ML20058L147
| ML20058L147 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 08/03/1990 |
| From: | Boston J WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9008070009 | |
| Download: ML20058L147 (32) | |
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{{#Wiki_filter:= , . . _ _ . . . . . _ _ _ _ , . . . , o.;. Wosconson 1 Electnc PONER COMPANY 23i W Michoort Po. Bcw 20n thwoukee. WI 53201 (414)221 2345 August 3, 1990 Document Control Desk U S Nuclear Regulatory Commission Mail Station P1-137 Washington, D C 20555 Gentlemen: Dockets 50-266 and 50-301 REEEonse to Insoection Reoorts 50-266/90-201 and 50-301/90-201 Electrical Distribution System Functional InsDectigD Point Beach Nuclear Plant Units 1 and 2 On June 5, 1990, we received Inspection Reports 50-266/90-201 and 301/90-201- dated June 1, 1990, which reported on the results of the electrical distribution system functional inspection (EDSFI) conducted by the NRC Office of Nuclear Reactor Regulation during March 12 through 16 and March 26 tnrough April 6, 1990 at our Point Beach Nuclear Plant Units 1 and 2. This inspection was _ performed to determine whether the slectrical distribution system as designed, installed, and configured at the Point Beach Nuclear Plant would be capable of performing ~ its intended safety functions. During this inspection the' team identified four general areas of weaknescessand 27 technical deficiencies. In the attachments to this letter, we have responded to each of these items. Attachment 1 contains our discussions'regarding the identified weaknesses and Attachment 2 is an item-by-item response to the identified deficiencies. On May 10, 1990, we sent you a letter which discussed the information presented.to the inspection team during the April 17, 1990, exit meeting. At that meeting we had discussed the steps we-had taken, or had-planned to take, to address the inspection findings as we understood them'at that time. Since the information presented in the subject inspection report provides the formal inspection findings and does not include information
- presented at the exit meeting, we wish to note that the information in this response either incorporates or supersedes the information provided in our May 10 letter.
As you--are aware through our frequent discussions with the NRC Region III personnel, we have already expended considerable effort in upgrading the electrical distribution system at Point Beach. These efforts included a self-initiated SSFI conducted in 1988 of the Emergency Diesel Generator systems. Many of the items l 9008070009 900003 O '/ PDR ADOCK 05000266 o PDC A mMA,qefIlluwsin EwxyOxpn&w lfl '
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(* ' August 3, 1990 Page 2 idsntified in this inspection were similar to those items we had already identified and shared with the inspection team. While we do acknowledge that the deficiencies identified in your inspection exist, many of these deficiencies had already been self-identified and corrective actions, in some cases, had already been initiated. The discussions in the attachments to this letter contain many commitments by Wisconsin Electric for specific evaluations, modifications, or other corrective actions. The schedules presented fo. completion of these actions are our best estimates for doing the required work. These estimates assume effective and ' efficient management of our available resources and refleet our present understanding of the efforts involved. We also recognize that we may have to address new issues not currently identified. Such efforts would be likely to impact the programs dir. cussed in this response. We will inform you of any changes to these commitments necessitated by scheduling of newly identified , projects or requirements. After you have had the opportunity to review the information included in this letter and attachments, it may be appropriate for us to schedule a meeting to discuss in more detail, or further clarify, our responses. In this regard, you should be aware that we are presently planning with our Project Manager, Mr. Robert Somworth, a meeting to be held in September to discuss in greater detail our plans for installation of the additional diesel generators and extra station batteries mentioned in our response to this inspection.
- Si erely, !
l /& ~ John W. Boston President and L Chief Operating Officer l Copies to: NRC Regional Administrator, Region III ( NRC Resident Inspector P
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ATTACHMENT 1 i Resnonses to Identified Weaknesses 1 The June 1, 1990, inspection report.for the electrical distribution system functional inspection (EDSFI) identified four general areas of weaknesses in the licensee's operations regarding this subject. The areas of weaknesses the team identified were (1) design and modification deficiencies in the Emergency Diesel Generator (EDG) and-125-Vdc systems, (2) lack of available design.and engineering information, (3) design features where a single failure can disable redundant equipment, and (4) engineering support that did not fully evaluate design or changes to design. Further clarification of these weaknesses and specific comments regarding the topics were provided on pages 1-111 of the inspection report. This' attachment - contains our responses to these identified weakness. The responses are identified with the numbers noted above. l-i 4 L l 4 7_ 1
c e '; , i a u . 4 Resoonse to Weaknees (1): The clarification of this weakness identified five specific 1 H cond>tions which exist in the diesel generator system and four specific conditions which exist in the 125 VDC. system. Each.of these conditions has been specifically addressed in a deficiency response as presented in Attachment 2. L Wisconsin Electric agrees with the conclusion presented in the inspection report that these two systems because of
- their design have great safety significance. Both syatems L are shared between units. The diesel generator system L includes two dierels.which are. shared. The 125 VDC system consists of four safety related batteries, all shared l between units. Two of these batteries were, however, added in the early 1980's and are presently not configured to be redundant with either of the two original plant station batteries which: provide power for most of the~ plant safeguards functions. Due, at least_in part, to the safety significance of these systems and their shared configuration Wisconsin Electric is in the process of preliminary design of major modifications to each system.
Wisconsin Electric had purchased early in 1990 prior to the inspection, and intends to install, two additional diesel l, generators at Point Beach. These diesels are of the same L manufacturer and are similar in size to the existing Point l Beach diesels. These additions and associated rearrangement. of.the 4160 volt electrical system will enhance our onsite AC power capabi'11 ties. Two diesels will be available even if one is out of service for maintenance or testing and a' single failure of a diesel occurs. This will result in a larger margin between the capabilities of the incividual diesel. generators and the electrical load they will be i required to supply under design basis scenarios. We expect to complete the diesel generator addition project in 1994. Wisconsin-Electric is also in the process of obtaining bids [' for the engine.ering necessary to add two additional station batteries to ~?oint Beach Nuclear Plant.
. The evaluation of the desireability of additional. station batteries was initiated prior to this inspection. The first of these batteries is to be an additional safety-related battery. It is our intention that this battery will be interconnected with the four existing station batteries such that it will be capable of providing the same function as any one of the
'four existing batteries should it be removed from service for maintenance or testing. It will also normally be available as an additional source of emergency DC power during design basis accident conditions. The second new battery will be a non-safety-related station battery. The addition of this battery will include the transfer of several large non-safety-related loads from the existing 2
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.v-station batteries to this new battery. Tnis transfer will significantly increase the margin between the capability of the existing safety-related station batteries and the load they would be required to supply under design basis conditions. The present schedule for completion of these additions is by the end of 1992.
