ML20072J340

Responds to NRC Re Violations Noted in Insp Rept 50-305/94-09 on 940516-0704.Corrective Actions:Memo,Stating That Turbine Driven AFW Pump Should Be Declared Inoperable Whenever AFW-10A or 10B Closed or Inoperable,Issued

ML20072J340
Person / Time
Site:	Kewaunee
Issue date:	08/22/1994
From:	Schrock C WISCONSIN PUBLIC SERVICE CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9408290016
Download: ML20072J340 (5)

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• Green Bao Wi 54307 9002 August 22, 1994 Reply to a NOV (10 CFR 2.201)

U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Ladies / Gentlemen:

Docket 50-305 Operating License DPR-43 Kewaunee Nuclear Power Plant Response to inspection Report

Reference:

1) Letter from M. J. Farber (NRC) to C. A. Schrock (WPSC) Dated July 21, 1994 (Inspection Report 94-009)

In reference 1, the Nuclear Regulatory Commission (NRC) provided Wisconsin Public Service Corporation (WPSC) with the results of a routine inspection conducted from May 16 through July 4,1994. The attachment to this letter provides our detailed response to the violation identified during the inspection.

If you have any questions concerning this issue, please contact me or a member of my staff.

Sincerely, Olt' ,YWz -

C. A. Schrock Manager - Nuclear Engineering TJW/cas Attach.

cc - US NRC, Region III US NRC Senior Resident Inspector

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Attachment to the Letter From:

C. A. Schrock (WPSC)

To:

U.S. Document Control Desk (NRC)

Dated:

August 22,1994 Re:

Inspection Report 94-009 l

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Document Control Desk August 22,1994 Attachment 1, Page 1 NRC Notice of Violation During an NRC inspection conducted from May 16,1994 through July 4,1994, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:

10 CFR Part 50, Appendix B, Criterion V requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Kewaunee Nuclear Administrative Directive (NAD) 3.5, " Shift Supervisor's Logs,"

Revision B dated December 28,1993, at step 5.9.13 required that all " entering / leaving a Technical Specification action statement" shall be entered in the shift supervisor's log.

Contrary to the above, on April 1,1994, the shift supervisor failed to document (in his log) the " entering into" and " leaving from" a Technical Specification action statement when the Turbine Driven Auxiliary Feedwater pump was removed from service during the performance of a surveillance test.

This is a Severity Level IV violation (Supplement I). (305/94009-01)

WPSC's Response Wisconsin Public Service Corporation does not contest this violation.

Description of the Events At 1920 hours0.0222 days <br />0.533 hours <br />0.00317 weeks <br />7.3056e-4 months <br /> on April 1,1994, the Shift Supervisor gave approval to start the full flow test of the auxiliary feedwater (AFW) pumps and logged the surveillance procedure in the Shift Supervisor's Log. At various times during the performance of the procedure the operators are I directed to close or throttle motor operated valves AFW-10A and AFW-10B. These valves are the AFW pump cross connect valves and located on the discharge header of the turbine driven AFW pump, which supplies AFW flow to both steam generators (SG). Closing the valves isolates flow from the turbine driven AFW pump to the respective SG. Other steps of the procedure direct the operators to close valves MS-100A and MS-100B, the steam supply valves to the turbine driven AFW pump.

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Document Control Desk August 22,1994 Attachment 1, Page 2 During the test on April 1,1994, the NRC Inspector explicitly asked the Shift Supervisor and the Operations Supervisor if the turbine driven AFW pump was inoperable when valves AFW-10A or AFW-10B were closed or throttled. Both supervisors responded that they believed the pump was operable since an operator was stationed at the valves and the valves could be easily and quickly repositioned if required. Although the supervisors were correct that adequate time existed to reposition the valves manually and still fulfill the design basis of the pump, under Kewaunce's Technical Specifications the pump should have been considered inoperable. The NRC inspector did not ask the Shift Supervisor or the Operations Supervisor if closing valves MS-100A or MS-100B, steam supply valves to the turbine driven AFW pump, rendered the pump inoperable.

Approximately 2 to 3 months later the NRC Inspector raised similar pump operability questions in regards to the positions of MS-100A and MS-100B. Both supervisors were interviewed by WPSC and stated that closing the steam supply valves would render the pump inoperable as described in the procedure. The practice of logging surveillance procedures and not the exact entry and exit times from a Limiting Condition for Operation (LCO) is standard practice at Kewaunce. Since the surveillance procedure that controlled the testing had been logged, the Shift Supervisor did not log the LCO for the pump each time the valves were manipulated.

Cause of the Event The issues surrounding the operability of the turbine driven AFW pump as it relates to the status of the cross connect valves has been a point of debate between the NRC and WPSC for a number of years. The continued discussion on this issue resulted in Kewaunee plant management and Plant Licensing failing to provide a clear interpretation of the associated AFW Technical Specification. The lack of clear guidance resulted in confusion among the staff.

The intent of the Shift Supervisor's log is to provide operating personnel with a continuous record of plant status and provide a mechanism to retrieve information for future evaluations, i Logging a surveillance procedure which describes the entry and exit requirements for a LCO meets this intent. Therefore, Kewaunee plant management's interpretation of NAD 3.5 has allowed the practice of logging the surveillance procedures that control equipment operability l and not the exact entry and exit times for a LCO.

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Document Control Desk August 22, 1994 Attachment 1, Page 3 Corrective Actioils_

l. A memo stating that the turbine driven AFW pump should be declared inoperable whenever AFW-10A or AFW-10B are closed or inoperable was issued and placed in the required reading material for all operators.

2. Proposed amendment 108 to Kewaunee's Technical Specifications has been submitted to the NRC. The proposed amendment clarifies the operability requirements for the AFW pumps and the valves in the AFW system.

3. This event will be discussed during the next round of operator requalification training.

Requalification training on this issue will be completed in November 1994.

4. The operations group will review N AD 3.5 to determine if procedural or policy changes are required to improve the Shift Supervisor's log. Required procedural or policy changes will be rnade by January 1995.