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Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $25,000.Violation Noted:Msivs Could Not Close Because Dc Control Power Removed from Associated Solenoids & Event Not Reported within Required 4 H
	ML20236G512
Person / Time
Site:	Point Beach
Issue date:	10/29/1987
From:	Davis A; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	;
Shared Package
ML20236G501	List: IR 05000301/1987016; ML20236G512;
References
	EA-87-182, NUDOCS 8711030053
	Download: ML20236G512 (3)
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' NOTICE OF VIOLATION ,1 AND L-PROPOSED IMPOSITION OF CIVIL PENALTY--

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. -l' Wisconsin Electric Power Company Docket N6. 50-301

' Point Beach Nuclea'r Plant, Unit 2 License No. DPR-27 s ;

EA'87-182 An NRC special safety inspection conducted during the period August.19-28, '1987, identified violations of NRC requirements. JIn accordance with the General .

-Statement of Policycand Procedure for~NRC Enforcement' Actions,"~10 CFR Part 2, 1 Appendir C.(1987), the Nuclear Regulatory Commission proposes,to impose a civil: penalty pursuant to Section.234Lof theLAtomic Energy ~Actiof 1954, as -)

amended (ACT), 42 U.S.C. 2282, and 10 CFR 2.205 .The particular' violations =

i and associated civil penalty are set-forth.below:

A. Technical Specification.15.3.5'.C states "In the event the number'of j channels of a particular sub-system in service falls below the limitr- !

given..in the column entitled. Minimum Operable Channels, or. Minimum Degree 1 of Redundancy cannot be achieved,-operation shall be limited;according.to the' requirement shown in, tables 15.3.5-2-through-15.3.5-4, 0perator ;

Action when minimum operable. channels. unavailable." Table 15;3.5-4,..

. Number 2,Esteam Line ' Isolation, lists. required minimum operable channels; for.

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1. Hi Hi Steam Flow with Safety Injection .

One Operable Channel l

2. Hi ' Steam Flow and 2 of 4 Low Tavg with Safety l< Injection One Operable Channel

3. Hi Containment Pressure Two Operable Channels I 4. Manual -

One Operable Channel / Loop ,

L and provides.that if the ' required minimum operable channels:cannot'be met, the unit shall be placed in hot shutdown.

Contrary to the above,-from 11:05 p~.m' on' August .'17,1987 until 3:00- a.m.

on August 18, 1987,.with the reactor critical at less than three percent? !'

power, the licensee. failed to have'any operable _ channels ofl steami line isolation specified in T.S. Table 15.3.5-4 in that, the main / steam isolation valves:could not close because DC control power was removed from;the: associated solenoids. Further,.with all-channels of main' steam-isolation inoperable the' licensee did not; place'the unit in' hot-shutdown. ,

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Notice of Violation 2 OCT 2 91987

8. 10 CFR Part 50, Appendix B, Criterion XVI_. requires in part that the identification of a significant condition adverse to quality, the cause of the condition and the corrective action taken be reported to the appropriate levels of management.

10 CFR 50.72 requires the licensee to notify the NRC Operations Center via the Emergency Notification System of events described in Paragraph (b) of this section. Paragraph (b)(2), states, "Four hour reports.

If not reported under Paragraph (a) or (b)(1) of this section, the ,

licensee shall notify the NRC as soon as practical and in.all cases, within four hours of the occurrence. of any of the following...(iii).

Any event or condition that alone could have prevented the fulfillment of the safety function of structures or systems that are needed to...

(D) Mitigate the consequences of an accident."

Contrary to the above, on August 18, 1987, at 3:30 a.m. the plant staff identified that the main steam isolation valves would not have been able to perform their intended function but this condition was not promptly evaluated or reported to the appropriate levels of licensee management.

l Additionally, it was not reported to the NRC Operations Center via the Emergency Notification System until 12:00 noon on August 20, 1987. This represented a period of 56 hours6.481481e-4 days 0.0156 hours 9.259259e-5 weeks 2.1308e-5 months and 30. minutes after _ discovery.