Several of the specific conditions mentioned in the description of this area of weakness have to do with the fuel oil system. As indicated during the inspection, Wisconsin Electric was in the process of evaluating the actions necessary to upgrade the fuel oil system to the requirements for a safety-related system. The report on the steps necessary to upgrade this system to QA scope was completed'and presented to the Manager's Supervisory Staff-on July 25, 1990. The response to deficiency 90-201-18 lists the recommendations approved in that report. In addition to the above physical modifications, several other' actions are being taken which will assist in alleviating weakness in the design of the diesel generator and 125 VDC systems. The first of these is the development of design basis documents for the diesel generator system, the 4160 volt power system, the fuel oil system, and the 125 VDC systems- While the design basis reconstitution effort is a multi-year project (see response to weakness 2), development of design basis documentation for-the above systems will take place early in the pro $ect. The second of these is the development of the analytical tools and the compilation of the necessary data required to perform-detailed analyses of the design and capabilities of the electrical distribution systers at Point Beach. 'A description of the actions bsing.taken in this area is also
. included.in the. response to weakness (2). In addition to these two actions, we are in the process of creating a
-safety review group. It is anticipated that one of the functions of this group will be to review plant modifi-cations and operating methods to assure conformance to design basis and licensing basis requirements.
It-is our opinion that the above described actions when
- completed will result in stronger diesel generator and 125 VDC systems.
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O Response to Weakness (2): i The second general weakness identified by the NRC in the inspection report is. summarized as follows: The team's second identified area of weakness involved a lack of design documents and information. The team's review of the adequacy of > the electrical distribution system was complicated : by the lack of adequate and complete calculations and analysis. The team could not confirm ratings of certain equipment or determine fault currents to equipment. A steady-state load calculation'for , the EDGs did not exist until the inspection, and a transient analysis had not been performed. In addition, calculations for many device setpoints - did not exist. The team recognized that WEPCO had several existing _ programs that would address these concerns. However, the programs were preliminary efforts implemented too recently to be evaluated. It is the intent of the following to describe these i programs, their history, scope, and schedule for completion. ABB Imoell Proiect: The largest and most significant E program is that which is being accomplished by ABB Impell (Impell) for Wisconsin Electric (WE). This program was in existence at the time of the EDSFI and reflects WE concerns - in.some of the same areas as those identified by the inspection team. t Li In the mid 1980's it-was realized by Wisconsin Electric that i formal, documented calculations for several important aspects of electrical distribution systems at Point Beach j did not. exist or were otherwise not available to the
. engineering personne1' responsible for. operation and ,
l modification of the plant. ~ Examples of these aspects were l the electrical loading on components at various operating , conditions, the fault current available at points on the lf distribution systems, and the adequacy of electrical' l protection and selective coordination. While adequate - information was available to perform conservative engineering evaluation-in support of plant modifications, each evaluation was unique and no system was in place to ensure consistency in the evaluation methods or assumptions. 4 In addition,'the results of evaluations were not systematically incorporated into plant design information. L A specification was developed and Impell was contracted in late 1988 to develop the background data and annlytical tools necessary to allow for efficient and consistent evaluations of the electrical distribution systems at Point { 4 l I
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Beach. This project is presently in progress and is , expected to be completed.in mid 1992. This work is interided to create a system such that technical personnel will hava the tools and data necessary to efficiently and consistently evaluate such things as the level of electrical loading present on plant components and the acceptability of such loading, the voltage levels which would be present at points on the distribution system under various plant operating conditions, or the adequacy of l electrical protection for components. The general approach being used to accomplish this objective-includes the use of commercially-available software to provide the necessary analysis capabilities. Such programs are to be supplemented with one or more data bases, which will include all of the information required as input to the selected analysis programs. An executive program will be-developed which will translate the selected information in the data bases to create the system model to be evaluated by l the appropriate analysis software. This executive program = is being designed such that it provides flexibility to define exactly what is to be evaluated (i.e. whether or not
-the plant is in a normal configuration or some other arrangement) at the time an evaluation is requested. In addition, the executive program will contain the tools necessary to maintain and control the contents of the data bases. !
One particular' feature of the data bases will.be the extensive use of. references to identify the source of data , for future' references by engineering personnel. For example, the' electrical load resulting from an individual-load on the distribution system, under specified plant ' operating conditions, may have been determined by a formal calculation. The data base would reference this calculation. It.is.our opinion that this system will~ allow for the analysis.of the adequacy of the electrical distribution system at point Beach by providing the engineer with the tools and a consistent set of data and methods of analysis while providing the flexibility necessary for the engineer to analyze adequacy during abnormal conditions. Functions of Imoell DeveloDed Software System: As described above the analysis system being developed by Impell is intended to-provide engineering personnel with the following capabilities.and the data to utilize them:
- 1. The ability to determine which components or functions are affected by the loss of any one 5
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7 . t i of the four plant DC systems or portion thereof. 1
- 2. The ability to evaluate the steady state ;
electrical loading ~on plant equipment ' (including cables) for various combinations of plant operating conditions. This ability will be developed for both AC and DC plant-auxiliary systems. This capability will also . include the capability to evaluate the. i adequacy of the sizing of station batteries.. i 3.. The ability to determine the steady state i' voltage level at various points on the AC and ' DC electrical distribution systems'under various plant operating conditions.
- 4. The ability to determine the effects of motor starting on the voltage and frequency of the- !
distribution systems.
- 5. The. ability to automatically compare the electrical loading calculated in.(1) above to 't t the electrical rating of distribution system ',
equipment and to readily identify the methods
,and~ data used to determine such ratings.
- 6. The ability to calculate the available short '
circuit current at any point on the AC and'DC electrical distribution systems under various 1 plant. electrical configurations.
- 7. . The ability to evaluate the adequacy of
- equipment protection and proper selective
!. coordination of protective equipment. Initial efforts of this project were concentrated on the-selection of appropriate analysis software and the design of databases necessary to use this software. This.is being followed by collection of the necessary data. In early 1990 L development of the executive program necessary to control -{ l, analysis based upon database information was initiated.
.This development will be based upon a similar project-completed by Impell for another utility.- It is anticipated that a preliminary version of the overall system will be r operational and ready for use by the end of 1990.
