ML20082T988
| ML20082T988 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 09/13/1991 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-91-107 VPNPD-91-308, NUDOCS 9109190222 | |
| Download: ML20082T988 (5) | |
Text
v Wisconsin Electnc
_ POWER COMPANY 221 w M.cnoan. PO rn120e wwoges w 53201 (41M212MS VPNPD-91-308 NRC-91-107 September 13, 1991
-U.S.
NUCLEAR REGULATORY COMMISSION Document Control Desk Mail Station P1-137 Wachington,-D.C.
20555 Gentlemen:
DOCKETS 50-266 AND 50-30_1 BEPLY TO A NOTICE OF VIOIATJpH INSPECTION REPORTS 50-266/91017;_50-301/91017 POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 By letter dated August 16, 1991, the subject Inspection Report and Notice of Violation were transmitted to Wisconsin Electric Power Company and received on August 19, 1991.
Attached to this letter is our rc. ply to that Notice of Violation.
We have concluded that the violation, as stated, is factually correct and constituted a failure on our part to comply _with an NRC regulatory requirement.
A discussion of our corrective actions is provided in the attachment.
Please contact us if you have any questions regarding our response-in this mStter.
Very trul,y yours,
- f
~
s.
hN'S c C. W.
Fay 4
Vice' President
-Nuclear Power Copies.to NRC Regional Administrator, negjon III NRC.Recident Inspector-1 9109190222 910713 h{l PDR ADOCK 05000266 Q
.4 subsMig of lilwunski Dr.g (bewitsw
4 REPLY TO NOTICE OF VIOLATION POINT BEACH NUCLEAR PLANT i
l Enclosed with a letter dated August 16, 1991, Wisconsin Electric Power Company received a Notice of Violation which reads as follows:
"10 CFR 50.48 (d) (4) requires that fi e protection features l
involving dedicated shutdown capability be implemented within 30 months of NRC approval, which was granted in the Safety Evaluation Report dated July 27, 1988.
" Contrary to the above, on January 27, 1991, which was 30 months from the date of NRC approval in the Safety Evaluation Report dated July 27, 1988, the licensee had not implemented fire protection features involving dedicated shutdown capability.
This condition existed until May 31, 1991.
"This is a Severity Level IV Violation (Supplement I)."
Wisconsin Electric Power Company, Licensee for the Point Beach Nuclear Plant, acknowledges being in non-compliance with this regulation over the period specified and accepts this citation as a properly characterized violation.
As discussed in Inspection Reports 50-266/91017; 50-301/91017, we were aware of our inability to complete the dedicated shutdown modification in timo to satisfy the 30-month time limit and submitted a request for a schedular exemption pursuant to 10 CFR 50.12 on December 21, 1990.
Following a meeting at the Point Beach Nuclear Plant with members of the NRC Staff on January 31, 1991, we were advised that the NRC would probably deny the exemption request on the basis that the licensee's actions were pursued in a manner which did not reflect a " good faith effort."
The staff recognized that-the failure to-meet _this schedular commitment, when considered with the compensatory measures we had implemented as discussed in our exemption request, did not pose an undue risk to the public health and safety.
The NRC subsequently formally denied the-schedular exemption request in a letter dated March 14, 1991.
We have determined the following items to be the major contributing factors in our inability to meet the January 27, 1991, commitment date for the completion of the dedicated shutdown capability modifications:
1.
Underestimating of the nanpower and the time required to design, specify, and procure the major components of the modification.
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V'm,
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2.
Underestimating of-the manpower-needed to install and to'supervisc the installation of the design, 3.
. Assigning resources to the project based on the m
1 underestimates of manpower and time.
)
The Wisconsin Electric-engineering staff'had originally estimated 1,820 engineering hours would be required to complete the design of:these-modifications. -In actuality, approximately_16,000 d'
f-engineering hours were required to complete the design.
i Approximately_ seventy-five percent of this increase can be directly attributed.to the structural engineering design of seismic elec;rical raceways.
i e
'The-installation of the modification was initially estimated at i-11,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />, with construction supervision estimated at approximately 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br />.
In actuality, the installation required i
70,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> and the associated supervision-necessitated
{
9,0001 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to complete the installation of the modifications.
