ML20199F136

Insp Repts 50-266/97-21 & 50-301/97-21 on 971021-1130. Violations Noted.Major Areas Inspected:Operations, Engineering,Maintenance & Plant Support

ML20199F136
Person / Time
Site:	Point Beach
Issue date:	12/22/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20199F126	List: IR 07100021/2011030 ML20199F122 ML20199F136
References
50-266-97-21, 50-301-97-21, NUDOCS 9802030069
Download: ML20199F136 (27)

See also: IR 05000266/1997021

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U.S. NUCLEAR REGULATORY COMMISSION

REGION lli

Docket Nos.:

50 266, 50 301

Licenses No.:

DPR 24, DPR 27

Report No:

50-266/97021(DRP): 50 301/97021(DRP)

Licensee:

Wisconsin Electric Power Company

Facility:

Point Beach Nuclear Plant, Units 1 & 2

Location:

6612 Nuclear Road

Two Rivers, WI 54241 9516

Dates:

October 21 through November 30,1997

Inspectors:

F, Brown, Senior Resident inspector

A. McMurtray, Senior Resident inspector

P. Louden, Resident Inspector

Approved by:

J. W. McCormick Barger, Chief

Reactor Projects Branch 7

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EXECUTIVE SUMMARY

Point Beach Nuclear Plant, Units 1 and 2

NRC Inspection Report No. 50 266/97021(DRP); 50-301/97021(DRP)

This inspection included aspects of licensee operations, engineering, maintenance, and

plant support. The report covt,rs a 6 week inspection period by the resident inspectors.

Operations

Good command and control, deliberate conduct of operations, and good procedure

adherence were observed during the shutdown of Unit 2 and the startup of Unit 1.

(Section 01.1)

The facility was operated in a safe manner with a strong safety focus and generally

conservative operational decisions. Two notable examples were the decision to

promptly shut down Unit 2 when reactor protection instrumentation test problems

could not be resolved within the allowed time and the decision to delay the startup of

Unit 1 while a nuclear instrument detector was repaired. (Section 01.2)

Prior to unit restart, the inspectors determined that Unit 1 containment cleanliness

was sufficient to prevent immediate safety concerns; however, the inspectors

identified several items, including loose electrical tape, which should not have been

present. (Section 02.1)

The licensee had taken adequate measures to ensure those safety systems

susceptible to freezing during the winter months were protected. Also, the licensee

had taken acceptable actions in addressing concerns with the facade freeze

protection system discussed in a previous inspection report. (Section 02.2)

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The licensee identified and corrected three examples of the use of inappropriate

procedures. The need for numerous other procedure changes was identified by

operators prior to the use of inappropriate procedures. Despite these problems with

procedure development and review, the inspectors considered the use of procedures

in Operations to be good. This strong performance was based, in part, on

Operations Department initiatives to ensure that all required procedures were

performed as written, to ensure that activities requiring procedures were performed

using procedures rather than work plans, and to provide mentors who reinforced the

need for procedural control of activities affecting quality. (Section 03.1)

Most component cooling water (CCW) syntem normal, abnormal and emergency

operating procedures were considered appropriate, but the inspectors identified a

weakness with the failure of the emergency operating procedure to provide positive

isolation of nonsafety related CCW flow paths during the containment sump

recirculation phase of accident mitigation. This procedure weakness was considered

one aspect of a iest control violation. (Section 03.2)

Operator knowledge of the CCW system and its operation was good Reactor

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operators were familiar with the CCW system status and the cause for CCW system

annunciators. (Sections 04 & 05)

The quality assurance organization's identification and documentation of findings

improved significantly as the result of self critical program level arsessments

performed by the licensee. A self assessment performed by Quality Assurance

during this report period noted improvement in some areas but identified the need for

improvement in other areas. The inspectors considered the improvements and the

thorought.ess of the current self assessment to be positives. New performance

indicators for corrective action backlogs were implemented, but prioritization of

condition reports within each organization's backlog was of concern to plant

management and the inspectors. (Section 07.1, applicable to all functional areas)

The licensee committed to develop an Annual Plan which prioritized high-level

improvement initiatives and commitments to the NRC. This will provide a means for

licensee management to track the status of the improvement initiatives. (Section X2,

applicable to all functional areas)

Maintenance

No problems were noted during observations of maintenance and surveillance

activities involving the Unit 1 feedwater isolation feature and the auxiliary feedwater,

safety injection, and residual heat removal systems. (Section M1.1)

An inadequately controlled modification performed in December 1996 defeated the

Unit 1 containment upper hatch interlock system. This caused a Technical

Specification violation when the required compensatory actions were not

implemented. No instances were identified where containment integrity had been

degraded during the interlock system inoperability. (Section M2.1)

Maintenance supervision effectively responded to problems with maintenance

procedures for the CCW pump and motor repairs, inadequacies in the work scoping

process and insufficient lead time following procedure development con'ributed to

the procedure problems. (Section M3.1)

Enaineerina

The inspectors independently identified that CCW system testing had not

demonstrated the system's ability to provide its safety-related function when

instrument inaccuracies and potential accident condition system lineups were

considered. The inspectors also determined that four licensee operability

determinations for these problems generated between December 1996 and

November 1997, were inadequate. The licensee developed an adequate operability

determination after the inspectors brought this issue to the attention of plant

management. Two violations were identified. (Section E1.1)

A system engineer identified the potential for an unreviewed safety question if a test

of spare ventilation equipment, committed to in a Licensee Event Report, was

performed at power. This identification was the result of a comprehensive and

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thorough review of the proposed test by the system engineer. (Section E2.1)

Plant Support

The radiological housekeeping within the P mary Auxiliary Building was good.

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8tport Details

Summarv of Plant Status

Unit 2 was at full power and Unit 1 was in an extended outage at the start of the inspection

perled. Tw: unit operation was precluded due to previously identified concems with the

auxiliary feedwater system. Unit 2 was shutdown on November 15,1997, after the licensee

identified that complete testing of reactor protection system instrumentation and control

circuitry had not been completed as required by T/Ss. Unit i startup was underway at the

end of the Inspection period.