Completion of the overall project is expected in 1992. ' Transient Analysis: Development of the ability to analyze the transient effects of load sequencing on the diesel generators is not one of the capabilities being developed by 7 Impell. .It is anticipated that the purchase of such 6 i
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capability and development of the plant-specific data- - necessary.to utilize it will be completed by mid 1991. See response to deficiency 90-201-02. Electrical Distribution Setooint Calculations: Many of the setpoints for electrical distribution system equipment are not based on documented calculations. Instead they are based upon the initial settings provided by Westinghouse for initial _ plant startup as modified through the plant process fer setpoint changes. In addition, some adjustable components which are part of the electrical distribution system do not have setpoints in the plant _setpoint document. To alleviate this concern Wisconsin Electric will institute a program to create formal calculations to document (Le . L adequacy of electrical system setpoints. A review will be completed of those-adjustable components of the electrical distribution system and a determination made of which setpoints should'be added to the setpoint document. It is expected that the capabilities being developed and the data being collected by Impell will be helpful in this process. It is anticipated that both actions will be completed in , 1992. Early emphasis will.be placed on settings for devices which have safety-related functions. ; Desian Basis Documentation: This project will provide the methodology, structure, and system whereby the basic engineering information for the Point Beach Nuclear Plant < can be retrieved from its current repository, evaluated for adequacy and completeness, supplemented:where deficiencies exist or the information is not retrievable,.and developed
-into a set of documents which are necessary and. sufficient i to define the design basis for each system and component.
These design basis documents will better support the operation of the plant, modifications to the plant con-sistent with the design and' license limits, and regulatory examination of those changes previously' performed, currently in progress, or which'will be performed in the future. This information resides within Wisconsin' Electric, Westinghouse, Bechtel, and other engineering contributors to the design and' modification of Point Beach. This effort will proceed - on a seven year schedule, with a pilot program of three , systems tua start in 1990. i The work will be performed by teams of engineers-doing document searches, in-plant system walkdowns, and analyses to reconstitute design basis information. Searches of correspondence between WE, Westinghouse, Bechtel, other vendors, the NRC, and PSCW (covering the years 1966 through 1990) and current technical and operational documents will be performed to_' locate the technical information to define the-design, licensing, and operating basis for each system and major component. Each DBD will be researched, written, 7
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, . . . no; reviewed and. revised, published.for use both'in hardcopy and
.antered'into an:on-line' electronic access system. !
Discrepancies between the design basis and actual. plant configuration identified'duringuthe research, development,
*- .or. review process will be resolved. When necessary, J technical justification for continuing operation will be-provided. consistent with the licensing basis, FSAR, and Technical Specifications.
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.a Response to Weakness (3): !
e The inspection report executive summary at page 11 identified four specific conditions that, given a single failure, could jeopardize redundant equipment required for 37 the. safe _ operation-of-the plant. Each of these conditions
.has been specifically addressed in a deficiency response as presented in Attachment 2. While we have no structured program in place to re-review the overall plant structures, systems, and components strictly for single failure concerns, we have corrected these situations as we-have l identified them. The design basis reconstitution project, i as discussed in the response to weakness (2), may also identify other areas in the plant and'other structures, i systems or components which are be susceptible to single ;
failure concerns. We will evaluate those concerns as they l are revealed. l We have had for many years an operating experience. review program which has proven effective in identification of the ' problems occurring throughout the industry and relating them i to our own plant. In the past this process has been effective in uncovering single failure concerns. We intend p to add resources to this program with our staff additions ! and thereby improve the effectiveness of our evaluations of I these operating experiences. Regarding reviews of plant modifications,.we have in recent. years significantly revised and strengthened our_ procedures ; for conducting 10 CFR 50.59 evaluations.- This has been i evident both in the numbers of 50.59 reviews we have initiated and in the thoroughness of these review, and reflects'a trend seen throughout our industry. We believe !
- the-inspection team found that the. documentation for more ,
recent' modification requests included improved 50.59 " evaluations and better addressed single failure concerns. We have also created, and are in the process of staffing, a i Safety Evaluation Group whose functions will include the , preparation or review of 50.59 evaluations. This should i , further enhance the uniformity of our evaluations and should L improve our~ ability to identify and address single failure Concerns. I s l 9 v
.- Resnonse-to Weakness (4):
The. description of this item in the inspection report included the listing of-four examples of specific. engineering support
- weaknesses. Each'of these four items is discussed in detail'in the response to specific deficiencies contained in Attachment 2.
Four other examples were included. These are: (1) performing some modifications without considering industry-standard practices, (2) adding incorrect information into emergency operating procedures, (3) upgrading safety-related status of systems without a controlling program or procedure, and (4) permitting adverse conditions to exist in the plant for over 10 years. , We agree that a lack of adequate design basis documentation and information,_along with the limited size of our engineering staff, has contributed to the weakness identified in engineering support.
.As discussed under_ weakness (2), we have initiated a multi-year design basis reconstitution effort. As discussed =in our letter to the Director, Office of Enforcement dated May 15, 1990, and during i our meeting with the NRC Staff on February 20, 1990, we have also '
committed to significant staff increases. At this time the number of planned personnel additions is sixty-eight, an increase in our staff size of about 16%. These' staffing additions include additions to~our_ plant organization, the corporate nuclear engineering organizations, and the quality assurance organization. We are in the process of~ identifying candidates to fill these newly created positions and have completed the first of these staff additions. We expect to have 50% of these positions filled by December-31, 1990, and essentially 100% filled by July 1, 1991. The combination of providing a more detailed and complete design basis for the plant and the staff additions now planned and for the future should do much to alleviate the. elements.which contribute to the inspection team's identified weaknesses. Please note that we believe item (4), as noted in the first
. paragraph of this response, requires a specific clarification.
On November 3, 1980, Wisconsin Electric sent a letter to the NRC concerning the instrument bus modifications for Point Beach. In that letter we committed to interlock the output circuit breakers for batteries DOS and DO6 to the existing backup battery charger so that the two batteries could not be paralleled. The fact that we have not completed this commitment does not, we believe, constitute a condition adverse to safety. During this time period, we have exercised reasonable and effective administrative-controls over the use of these breakers. In 1988 a non-conformance was issued because this commitment had not been met. As a result , we initiated a modification request, MR 88-111, which we anticipated would be installed in 1989-during the station battery changeout. A subsequent decision to permanently install a spare battery under MR 90-134, resulted in cancellation of MR 88-111, since as part of MR 90-134 we will install new electrical distribution panels which will have the appropriate electrical interlocks. 10
I . L. , ATTAC3DfENT 2 Responses to Unresolved Deficiencies During the EDSFI twenty-seven deficiencies were identified by the !
' inspection team as requiring additional review or action by . I Wisconsin Electric or the NRC to fully resolve the issue or to verify corrective action. These unresolved deficiencies were listed in Appendix A of the inspection report and were assigned individual deficiency numbers. This attachment includes .i Wisconsin Electric's responses to each of these deficiencies.