These large man-hour increases were unexpected based upon our
?
previous experience-in performing post-TMI'and other electrical modifications at-our: facility.
i Some factors which contributed to this gross deviation from our previous installation experience were attributed to theffollowing elements:.
i.
a.
Increased Raceway Sizes - The modification required the installation-of primarily power raceways / cabling (e.g.;
6" x 24". cable trays, conduits larger than 2",
and L-power cables larger than 250 MCM), whereas the TMI c
modifications _ typically involved-installation of control 1and instrumentation raceways / cabling.
i
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'b.
Unanticipated: difficulties:in training craft labor in i
the use of;now~ raceway installation procedures.
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c.
Interferences and other logistical difficulties j;
encountered due to a large number of craft personnel-in j
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restricted work spaces in an. operating plant.
1 The1 resultant increase in engineering and installation man-hours directly impaired our ability, utilizing our engineering staff l
Land;the: increased staff of contractors, to complete the. project inithc1 required time frame.
As discussed in the attachment: to our December 21',
1990,' schedular exemption request, we initiated 1
a rundaer of additional measures. to attempt to cope with our gross i
Eunderestimation of the installation and engineering man-hours
- involved.
These' measures included contracting for additional structural engineering assistance, extra construction supervision personnel, and additional craft personnel _for a'second shift and a six-day week overtime schedule.
While these efforts did not 2
1
allow us to meet the 30 month schedule, they represent a significant commitment and were necessary for Wisconsin Electric to meet the revised completion date of June 1, 1991, set in our schedular exemption request.
In order to avoid further schedular problems of this nature, a number of actions have been initiated to enhance our ability to more effectively manage engineering projects of this magnitude.
A number of these initiatives have been discussed with the NRC previously, but had not been completely implemented in time to preclude this violation.
These efforts included an initial substantial staffing increase which was initiated in mid-1990 and completed on schedule in July of this year.
The majority of these increae.s were realized in the engineering and plant support are :.
Within the past year, we also revised our procedures for the tracking and prioritization of commitments, the process for bringing additional management attention to near-term and overdue commitments, and for the correction of deficiencies.
Subsequent to our failure to meet this regulatory commitment, we have completed a major restructuring of our engineering support organization in Wisconsin Electric's Nuclear Power Department.
This reorganization included the establishment of three support sections within the corporate office including the creation of a single nuclear engineering section solely responsible for the management, design, and coordination of all modifications at our facility.
This includes both on-site and corporate engineering resources.
The organization within this section has included the assignment of project teams and design teams involving multiple engineering disciplines to develop and support the implementation of major plant modifications.
Another of the new sections created as a result of the recent corporate restructuring hea been specifically tasked with helping the Nuclear Power Department to improve its performance in meeting commitments.
Project / resource management, budgeting, and commitment tracking systems will be employed in conjunction with industry and in-house experience to assist Department personnel in establishing more accurate construction estimates and schedules.
Critical to achieving these results will be improved project prioritization and planning and a greater awareness of resource requirements and availability.
Additional significant staffing increases in the Nuclear Power Department are also anticipated through 1993.
The majority of these staff increases are presently expected in the engineering and plant support areas.
Elements of these staff. increases and other corrective actions were discussed with members of the NRC Staff during our meeting in Rockville on July 9, 1991.
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'The NRC Staff has also suggested that our corrective actions include the evaluation of the adequacy of internal or external audits to_ assess our corrective action program effectiveness.
We believe our audit process has been largely offective in identification of corrective action program weaknesses.
In the past, however, the Nuclear Power Department has not been particularly offective in addressing the results of these audits and promptly initiating improvements to program deficiencies.
We believe the corrective actions we have discussed above, including increased staffing and restructuring of our engineering responsibilities, will be effective in assuring that recurring violations of this nature are avoided.
As reported in our letter to the NRC dated June 4, 1991, we completed the modifications necessary to meet the requirements of 10 CFR 50, Appendix R, Section III.L, on May 31, 1991.
As of that date, all the equipment necessary for dedicated remote shutdown was installed and considered operable.
Procedures and operator training necessary to familiarize the operators with use of this modification had also been completed.
We, therefore, believe that our compliance with 10 CFR 50.48 (d) (4), which requires implementation of fire protection features involving dedicated shutdown capability, is complete.
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