Inspection Focus

During this inspection period, the inspectors integrated a vertical slice review of the

component cooling water (CCW) system into the routine inspection of the Operations,

Engineering, and Maintenance functional areas,

l. Operations

01

Conduct of Operations

01.1 Shutdown and Startuo Activities

a.

Insoection Scope (Inspection Procedure (IP) 71707)

The inspectors observed the T/S-required shutdown of Unit 2 on November 15,

1997, and the startup of Unit 1 which began November 21,1997, and was

completed November 30,1997.

b.

Observations and Findinas

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Shutdown of Unit 2

During a review of NRC Generic Lette- N 01," Testing of Safety Related Logic

Circuits," licensee engineering staff k wiled that multiple permissive logic circuitry

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T/S requirements. Technical Specification

Table 15.4.11 Item 45 identifies these permissives and the required f4quency of

testing (every refueling outage). The engineering review identified that these

combination logic tests had not been performed and a Condition Report (CR) 97-

3786, dated November 14,1997, was written.

A 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> delay was allowed by T/Ss to accomplish the missed surveillance, but the

licensee determined that an acceptable procedure likely could not be written,

approved, and implemented within the 24-hour time limit Consequently, the

Ucensee decided at 11:30 a.m. on November 15 to shut down the unit.

Once the decision was made to shut down, the T/S action statement of Table 15.3.5-

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2 went into effect, requiring the unit to be in Hot Shutdown within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The

licensee subsequently provided an event notification to the NRC Operations Office at

1:25 p.m. in accordance with 10 CFR 50.72(b)(1)(1)(A) and (b)(2)(iii)(A).

The inspectors observed the Manager's Supervisory Staff (onsite review committee)

meetings which led to the decision to shut down Unit 2, and noted that senior plant

management consistently queried plant staff to ensure that they were not pressing

too hard for a desired result and being too production focused. The inspectors

concluded that the decision to shutdown Unit 2 was conservative and appropriate for

the situation.

The inspecturs observed control room activities during the shutdown of the Unit 2

reactor. The shutdown was methodically conducted, and control room command

and control was adequate. Ono delay in the direct shutting down of the unit

occurred during the testing of the Unit 2 main steam isolation valves (MSIVs).

Operations elected to perform the non required test to gather information for

engineering trending. During the shutdown, just prior to starting the test, a control

(reactor) operator noted that an initial condition for the test was that the reactor be

between 2 percent and 5 percent power. The reactor at the time was at about 1.5

percent. Operations department supervision decided to increase reactor power to

within the band indicated in the procedure and continue with the test. Other minor

delays occurred during the testing of the 'A' MSIV. The result of these test

decisions led to the reactor reacning hot shutdown status at 7:00 p.m. on November

15,1997,30 minutes prior to the required limit and 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> later th:n had the testing

not been conducted.

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Startuo of Unit 1

The inspectors performed extensive control room observations during the startup of

Unit 1. Good use of procedures and good command and control were noted. No

negative observations were identified.

c.

Conclusions

Good command and control, deliberate conduct of operations, and good procedure

adherence were observed during the shutdown of Unit 2 and the startup of Unit 1.

01.2 Safety Focus in Operational Decision Makina

a.

Inspection Scope

The inspectors monitored operation of the facility to assess whether an appropriate

safety focus was maintained.

b.

Observations and Findinai

The inspectors observed an appropriate safety focus in the operation of the facility,

most notably in the decision to promptly shut down Unit 2 when it was determined

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that the instrumentation test problems discussed in Section 01.1 could not be

resolved, within the allowed time, to plant management's satisfaction. The deelslon

to delay startup while an intermediate range nuclear instrumentation detector was

repaired was another example of conservative decision making, in that the T/3

allowed startup with only one operable detector.

Four examples of operational decisions which were not consistent with the normally

strong safety focus were noted by the inspectors. None of these decisions had a

direct impact on the safe operation of the facility. Multiple equipment failures or

human errors would have been required while these decisions were in effect for

there to have been an impact on the safe operation of the facility,

The first decision was to perform the MSIV maintenance diagnostic test during a T/S

required shutdown, which resulted in the unit remaining critical approximately an

hour longer than necessary (as discussed in Section 01.1). Following this

shutdown, the operations manager directed that a new procedure be written to

ensure that T/S required shutdowns were not delayed by the performance of optional

testing.

The second decision involved restart of Unit 1 with an inoperable upper containment

personnel hatch interlock. While allowed by the T/Ss, this decision resulted in

reliance on manual action rather than automatic action to prevent defeat of the

personnel hatch should use of the hatch be required during an emergency. A new

procedure was written to help ensure proper operation of the hatch.

The third decision involved performing repairs to Unit 1 control room annunciators.

Shortly before pressurizing and heating up the plant, plant staff identified that an

outage of annunciator panel 10-03 would be required to repair a degraded resistor.

The outage removed 122 annunciator windows from service. The required repair

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could have been performed prior to exiting cold shutdown conditions, but it was nnt.

The licensee established appropriate administrative controls for the annunciator

outage. The inspectors observed the outage, which lasted approximately 1% hours,-

and did not note any performance problems.

The fourth decision involved relying on an analysis to demonstrate Unit 1 CCW

system operability rather than performing a test to confirm proper system alignment

and operation. This issue is discussed in more detail in E1.1.

b.

Conclusions

The facility was operated in a safe mannei with a strong safety focus and generally

conservative operational decisions.

02

Operational Status of Facilities and Equipment

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a.

Inspection Scope

The inspectors performed a walkdown of the Unit 1 containment. This walkdown

was performed after licensee management's containment walkdown but prior to final

containment closeout.

b.

Observations and Findinat

The inspectors verified that equipment stored in containment was appropriately

secured. The general cleanliness of the containment was considered to be

acceptable in that no immediate or direct challenges to safety related systems or

components were observed; however, the inspectors found and removed several

pieces of loose tape, a broken stay tie, an aerosol can cap, a radiological posting, a

bottle of leak detection fluid, and some other miscellaneous trash. The total volume

and surface area of the removed items was insignificant compared to the available

surface area of the emergency core cooling system sump recirculation strainers.

