ML20125C735
| ML20125C735 | |
| 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. |
| References | |
| EA-92-205, NUDOCS 9212140054 | |
| Download: ML20125C735 (5) | |
See also: IR 05000301/1992018
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DC 0/Oc.6
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Decembei 8, 1992
Docket No.
50-301
License No.
DPR-i~.
EA 92-205
Wisconsin Electric Power Company
ATTH:
Mr.
R.
E.
Link, Vice President
fluclear Power
231 West Michigan Street - P379
Milwaukee, Wisconsin
53201
Dear Mr. Link:
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SUBJECT:
NOTICE OF VIOLATION AllD PROPOSED IMPOSITION OF CIVIL
PENALTY - $75,000
(NRC INSFECTION REPORT 50-301/92018)
This refors to the safety incpection 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
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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
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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.
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Plant personnel believe that the disk was inserted into an
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existing section of piping when it was cut to install a "T"
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connection for modification IWP 88-098 which was performed during
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the fall 1991 refueling outage.
This modification allows full
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flow testing of containment spray (CS), safety injection (SI),
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and residual heat removal (RHR) systems as recommended by NUREG-
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0578.
The modification consisted of 6-inch diameter (15 cm)
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Deumber 8, 1992
Wisconsin Electric
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piping connecting the various pump discharges to the refueling
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water storage tank (RWST).
Post-modification testing had
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verified that all newly installed pipe was free of blockage.
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However, the existing piping that was not modified as part of the
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full flow test line modification was not tested.
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In addition to being used to perform the annual containment spray
leakage test, this line is used during the recirculation mode of
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safety injection.
Therefore, the disk remaining in the system
following the modification rendered the
"A" train safety
injection system piping inoperable.
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The violations are described in the enclosed Hotice of Violation
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and Proposed Imposition of Civil Penalty (Notice) and involve the
failure to ensure that foreign material exclusion requirements
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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
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inoperable in violation of technical specifications (TS).
The-
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violations in the aggregate represent a significant safety
concern and are ca+egorized as a Severity Level III problem in
accordance with the General Statement of Policy and Procedure
for NRC Enforcement Actions," (EnDircement Policy) 10 CFR Part 2,
>
Appendix C.
The root cause of leaving the foam di k in the system was
inadequate procedures for material exclusion control. You
indicated at the enforcement confere:.cc 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 worP 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
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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
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- extensive radiographic and boroscopic examinations of as much of
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the CS, RHR, and SI systems for both Units-1 and 2 as were
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December 8, 1992
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
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guidelines) and are creating and implementing an enhanced foreign
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material exclusion program.
Also, the maintenance group's job
observation checklist will be revised to include observation of
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
activities performed on safety systems are properly implemented
and erecuted under strict compliance with foreign material
exclusicn requirements, and that adequate contractor oversight is
provided, I have been authorized, after consultation with the
Director, Office of Enforcement, and the Deputy Executive
Director for Nuclear Reactor Regulation, Regional Operations and
Research, to issue the enclosed Hotice of Violation and Proposed
Imposition of Civil Penalty in the amount of $75,000 for the
Severity Level III problem.
,
The base civil penalty for a Severity Level III problem is
$50,000.
The escalation and mitigation factors in tbc
Enforcement Policy were considered.
Mitigation of 25 percent was
appropriate for your initiative in identifying the root cause of-
this self-disclosing event.
Mitigation of 2S percent was also
appropriate for your corrective actions that involved procedural,
job observation checklist, and work control _ improvements and a
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
allowance for this factor was not appropriate because you did not
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
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event.
However, you have not addressed whether there'is a
broader problem in maintaining overcight of contractors.- Thel
civil penalty was escalated 100 percent because of the-duration
of this avoidable and safety significant problem that resulted in
operating the plant for nearly a year with one train of the SI
system piping inoperable.
The other factors in the Enforcement
Policy were considered and no further adjustment was appropriate.
Based on the assessment of the civil pensity adjustment factors,
the base civil penalty was escalated 50 percent.
You are required to respond to this letter and should follow the
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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.
After reviewing your response to this. Notice,
including your proposed corrective actions and the results of
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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 determine whether further NRC
enforcement action is necessary to ensure compliance with NRC
regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practico,"
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,
d zSv6b2 i
A.
Bert Davis
Regional Administrator
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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Wisconsin Electric-
Power Company
DISTRIBUTION:
SECY
CA
JSniezek, DEDR
ADDavis, RIII
JLieberman, OE
LChandler, OGC
JGoldberg, OGC
TMurley, NRR
JPartlow, NRR
Enforcement Coordinators
RI, RII, RIV, RV
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
IMS;RIII
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Davis
12/
/92
12/q/92
12//:/92
12///92
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- Concurrence received via fax.
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AND
PROPOSED ,T(POSITION OF CIVIL PENALTY
Wisconsin Electric Power Co.
Docket No. 50-301
Point Beach Nuclear Plarit
License No. DPR-30
Unit 2
EA 92-205
During an inspection conducted from August 24 through October 12,
1992, violations of NRC requirements were identified.
In
accordance with the " Statement of Policy and Procedure for NRC
Enforcement Actions," 10 CFR Part 2, Appendix C,
the Nuclear
Ragulatory Commission proposes to impose a civil penalty pursuant
to Section 234 of the Atomic Energy Act of 1954, as amended
(Act), 42 U.S.C.
