ML20199D775
| ML20199D775 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 01/08/1999 |
| From: | Caldwell J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Reddemann M WISCONSIN ELECTRIC POWER CO. |
| References | |
| EA-99-002, EA-99-2, NUDOCS 9901200202 | |
| Download: ML20199D775 (5) | |
Text
%) p tscg}o,7, UNITED sT *.Es NUCLEAR REGULATORY COMMISSION 8
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,o January 8, 1999 EA 99-002 Mr. M. Reddemann Site Vice President Point Beach Nuclear Plant 6610 Nuciear Road Two Rivers, WI 54241
SUBJECT:
NOTICE OF ENFORCEMENT DISCRETlON FOR WISCONSIN ELECTRIC REGARDING POINT BEACH UNIT 1, NOED 99-3-001
Dear Mr. Reddemann:
By [[letter::NPL-99-0010, Requests Enforcement Discretion from Specific Plant TS Requirements Re Inoperability of Both SI & Both CS Pumps for Unit 1.Subject Pumps Were Declared Inoperable Upon Discovery of Failed Freeze Protection Circuit|letter dated January 6,1999]], you requested that the NRC exercise discretion not to enforce compliance with the actions required in Technical Specification 15.3.0.B. Your letter documented information previously discussed with the NRC in a telephone conversation on January 5 at approximately 4:30 p.m. (CST). The principal NRC staff members who participated in that telephone conference included Messrs. J. Caldwell, Acting Regional Administrator, C. Pederson, Acting Deputy Regional Administrator, M. Dapas, Deputy Director, r
Division of Reactor Projects, C. Carpenter, Director, Project Directorate ill-1, and T. Collins, Chief, Reactor Systems Branch. You stated that at 7:40 p.m. on January 5,1999, Point Beach Unit 1 would not be in compliance with Technical Specification 15.3.0.8, which required that "In the event an LCO [ Limiting Condition for Operation] cannot be satisfied because of equipment failures or limitations beyond those specified in the permissible condition of the LCO, action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the affected unit in: 1) Hot shutdown within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> of entering thir specification; and 2) Cold shutdown within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> of entering this specification."
At the time of the request, the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> time limit to initiate actions for shutdown had expired and the licensee had entered the portion of the action statement requiring the plant to be in hot shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. You requested that a Notice of Enforcement Discretion (NOED) be issued pursuant to the NRC's policy regarding exercise of discretion for an operating facility set out in Section Vll.c. of the " Genera' Otatement of Policy and Procedures fcr NRC Enforcement Actions"(Enforcement Policy), NUREG-1600, to extend the action statement requiring the plant to be in hot shutdown for an additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, until 1:40 a.m. on January 6,1999. This letter documents our telephone conversation on January 5, at 6:00 p.m.
(CST) when we orally issued this NOED. We understand that the condition causing the need g
for this NOED was corrected by you and that you exited from Technical Specification 15.3.0.B and f om this NOED on January 5 at 11:30 p.m. (CST).
The event leading up to the request for the NOED involved the declaration of both of the safety injection and containment spray systems inoperable on January 5 at 12:40 p.m. (CST) after the identification that the common rninimum flew line retuming to the Refueling Water Storage Tank (RWST) 3vas frozen. Polons of this line and the RWST are located in an unheated enclosure. The minimum flow ine was discovered frozen during an attempt to recirculate water 9901200202 990108 PDR ADOCK 05000266 V
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in the RWST, You concluded that the additional time requested before the plant would have to L
be in hot shutdown in order to allow you to return one train of safety injection and the l
containment spray system to an operable condition, would result in a minimal increase in risk to I
the safe operation of Unit 1. In addition, you stated that compliance with Technical l
Specification 15.3.0.B may be detrimental in that subjecting the plant to a shutdown transient l
may entail additional risk. Also, while a power grid emergency had not been declared, the grid l
was in a " Yellow Condition," as determined by the Wisconsin Electric Control Center, which
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meant that the loss of generating capacity from the shutdown of Point Beach Unit 1 may have l
resulted in the curtailment of service to some sectors of electric customers. Compensatory l
measures included: (1) the modification of operating and emergency procedures to allow the i
temporary use of the installed full flow test line to provide minimum flow protection for the B train safety injection pump; (2) an analysis of the containment spray system that addressed operability of the containment spray system without a minimum flow path; (3) the conduct of a 10 CFR 50.59 safety evaluation to ensure that the modifications to operating and emergency procedures did not involve an unreviewed safety question; (4) the conduct of an operability l
evaluation using the guidance in NRC Generic Letter 91-18 to provide justification for declaring j
the B train of safety injection operable; and (5) training of each operatingerew before turnover l
to make sure the operators and their supervision were aware of the unusual safety injection system alignment and the changes to operating and emergency procedures.