The inspectors also noted two pieces of modular reflective insulation unsecured

within the *B" reactor coolant pump (RCP) cubicle, a spare valve protector for a

portable nitrogen bottle, and about twenty pieces of electrical tape dangling from

electrica: conductors on the containment polar crane. The inspectors informed the

licensee of these observations, and the observed items were subsequently removea

from the containment by licensee staff .nrior to final containment closeoui. The

electrical tape removed from the polar crane was characterized as being quite old

and degraded.

c.

Conclusistni

The inspectors determined that Unit 1 containment cleanliness was sufficient to

prevent immediate 6afety concems; however, the inspectors identified several items,

including loose electrical tape, which should not have been present.

02.2 Cold Weather Preparations

a.

insoection Scoco flP 71714)

The inspectors reviewed the implementation of the licensee's cold weather

preparations and freeze protection program for safety-related systems.

b.

Observations ansi Findinos

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The inspectors reviewed the licensee's completed surveillances for cold weather

preparations and performed independent verification checks of selected cold weather

protection equipment. No problems were identified.

During a previous inspection ' Inspection Report No. 50-266/97003(DRP);

50 301/97003(DRP)), the inspectors identified concerns with the material condition of

the facade freeze protection system and with work orders not receiving the

appropriate priority to ensure completion before the onset of cold weather. An

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additional concern involved the uncontrolled use of heat lamps in the facades to

alleviate freeze protection circuitry problems in heat traced lines.

The inspectors reviewed the licensee's response to these concerns and noted that a

facade freeze protection improvement initiative was started in June of 1997. The

maintenance backlog reduction group was given the task to address the freeze

protection circuitry problems. The major problem involved the functional quality of

the existing heat tracing coils. To address this problem, new heat tracing wiring and

leads were installed on much of the facade piping. At the conclusion of the

inspection period, about 90 percent of the new heat tracing had been installed in the

facade systems requiring heat tracing. The remaining 10 percent was scheduled to

be completed within the next few weeks. The inspectors concluded that the licensee

had made acceptable efforts to restore the facade freeze protection system to a

reliable functioning status.

During this inspection, no heat lamps were in place within the facades and

operations department management implemented the use of the station's temporary

information tag or temporary modification programs as the formal means to track

heat lamp usage.

Also during this inspection period, an NRC Maintenance Rule

Inspection Team identified the failure to consider the facade freeze

protection system to be within the scope of the Maintenance Rule (see

Inspection Report No. 50 266/97025(DRS); 50 301/97025(DRS)).

c.

Conclusions

The licensee had ta'Kon adequate measure to ensure that safety systems susceptible

to freezing were protected during the wir ter months. Actions taken to address

previous concerns with facade freeze protection system were also acceptable.

03

Operations Procedures and Documentation

03.1 Use of Procedures in the Operations Department

Ln.ipection Scoce

a.

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The inspectors monitoled the facility's control and use of proceduret to ensure

compliance with NRC regulations and the T/Ss, and to ensure that activities affecting

quality were appropriately planned and executed.

b.

Observations and Findinas_

The inspectors observed good use of procedures by operators in the control room

and in the plant. Procedures which could not be performed as written were

corrected prior to performance of work: however, the large number of required

procedure changes was indicative of the poor past practices regarding procedure

development and use.

Proactive lmorovements in Ooerations Procedures and Usagg

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The inspectors discussed the improved procedure usage with tne operations

manager who informed the inspectors of two initiatives within the operations

department. The inspectors considered these initiatives to be significant. The first

initiative involved the reclassification of all operations procedures as ' Continuous

Use." This classification dealt with a reported mind set among operators that non.

continuous use procedures did not need to be performed as written. The inspectors

discussed this mind set with the Regulatory Services and Licensing Manager, who

acknowledged that the failure to perform any required procedure as written, unless

authorized by 10 CFR 50.54(x), was inconsistent with NRC requirements ar.d the

licensee's Nuclear Power Business Unit, Procedure 1.1.2, *Procedurs Use and

Adherence." The second initiative involved the conversion of all repetitive use

operations work plans to procedures. This initiative reduced the possibility that a

work plan would be used to perform activities that the T/Ss required in be

procedurally controlled. The inspectors will monitor the effectiveness of these

operations department initiatives and the use of procedures by other departments

under the previously opened inspection follow up item (IFI) 50 266/97020-02(DRP);

50 301/97020-02(DRP).

The inspectors also observed positive examples of another operations department

significant initiative. The experienced contractors mentoring operators in the control

room were observed to coach plant staff to ensure that activities affecting quality,

such as troubleshooting a failed control rod drive logic card, were planned and

controlled using approved procedures.

inadeauste Procedure Reviews

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An operator initiated CR 97 3877 on November 17,1997, to document an

inadequacy in Surveillance Procedure TS 30," Low Head Safety injection Check

Valve Leakage Test (Cold Shutdown)," Revision 16. Specifically, the procedure

directed that containment isolation valves be opened, while containment integrity was

in effect, without establishing the appropriate compensatory control of having a

dedicated operator stationed at the valve. Another operator initiated CR 97-3870 on

November 23,1997, to document an inadequacy with In service Test (IT) 300,

• Feedwater Leakage Check Test Line Valve," Revision 10. This procedure also

directed that a containment isolation valve be opened without specifying the use of a

dedicated operator. On both of these occasions, the involved operators identified the

procedure errors after the valves were opened but before T/S containment integrity

requirements were violated. Work was stopped, the containment isolation valves

were shut, and the procedures were corrected.

The low temperature overpressure protection (LTOP) system actuated on October

23,1997, when operators started the Unit 1 "A" RCP using Operating Procedure

(OP) 4A, * Filling and Venting Reactor Coolent System,' Revision 44, and OP 48,

" Reactor Coolant Pump Operation," Revision 33. This RCP start was unusual in that

it was part of a fill-and vent evolution but the primary system was solid with little

entrained gas. The operating crew anticipated rapid pressure swings when the

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pump was started, so the control operator made large and rapid changes to the

chcmical and volume control system (CVCS) letdown and charging controls.

Because of the lack of entrained gas in the primary system, the system induced

pressure transient was insignificant. The manipulation of the CVCS controls resulted

in en overfilling transient which was terminated by the operator's actions and the

LTOP a:tuation. The October 23,1997, LTOP event was the second time that a

RCP had been started during fill and venting of a solid, de-gassed primary system.