2282, and 10 CFR 2.205.
The particular
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violations and associated civil penalty are set forth below:
A.
Technical Specification 15.3.3.A.1.g requires, in part, that
a reactor shall not be made critical, except for low
temperature physics tests, unless al) valves and piping
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associated with the safety injection system components that
are required to function during accident conditions are
Contrary to the above, on or about November 13, 1991, the
Unit 2 reactor was made critical, not in connection with low
temperature physics tests, while the piping associated with
train A of the containment recirculation mode of safety
injection, which is required to function during accident
conditions, was inoperable.
Specifically, a foreign
material exclusion disk had been left in a section of the
system piping leading to the suction of the train A safety
injection pump.
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B.
Criterion V,
" Instructions,
Procedures, and Drawings", requires, in part, that
activities affecting quality be prescribed by procedures of
a type appropriate to the circumstances and shall include
appropriate quantitative or qualitative acceptance criteria
for determining that important activities have been
satisfactorily accomplished.
Contrary to the above, on or about October 17, 1991,
Procedure QAP-105-PB, " Cleanliness Inspection of Fluid
Systems and Components," Revision 1,
a procedure affecting
quality, did not include appropriate guidance or acceptance
criteria to ensure that debris was not left inside the
safety injection and containment spray pump suction during
performance of modification IWP 88-098.
'this is a Severity Level III problem (Supplement I).
Civil Penalty - $75,000
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Pursuant to the provisions of 10 CFR 2.201, Wisconsin Electric
Power Company (Licensee) is hereby required to submit a written
statement of explanation to the Director, Office of Enforcement,
U.S.
Nuclear Regulatory Commission, within 30 days of the date of
this Notice of Violation and Proposed Imposition of Civil Penalty
(Notice).
This reply should be clearly marked as a " Reply to a
Notice of Violation" and should include for each alleged
violations
(1) admission or denial of the alleged violation, (2)
the reasons for the violation if admitted, and if denied, the
reasons why, (3) the corrective steps that have been taken and
the results achieved, (4) the corrective steps that will be taken
to avoid further violations, and (5) the date when full
compliance will be achieved.
If an adequate reply is not
received within the time specified in this Notice, an order or a
demand for information may be issued as to why the license should
not be modified, suspended, or revoked or why such other actions
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as may be proper should not be taken.
Consideration may be given
to extending the response time for good cause shown.
Under the
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authority of Section 182 of the Act, 42 U.S.C.
2232, this
response shall be submitted under oath or affirmation.
Within the same time as provided for the response required under
10 CFR 2.201, the Licenseo may pay the civil penalty by letter
addressed to the Director, Office of Enforcement,
U.S.
Nuclear
Regulatory Commission, with a check, draft, money order, or
,
electronic transfer payable to the Treasurer of the United States
in the amount of the civil penalty proposed above, or may protest
imposition of the civil penalty in whole or in part, by a written
answer addressed to the Director, Office of Enforcement,
U.
S.
Nuclear Regulatory Commission.
Should the Licensee fail to
answer within the time specified, an order imposing the civil
penalty will be issued.
Should the Licensee elect to file an
answer in accordance with 10 CFR 2.205 protesting the civil
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penalty, in whole or in part, such answer should be clearly
marked as an " Answer to a Notice of Violation" and may:
(1) deny
the violations listed in this Notice in whole or in part, (2)
demonstrate extenuating _ circumstances, (3) show error in this
Notice, or (4) show other reasons why the penalty should not be
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imposed.
In addition to protesting the civil penalty in whole or
in part, such answer may request remission or mitigation of the
penalty.
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In requesting mitigation of the proposed penalty, the factors
addressed in Section V.B of 10 CFR Part 2, Appendix C,
should be
addressed.
Any written answer in accordance with 10 CFR 2.205
should be set forth separately from the statement or explanation
in reply pursuant to 10 CFR 2.201, but may incorporate parts of
the 10 CFR 2.201 reply by specific reference
(e.g.,
citing page
and paragraph numbers) to avoid repetition.
The attention of the
Licensee is directed to the other provisions of 10 CFR 2.205,
regarding the procedure for imposing a civil penalty.
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Upon failure to pay any civil penalty due which subsequently has
been determined in accordance with the applicable provisions of
10 CFR 2.205, this matter may be referred to the Attorney
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General, and the penalty, unless compromised, remitted, or
mitigated, may be collected by civil action pursuant to Section
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234c of the Act,-42 U.S.C.
2282c.
The responses noted above (Reply to Notice of Violation, letter
with payn.ont of civil penalty, and Answer to a Hotice of
Violation) should be addressed to:
Director, Office of
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Enforcement, U.S. Nuclear Regulatory Commission, ATTN:
Document
control Desk, Washington, D.C.
20555 with a copy to the Regional
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Administrator, U.S.
Nuclear Regulatory Commission. Region III,
799 Roosevelt Road, Glen Ellyn, Illinois 60137, and a copy to the
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NRC Recident Inspector at the Point Beach Nuclear Plant.
FOR THE NUCLEAR REGULATORY COMMISSION
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Bert Davis
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T<egional Administrator
Dated at Glen Ellyn, Illincip
this 8th day of December l'392
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