The responses which follow are numbered to correspond to the deficiency to which they reply. For clarity the deficiency title is also listed with the response. q
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i o , 90-201-01: Non-Conscrvativo Dios31 G3norator Stoady-Stato Londing ;
- . . Calculation The need for a revised emergency diesel generator (EDG) loading '
analysis was identified previously by our personnel.in 1988 and a consultant was hired'to complete this analysis. The consultant's calculations were transmitted in early 1990 and documented a worst case EDG loading of 2939KW compared to the machines 200 hour rating of 2963KW. This worst case-loading was based upon the loss of off-site power, an accident in one unit, and the shutdown of the other unit from power. We concluded at that time, based on this calculation, that there were no operability concerns with the diesel Acading. During the inspection, the team questioned whether the , pressurizer heaters and a containment ventilation. fan for the unaffected uait should be added to the loading assumed in the calculation. In response to this question, we performed additional evaluations and determined that the pressurizer heaters were not needed but that the fan load should be included. l We also determined that certain auxiliary building fans included in'our consultant's original analysis were not needed. The net. result of these changes is a decrease in EDG loading under this worst case scenario. We intend to revise Impell calculation 0870-103-011 to include these changes as well as the results of detailed emergency operating procedure (EOP) walk-throughs to determine a worst-case load versus time profile based upon automatic' starts and subsequent manual actions. This revision l will be completed by September 1, 1990. We are also planning to complete an additional calculation to determine the steady-state loading which could result from a loss of off-site power, an accident;in one-unit, and_ shutdown conditions requiring residual heat removal in the other unit.' The power requirenants for such a scenario are different.than those assumed in the original calculation and may be more. ~ restrictive. This calculation will be completed by December 1, 1990. We will then reevaluate the existing EOP's to determine if they provide adequate' guidance for the control of diesel generator loading under emergency conditions. This will be done by January 15, 1991. l other actions ve are planning include:
-Revision of the FSAR to more accurately reflect actual l worst case EDG loading. This will be included in'1991 FSAR l . update.
-Issue a Design and Installation Guideline to describe the ,
actions necessary to adequately evaluate changes which may affect diesel generator steady-state loading by April 1, 1991. 2
* - l90-201-02: Lack of Tranciont Analycia of Diocol Gonorator Icading
.In response to this deficiency Wisconsin Electric will take the actions.necessary to obtain analysis software capable of analyzing the transient behavior of~the EDG and related systems.
'It is' anticipated that such software will-be available by January 15,.1991. -In addition we will gather the data necessary and complete initial evaluations of the adequacy of the EDG and associated systems under transient conditions by March 31, 1991.
The following actions will also be taken:.
-We vill determine the accuracy of the 2400 series Agastat timing relays-following a seismic event. These relays are utilized'for. timing of load additions which make up the automatic-load sequencing on the EDG's at Point Beach. This item will be accomplished'by October 1990.
-Me will obtain motor torque vs. motor current and motor torque vs. motor speed curves for the safety injection pumps. A formal calculation will be created which documents the basis for'the overcurrent relay setting for the breakers which supply the safety injection pumps. This basis will.
in-lude the requiremant that these.overcurrent relays not operate to isolate the safety injection pumps when they are started under conditions which include loss of normal supply-and automatic start and loading of the EDG's. This calculation will be complete by October 1990.
-similar calculations will.be completed for-overcurrent trip.
devices on all circuit breakers for major loads which are-part-of the EDG automatic load sequencing. These calculations will be completed by April 1, 1991.
--The acceptance criteria for the time delay of relays which provide for EDG load sequencing presently specified in.
procedure ORT-3 will be revised. This'will be completed by-October 1, 1990.
-The FSAR will be revised in the 1991 update to accurately reflect the actual timing of the EDG loading sequencing.
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.... q f' 20-201-03: Incorrcct-Load-Ratings Listed in EOP'O '
Non-conformance report'(NCR) 90-093 was issued for this item. As part of the NCR evaluation, corrected ~ data for EDG supplied loads was obtained and a calculation, N-90-042, completed to substantiate a revised load list. Revisions were issued to the e below. listed EOP's:and ECA's to include the revised load list. The corrective action for this deficiency has been completed. EOP 0 App. C Rev. 8 'ECA 0.0 App. D Rev. 7-EOP 1- App. A Rev._8 ECA 0.2 App. A Rev. 5' EOP 1.1 App. A Rev. 6 ECA 2.1 App. A Rev. 7 . EOP 3 App. B Rev. 8' 1 ECA 3.1 App. A Rev. 8 1 l f s 1 1 L , r , i k s i 4
- 90-201-04: EDG Loading,00 In2tructcd by EOP'O for o DBA In response to this concern, detailed reviews of appropriate :
E0P's were conducted by engineers, plant operators, and shift . superintendents in April 1990. As a result of these reviews temporary changes to several E0P's were approved and distributed in April. These changes provided further guidance to the - operators for managing EDG loads during an accident. It is expected that permanent procedure changes will be incorporated by
.the end of August 1990.
In addition a NCR (N-90-097) was initiated to evaluate the ! apparent inaccuracy of the EDG KW meters. In response to this , NCR the meter for each EDG was recalibrated in April. Other actions we propose include the following:
-complete an overall evaluation of the accuracy of the EDG KW metering circuits. This will be done by December 31, 1990.
-Incorporate the inaccuracies of the notering circuits into the EDG loading calculations by December 31, 1990.
-Evaluate the need for physical modifications to increase
-the accuracy of the EDG load meters. This will also be done i by February 1, 1991.
-Evaluate the need for more frequent calibration of these meters by February 1, 1991.
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+ , 90-201-058- Non-Conformanco to D3cign Basic Critoria for
,; Electrical Cable Tray Fill and Cable Ampacity Non-conformance Report H-90-092 has been written to evaluate and, where necessary, correct this situation. Evaluation of this non-
.conformance included a search of the Cable and Raceway Data system (CARDS) data base to identify those power and control cable trays which have cable fill greater than 30% and those
, instrument cable trays which have fills greater than 40%. This search resulted in the identification of 210 cable trays l .containing more than 4000 cables. Preliminary evaluation of this condition has concludcd that these situations do not constitute an immediate operability concern.- We have begun a process to formally evaluate the ampacity of cables running through these trays and evaluate the-adequacy of the ampacity to perform the i o required functions of the cables. Due to the large number of cables involved, it is anticipated that these evaluations will i not be completed until'the and of 1991. Priority will be placed on evaluating the adequacy of large power cables which are more l l likely to pose ampacity problems. i Additional actions to be taken in response to this deficiency include:
-Issuance of interim guidance to all engineering personnel-on cable tray fill requirements.- This was completed on June 28, 1990.