Collectively these violations have been evaluated as a Severity Level III problem (Supplement I). ;

1 Cumulative Civil Penalty - $25,000 (assessed equally between the violations).

Pursuant to the provisions of 10 CFR 2.201, Wisconsin Electric Power Company is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of this Notice. This reply should be clearly marked as a." Reply to a Notice of Violation" and should include: (1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, (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 may_be issued to l show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken. Consideration may be given to extending the response time for good cause shown. Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

l l Within the same time as provided for the response required above under 10 CFR 2.201, the Licensee may pay the civil penalty by letter to the l Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a

l Notice of Violation 3 OCT 2 91987 check, draft, or money order payable to the Treasurer of the United States in 'l the amount of 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 j civil penalty will be issued. Should the Licensee elect to file an answer'in i accordance with 10 CFR 2.205 protesting the civil penalty, in whole or in I part, such answer should be clearly marked as an " Answer to a Notice of !

Violation" and may: (1) deny the violation. 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 imposed. In l addition to protesting the civil penalty, such answer may request remission or.

mitigation of the penalty. !

I In requesting mitigation of the proposed penalty, the five factors addressed in Section V.B of.10 CFR Part 2, Appendix C (1987), should be' addressed. Any-written answer in accordance with 10 CFR 2.205 should be set forth-separately l 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.

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 General, and the penalty, unless compromised,~ remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the l Act, 42 U.S.C. 2282c.

The responses to the Director, Office of Enforcement, noted a'bove (Reply to a l

i Notice of Violation, letter with' payment of civil penalty, and answer to a Notice of Violation) should be addressed to: Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, ATTN: Docume'nt Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, U.S. Nuclear _ Regulatory Commission, 799 Roosevelt Road, Glen Ellyn, Illinois, 60137, and a copy to the l NRC Resident Inspector at Point Beach.

1 i FOR THE NUCLEAR REGULATORY COMMISSION

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A. Bert' Davi Regional Administrator Dated at Glen Ellyn, Illinois this pq day of October 1987 l

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_U.S. NUCLEAR REGULATORY COMMISSION-REGION III Report No. 50-301/87016(DRP)

Docket No. 50-301- = License No. DPR-27 Licensee: Wisconsin Electric Company 231 West Michigan-Milwaukee, WI 53203 Facility Name: Point' Beach Unit 2 Inspection At: Two Creeks, Wisconsin.

Inspection Conducted: August 19-28, 1987-Inspector: .R. L. Hague feQ-I/h*k.h' Approved By: R. DeFayette, Chief 09//4/N' 3' Reactor Projects.Section'2B Date Inspection Summary Inspection on August 19-28, 1987 (Report No. 50-301/87016(DRP)) ..

Areas Inspected: Special safety inspection by R. L. Hague, of the events and circumstances surrounding the. licensee's failure to~ meet the Technical Specification related to_ operability of the main steam isolation valves and its deportability to the NRC.

Results: Two apparent violations were identified. failure.to'have'all four methods of steam line isolation operable'while the reactor;was operating; and failure to report the event to the NRC_in the required time.

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DETAILS

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1. Persons Contacted

R. W.: Brit, President.and Chief Operating Officer "C. W. Fay, Vice' President Nuclear Power:

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J. J.-Zach,' Manager, P8NP; '

R. 'J. Bruno, Superintendent, Training ~:

R.~ D. Seizert Project Engineer T. J.'Koehler, General Superintendent a

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G.-J. Maxfield, Superintendent, Operations- "

J.'C. Reisenbuechler, Superintendent, EQRS j W.-J. Herrman, Superintendent,. Maintenance and Construction 1

J. E. Knorr, Regulatory Engineer The. inspector also' talked with and. interviewed members of.the 1

Operation, Maintenance, and Instrument and Control Sections. .

Denotes personnel attending exit interviews. [

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2. Introduction 4 During day shift on August 17, 1987, when it became evident thatt the inspection of the 2X01 transformer was going to take: longer...than~ ;

anticipated and with the requirement.to repair the steam driven auxiliary

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feedpump prior to unit criticality, maintenance personnel decided'they had enough time to perform some: minor secondary sidelinspections/ repairs and requested that operations personnel tag the main steam: isolation

. valves (MSIVs) shut to facilitate this work. . TheJoperations supervisor-was quite busy at the time and requested.that the. Unit 12 reactor operator-fill out the danger tag location sheet and the red ta'gs. !When the reactor-operator finished, he1provided the'sheetito the! operations supervisor for.

review. The operations supervisor noted that the tagout.providedLfor four- ~

tags tagging the-two DC control power breakers to the instrument air'-

solenoid valves ~open and the'two instrument' air isolation valves to the MSIVs' shut. He concluded that tagging th'e instrument' air: isolation 4 i

