ML20125C730

Discusses Safety Insp Rept 50-301/92-18 on 920824-1012 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $75,000 for Severity Level III Problem. Enforcement Conference Held on 921106 to Discuss Violation

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: ML20125C730 ML20125C748
References
EA-92-205, NUDOCS 9212140054
Download: ML20125C730 (5)

See also: IR 05000301/1992018

Text

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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. DPR-27

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

RECEIPT REOUESTED

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9212140054 921208

PDR ADOCK 05000301

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Wisconsin Electric -2 -

December 8, 1992

Power Company

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

.'

remained in the system upon completion of the modification.

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

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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l Wisconsin Electric -3 - December 8, 1992

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accessible. In the longer term, you are revising your procedures

to better control such work (using INPO good practices

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guidelines) and are creating and implementing an enhanced foreign

(- material exclusion program. Also,-the maintenance group's job

1 observation checklist will be revised to include observation of

) foreign material exclusion practices on the job.

i

Nevertheless, due to the safety significance of this violation,

and to emphasize the importance of ensuring'that modification-

i activities performed on safety systems are properly implemented

i and executed under strict compliance with foreign material

'

exclusion requirements,.and that adequate contractor oversight is

provided, I have been authorized, after consultation with the

j Director, Office of-Enforcement, and the-Deputy Executivo

i Director for Nuclear Reactor Regulation, Regional Operations and ,

j Research, to issue the enclosed Notice of Violation and Proposed j

, Imposition of Civil Penalty in the amount of $75,000 for the

-

Severity Level III problem.

i The base civil penalty for a Severity Level III' problem is

i $50,000. The escalation and mitigation factors in the

l- Enforcement Policy were considered. Mitigation of 25 percent was

1

appropriate for your initiative in identifying the root cause of

j this self-disclosing event. Mitigation off25 percent was also

appropriate for your corrective actions that involved procrdural,

! job observation checklist, and work control improvements-and a

l significant effort to verify the-scope of the potential problem

through testing and inspection. The Enforcement Policy permits '

! 50 percent mitigation for corrective actions but the full

l allowance for this factor was not appropriate because you did not

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l broadly address the issue of contractor oversight-(i.e., training

and supervision). Specifically, you have taken-corrective

! actions for future contractor work involving foreign material

) exclusion which will prevent problems similar to_those in this

! event. However, you have not addressed whether there is'a -

!- broader problem in maintaining oversight of contractors. The ,

! civil penalty was escalated 100 percent because of the duration

! 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.

-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,

i

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 -

! 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 -4 - December 8, 1992

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,

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di 2%5b. cw%

A. Bert Davis

Regional Administrator

i

Enclosure: Notice of Violation and

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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, . Power,Ccmpany .

DISTRIBUTION:

SECY

CA

JSniczek, DEDR

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ABDavis, RIII

JLieberman, OE

LChandler, OGC

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JGoldberg, OGC

TMurley, NRR

JPartlow, NRR

<

Enforcement Coordinators

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RI, RII, RIV, RV

FIngram, GPA/PA

DWilliams, OIG

BHayes, OI

EJordan, AEOD

JLuchman, OE

LTran, OE

Day File

. EA File

~DCS.

RAO:RIII

SLO:RIII

PAO;RIII

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IMS;RIII

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