-Issue permanent guidance on allowable cable tray fill by March 1, 1991.
-Revise the FSAR to remove conflicts and to document correct; fill requirements. This will be completed as part of the 1991 FSAR update.
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+ ;Do-201-061-Lack;of Asococm0nt of Availablo Short-circuit Currcnt
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.. Due to High Battery Temperature-In. response to thisiitem we have initiated several actions to p evaluate the adequacy of DC Bus protection and breaker coordination. These actions include the following
-A calculation is being created to determine the available short' circuit current at all distribution' busses.which are part of the'125 VDC systems assuming maximum available battery temperature.- This calculation will be completed by :
August 15, 1990. ,
-An evaluation to determine the adequacy of protection and i selective coordination for the two original plant DC systems-( . vill be' completed by August 15, 1990.-
-Resulting modification requests to correct deficiencies in. ,
l DC system protection and coordination will be-initiated by August 31, 1990. These modifications should be completed by
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' -. '90-201-07t'Innd qucto Scionic~Evoluation for Modification to 4160 1
. VAC Safeguards Bus Tie-Breaker )
Upon the identification by the inspection team of'their concerns in this matter, the breakers in question were physically removed from the cubicle and placed in storage outside the safe shutdown area. We have confirmed that the new bus tie breaker configuration would not compromise any actions required by our response to 10 CFR 50 Appendix R since the bus tie breakers are not required by the Appendix R safe shutdown procedure, AOP-10A. I We have also revised operating procedure 0I-35 to reflect an eight hour limit on the use of these breakers during maintenance. The revised instruction also includes additional requirements which significantly restrict the use of these breakers to specific unit operating conditions. Finally, we intend to update l FSAR Section 8.2.3, page 8.2-13 to reflect the current I configuration of the bus tie breakers. This update should be l incorporated into the 1991 FSAR annual revision. Based on the ! above, we consider this deficiency to be closed. e i l l' 8
p , 4. 90-201-08: Singis Failuro of Sofcgucrdo 480 Voc Bu3-Tio Brockor Immediate corrective action for this single failure concern was to remove the control power fuses from the DC control circuits for these breakers. This prevents electrical operation of the l breakers. Operator aids were posted at breakers 1B52-16C and 1 2B52-40C and OI-35, " Electrical Equipment operation" was revised to reflect the removal of the DC control power fuses and to define conditions under which they may be reinstalled. A LER (No. 50-266/90-004-00) was also submitted to the NRC describing this single failure potential and documenting these corrective , actions. These actions were all completed by April 17, 1990. l We have subsequently revised RMP's 23A and 23B to address installation and removal of the control power fuses and have completed a safety evaluation to insure the corrective action was acceptable. A review of Appendix R requirements and commitments indicates that removal of the control power fuses is acceptable. Worst case Appendix R scenarios include removal of control power to these busses to prevent inadvertent operation. Since the i breakers are still installed and capable of being manually closed, Appendix R requirements are net. 1 We are presently. evaluating the need for a modification to provide control room indication of breaker position when the , control power fuses are removed. This evaluation will be
-completed by November 30, 1990, 9
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i .: 90-201-09 Incorr0ct SQfoty Classification and Non-Conformanco l - with separation criteria-of Control cabling of 480 Vac Bus Tie Breaker The corrective actions for deficiency 90-201-08 resulted in the deenergizing of the cables which are the subject of this deficiency. The corrective actions in that deficiency also significantly restrict the situations under which these cables would have any function at all. The classification of these cables is, therefore, only a concern under the conditions for which they would be allowed to be energized. Corrective actions for this item will include completion of a number of the corrective actions for deficiency 90-201-08, a determination-of the appropriate classification for these cables under the conditions for which they are allowed to be utilized, an assessment of any potential separation problems should the previous step result in safety-related classification, and correction of any separation problems should they be identified. These steps'will be completed by December 1, 1990. If modifications are necessary, we may not be able to complete them until the next unit outage. The more general concern of the adequacy of electrical separation-of cables and the adequacy of CARDS system data is addressed in the response to deficiency 90-201-22. 10
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90-201-10 'Non-Conformance with FSAR Separation Criteria-and Potential for Common-mode Failure of both CCW Pumps The. component cooling water (CCW) systems at Point Beach were not originally designed as a nuclear safety-related system.. In 1988 we initiated a long term program to upgrade the CCW system to nuclear safety-related. While the EDSFI inspection team recognized that our upgrade was not yet complete, they identified this instance of' inadequate cable separation and potential i common-mode failure. We promptly completed temporary modifications, TM90-23 and TM90-24 for Units l'and 2 respectively, to disable the auto-start circuit for the "B" CCW ! pumps and have designated those pumps as the preferred pumps for 1 continuous operation.. We have also initiated a modification i request to correct the separation problem in the R82 riser._ We , expect to complete these modifications by December 1, 1990, for l' Unit 2 and by_ June _1, 1991, for Unit 1. l f j i
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y . l 90-201-11: Use of Non-Qualified components in Safeguards Bus 1 Breaker Control Circuits 1 An NCR han been written to document this situation. Corrective i actions will include completion'of an evaluation to determine the appropriate classification of the miscellaneous relay racks (MRR). This evaluation will include a definition of those actions necessary to upgrade the racks, and included components, to QA scope, to safety-related, and/or seismic class I if
. required by the evaluation of classification. The evaluation should-be complete by the end of September 1990. l It is anticipated that the actions identified in the evaluation to upgrade the racks, and components if appropriate, can be scheduled for completion in June 1991. This will obviously be
' dependent on the results of the evaluation. Identified actions
, are expected to include an assessment of the-seismic adequacy of the racks and. required internal components.