The NRC evaluated your safety rationale for the requested NOED and verified that the request l-to extend the action statement of Technical Specification 15.3.0.8 an additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> involved minimal increase in risk to the safe operation of Point BecA Unit 1. The staff also evaluated the length of time requested and determined that the short duration of the request was also appropriate, since you had already reconfigured the plant to use the installed full flow test line in lieu of the common minimum flow line to the RWST in order to provide minimum flow j
protection for the B train safety injection pump, and had revised both operating and emergency procedures for the use of this test line, but had not yet completed 'he associated 10 CFR 50.59 t
safety evaluation. In addition, the NRC considered the compounding factor of the " Yellow Condition" of the power grid and the potentialinterruption of power at a time when sub-zero
~ temperatures existed. Based on these considerations, the staff concluded that Criterion 1 of l-Section B and the applicable criteria in Section C.4 to NRC Manual Chapter 9900, " Technical Guidance, Operations - Notice of Enforcement Discretion," were met. Criterion 1 of Section B
-states that for an operating plant, the NOED is intended to avoid an undesirable transient as a l
result of forcing compliance with the license condition, and thus minimize the potential safety I
. consequences and operational risks.
On the basis of the staff's evaluation of your request, we have concluded that an NOED is warranted bc-use we are clearly satisfied that this action involves minimal safety impact, is consistent with the enforcement policy and staff guidance, and has no adverse impact on public health and safety. Therefore, it is our intention to exercise discretion not to enforce compliance with Technical Specification 15.3.0.8 for the period from January 5 at 7:40 p.m. (CST) until January 6 at 1:40 a.m.(CST), a period of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
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M. Reddemann l-As stated in the Enforcement Policy, action will be taken, to the extent that violations were l
involved, for the root cause that led to the noncompliance for which this NOED was necessary.
Sincerely,
/s/ J. L. Caldwell James L. Caldwell Acting Regional Administrator i
l Docket Nos.: 50-266;50-301
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License Nos.: DPR-24; DPR-27 l
cc:
R. Grigg, President and Chief Operating Officer, WEPCO M. Sellman, Chief Nuclear Officer J
l R. Mende, Plant Manager J. O'Neill, Jr., Shaw, Pittman, Potts & Trowbridge K. Duveneck, Town Chairman Town of Two Creeks B. Burks, P.E., Director Bureau of Field Operations 1
J. Mettner, Chairman, Wisconsin Public Service Commission S. Jenkins, Electric Division Wisconsin Public Service Commission State Liaison Officer DOCUMENT NAME: G:\\POIN\\9NOEDPB1.WP SEE PREVIOUS CONCURRENCES 1
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NAME Burgess:nh Clayton Dapas/# M Grant Cafgflelf DATE 01/ /99 01/ /99 01/7/99 01/ /99 01/h99 OFFICIAL RECORD COPY L
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i M. Reddemann i j
As stated in the Enforcement Policy, action will normally be taken, to the extent that violations were involved, for the root cause that led to the noncompliance for which this NOED was necessary.
l Sincerely, James L Caldwell l
Acting Regional Administrator i
Docket Nos.: 50-266;50-301 License Nos.: DPR-24; DPR-27 l
cc:
R. Grigg, President and Chief Operating Officer, WEPCO M. Sellman, Chief Nuclear Officer R. Mende, Plant Manager J. O'Neill, Jr., Shaw, Fittman, Potts & Trowbridge.
K. Duveneck, Town Chairman Town of Two Creeks B. Burks, P.E., Director Bureau of Field Operations J. Mettner, Chairman, Wisconsin Public Service Commission S. Jenkins, Electric Division Wisconsin Public Service Commission 1
State Liaison Officer l
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l DOCUMENT NAME: G:\\POIN\\9NOEDPB1.WP To receive a copy of this docurnent. Indicate in the box *C" = Copy without attachenent/ enclosure *E' = Copy with attachtnent/ enclosure l
- N* = No copy OFFICE Rll)Af li Rlli l C. Rlli l
Rill l
NAME BMss:co Clayton M Grant @
Caldwell DATE 01/3/99 01h 8/99 01/ilhidlU 01/ /99 OFFICIAL RECORD COPY i
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- s M. Reddemann Distribution:
J. Lieberman, OE J. Goldberg, OGC B. Boger, NRR CAC (E-Mail)
RPC (E-Mail) l Project Mgr., NRR -
lF J. Caldwell, Rlli l
C. Pederson, Rlli L
B.' Clayton, Rill SRI Point Beach'-
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GREENS LEO (E. Mail)
DOCDESK (E-Mail)
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