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A subsecor't review of data from the first time evolution, in September 1997,

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indicateu that an LTOP actJallon had nearly occurred on that occaslon. Procedure

OP 4B I;ad been changed on August 2,1997, to cover sta . . 4 RCPs in the

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condtions cescribed above, but this change had not established controls or

cor.Wed cautions for the operato,s to prevent the LTOP actuation. Planned

corre.;tive action 6 for the latest event includes additional crew training and revision of

the procedures.

The inspectors concluded that the inadequate procedures described above were not

indicative of a repetitive problem because of the large number of new procedures

and revised procedures which were implemented during this inspection period. The

licensee identified and corrected, non-repetitive inadequacies in IT 300, TS 30, and

OP 48 are considered to be examples of a non-citeo violation

(NCV 5F266/97021-01(DRP); 50 301/9702101(DRP)). In recent insoection periods,

the insp;,ctors had noted that operators were being relied upon to catch procedure

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errors which should have been corrected during procedure preparation and review.

The events described above indicate the risk associated with continued reliance on

operators to catch procedure problems. The effectiveness of the initiatives to

improve procedures and procedure reviews so that less burden is placed on

opMators will be monitored under the previously opened IFl 50 266/97020-02(DRP);

50-301/97020 02(DRP),

c.

Conclusions

The licensee identified and corrected three examples of the use of inappropriate

procedures. The need for numerous other procedure changes was identified by

operators prior to the use of the procedures. Despite these problems with procedure

development and review, the inspectors considered the use of procedures in

operations to be good. This strong performance was based, in part, on operations

department initiatives to clarify that all required procedures were to be performed as

written, to ensure that activities requiring procedures were performed using

procedures rather than work plans, and to provide mentors who reinforced the need

for procedural control of activities affecting quality.

03.2 Comoonent Coolina Water Procedures

a,

bsDection ScoDe

The inspectors reviewed normal, abnormal, and emergency operating procedures

for the CCW system.

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b.

Observations and Findinos

The inspectors reviewed OP 6A, * Operation of Component Cooling System,"

Revision 21, and Check List 6A, * Component Cooling, Unit 1,* Revision 22, and did

not identify any signincant issues. The inspectors also reviewed Abnormal Operating

Procedure (AOP) 98, Unit 1,' Component Cooling System Malfunction," Revision 9,

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and only identified one potential concern. Specifically, Step 6 directed that the CCW

surge tank vent valve, CC.17, be opened if the CCW surge tank level was trending

lower. Valve CC.17 must be closed (closed system outside of containment) to

maintain containment integrity because there are not two containment isolation

valves in the CCW system. The inspectors were concerned that operators

implementing AOP 9B could overlook the impact of opening CC.17 under the stress

of responding to a CCW system failure. The inspectors detennined that this issue

did not make AOP 9B inadequate, but discussed the concern with the procedure and

tho basic system configuration limitations which affected the procedure, with licensee

tranagement.

The inspectors reviewed Emergency Operating Procedure (EOP) 0.0, *Redlagnosis,"

Revision 5, and EOP 1.3, " Transfer to Containment Sump Recirculation," Revision

15 to determine whether the CCW system was adequately described and controlled.

The inspectors did not identify any concerns with EOP 0.0. However, the inspectors

identified that Step 9, * Establish Desired Component Cooling Lineup," of EOP 1.3 did

not establish the same system lineup described in the operability determination (OD)

for CR 96-416 (see Section E1.1). Specifically, the inspectors identified that the

CVCS seal water heat exchanger and the waste gas compressors were not isolated

by EOP 1.3 but were not considered as flow paths in the OD. The site system

engineers wrote CR 97 3754 and an associated OD to document and address this

inspector-identified issue (Section E1.1). The inspectors also identified that EOP

1.3, Step 9e, directed that CCW flow to the CVCS non-regenerative heat exchanger

be isolated by closing valve 1(2)CC 130 using its pneumatic actuator controller

1(2)HC 130. The inspectors noted that 1(2)CC-130 was a fall-open butterfly valve

and that its pneumatic actuPor was nonsafety related. The inspectors also noted

that there was no direct control board indication of the position status of 1(2)CC-130

or direct indication of CCW flow through the CVCS non regenerative heat exchanger.

The only available indication for an operator to use in determining whether use of the

pneumatic actuator had achieved the desired results was the CCW system total flow

indicator. The inspectors noted that no quantitative value for flow change as a result

of successful closure of 1(2)CC 130 under accident conditions was available to the

operators, and flow changes in the CCW system from completion of Steps 9c

(placing a residual heat removal (RHR) heat exchanger in service), 9d (isolating

CCW loads in containment), and paraiset performance by an auxiliary building

operator of iso!ating a boric acid evaporator (Attachment A of EOP 1.3) could mask

the effect of Step 9e. Additionally, if the nonsafety related actuator were to fall open

after completion of Step 9e, there would be no direct indication of CCW system flow

diversion from safety related loads.

The inspectors reviewed the CCW system test procedures and ODs, and concluded

that the effect of CCW flow diversion through the non regenerative heat exchangers

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was not evaluated or bounded, and had the potential to directly affect the mitigation

of a design basis loss of coolant accident. The non regenerative heat exchanger

Isolation valve,1(2)CC 7408, was used during performance of CCW system tests to

serve the function covered by EOP 13, Step 9e. The weaknesses in controlling _

CCW system configuration during accident conditions was a contributing aspect of

the test control inadequacies described in Section E1.1.

c.

Csnelusions

Most CCW system normal, abnormal and emergency operating procedures were

considered appropriate,- but the inspectors identified weaknesses associated with the

failure of the EOP to provide for positive isolation of nonsafety related CCW flow

paths during the containment sump recirculation phase of accident mitigation.

04

Operator Knowledge and Performance

The inspectors interviewed several licensed and non licensed operators regarding

the function, design, component makeup, and system interrelationships of the CCW

system. All opemtors interviewed displayed a solid fundamental understanding of

the system and its overall purposes. Control room operators were familiar with the

cause of alllit CCW system annunciators and accurately explained all system

Indications discussed with the inspectors.