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l 1 201-12: Vulnerability of Switchgear control Power to Seismic l Event that Opens Manual Transfer Switches DC control power to each vital 4160 V ind'480 V bus 11ncludes a j
; knife switch that allows selection of normal or alternate power supplies. A' calculation has been completed'which shows that the peak-seismic force acting on the switch center of gravity during I
a SSE would be about 1.671b-f, On April 20, 1990, we completed field measurements on the pull-out force required to open all Unit 1 knife switches. The minimum as found force-was 1.751b-f'
=and the minimum as left force was 2.751b-f. We have concluded that these switches will remain closed during a seismic event, that this issue should not be considered a common-mode failure >
concern, and that it does not constitute an operability question. In addition,fwe have contacted the seismic.Qv111fication Utility Group'(SQUG)'and requested any available data to demonstrate i adequacy of similar switches at other' facilities. We intend to measure the pull-out force of the Unit 2 switches during the fall 1990 refueling outage. This should be completed in November 1990. Finally,.we will also evaluate the need for modification or replacement of these switches to better secure them under , seismic conditions by March 1, 1991. I J k i 13
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,.? . 90-201-13: Non-Conforming Diesel Generator Sequence Logic The:FSAR states that the EDG output breakers will-close when the machine is up to speed and adequate generator output voltage is I present. The actual as-built circuitry includes a contact that I closes when the EDG is up to speed and a contact that opens if. field voltage does not exist within six seconds of the diesel i attaining a speed of 125 RPM. Both adequate speed and presence of field voltage are required prior to closing the EDG output breakers. A direct interlock which prevents closing of the output breaker based on output voltage does not, however, exist. In order to demonstrate.the-adequacy of the EDG output voltage prior.to c. Losing ~the breakers, a'special test was performed on ! both EDG's to measure generator voltage as a function of time and compare it to other events in the starting sequence. These tests were completed on Unit 1 on April 13 and on Unit 2 on May 2,
, 1990. Both tests demonstrated that a voltage of greater than -
100% of nominal output voltage was present at the. time the output breakers would have received a closing signal. We have1thus , concluded.that this issue does not constitute an immediate- ' operability concern. We are presently evaluating the need for
- . periodic testing to confirm the.se measurements. We are also evaluati g whether to' initiate modifications to the EDG output breaker control circuits to reflect-the FSAR description or to ,
correct the FSAR to reflect the as-built configuration. This 4 evaluation.will be completed by December 31, 1990. Please note that the transient analysis capability being obtained as described =in the response to deficiency 90-201-02 will result in the capability to analyze the starting and loading.of the EDG under. design-basis conditions. l. 8 14 w----- _ ___ _ _ _ _ _ _ - - _ _ . _ _ _ _ - _ _ _ - - _ _ _ _ _ _ _ _ - _ _ _ _ - - . _ - _ _ _ . - _ _ _ _ _ _
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.- 90-201-14: Excessive-DC Voltage Applied to Equipment Terminals 1
The inspection team expressed a concern that the battery float l voltage exceeds the manufacturer's recommendation of acceptable L voltage levels for equipment supplied from the associated DC-systems. The float voltage level of the DC systems at Point Beach has been a concern for several years. The appropriate float voltage is a tradeoff between the capability of utilization devices to operate at higher voltages and the degradation of the batteries resulting from lover float voltages. In general battery manufacturers have indicated that lead acid type batteries should be' floated at a minimum 2.25 volts per cell or they should periodically receive an equalizing-charge at higher l per cell voltages. The present physical arrangement of the DC l systems at Point Beach does not allow for the equalization l charging of batteries without removal from service. Although the l technical specifications allow for removal of batteries from l service for limited periods of time, this has'never been considered a desirable operating condition. We are therefore revising our procedures, RMP-46 and OI-33, to lower the maximum L l battery float voltage for DOS and DO6 to 132.75 volts (2.25 volts per cell for 59 cells). This will be completed by September 1990. We will also be-installing an additional safety-related battery. The addition of this battery will allow for periodic equalizing charges on the existing station batteries. In addition we will l 'be installing a non-safety-related station battery. This will
- allow for the removal of several-large non-safety-related loads L from the existing station batteries. Such load-reductions may I allow removal of an additional cell from each of the existing- I
- i. -batteries further reducing DC uystem voltage. It is anticipated ;
that both of these batteries will be installed-by mid-1992. 1
-Lastly, we are performing a' detailed analysis to determine the maximum allowable DC system = voltage based upon the capabilities '
l of connected components. This analysis will'be completed by July L -1991. 15 L l
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.,. 90-201-15: ' Inadequate Fuel Oil System Seismic Cat. 1 Classification-In the process of evaluating the seisuic capability of the EDG fuel oil-system piping during the inspection, we determined that piping supports in the fuel oil pump house would not meet operability or code allowable stress limits in the-event of an-SSE. After completing the analysis of fuel oil piping in the pump house, we designed and installed a multi-pipe support in the fuel oil pump house which alleviated the operability concern with the piping.- This was completed on April 15, 1990. We also analyzed the fuel oil piping in the control building and-determined the stresses to be within operability criteria. Thus, no operability concerns existed in this area. . We have initiated modifications to support the fuel oil piping in the control building to limit stresses to below code allowables. These modifications should be completed in October 1990. In the longer' term we are analyzing the seismic adequacy of all the fuel oil y makeup and gas turbine supply piping in the fuel oil pump house.
Modification requests for supports will be initiated as required. These activities =should be. completed by the end of 1990. In addition to the piping analyses, we are also conducting ' evaluations of the seismic' adequacy of the fuel oil pump house concrete structure, the spiral. stairs in the pump house, the power supplies for the fuel oil transfer pumps in the fuel oil pump house, the facade, and the turbine hall, and the fire protection header piping in the pump house. From our preliminary seismic evaluations we determined that the concrete structure of the fuel oil pump house is adequate to resist seismic loads. The formal analysis of the structure was completed in July and substantiated this: determination. The block walls in the pump house were initially judged to'be seismic by comparison to other seismic block walls. . A formal analysis of the block walls is scheduled for completion by December 31, 1990. The calculations which show'the seismic adequacy of the stairs in the fuel oil L pump house will.be completed by December 1, 1990. The fuel oil transfer pump power supply conduits were found to be supported l similar to other seismic. installations. The formal evaluation of the seismic adequacy of the power supply conduit will be l completed by June 1, 1991. Cables will be rerouted if that is found to.be necessary.- We shall also formally evaluate the L facade structure in the vicinity of the fuel oil transfer pump- j~ power supply cable trays and reroute cables if necessary. This evaluation will be-done by September 1, 1991.. An analysis and seismic support of the fire protection header in the fuel oil
. pump house will also be completed by December 30, 1990.
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.- 90-201'-16: Fuel Oil Cloud Point substantially Higher than aequired We are in the process of' obtaining a new fuel oil specification from EMD, the manufacturer of the Point Beach EDG's. This specification will be evaluated to verify compatibility with the other fuel' oil users including the gas turbine. The new fuel oil specification should be available and accepted by September _15, 1990. Any changes to the fuel oil inventory resulting from the new specification will be completed by October 30, 1990. We shall also evaluate the need for any modification to the fuel oil supply system as a result of any fuel oil change. This evaluation should also be completed by October 30, 1990.
