View source for NPL-98-0183, Responds to NRC Re Violations Noted in Insp Repts 50-266/97-26 & 50-301/97-26 on 971201-980120.Corrective Actions:Addendum to Four Hour non-emergency NRC Notification Was Made on 980113

{{Adams
| number = ML20216E719
| issue date = 03/10/1998
| title = Responds to NRC Re Violations Noted in Insp Repts 50-266/97-26 & 50-301/97-26 on 971201-980120.Corrective Actions:Addendum to Four Hour non-emergency NRC Notification Was Made on 980113
| author name = Patulski S
| author affiliation = WISCONSIN ELECTRIC POWER CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000266, 05000301
| license number = 
| contact person = 
| document report number = 50-266-97-26, 50-301-97-26, NPL-98-0183, NPL-98-183, NUDOCS 9803180134
| title reference date = 02-10-1998
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 7
}}

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{{#Wiki_filter:- - _____-_-___ _ _ - -____---__--- - --_--                                      _
Wisconsin                       '
Electnc
                                                                &OWER COMPANY Point Beach Nuclear Pont                                                                      (920) 755-2321 6610 Nuclear Rd.. Two Rivers, WI 54241 NPL 98-0183                                                           10 CFR 2.201 I                                             March 10,1998 Document Control Desk U. S. NUCLEAR REGULATORY COMMISSION Mail fntion PI-137 Washington,DC 20555 Ladies / Gentlemen:
DOCKETS 50-266 AND 50-301 2                                               REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT NOS. 50-266/97026 AND 50-301/97026 POINT BEACH NUCLEAR PLANT. UNITS 1 AND 2 in a letter from Mr. John A. Grobe dated February 10,1998, the Nuclear Regulatory Commission forwarded the results of an inspection conducted by your staff at our Point 13each Nuclear Plant.
The inspection was conducted from December 1,1997, through January 20,1998. The inspection report included a Notice of Violation which identified three violations of NRC requirements.
We have reviewed the Notice of Violation and, pursuant to the provisions of 10 CFR 2.201, have prepared a written response to the violations as requested by your letter of February 10,1998.
Our written response to the violations is included as an attachment to this letter.
.                                              We believe that the attached reply is responsive to the Notice of Violation and fulfills the requirements identified in your {{letter dated|date=February 10, 1998|text=February 10,1998, letter}}.
New commitments that have not been previously docketed r;c identified by italics.
If you have any questions or require additional information regarding this response, please contact me.
Sin ' rely,                  ,-
                                              . cott . I tulski .                                                                                   g Site Vice President
=                                             Point 13each Nuclear Plant
                                                                                                                                         >             1
=
Attachment 9803180134 980310 PDR       ADOCK 05000266 G                     PDR cc:          NRC Regional AdnCs,trator                  ,
NRC Resident Inspector              **b-vs NRC Project Manager PSCW
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                                                                                                      = = =

Attachment to NpL 98-0183 March 10,1998 page1 DOCKETS 50-266 AND 50-301 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-266/97026 AND 50-301/97026 POINT BEACil NUCLEAR PLANT UNITS 1 AND 2 During an NRC inspection conducted from December 1,1997, through January 20,1998, three violations of NRC requirements were identified. Inspection Reports 50-266/97026 and 50-301/97026 and the Notice of Violation (Notice) transmitted to Wisconsin Electric on February 10,1998, provide details regarding the violations.
In accordance with the instructions provided in the Notice, ur reply to the violation includes: (1) the ruson for the violation, or if contested, the basis for disputing the violation; (2) the corrective action taken and the results achieved; (3) corrective actica to be taken to avoid further violations; and (4) the date when full compliance will be achieved.
Viniation 1:
       " Technical Specification 15.3.0.B. " Limited Conditions for Operation (LCO); General Considerations," requires, in part, that in the event an LCO cannot be satisfied because of equipment failures or limitations beyond those specified in the " permissible conditions" of the LCO, action shall be initiated within one hour to place the affected unit in hot shutdown within seven hours of entering this specification.
Technical Specification 15.3.7.A.1, " Auxiliary Electrical Systems; Specifications," defines the electrical system LCO as acquiring, in part, that both the normal power supply and a standby emergency power supply to all the safety-related 4160/480-volt buses be operable, and that the buses be energized from their normal power supply.
Contrary to the abr~e, from 7:04 p.m. on January 8,1998, through 12:44 a.m. on January 9,1998, operators failed to initiate actions within one hour to place the Unit in hot shutdown when both Unit I safety-related 4160-volt buses were powered from their standby emergency power supply, a limitation beyond those specified in the permissible conditions for the LCO.
This is a Severity Level IV violation (Supplement I)."
Response to Violation 1:
l Reason for Violation:
We concur that this is a violation of NRC requirements as characterized in the inspection report. The personnel involved in this event and personnel who supported the operating crew failed to recognize when both of the Unit 1 safety-related 4160 kV buses were powered from their standby emergency power supply, that entry into Technical Specification (TS) 15.3.0 was required. A 4-hour notification of an engineered safety features actuation was made to the NRC Operations Center on January 8,1998, at        j 2139 hours. A root cause evaluation team was chartered to investigate this event. The team was             !
L.

