ML20125C730
| ML20125C730 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 12/08/1992 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Link R WISCONSIN ELECTRIC POWER CO. |
| Shared Package | |
| ML20125C734 | List: |
| References | |
| EA-92-205, NUDOCS 9212140054 | |
| Download: ML20125C730 (5) | |
See also: IR 05000301/1992018
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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December 8, 1992
Docket No.
50-301
License No.
EA 92-205
Wisconsin Electric Power Company
ATTN:
Mr. R.
E.
Link, Vice President
Nuclear Power
231 West Michigan Street - P379
Milwaukee, Wisconsin
53201
Dear Mr. Link:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL
PENALTY - $75,000
(NRC INSPECTION REPORT 50-301/92018)
This refers to the safety inspection conducted during the period
from August 24, 1992, through October 12, 1992, at the Point
Beach Nuclear Plant Unit 2.
During this inspection, significant
violations of NRC requirements were identified, and on
November 6,
1992, an enforcement conference was conducted in the
Region III office.
Attending the enforcement conference were
you, Dr. Carl Paperiello, Deputy Regional Administrator, and
other members of our respective staffs.
The report documenting
the inspection was sent to you by letter dated October 30, 1992.
The report summarizing the enforcement conference was sent to you
by letter dated November 18, 1992.
During performance of an annual containment spray leakage
reduction test on the
"A" train for Unit 2 on September 17, 1992,
the discharge pressure of containment spray pump P-14A was
observed by operators to be lower than that for containment spray
pump P-14B.
During the quarterly containment spray pump test on
the
"A" train for Unit 2 on September 18, 1992, operators
observed abnormally low discharge pressure and noises on
containment spray pump P-14A.
Subsequent disassembly of the pump
revealed a foam disk wrapped in duct tape blocking the impeller
of the pump.
Plant personnel believe that the disk was inserted into an
existing section of piping when it was cut to install a
"T"
connection for modification IWP 88-098 which was performed during
the fall 1991 refueling outage.
This modification allows full
flow testing of containment spray (CS), safety injection (SI),
and residual heat removal (RHR) systems as recommended by NUREG-
0578.
The modification consisted of 6-inch diameter (15 cm)
CERTIFIED MAIL
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RECEIPT REOUESTED
9212140054 921208
ADOCK 05000301
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Wisconsin Electric
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December 8, 1992
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piping connecting the various pump discharges to the refueling
water storage tank (RWST).
Post-modification testing had
verified that all newly installed pipe was free of blockage.
However, the existing piping that was not modified as part of the
full flow test line modification was not tested.
In addition to being used to perform the annual containment spray
leakage test, this line is used during the recirculation mode of
safety injection.
Therefore, the disk remaining in the system
following the modification rendered the "A" train safety
injection system piping inoperable.
The violations are described in the enclosed Notice of Violation
and Proposed Imposition of Civil Penalty (Notice) and involve the
failure to ensure that foreign material exclusion requirements
were adequately implemented during modification activities
associated with the fall 1991 refueling outage.
The Notice also
pertains to restarting the plant and operating it for nearly a
year with one train of the safety injection system piping being
inoperable in violation of technical specifications (TS).
The
violations in the aggregate represent a significant safety
concern and are categorized as a Severity Level III problem in
accordance with the " General Statement of Policy and Procedure
for NRC Enforcement Actions," (Enforcement Policy) 10 CFR Part 2,
Appendix C.
The root cause of leaving the foam disk in the system was
inadequate procedures for material exclusion control. You
indicated at the enforcement conference that inserting such
foreign material exclusion disks in piping systems during
modification work is not prohibited by plant procedures, and that
the decision to use these was left up to the craft personnel
doing the work.
In this case, the contract craft personnel
performing the work chose to use a disk, but neither their
procedures nor QC inspection personnel identified that the disk
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remained in the system upon completion of the modification.
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Additionally, your personnel had not reviewed the contractor's
procedure prior to its use to verify if it contained adequate
controls.
Therefore, the plant was in violation of the TS that
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prohibits plant startup unless all valves and piping associated
with the safety injection system that are required to function
during accident conditions are operable.
The plant was made
critical in November 1991 and operated until the problem'was
discovered in September 1992.
The staff recognizes that immediate corrective actions were taken
when the problem was identified.