Revisions to technical manuals and procedures that recognize the new fuel oil acceptance criteria will be completed by the end of March 1991. 17
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- t 90-201-17: No Procedure to control Upgrade of Fuel. Oil System to-Safety-Related Status ,
There currently exists a procedure for the upgrading of systems to QA scope (QP 2-1, ' Upgrading of Non-QA Scope Systems to QA Scope Status"). The guidance provided in that procedure, as well as guidance provided by NUREG 0800, has been used in upgrading. systems to a safety-related classification. In order to Lore specifically address the process of upgrading systems nr components.to safety-related, revisions to QP 2-1 or a new-procedure, as appropriate, will be drafted for departmental !' review by November 30, 1990. Approval and. issuance of the procedure should be completed by March 1, 1991. The current status of the upgrading of the fuel oil system is discussed under deficiency 90-201-18. i l I v ) 18
-. 90-201-18: Undocumented Upgrade of Fuel oil System to QA Status It was the conclusion of the EDSFI inspection team that Wisconsin Electric did not have the documentation to support the upgrading
[ of the fuel system to QA status. An engineering action request has existed to upgrada the fuel oil system to safety-related L status (PBAR 89-013). The work scope of that project included evaluation of system design parameters, identification of operating requirements, and recommendations to the plant staff on . the safety basis for the fuel oil system operation. The action request has been completed and was presented to the plant staff on July 25, 1990. The evaluation recommended that a material p: history review, system testing, and a supply system support review be completed to fulfill the requirements of QP 2-1. These reviews and testing will complete the Wisconsin Electric requirements for upgrading a system to QA-scope. The resolution of the additional steps necessary to reclassify the system to safety-related status are dependant on the action discussed under deficiency 90-201-17. L( c k. = M 9 19
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. 90-201-19: Procedure 4.12.22, Revision 13, Deficient for ,
Delivering Puel oil Under Emergency conditions After this deficiency was identified by the inspection team, a special Order, PBNP 90-01 was issued on April 10, 1990 which , provided instructions for supplying fuel oil to the emergency diesels and the diesel fire pump engine day tanks if the normal supply is unavailable subsequently, PENP 4.12.22, Revision 14, - was issued on July 14, 1990, to provide proceduralized provisions - for fuel oil delivery under foreseeable esercancy circumstances. ! We consider our corrective actions fur this deficiency to be complete. t i 9 1 20
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- 90-201-20: Feasibility of Appendix R Scenario Inadequately Investigated by the Licensee l
We believe the inspection team's alleged deficiency is, at least in part, due to a misunderstanding of the Appendix R fire scenario which would require the use of gravity feed to provide fuel oil to a EDG. The Appendix R shutdown loads can be supplied by only one EDG. Thus, the calculations do not address supplying fuel oil to both diesels. In addition, the diesel driven fire purp has more than sufficient fuel storage to provide water for extinguishing the fuel oil pumphouse fire and, under the Appendix R scenario, there is no need to provide additional fuel to the ' fire pump. t We also believe the team misunderstood the basis for the calculation performed to demonstrate gravity drain capability. The calculation initially assumed conservatively high values for pipe and valve resistance (equivalent length of pzpe). Subsequent tests. demonstrated gravity flow capability substantially greater than these conservative calculations. The ' actual system resistance was obtained from the test data and was used in a subsequent portion of the calculation. This method * (calculating system resistance from actual test data) is commonly accepted in determining system resistance. Finally, the calculations do not demonstrate that gravity drain can not be accomplished below 0 degrees F. Rather, the calculations were performed assuming a fuel oil temperature of 0 degrees F as a conservatively low temperature in view of the below ground fuel oil tank and piping which is partially enclosed in a heated concrete structure. The team expressed additional concerns regarding the lack of procedures for use of a portable pump, for providing access to valves in the fuel oil pump house, and the leaktightness of the fuel oil tank. Monthly verificetions of tha availability and l location of the portable pump are performed under periodic callups (PC-75, Part 5) by operations personnel who are also I. members of the fire brigade. We therefore believe there is adequate assurance that the portable pump would be available and used in the event of a postulated Appendix R fire in the pump house. The gravity drain through the emergency fuel oil tank does not require establishing a siphon. The tank is vented to the atmosphere through vents which extend above the level.in the above ground storage tanks. In addition, while the emergency fuel oil tank does have bolted and gasketed closures which are not periodically tested, any minor leakage in these closures would not significantly affect the gravity drain capability. It l uhould be noted that the gravity flow tast verified the leaktightness of these closures. While we are confident that more than adequate capability for gravity flow exists under severe environmental conditions, we l l 21 l
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. will perform further calculations and tests to provide additional ,
assurance. Following completion of the investigations discussed under deficiencies 90-201-16 and 90-201-19, a revised calculation ' will be performed to determine the fuel oil gravity drain ; capability. This calculation will recognize any revised-fuel oil specifications and chunges or modifications to the system. Previous calculations will be formally superseded. We will also perform WMTP 9.23 to verify that the outside storage tanks can i gravity drain into the EDG tanks under both cold and hot weather conditions. These actions will be completed by July 31, 1991. . t i h i 22
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90-201-21: Non-conservative Calculation for EDG Room Temperature The diesel nanufacturer's calculated heat rate was not based on room temperature or air balance inputs. It was determined om a very conservative energy balance and was very sensitive to 12e1 consumption (e.g. a 10% difference in fuel consumption results in a 18% change in radiation rate). We therefore believe that the heat rate determined by actual testing, although less conservative, is more realistic and appropriate to verify operability of the diesels. We will, however, re-evaluate the calculations of the Emergency Diesel Generator room temperatures under various conditions to verify our conclusions and recommend , andifications if necessary. This review and evaluation has been scheduled for completion in Pay 1991. 1 l 23
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90-201-22: Inadequate Physical Independence of Redundant Class IE Cables During the inspection, the EDSFI team identified several examples of inadequate cable separation and questioned whether other cases existed. By using the Point Beach Cable and Raceway Data System (CARDS), twenty-five cases of inadequate cable separation involving redundant train cables in the same raceway were identified. By April 17, 1990, we had completed an operability evaluation for all of these cases. Immediate corrective actions included modifications to the Unit 2 steam driven auxiliary feedwater pump starting circuit and the CCW pump starting circuits (See 90-201-23 and 90-201-10). Procedure changes for operation of the power operated relief valves were also completed. In no other cases were plant operability problems identified. We have completed the process of evaluating each of these cases to determine how to correct the situations. Corrections include physical separation by modification, correction of errors in the CARDS database, and further evaluation. We anticipate completing the required corrective actions by the end of 1990 for Unit 2, subject to the availability of required equipner t, and for Unit 1 by the and of the spring 1991 refueling outage. In further response to this deficies.ey and the weakness in design documentation identified by the inspection team, the following changes to the CARDS system are anticipated: A. Procram Changes-Prior to the EDSFI, Wisconsin Electric was in the process of upgrading the CARDS system to Revision 3 from Revision 1. This upgrade was being supplied by EPH Corporation. The new revision contains greater functionality than the original version. In addition we are having several additional functions ! or upgrades of the data implemented at the same time. These are i described as follows: l l
- 1. The CARDS data base contains all the data necessary to calculate the allowable ampacity of electrical cables. A L
function will be added to the CARDS system which will r calculate the allowable ampacity of each cable based upon an algorithm provided by WE. The value determined will be , retained in the data base as an attribute of the cable. The data verification capabilities described in item 3 below can be utilized to track whether the cable rating has beer. automatically calculated or is based on another referenced source.