i A'ttachment to NPL 98-0183 March 10,1998
!     Page 2 specifically chartered to evaluate the root causes of the event including regulatory reportability issues.
The root cause evaluation team has completed its investigation and has issued its report on this event.
Regarding the specific issues associated with this violation, the root cause evaluation team concluded this violation occurred because:
      .        Personnel did not read the applicable TS operability requirements contained in Section A.1 of TS 15.3.7," Auxiliary Electrical Fystems." It was determined to be typical that personnel refer to allowable degraded conditions rather than first reading the operability requirements. Use of the TS in this manner was based on typical experiences that tended to reinforce this practice, such as planned voluntary Limiting Condition for Operation (LCO) entries or equipment inoperabilities.
      .        TS training typically focu.ms on content and/or application of the TS, rather than logical construction. Simulator tiased training scenarios tend to focus on procedure use rather than TS compliance during "significant events" such as loss of offsite power.
      .        Procedure guidance for LCO consideration did not provide appropriate guidance in this situatic .
as there is no procedural guidance for the loss of X04 in the abnormal operating procedures.
Likewise, alarm response procedures provided no specific guidance on LCO consideration.
      .        Duty and call supporting personnel failed to provide an independent verification of TS applicability.
      .        The Duty & Call Superintendent (DCS) llandbook guWice, DCS 3.1.20,"Offsite Power Operability," provides guidance for compliance with TS if the X03 transformer is inoperable.
This guidance was not used.
* Personnel determined that the Unit 1 A05 and A06 normal power supplies were operable by the 13.8 kV tie. This judgment was not correct. The operability requirements and relaxation contained in TS 15.3.7 for A05 and A06 do not allow the normal power supply to be considered operable ifit is not energized and connected. This situation is similar for the X04 transf;rmer and the A03 and A04 buses.
Corrective Actions Takeni
: 1.       An addendum to the four-hour non-emergency NRC notification was made on January 13,1998, j              regarding TS 15.3.0 not being entered as required by Technical Specifierw is.
: 2.       Expectations for DCS involvement and communication with the DSS in "significant" or
               " difficult" involuntary LCO management were reinforced to DCSs by the Plam Manager on January 16,1998. It is an expectation that the DCS independently review the Technical Specification; applicability based on plant conditions and equipment status.
: 3.       Expectations regarding use of TS and the DCS handbook were communicated to DCSs, Duty Technicel Advisors, Regulatory Services & Licensing management, and senior licensed operators on January 16,1998.
I l