You formed an incident
investigation team to thoroughly review the event and performed
extensive radiographic and boroscopic exar; nations of as much of
the CS, RHR, and SI systems for both Units 1 and 2 as were
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December 8, 1992
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Wisconsin Electric
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accessible.
In the longer term, you are revising your procedures
to better control such work (using INPO good practices
guidelines) and are creating and implementing an enhanced foreign
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material exclusion program.
Also,-the maintenance group's job
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observation checklist will be revised to include observation of
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foreign material exclusion practices on the job.
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Nevertheless, due to the safety significance of this violation,
and to emphasize the importance of ensuring'that modification-
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activities performed on safety systems are properly implemented
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and executed under strict compliance with foreign material
exclusion requirements,.and that adequate contractor oversight is
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provided, I have been authorized, after consultation with the
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Director, Office of-Enforcement, and the-Deputy Executivo
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Director for Nuclear Reactor Regulation, Regional Operations and
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Research, to issue the enclosed Notice of Violation and Proposed
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Imposition of Civil Penalty in the amount of $75,000 for the
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Severity Level III problem.
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The base civil penalty for a Severity Level III' problem is
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$50,000.
The escalation and mitigation factors in the
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Enforcement Policy were considered.
Mitigation of 25 percent was
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appropriate for your initiative in identifying the root cause of
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this self-disclosing event.
Mitigation off25 percent was also
appropriate for your corrective actions that involved procrdural,
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job observation checklist, and work control improvements-and a
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significant effort to verify the-scope of the potential problem
through testing and inspection.
The Enforcement Policy permits
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50 percent mitigation for corrective actions but the full
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allowance for this factor was not appropriate because you did not
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broadly address the issue of contractor oversight-(i.e., training
and supervision).
Specifically, you have taken-corrective
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actions for future contractor work involving foreign material
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exclusion which will prevent problems similar to_those in this
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event.
However, you have not addressed whether there is'a
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broader problem in maintaining oversight of contractors.
The
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civil penalty was escalated 100 percent because of the duration
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of this avoidable and safety-significant problem that resulted in
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operating the plant for nearlyLa year with one1 train of the SI.
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-system piping inoperable.
The other factors in the. Enforcement
Policy were considered and no further adjustment was appropriate.--
Bases on the assessment of the civil penalty adjustment factors,
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the base civil penalty was escalated 50 percent.
You are required to respond to this letter and should follow-the
instruction specified in-the enclosed Notice when preparing-your
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response.
In your response, you should document the specific
actions taken and any additional actions you plan to prevent
recurrence.
.ifter reviewing your response to this-Notice,
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Wisconsin Electric
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December 8, 1992
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Power company
including your proposed corrective actions and the results of
future inspections, the NRC will deturmine whether further NRC
enforcement action is necessary to ensure compliance with NRC
regulatory requirements.
In accordance with A0 CFR 2.790 of the NRC's " Rules of Practice,"
a copy of this letter and its enclosure will be placed in the NRC
Public Document Room.
The response directed by this letter and the enclosed Notice are
not subject to the clearance procedures of the Office of
Management and Budget as required by the Paperwork Reduction Act
of 1980, PL 96-511.
Should you have any questions concerning this letter, please
contact us.
Sincerely,
di 2%5b. cw%
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A. Bert Davis
Regional Administrator
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Enclosure:
Proposed Imposition of Civil Penalty
cc w/ enclosure:
DCD/DCB (RIDS)
G. J.
Maxfield, Plant Manager
OC/LFDCB
Resident Inspector, Point Beach
Virgil Kanable, Chief
Boiler Section
Charles Thompson, Chairman
Wisconsin Public Service
Commission
Robert M. Thompson, Administrator
WI Div. of Emergency Govt.
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December 8, 1992
' Wisconsin Electric
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DISTRIBUTION:
SECY
CA
JSniczek, DEDR
ABDavis, RIII
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JLieberman, OE
LChandler, OGC
JGoldberg, OGC
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TMurley, NRR
JPartlow, NRR
Enforcement Coordinators
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RI, RII, RIV, RV
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FIngram, GPA/PA
DWilliams, OIG
BHayes, OI
EJordan, AEOD
JLuchman, OE
LTran, OE
Day File
EA File
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RAO:RIII
SLO:RIII
PAO;RIII
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