05

Operator Training and Qualifications

The inspectors reviewed Training Handbook 10,9," Primary Systems Descriptions:

Component Cooling System," Revision 4, and found it to be informative and

accurate. Some of the non licensed operators stated during interviews with the

inspectors that

improvements could be made regarding the depth of training they receive on system

interrelationships following initial operator qualifications.

07

Quality Assurance in Operations

07.1 Imorovements In the Licensee Quality Assurance Function (IP 40500)

a.

Insoection Scope

The inspectors performed reviews of some licensee Quality Assurance (QA)

organization uudits, assessments, and CRs to determine the effectiveness of the QA

function,

b.

Obseivations and Findinas

The licensee conducted three program-level assessments of the Point Beach QA

organization and function during the last 18 months. The most recent was

completed in April 1997, and two of the three assessments were conducted by

outside contractors. The assessments were critical of the organizational and

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functional performance, and consequently major organizational, personnel, and

staffing changes were implemented. The inspectors noted significant improvement

in the number and quality of QA findings following these changes. The most

important QA findings were classified as QA Program Significant issues, and were

tracked as separate high level priorities within the licensee work and improvement

prioritization process.

In addition, the QA orgnizetion performed a self assessment, S A 9719, dated

November 20,1997, of their performance in implementing corrective actions from the

program level assessments. This self assessment involved the participation of two

CA managers from other nuclear power plants. The self assessment acknowledged

the improvements noted by the inspectors, and also identified opportunities for

continued improvement, including better training and qualification of OA staff, more

consistent initiation of CRs, and more time for preparation for performance of audits.

One additional issue in "1e self assessment was that the QA Program Significant

Issues list was one of ma,iy priority lists in the prioritization process, and that this

fact led to uncertainty on the part of line managers as to relative significance (see

also Section X2 for discussion of work prioritization issues).

Another positive action observed during this report period was the development of

performance indicators for corrective action backlogs in the line organizations. This

action was undertaken to help focus management attention on the CR process. One

issue that was of concern to the inspectors was the lack of a programmatic process

for assigning work priorities within the CR backlog. Plant management had directed

individual line managers to ensure that CRs were worked in the order of safety

significance, but no process existed to evaluate performance in this stea,

c.

Conclusions

Performance of the QA organization's identification and documentation of findings

improved significantly as the '. ssult of self critical, program-level assessments

performed by the licensee. A self assessment performed by QA during this report

period noted improvement but identified additional areas for improvement. The

inspectors considered the improvements and the thoroughness of the current self.

assessment to be positives.

New performance indicators for corrective action backlogs were implemented, but

prioritization of CRs within each organization's backlog was of concern to plant

management.

08

Miscellaneous Operations issues

08.1 [Qlgsed) IFl 50 266/97003-01(DRP): 50 301/97003-01(DRP): Miscellaneous

concerns regarding the facade freeze protection system. The inspectors' follow-up

review of these matters is discussed in Section O2.2 of this report. The inspectors'

original concerns were determined to be adequately addressed.

14

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OS.2 (Closed) Ucensee [ *nt Report (LER) 50 266/95005-00: Manual Reactor Trip

During Startup Physics Testing. On April 15,1995, control rod F-12 dropped into the

Unit 1 core during low power physics testing. Unit 1 was critical below the point of

adding heat at the time. During troubleshooting on April 16,1995, a second control

rod, E 11, dropped part way into the core when the control operator withdrew rods in

control bank A. When the second rod entered the core, the reactor went subcritical.

The duty shift superAor ordered the reactor manually tripped.

The licensee dete.

ad that rod E 11 dropped because fuses pulled to facilitate

troubleshooting actN, des on rod F 12 were common to movable gripper coils of both

rods. After the manual reactor trip, troubleshooting activities on the F 12 rod

determined that the rod had dropped due to the failure of its stationary gripper coll.

The licensee initiated CR 95 255 for this event and performed Root Cause

Evaluation 9510 since human performance factors contributed to the partial drop of

E 11. The root cause evaluation determined that there was a miscommunication

between the instrument and control engineer coordinating F 12 troubleshooting

activities and the reactor engineer and control operator for Unit 1. The root cause

evaluation also determined that inadequate shift tumover and pre job briefs

contributed to this event.

The licensee replaced the failed stationary gripper coil stack and successfully tested

it prior to the subsequent restart of Unit 1. The licensee had an off site laboratory

analyze the failure mechanism of the failed stack. The laboratory determined that

the primary contributor to the coil failure was high temperv

' hat resulted from the

failure of a control rod drive motor shroud fan damper.1

censee repaired the

damper and shroud temperatures remained normal during Unit 1 operation.

Secondary contributors to the coil failure were aging and moisture / boric acid

intrusion. The licensee subsequently inspected the stationary gripper coil stacks for

Unit 1 and Unit 2. No problems were identified.

The inspectors reviewed the root cause evaluation, the CR, the laboratory report,

and F 12 troubleshooting, and coil stack replacement work plans. The inspectors

had no concerns with any of these activities. The inspectors also noted that recent

improvements in communications during reactivity maneuvers, shift tumovers, and

pre job briefs should prevent this event from occurring again. The inspectors had no

additional concerns with this issue.

II. Maintenance

M1

Conduct of Maintenance

M1.1 Te9s and Surveillances

NRC Inspection Procedures 62707 & 61726 were used in the inspection of plant

15

4

maintenance and surveillance activities, The inspectors observed and reviewed

selected ponions of the following tests:

In service Test Procedure 10A," Test of dectrically Driven Auxiliary Feed

Pumps and Valves With Flow to Unit 1 Steam Generators (Quarterly)?

Revision 1, conducted on November 26,1997.

TS Test 45 "Feedwater Isolation Test From a Safety injection Signal Unit 1,"

Revision 0, conducted on November 14,1997.

In service Test Procedure 530A,' Leakage Reduction and Preventive

Maintenance Program Test of the Train A High Head Safety injection and

Residual Heat Removal Systems Unit 1," Revision 2, conducted on November

26,1997.

The work performed under these activities was professional and thorough.

Technicians were experienced and knowledgeable of their assigned tasks. The work

packages were present at the job site and actively used by the technicians for all

work observed. System engineers were frequently observed monitoring job

progress.

