ML20204D816

Forwards Insp Rept 50-266/99-04 on 990105-0222.One Violation of NRC Requirements Occurred & Being Treated as non-cited Violation,Consistent with App C of Enforcement Policy

ML20204D816
Person / Time
Site:	Point Beach
Issue date:	03/12/1999
From:	Dapas M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Reddemann M WISCONSIN ELECTRIC POWER CO.
Shared Package
ML20204D820	List: ML20204D816 ML20204D831
References
50-266-99-04, 50-266-99-4, EA-99-002, EA-99-2, NUDOCS 9903240290
Download: ML20204D816 (4)

See also: IR 05000266/1999004

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NUCLEAR REGULATORY COMMISSION

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9***** March 12, 1999

EA 99-002

Mr. M. E. Reddemann

Site Vice President

Point Beach Nuclear Plant .

6610 Nuclear Road

Two Rivers, WI 54241

SUBJECT: POINT BEACH INSPECTION REPORT 50-266/99004(DRP)

Dear Mr. Reddemann:

On February 22,1999, the NRC completed a specialinspection at your Point Beach Unit i

reactor facility. The purpose of the inspection was to examine the circumstances associated

with the identification of an ice-induced flow blockage in the normal minimum flow path for the

two safety injection (SI) pumps. The enclosed inspection report presents the results of that

inspection.

On January 5,1999, the NRC identified that SI system operability could be affected by a

degraded material condition in the facade freeze protection (FF) system for which your staff had

initiated a work order on December 22,1998. Your staff followed up on this concern and

identified that the normal minimum flow recirculation line from the discharge of thf., two SI

pumps to the refueling water storage tank was blocked. Following the identification of the flow

blockage, your staff's short- and intermediate-term corrective actions were generally considered

appropriate, with one exception described below. As the result of detailed tests and evaluations

performed subsequent to this event, your staff determined that the SI system was not rendered

inoperable by the ice blockage. However, your staff's operability conclusion was based upon

the structural failure of low pressure system boundary valves that were not designed to fail.

The design and licensing basis does not credit the structural failure of low pressure system

boundary valves to ensure that an emergency core cooling system is operable.

On January 8,1999, the NRC identified that your staff response to another FF system alarm

was focused on the wrong pipe, in discussing this issue with your staff, the inspectors were

informed that the FF system operating procedure was known to contain inaccurate and

incomplete information, in part because of the failure to update the procedure following a FF

system modification. Only after discussion with the inspectors did your staff update the FF

system operating procedure to more accurately reflect the known discrepancies.

Numerous other program and performance weakness were identified by the NRC inspectors.

These findings were consistent with the preliminary findings of your event investigation team.

Examples of the weaknesses included the failure to adequately maintain the material condition

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of the FF system, the failure to provide adequate engineering design and installation drawings

for the FF system, and the failure to establish minimum operability criteria for the FF system

prior to the' onset of cold weather,

Based on the results of this inspection, the -NRC has determined that one violation of NRC

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requirements occurred.' This violation is being treated as a Non-Cited Violation, consistent with

-- Appendix _C of the Enforcement Policy. The NCV is described in the subject inspection report.

If you contest the violation or severity level of the NCV, you should provide a response within.

30 days of the date of this inspection report, with the basis for your denial, to the Nuclear

Regulatory Commission, ATTN: Document Control Desk, Washington D.C. 20555-0001, with .

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copies to the Regional Administrator, Region Ill, and the Director, Office of Enforcement, United

States Nuclear Regulatory Commission, Washington, D.C. 20555-0001

In addition, one apparent violation was identified and is being considered for escalated

enforcement action in accordance with the " General Statement of Policy and Procedure for

NRC Enforcement Actions"(Enforcement Policy), NUREG-1600. This apparent violation

. involves the failure of your staff to take prompt corrective action on December 22,1998, when

they received an alarm indicating that a safety-related pipe was at a temperature near freezing.

As described above, the potential safety significance of this condition was not recognized until

' the NRC intervention on January 5,1999. Accordingly, no Notice of Violation is presently being

issued for this inspection finding. In addition, please be advised that the number and

characterization of the apparent violation described in the enclosed inspection report may

change as a result of further NRC review.

An open predecisional enforcament conference to discuss this apparent violation has been

scheduled for March 26,1999, at 9:00 a.m. (CST), in the NRC Region ill Office in Lisle, Illinois.

The decision to hold a predecisional enforcement conference does not mean that the NRC has

determined that a violation has occurred or that enforcement action will be taken. This -l

conference is being held to obtain information to enable the NRC to make an enforcement

decision, such as a common understanding of the facts, root causes, missed opportunities to

identify the apparent violation sooner, corrective actions,' significance of the issues and the

need for lasting and effective corrective action. In particular, we expect you to discuss: 1) tne

test on the diaphragm valve, including the methodology used and why the test is bounding,

from which you concluded that the safety injection system' remained operable,2) operator

performance, including the decision-making process, involved with the response to the low

temperature alarm on December 22,1998, and 3) the process used to classify the freeze

protection system as nonsafety-related and to establish the maintenance and operational

controls (e.g.,' how are failures evaluated for the effect on safety-related components / systems).

-in addition, this is an opportunity for you to point out any errors in our inspection report and for

you to provide any information conceming your perspectives on: 1) the severity of the violation,

2) the application of the factors that the NRC considers when it determines the amount of a civil

penalty that may be assessed in accordance with Section VI.B.2 of the Enforcement Policy, and

3) any other application of the Enforcement Policy to this case !ncluding the exercise of

discretion in accordance with Section Vll.

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M. Reddemann -3-

You will be advised by separate correspondence of the results of our deliberations on this

matter. No response regarding the apparent violation is required at this time.

In accordance with 10 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.

Sincerely,

/s/ Marc L. Dapas

Marc L. Dapas, Deputy Director

Division of Reactor Projects

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I Docket No.: 50-266

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License No.: DPR-24

Enclosure: Inspection Report 50-266/99004(DRP)

cc w/ encl: R. Grigg, President and Chief

Operating Officer, WEPCO

M. Sellman, Chief Nuclear Officer

R. Mende, Plant Manager )

J. O'Neill, Jr., Shaw, Pittman,

Potts & Trowbridge

K. Duveneck, Town Chairman

Town of Two Creeks

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B. Burks, P.E., Director

Bureau of Field Operations

J. Mettner, Chairman, Wisconsin  ;

Public Service Commission l

S. Jenkins, Electric Division  !

Wisconsin Public Service Commission

State Liaison Officer i

DOCUMENT NAME: G:\POIN\ pol 99004.DRP

• See previous concurrences

To receive a copy of this document, indicde in the box: "C" = Copy w/o attach /enci"E" = Copy w/ attach /enci"N" = No copy

OFFICE * Rill:DRP lE * Rill:DRP lE Rlli:DRP } l

NAME Kunowski/kjc/co, Lanksbury RnP_ Dapas#JP(/

DATE 03/11/99 F 03/t L /99 03// 2 /99

OFFICIAL RECORD COPY

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Distribution: .

CAC (E-Mail)

RPC (E-Mail)

J. Lieberman, OE w/enci

J. Goldberg, OGC w/enci

R. Zimmerman, NRR w/ encl

Project Mgr., NRR w/ encl

J. Caldwell, Rlli w/enct

B. Clayton, R!ll w/ enc!

SRI Point Beach w/enct

DRP w/enci

DRS (2) w/ enc!

Rill PRR w/ encl

PUBLIC IE-01 w/ encl

Docket File w/enci

GREENS

LEO (E-Mail)

DOCDESA (E-Mail)

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