- 2. As part of the upgrade, the program function which prevents the design or installation of cables which violats electrical separation criteria will be implemented. Such implementation requires that WE define the rules upon which allowable separation is determined.
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- 3. Revision 3 of the CARDS software includes the capability to record the source of information for each attribute of each cable or raceway in the database. This function will enhance the capabilities to record any future verification efforts. -
B. Verification of Existina Routino Information- paragraph 5.1.1 of the inspection report and the evaluation resulting from identification of the condition documented by deficiency 90-201-22 indicate thet there are errors in the routing of electrical cables as included in the CARDS database. A program will be , initiated to verify the accuracy of the reuting data. Emphasis will be placed on routing of safety-related cables and conformance to separation criteria. C. Uoarade of CARDS Data- The data presently in the CARDS data ' base consists of that provided by Bechtel in the early 1980's as representing original plant design. This information has been updated as required to include any changes / additions resulting from modifications since about 1984. The existing data base therefore does not reflect modifications made prior to 1984. It also does not include information for certain areas of the plant or plant systems. Examples of these areas include the pump House and the Gas Turbine Building. A project is being initiated which will identify'those electrical cables which do not exist in the , data base. It is anticipated that this effort will include a comparison of plant connection drawings to CARDS data and a review of older plant modifications. 25 l l l
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- 90-201-23: potential for Common-mode Failure of Turbine Driven Auxiliary Feedwater pump Automatic Start As mentioned under item 90-201-22, it was identified that the auto-start circuit fcr the motor-operated steam supply valves to the Unit 2 turbine driven AFW pump did not meet separation criteria as defined in the FSAR. On April 3, 1990, that pump was declared out of service and a 72 hour Technical specification Lco was entered.
A~ modification request was created, reviewed, and approved for rerouting of the necessary cables. These cables were subsequently rerouted. A post modification test of the pump start circuit and general operation was completed on April 5, 1990, and the ATW pump declared back in service. A licensee event report (LER 90-001-00) was written describing this modification and an inadvertent start of the motor-driven AFW pump during testing of the under-voltage start circuit for the turbine-driven AFW pump. The Unit 1 pump start circuits were checked and no similar separation problems identified. We consider our corrective actions for this deficiency to be complete. 4 26 l l
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'? l 90-201-24: Venting Steam on Safety-Related Cables l As discussed in this deficiency, a situation was observed in l 1 which several trays of electrical cables were subjected to a low ! energy steam environment in the vicinity of a condensate receiver tank vent. Initial investigation determined that some of the cables in these trays were classified as safety-related. A visual inspection of these trays was completed on April 4,1990. This inspection resulted in the identification of two non-safety-related cables which had apparent damage to the cable jacket and possibly to the insulation. Based on this inspection, all safety-related cables were determined to be undamaged and fully functional. The two non-safety-related cables were repaired under a maintenance work request on April 5, 1990. Our evaluation of this situation concluded no immediate operability concerns existed and establish'the absence of a harsh environment as defined by 10 CFR 50.49. In addition to the above, a temporary modification to shield the affected cable trays will be completed by September 1990. Future corrective actions include the completion of a plant nodification to the steam vent system to minimize releases of steam near the cables in question. This modification should be completed by December 1, 1990. All of the non-safety-related cables in the affected cable trays will be meggar tested to assess their electrical integrity. This will be done by December 30, 1990. Since we have not been able to identify any method which will allow for adequate evaluation of the condition of the insulation on the safety-related cables in these trays, it is our intention to replace those cables. The work plans and safety evaluations for these replacements will be completed by December 1990. It ; is expected that these cable replacements can be completed by June 1991. I 27
_ _ . _ _ ~ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . . _ _ _ _ _ _ __ .__ _ _ t ', 90-201-25: Inadequate Program for Calibration of Protective Relays Upon identification of this item, we made a decision to stop work on all safety-related relay calibrations. A non-conformance report was also initiated. Our review of the existing conditions verified that certain controls were adequately implemented and that additional actions were required to allow continuation of the work. We have reviewed and established setting tolerances for all safety-relatad relays not included in the Technical Specifications. We have also reviewed and established the adequacy of test equipment calibration, reviewed previous calibration records to determine.their acceptability, and determined that the one instance of relay part replacement by non-qualified personnel was acceptable since the relay itself was subsequently replaced. By the indicated dates we will:
-Create RMP's to cover all safety-related relays not covered by the Technical Specifications by October 1, 1990.
-Incorporate relay tolerances settings into the procedures and document in an appropriato calculation by October 1, 1990. <
-Formalize the calibration program for test equipment by February 1, 1991.
-Provide quality assurance indoctrination for the personnel I
involved in the protective relay calibration program by October 1, 1990. I t 28 I
,#' o 90-201-26: Inadequate surveillance Procedure for Elgar Inverters i The inspection team nenbers were concerned that the DC input voltage level at which the Elgar inverters would automatically isolate was not clearly defined. Although we have determined !
from conversations with the inverter vendor that the Point Beach ! application of these units has no need for low voltage protection,i i have verified the existence of this feature. We have suosequently completed the adjustment of the low voltage cutout function to 100 Vdc on all of the units. By the end of . 1990 we will provide a nethod for periedic surveillance of this setting. In addition, we will also evaluate other features of the station battery charges and inverters and determine the need for periodic surveillance of thosa features and associated settings. This evaluation will be completed by February 1, 1991. I l 1 l 1 i i l = 29 l
t b 90-201-27: No Acceptance Criteria in Routine Maintenance Procedure 46 for Locating Grounds This deficiency expressed concern with our failure to provide procedural guidance on the evaluation and trending of battery bus ground resistance readings. We presently do monitor and record , ground resistance readings on each of the DC systems. In order to properly address this deficiency, we have placed a purchase order for more sensitive testing equipment. We will establish ground resistance acceptance criteria and a formal tracking and trending program in a revision of RMP 46 within 60 days of receipt and acceptance of the new testing eyeipment. Receipt of ; this equipment is expected in August 1990. Ir addition to the tracking and trending program for De grounds, we will also establish tracking and trending programs for cell specific gravity and cell voltage by December 1990. 4 9 l 30
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