M2

Maintenance and Material Condition of Facilities and Equipment

M2.1 . Containment Hatch Interlock inocerability

a.

insoection Scope (IPs 62707 & 37551)

The inspectors reviewed the circumstances surrounding the licensee's identification

that a gear was missing from the Unit 1 containment upper personnel hatch interlock

mechanism. The inspectors also reviewed the results of the licensee's root cause

investigation into the matter,

b,

Observatipns and Findinas

'

Maintenance workers identified that a gear was missing from the Unit 1 containment

upper hatch interlock mechanism while preparing to perform operational checks on

the hetch. Condition Report 97-3574 was written to address the defect and to note

that the absence of the gear inight defeat the interlock system. Licensee

management requested a root cause evaluation of the missing gear.

,

Licensee engineering staff verified through field tests that, with the gear missing, the

interlock system could be defeated if the normd lever manipulations for opening the

hatch doors were not followed. This condition was documented in CR 97-3756.

The licensee's root cause evaluation determined that the gear was removed on

December 28,1996, following an unsuccessful containment hatch leakage test. The

failure of the test was attributed to a bent remote operator shaft which was causing

damage to the quad ring seal. Removing the hatch interlock gear was intended to

16

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eliminate stresses on the seal ring caused by the bent shaft. Removal of the gear

was not recognized as being a temporary modification to the hatch interlock system;

therefore, the design control process was not used and the proper reviews and

approval of the gear removal were not obtained. The gear was removed under work order 9614237. A station log entry referenced that the hatch was operable based on

a successful hatch leakage test performed following the removal of the gear. No

post maintenance testing of the hatch interleck was performed.

Unit 1 was at power between December 28,1990, and February 18,1997, with the

Unit 1 containment hatch interlock system inoperable. The failure to perform the

required compensatory actions was a Violation (VIO 50-266/97021-02(DRP);

50 301/97021-02(DRP)) of T/S 15.3.6.A.1.d.2. No instances were noted that

indicated that the containment ilitegrity for Unit 1 was degraded during this period,

c.

Conclusions

The licensee inadvertently defeated the Unit 1 containment upper hatch interlock

system by removing a gear from the system without utilizing the appropriate design

control processes for work on safety related components. One T/S violation was

identified.

M2.2 Comoonent Cooling _ Water System Walkdowns and Material Con @gn

The inspectors conducted walkdowns 'the CCW system and saw no obvious

material condition problems. The inspectors also reviewed CRs for the CCW

system. Many of the CR's identified isolated problems or deficiencies. However,

one issue which was noted in several CRs was the unreliability of pressure

controllers and level transmitters in the system. The instruments had been

frequently found out of tolerance end presented calibration repeatability difficulties.

Another issue involved a several year old problem with fluctuations in the CCW

surge tank level. There were several apnarent contributors to this level fluctuation,

,

but definitive corrective actions had not been taken. The inspectors concluded that

there was no safety consequence associated with the surge tank level fluctuations.

M2.3 Primarv Auxiliary Buildina (PAB) Boric Acid L.eaks

During tours of the PAB and the Unit 1 containment, the inspectors observed boric

acid build-up and numerous work order tags on several pieces of safety-related

equipment. Boric acid build-up was present on the mechanical seals for the safety

injection (SI) and RHR pumps and body-to-bonnet joints and packing for charging,

SI, and RHR valves. There were more work order tags and boric acid build up than

the inspectors had observed during previous tours of the PAB, but the inspectors

had no operability concerns. All observations were discussed with plant

management.

17

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M3

Maintenance Procedures and Documentation

M3.1 CCW Pumo Modification

a.

Inspection Scope (IP 62707)

The inspectors reviewed the replacement of the Unit 1 CCW system *B" pump motor

and the overhaul of the pump impeller,

b.

Observations and Findinas

The licensee pit.nned to replace the motor for the Unit 1 CCW *B* pump (due tc high

vibrations) with the spare pump motor maintained onsite to meet 10 CFR 50,

Appendix R requirements. Pump impeller overhauls were also planned to be

performed during the motor replacement.

After a couple of days of work, the job vlas stopped following requests by the job

leaders because the procedures being used were cumbersome to implement and

hard to follow. At one point prior to the work being stopped, maintenance workers

were referencing three procedures at one time. Maintenance management stopped

the work and immediately met with workers to more fully understand the problems

and establish a strategy to address the concerns prior to work recommencing.

The inspectors discussed the circumstances with maintenance personnel and

supervision and determined that the causes for the procedural problems leading to

the work stoppage included inadequate management guidance regarding the scope

of the work, and failure to provide enough lead time following procedural

development to allow for a thorough procedure review and walkdown.

,

Once the work was restarted, it was conducted smoothly and in a timely manner.

The inspectors noted that workers involved with the repairs exerdsed good craft

skills, housekeeping in the work area was tidy, and appropriate tools were used

during the repairs. However, there were inconsistencies in the manner by which

foreign material exclusion areas were established and controlled during the work

suggesting that the intent of the program and/or station procedures were not clearly

understood by the workforce.

c.

Conclusions

The inspectors concluded that maintenance supervision effectively responded to

problems encountered by workers during the CCW pump and motor repairs.

Inadequacies in work scoping and insufficient lead time following procedure

devebpment caused the problems.

>

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______ _ __ _______ _ _ -_ _ _

.

lll Enn neerina

E1

Conduct of Engineering

E1.1

CCW System Testina Inadecuacies

a.

Inspection Scope UP 3755.)

The inspectors reviewed the CCW system test and surveillance procedures to

ensure that the system was tested in a manner which ensured that design basis

requirements would be met under postulated accident conditions and configurations.

b.

Qblervations and Findinas

The inspectors found that identifying design bases requirements for the CCW system

was difficult. The T/Ss did not contain any quantitative requirements for the system.

The Final Safety Analysis Report (FSAR) provided adequate discussion of some

design bases information such as containment integrity considerations, but did not

list required flow rates for all safety related loads and did not reference critical

operational controls such as the need to throttic the CCW system outlet valves from

the RHR heat exchangers to prevent pump run out. The FSAR also provided only

one taference to design basis documents for the CCW system. The inspectors

reviewed two recent 10 CFR 50.59 r /aluations: Safety Evaluation 97-183 and Safety

Screening 97-1259-01. Neither e'.alu0 tion referenced CCW system current licensing

basis requirements other than the T/Ss and FSAR. The inspectors did not identify

any inadequacies in the two evaluations; however, the potential existed to miss

important considerations when modifying the system or system procedures.