(stop) valves shut would prevent opening the MSIVs and tagging the DC' .

control power breakers open would prevent the solenoid valves 1 from being continually energized with the control room switch in the closed position, a normal' practice during long term outages. 'He then turned-the. tags over-to two qualified red. taggers to perform the tag outJand verification. j Once_the tags were hung, one copy of the' danger tag location' sheet wasi kept in the control room and the other was given to maintenance ~ personnel-as approval to start work; i

At about 9:00 p.m. on Augustc17, 1987, the maintenance foreman notified the control room that the' secondary side work.was completed and the-tag; out on the MSIVs could'be removed.; The swing shift operations supervisor removed the tag.out. sheet from the' log book and assumed.from.the wording-that.the two instrument: air ~stop valves were tagged shut and that.two of,. J '

theLlocal vent solenoid valves were tagged open. 'Because it was.

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approaching shift. turnover time, he. called the auxiliary building" aux'iliary.

operator (AO) an'd told him to " remove the-red tags on the MSIVs'and open the = instrument air stop valves." The AO completed this task'and called back to the control. room reporting,."the red tags;have been removed and the instrument air stops are open." Again.'using his initial assumption, the operations supervisor assumed that all four? red tags had been removed _

and he initialed the cleared section of!the danger tag-locationLsheet with-a slash and the' A0's initials to indicate that the tags were cleared per-verbal verification. In fact, only two of the four red tags had been.

removed.

At 11:0S p.m., August 17, 1987, the mid-shift shift supervisorLordered his auxiliary building A0 fto reset the four instrument. air solenoid valves-for each MSIV, thereby opening the MSIVs. .At 3:30 a.m., August- 18. 1987, ,

- during performance of OP-10, " Low. Power Operation to Nomal) Power Operation,".

Step 4.1, " Energize Following Circuits," the shift supervisor went to the-DC control power breaker panels. _He opened the door on thetfirst panel-to.look for the circuits by name and noticed the red tag on:the "A".MSIV -

solenoid power' supply. - He checked further in another panel. and found. the "B" MSIV solenoid power supply.was also tagged open. He then checked and-found that the tag series had been cleared.on the previous shift and knew ^

that there was no secondary maintenance.in' progress so he; removed the red tags and closed the breakers. He then went on with the' normal business-of lighting off the turbine and getting the unit on line.

When the mid-shift shift supervisor Ltook the watch:the { initial conditions of OP-10 had been' signed off as completed although after Step 3.1 was completed the MSIVs were tagged. shut for maintenance { Stepl3.1 required the performance of applicable portions of OP-13A. The shift supervisor started'reaccomplishing the . steps in OP-13A, " Secondary Systems Startup and Shutdown," Section 4.5, " Bringing-Steam Into Turbine _ Building."

When he got to Step 4.5.4, "Open and Cycle the MSIVs," he made~ the decision that inasmuch as'they had already.been cycled and IT-280/285,." Inservice Testing of Main Steam Stop Valves," had been run earlier that day there was no need to cycle the MSIVs again. Had he.not. violated procedural step 4.5.4 the subsequent investigation as to why the MSIVs.would not shut would have disclosed the' open breakers.

The mid-shift shift supervisor left a note for the swing shift operations supervisor stating'that he had found the MSIV solenoid'breakersLtagged open and that a violation may have been involved. The swing shift' operations supervisor and shift supervisor prepared a nonconfonnance report detailing.the incident.. This -information did not reach the appropriate individuals until'the next day at which. point they decided that they.had a Technical Specification violation and an LER would be-required.- However, they wanted more information from the. shift supervisor-before making a determination on the emergency notification system.(red '

phone) deportability to the NRC. - Therefore, red phone notification was: 1 delayed until noon on August 20, 1987.-

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- 3. Sequence of-Events ;

August 16, 1987' Lightning strike'on Unit 2 transformer 2X01'. -;

6:55 p.m. Generator lock-out, Reactor Trip. i August 17, 1987 2P29, Unit'2 steam driven auxiliary feedwater- -;

10: 35 a.m. . pump declared out of service for. thrust bearing replacement August 17, 1987 Red tag Series87-752 issued to maintenanc'e During Day Shift department for various secondary side jobs August.17,-1987 Transformer 2X01 cleared for use 1 6:55 p.m. J August 17, 1987 Unit 2.. steam driven' auxiliary feedwater 9:05 p.m. Pump 2P29 returned to service l August 17, 1987 Unit 2 reactor critical

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l August 17, 1987 Removed red tags from instrument air valves I 10: 30 p.m.