Attachment to NPL 98-0183 March 10,1998 Page 3 f
: 4.       Expectations that applicable Technical Specifications will be discussed during simulator training were communicated to all Operations training instructors on February 19,1998.
Corrective Actions to be Taken:
: 1.       Duty & Call Superintendents, licensed o?vrators and DTAs will be briefed on the proper use of Technical Spccifications, with spafic emphasis on TS 153.0 and TS 153. 7 during licensed operator requalification cycle LOR 98-2. Training, including makeup attendance, will be completed by July 3,1998.
: 2.       Team skills training will be provided to all shift personnel which reinforces the role ofindividual contributors to the team and advocacy oftheir individualpositions. This training will be administered during licensed operator requalification cycle LOR 98-02. Training, including makeup attendance, will be completed by July 3,1998.
: 3.       Tt- 'icensed Operator Continuing Training Program will be updated to require that applicable Technical Specifications be called out and discussed during simulator training. 7'he program update will be completed by April 30.1998.
Date Of Full Compliance:
Full compliance will be achieved by July 3,1998.
Viohttim1_2:
      "10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings," requires, in part, that activities affecting quality be prescribed by documented procedures of a type appropriate to the circumstances.
Technical Specification 15.6.8.3, " Plant Operating Procedures; Changes to Procedures," requires, in part, approval by the cognizant group head (duty shift superintendent in operations) and one of the duty and call superintendents for changes to procedures.
Contrary to the above, as of January 22,1998 OM [ Operations Manual] 3.7, " Emergency Gperating Procedure Use and Adherence," Revision 4, a procedure prescribing activities affecting quality, was not appropriate to the circumstances. Specifically, Procedure OM 3.7 provided blanket authorization to change emergency and abnormal operating procedures by performing steps out-of-sequence, or by performing additional steps not specified in the procedures, without reauiring approval by the cognizant group head and one of the duty and call superintendents.
TI is is a Severity Level IV violation (Supplement 1)."

I Attachnient to NPL 98-0183 March 10,1998 Page 4 Response to Violativ.c 2 Reason for Violation:
We concur that this is a violation of WRC requirements as characterized in the inspection report.
OM 3.7 allowed emergency and abnormal operating procedure steps to be performed out of sequence.          1
    - An Operations Feedback form initiated on November 24,1997, documented that this situation existed and that the condition is contrary to the Westinghouse EOP guidance. The matter, however, was not identified or documented as a condition adverse to quality, nor was the matter reported via the condition reporting system. In addition, this procedural provision is contrary to FSAR 12.4.3, which states that actions are expected to be performed in the indicated order; however, actions are not required to be completed prior to continuing with the next step.
    . During the initial investigation of this event, it was questioned whether the actions stipulated by AOP 18B," Train B Equipment Operation," had been performed in sequence. The question was raised because the documentation in the station log of the steps being completed was not in the sequential order that the steps had been called out to be performed in the procedure. The root cause evaluation concluded that all steps of AOP 18B were perfcrmed in sequence, even though the supporting station log entries would appe .r to indicate this was not the case since the station log documented completion times.
Corrective Actions Taken:
i
: 1.      A root cause evaluation of the procedure feedback system was performed. It was determined that procedure feedback forms need to be evaluated to determine whether a condition report should be initiated. Procedure feedback forms initiated by Operations personnel to date have been reviewed with several condition reports having been initiated, where appropriate. The practice has been established to ensure that whenever a procedure feedback form is received, it is reviewed to determine whether a condition report should be initiated.
: 2.       The Operations Manager has reinforced the expectations for procedure compliance with the operating crews. Reinforcement of expectations included a discussion of the requirement that      J incorrect or inadequate procedures should be revised prior to use. This action was completed at meetings held with the operating crews during the first two weeks in January,1998.                 j Corrective Actions to be Taken:
OM 3. 7 will be revised to remove steps thatpermit performance ofEOP and AOP steps out ofsequence           l unless specifIcally authori:ed in the procedure. The procedure will also be revised to require use ofthe    ;
temporary change process or to invoke the provisions of10 CFR 50.51(x) to deviatefrom an EOP or AOP. The revision will be completed and training will be conducted by May 23,1998.                          !
Date of Full Compliance L    Full compliance with NRC requirements will be achieved by May 23,1998.