The CCW system had only a single containment isolation valve on the return lines

from containment. To compensate for this, the system outside containment was

maintained as closed to the environment. This provided redundancy for the

contait. ment isolatinn function. The inspectors noted that some of the valves relied

upon for keeping the system closed outside of containment were known to have

small amounts of seat leakage, but the valves were not included in the periodic valve

leak check program, the leak rates were not quantified, and a bounding analysis of

acceptable leak rates was not developed. The licensee informed the inspectors that

this condition had been reviewed and found acceptable within the current licensing

basis (CLB). The inspectors will review the acceptability of classifying a system as

closed without performing boundary valve leak checks as an IFl (50-266/97021-

03(DRP); 50 301/9702103(DRP)).

The inspectors reviewed IT 12, " Component Cooling Water Pumps and Valves

(Quarterly)," Revision 12, to determine whether the ability of the CCW system to

meet its design bases requirements under accident conditions was adequate!y

demonstrated. Procedure IT 12 provided testing methodology which satisfied the in

service test requirements of TS 15.4.2; however, it did not demonstrate system

operability relative to safety-related flow and flow distribution. The system

engineering group referred the inspectors to Wisconsin Michigan Test Procedure

19

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(WMTP) 12.11,' Component Cooling System Flow Test," Revision 1, performed on

November 2,1989, and Point Beach Test Procedure (PBTP) 52, "Coi.vonent

Cooling Water System Flow Test - Unit 2,* Revision 0, performed on June 10,1997.

The inspectors detemuned that WMTP 12.11 did not test the CCW system in its

accident configuration and did not include provisions for considering instrument

inaccuracy in establishirg acceptance criteria. Procedure PBTP 52 also did not test

the CCW system in its accident configuration, and the specified acceptance criteria,

which included instrument inaccuracy, had not been satisfied. The licensee informed

the inspectors that there were no other applicable test procedures. The failure to

perform testing that demonstrated that the CCW system would satisfactorily perform

its safety-related function under accident conditions, was a violation

(50-266/97021-04(DRP); 50-301/97021-04(DRP)) of 10 CFR 50, Appendix B,

Criterion XI, " Test Control."

After identifying the testing problems discussed above, the inspectors reviewed the

licensee's record of CRs and ODs for the CCW system to determine whether

reasonable assurance of system operability existed. The inspectors found that CR

96-416 and an OD had been written on December 30,1996, which clarified design

basis flow requirements and relied on some of the test data from WMTP 12.11 to

demonstrate operability. This OD was inadequate in that, while relying on some test

data from WMTP 12.11, it ignored other data from WMTP 12.11 and did not consider

the impact of nonsafety-related loads which were not isolated under accident

conditions. CR 97-1863 had been written to document the tailure to obtain

acceptable test results during performance of PBTP 52. An OD associated with this

CR stated that sufficient margin existed to allow lowering the required acceptance

criteria. This OD wac inadequate in that action was not taken to develop revised

acceptance criteria or to change the CLB. On November 4,1997, the inspectors met

with licensee staff and provided specific concems with CCW system bst

methodology and the OD associated with CR 96-416.

On November 11,1997, a licensee engineer wrote CR 97-3754 to document

confirmation of the inspectors' finding that two nonsafety-related loads not

considered in the OD for CR 96-416 were left in service when following the steps of

EOP-1.3 (see Section O3.2). The OD for CR 97-3754 containec a corrective action

to revise EOP-1.3, prior to Unit 1 start-up, so that the CVCS seal heat exchanger

and waste gas compressor would be isolated during containment sump recirculation.

On November 25,1997, a system engineer wrote CR 97-3901 to document that

EOP-1.3 had not been revised prior to Unit 1 leaving cold shutdown in the start-up

process. The ODs for CRS 97-3754 and 97-3901 both failed to address the lack of

acceptable test results. On November 25,1997, the inspectors informed the plant

manager and the site vice president of their concerns with the adequacy of the

existing ODs for the CCW system. A new OD was completed on November 28,

1997, prior to Unit 1 going critical. This OD provided reasonable assurance that the

CCW system would perform its design safety functions by taking credit for seasonally

cool service water system temperatures. The failure to establish an adequate basis

for system operability between December 30,1996, and November 28,1997, was a

violation (50-266/97021-05(DRP); 50-301/97021-05(DRP)) of 10 CFR 50, Appendix

B, Criterion XVI, " Corrective Action."

20

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c.

Conclusions

The inspectore concluded tnat CCW system testing had not demonstrated the

system's ability to provide its safety related function when instrument inaccuracies

and potential accident condition system lineups were considered. The inspectors

3!so determined that four ODs for these problems had been generated between

December 1996 and November 1997, but that these ODs were not E.1 equate. The

licensee developed an adequate OD after the inspectors brought this issue to the

attention of plant management.

E2.1

Positive System Enciaeer Performance

The licensee committed to test and maintain spare ventilation equipment in

LER 266/97-020-00. While preparing a safety evaluation for the required test, a

system engineer identified that an unreviewed safety question (USQ) would exist if

the test were performed with a unit at power. This issue was identified as the result

of a thorough review of references in the FSAR. The inspectors considered the

performance of the extensive research required to identify this potential USQ to be a

positive.

E4

Engineering Staff Knowledge and Performance

The inspectors found system engineers to be knowledgeable of their systems in

most cases. However, during the course of the CCW system inspection, the

inspectors requested information on the operation of valve 1(2)CC-130. During

subsequent discussion between the inspectors anO the system engineer for the CCW

system, the system engineer stated that valve 1(2)CC-130 was a fail-closed valve.

The inspectors questioned this conclusion based on field observation of the valve

actuator arrangement. Additionally, check list 6A contained a note which stated that

valve 1(2)CC-130 was gagged to prevent CCW pump run out should the valve fail.

ihe difference between a fail-open and fail-closed valve was also significant

because of potential CCW flow diversion under accident conditions (see Section

O3.2). The system engineer later informed the inspectors that valve 1(2)CC-130

was a fail-open. The system engineer wrote a CR which indicated that the vender

information for the valve was incorrect. The inspectors considered the system

engineer's lack of familiarity with the as-installed method of operation of the valve

actuator to be a weakness.