August 17, 1987 Relatched solenoid valves, opened main steam 11:05 p.m. isolation valves, noted steam' leak on LP turbine rupture disc, called in maintenance personnel l l August 18, 1987 Steam'in Unit 2_ turbine hall, Unit 2: reactor .

critical at 2.8 x'10 8 amp intermediate. range, 0000 holding for rupture disc maintenance-August 18, 1987 Unit 2 turbine released by maintenance 1:44 a.m.

August 18, 1987 Commence drawing vacuum 1:58 a.m.

August 18, 1987 During performance of Procedure OP-IC,_" Low-3:30 a.m. Power Operation," Step 4.1, Energize Following Circuits, the shift supervisor opened DC control l power breaker _. Panels D-19 and D-22 and discovered control power to the MSIVs tagged.open August 18, 1987 Latch turbine 4:23 a.m.

August 18, 1987 Shift _sepervisor_ leaves note to swing. shift 7:00 a.m. on what he found ' stating _there may be a possible violation involved 4'

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August 18, 1987- Operations supervisor.and. shift supervisor- .

l Swing Shift prepared nonconformance report for managements review-August 19,:1987- Regulatory engineer informs senior resident ~

Afternoon inspector of~possible:LERlon Tech.-Spec. ;

violations, needed more--information from i mid-shift shift supervisor ,

' August 20, 1987 SRI reviews no'nconformance' report, callid i

Morning Region III to. discuss: the event. . SRI:

. ' questions.' red phoneL deportability--with licensee. Licensee had already determined! ,

need for 4 hr. ' report: . questioned need for i one hour report pending'results:on whether or not they were in an unanalyzed condition. 1 i

August 20, 1987 Licensee makes red phone. call to:NRC 1

'12:00 Noon l

l 4. Document Review l 1 The inspector reviewed the following documents:

Nonconformance Report No. N-87-140 Unit 2 Main Steam Stop Valves-

Technical Specification 15.3.5 Instrumentation System- 4

FSAR 14.2.5 Rupture of a Steam Pipe

OP-1C " Low Power Operation to- Normal! Operation" .]

OP-13A " Secondary System Startup and Shutdown"'

PBNP 4.2.1 " Shift Superintendent" ;

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PBNP 4.12.1 " Guidelines for Watch Standing" ,j

PBNP 4.13 " Equipment Isolation Procedure (Danger Tag Location)"

Point Beach Nucisar Plant Danger Tag Location Sheet

Incident Investigation 87-04 Preliminary Report !

5. Cause The failure to properly clear the red tags appears to.be an isolated case- l of poor communications. Contributing factors, althoughinot, procedural. ;

violations, were: !

1. Danger tag location sheet not specific enough as to tag. location.

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2. Failure to specify how many tags were to be removed.

3.- Decision that cycling MSIVs was not'necessary.

4. Failure to notify upper management immediately of possible i violation for deportability determination.

I Therefore, the cause appears to be twofold: an equipment isolation 1 procedure which is not specific enough; and a prevailing attitude _in the operations group that the MSIVs are not as.significant to safety as other safety-related equipment.

6. Technical Specification and Code Applicability Technical Specification 15.3.5.C requires a minimum number of operable channels for each of the four methods of steam line isolation. If these 'l minimum operability requirements cannot be met,-the unit must be in hot shutdown. With no DC control power, none of the minimum operability requirements were met for the four hours and 35 minutes that the MSIVs were~ open and the reactor was critical at low power.

10 CFR 50.72 (b)(2)(iii)(D), requires that any event or condition that alone could have prevented the fulfillment of the safety function of structures or systems that are needed to: mitigate the consequences of an accident, shall be reported as soon as practical, and in all cases within four hours of the occurrence. This event was-not reported until 79 hours9.143519e-4 days 0.0219 hours 1.306217e-4 weeks 3.00595e-5 months and 30 minutes after. initial discovery.- i

7. Exit Interview-The inspectors met with licensee representatives (denoted'in-Parag.aph 1) !

, throughout the inspection period and at the conclusion of the inspection period to summarize the scope and findings of the inspection activities.

The licensee acknowledged the inspectors' comments. The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not identify any such documents / processes as proprietary.

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ML20236G512

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