r 4
A'ttachnfent to NPL 98-0183 March 10,1998 Page ,5, i
i Violation 3:
l   "10 CFR Part 50, Appendix B, Criterion XI, " Test Control," requires, in part, that a test program be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test          i procedures. Test procedures shall include provisions for assuring that adequate test instrumentation is available and used, and that the test is performed under suitable environmental conditions.
Contrary to the above, Test Procedure PC-56, " Containment Accident Recire Heat Exchanger Performance Monitoring Unit 2," Part 2, Revision 5, performed for Unit 2 on December 20,1995, was not adequate to demonstrate that the 2HX-15D containment accident recirculation heat exchanger would perform satisfactorily in service. Specifically, servhe water flow rate instrumentation accuracy and control of test conditions, including service water flow rate ana temperature, were not adequate to ensure accurate test results.
This is a Severity Level IV violation (Supplement I)."
Ecsponse to Violation 3:                                                                                    j Reason For Violation:
We concur this is a violation of NRC requirements as characterized in the inspection report. The            !
required testing of the Unit 2 "D" fim cooler was not completed following the August,1997, Unit 2           l restart due to unsuitable test conditions. Improvements to the fan cooler test methodology over the previous test procedure (PC-56) included improved instrumentation, establishment of higher heat loads, and the elimination of condensation during the test.
This latter improvement requires the service water inlet temperature to be increased immediately prior to collecting data. The increase in service water temperature is brought about using the ice-melt mode of operation. This can only be done under cold lakewater temperatures so condenser vacuum can be maintained with lower circulating water flow. The lake temperature should be consistently below 50 F, and preferable in the 35-40 F range, to ensure a successful test. Since the improved test methodology was developed in the Spring of 1996, the earliest opportunity to test the Unit 2 fan cooler, with cold lake temperature and an at-power unit, occurred in November of 1997.
The Unit 2 test procedure (operating instruction 01-131,"Perfbrmance Test of 2HX-15Dl-D8 Containment Fan Cooler, Unit 2") was initiated on November 13,1997. An emergent issue associated with the Unit 2 containment hatch caused a short delay in testing. During this delay, a separate emergent issue involving a missed surveillance test led to the premature shutdown of Unit 2. This prevented fan cooler testing from being completed until the unit was returned to service. A CllAMPS call-up for the perfbrmance of the improved fan cooler tests was initiated on March 10,1998, to ensure that testing is f   scheduled and perfbnned on an annual basis.

      /ttachntent to NPL 98-0183 March 10,1998 Page 6 The cover letter accompanying this Notice of Violation requests Wisconsin Electric to identify whether there were any other restart items which were delayed until after the Unit 2 restart and which were not performed promptly. Our {{letter dated|date=December 12, 1996|text=letter dated December 12,1996}}, identified 81 specific Unit 2 restart commitments. In our letters to the Commission dated June 13,1997 (NPL 97-0348 and NPL 97-0353),
and July 7,1997 (NPL 08-0398), we summarized our progress on the 81 specific Unit 2 restart commitments. These letters identified commitments that .ould not be fully completed until after return of Unit 2 to sersice. The reason these commitments or restart items could not be accomplished prior to reactor restart was because the correct plant conditions had not yet been achieved for the conduct of post-maintenance or post-modification testing. We have reviewed the set of 81 resta t commitments that required post-maintenance or post-modification testing and have confirmed that the testing was
:     completed when plant conditions appropriate for their conduct was achieved.
Restart action item lists were developed as a result of the System Engineering Review Board (SERB) and Outage Review Committee (ORC) processes. We have reviewed Unit 2 action items that had not been completed as of August 16,1997, when Unit 2 returned to service. From this review we identified 12 items that had not been fully completed prior to restart; six of which related to equipment testing.
We have verified that these 12 items are complete; however, there is one item where not all of the paperwork is closed out, but physical work activities have been completed. In the six cases associated with equipment testing, post-modification or post-maintenance testing was completed when the plant I     conditions appropriate for the conduct of such testing had been achieved.
l t     Corrective Actions Taken:
On February 12-13,1998, a few days following restart of Unit 2,01-131 was successfully performed.
While a detailed calculation of the test results, including an uncertainty analysis and results of post-test instrument calibrations, is not yet complete, preliminary results indicate that the Unit 2 "D" fan cooler is capable of transferring well in excess of the required 37.5 MBTU/hr under design basis accident
!     conditions. This conclusion is not likely to change as a result of the more detailed calculations.
Lorrective Action To Be Taken:
1 Fnal calculation oftest resultsfor the Unit 2 "D" fan cooler test .cill be completed by March 31. I998.
Date of Full Compliance:
l J      Full compliance with NRC requirements will be achieved by March 31,1998.                                     j
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