IV, Plant Support

R1

Radiological Protection and Chemistry (RP&C) Controls (IP 71750)

During the inspection period the inspectors frequently entered the PAB to conduct

housekeeping inspections and surveillances observations. Generally, radiological

housekeeping was good. However, during an inspection on November 25,1997, the

inspectors identified that a piece of drain tubing associated with Unit 1 Leakage

Reduction and Preventive Maintenance Program tests was dripping a small amount

of reactor coolant onto the floor of the #2 pipeway within the PAB. The inspectors

21

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informed operations and health physics personnel of the condition and it was

appropriately addressed,

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V. Manaaement Meetinas

X1

Exit Meeting Summary

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

conclusion of the inspection on December 2,1997. The licensee acknowledged the findings

presented.

The insoectors asked the licensee whether any materials examined during the inspection

should be considered proprietary. No proprietary information was identified.

,

X2

Management Meeting Summary

A public meeting with the licensee was held on October 29,1997, in Manitowoc. Wisconsin.

Licensee senior management provided the NRC Point Beach Oversight Panel with the

current status of improvement initiatives. Individual managers described the review and

approval process for ensuring that Unit 1 was ready to be restarted. Planned improvements

in the work planning process were also discussed in detail. The NRC was also told that an

Operating Plan for 1998 was being developed. This plan will prioritize licensee initiatives

and commitments to the NRC, such as development of comprehensive current licensing

bases documents. It will also provide a means for licensee management to track the status

of the improvement initiatives. The NRC welcomed this initiative because the prioritization

tools in place, the QA Program Significant issues Listing, the Level 1 Report, the Plan for

Achievement of Operational Excellence, and the corrective action program Significant

Conditions Adverse to Quality allidentified appropriate information but did not appear to be

integrated.

23

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PARTIAL LIST OF PERSONS CONTACTED

. Wisconsin Electric Power Comoany

S. A.- Patuiski, Site Vice President

A. J. Cayla, Plant Manager

. R. G. Mende, Operations Manager

W. B. Fromm, Maintenance Manager

.J. G. Schweitzer, Site Engineering Manager

P. B. Tindall, Health Physics Manager

D. F. Johnson, Regulatory Services and Licensing Manager

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' INSPECTION PROCEDURES USED

IP 37551:

Onsite Engineering

IP 40500:

Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing

Problems

IP 61726:

Surveillance Observations

IP 62707:

Maintenance Observation

IP 71707:

Plant Operations

IP 71714:

Cold Weather Preparations

IP 71750:

Plant Support Activities

ITEMS GPENED, CLOSED, AND DISCUSSED

Opened

50-266/97021-01(DRP)

_

_

50-301/97021-01(DRP)

NCV

Procedural Inadequacies

50-266/97021-02(DRP)

50-301/97021-02(DRP)

VIO

Containment Hatch Interlock Inoperability

50-266/97021-03(DRP)

'

50-301/97021-03(DRP)

IFl

Closed System Without Boundary Checks CCW

System

50-266/97021-04(DRP)

_ VIO

Inadequate Testing of CCW System

50-301/97021-04(DRP)_

_

50-266/97021-05(DRP)

50-301/97021-05(DRP)

_VIO

Inadequate Operability Determination for CCW

System

Closed

50-266/97021-01(DRP)

50-301/97021-01(DRP)

NCV

Procedural Inadequacies

50-266/97003 01(DRP)

50-301/97003-01(DRP)

IFl

Concems with Facade Freeze Protection

-50-266/95005

LER

Manual Reactor Trip During Startup

Physics Testing

Discussed

50-266/97020-02(DRP)

IFl

Review of Procedure Adherence and

25

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Effectiveness

50-301/97020-02(DRP)

IFl

LIST OF ACRONYMS USED IN POINT BEACH REPORTS

AC

Alternating Current

AFW

Auxiliary Feedwater

AOP

Abnormal Operating Procedure

ASME

American Society of Mechanical Engineers

CCW

- Component Cooling Water System

CFR

- Code of Federal Regulations

CLUB

Current Licensing Basis

CR

Condition Report

CVCS

Chemical and Volume Control System

ECCS

Emergency Core Cooling System

EOP

Emergency Operating Procedure

ESF

Engineered Safety Feature

EP

Emergency Planning

FAR

Final Safety Analysis Report

IFl

Inspection Follow-up item

IP

inspection Procedure

IPE

Individual Plant Evaluation

IR

Inspection Report

ILRT

Integrated Leak Rate Test

IT -

In-service Test

LCO

Limiting Condition for Operation

LER

Licensee Event Report

LTOP

Low Temperature Overpressure Protection

MSIV

Main Steam Isolation Valve

MSS

Manager's Supervisory Staff

NCV

Non-Cited Violation -

NDE

Non-Destructive Examination

NRC

Nuclear Regulatory Commission

OD

Operability Determination

01

Operating Instruction

OM

Operations Manual

OOS

Out-of-Service

OP

Operating Procedure

ORT

Operations Refueling Test

PAB

Primary Auxiliary Building

PASS

Post-accident Sampling System

PBTP

Point Beach Test Procedure

PDR

Public Document Room

POD

Prompt Operability Determination

QA

Quality Assurance

RCP

Reactor Coolant Pump

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RCS

_ Reactor Coolant System

- RHR

Residual Heat Removal

RMP

Routine Maintenance Procedure

RP.

Radiation Protection

RWST -

Refueling Water Storage Tank

SALP

Systematic Assessment of Licensee Performance

SER

Safety Evaluation Report

SFP

Spent Fuel Pool

SI-

Safety injection

SW

Service Water

TDAFW

Turbine Driven Auxiliary Feedwater

-T/S

-Technical Specification-

TS

Technical Specification Test

URI

Unresolved item

USQ

Unreviewed Safety Question

VIO

Violation

VNCR

Control Room Ventilation

WMTP

Wisconsin Michigan Test Procedure

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