adequately direct the red tag installation and removal during this event.
2.2 An apparent attitude in the operations group that the safety significance of the MSIVs is not as great as other safety-related equipment.
3.0 CORRECTIVE ACTION 3.1 The procedure for control of equipment isolation will be revised to provide specific guidance as to the techniques for equipment isolation.
This procedure will be revised and training provided to personnel responsible for supervision of equipment isolation by March 1, 1988.
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REPLY.TO NOTICE OF VIOLATION NO. 50-301/87016 November 19, 1987 Page 6 3.2 To make it easier for operators to recognize safety-related equipment and to trigger the. reporting process when the operability of that. equipment is affected, a safety-related equipment list is being developed..This list is intended to be available-in the control room on the computerized maintenance record (CHAMPS). Currently, a safety-related equipment system list is.in the CHAMPS database; however, the list has not been validated and verified as being totally correct.
This list will be validated, verified, and modified for operator use by June 1, 1988.
3.3 A modification has been completed on Unit 2 which provides an alarm in the control room upon loss of DC control power to the MSIV solenoid valves.
All personnel involved have been counselled.
This 3.4 included discussion of proper use of red tags and the" safety-related classification of the MSIVs.
4.0 COMPLIANCE ACHIEVEMENT The valve was operable and in compliance with Technical Specification 15.3.5.C when the control power breaker was l
closed at approximately 0330-hours on August 18, 1987.
The notification of the NRC was made at noon on August 20, 1987, at which time full compliance with 10 CFR 50.72 was achieved.
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