ML20217D345

Notice of Violation from Insp on 980120-0302.Violation Noted:Replacement of 10CFR50,App B,Criterion V,State,In Part,That Activities Affecting Quality Shall Be Prescribed by Documented Instructions

ML20217D345
Person / Time
Site:	Point Beach
Issue date:	03/21/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20217D341	List: ML20217D336 ML20217D345 ML20217D353
References
50-266-98-03, 50-266-98-3, 50-301-98-03, 50-301-98-3, NUDOCS 9803270396
Download: ML20217D345 (3)

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Is NOTICE OF VIOLATION j

Wisconsin Electric Power Company Docket Nos.: 50-266; 50-301 Point Beach Nuclear Plant License Nos.: DPR-24; DPR-27 Units 1 and 2 During an NRC inspection conducted from January 20,1998, through March 2,1998, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

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1. The requirements of 10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings," state, in part, that activities affecting quality shall be prescribed by documented instructions of a type appropriate to the circumstances.

Contrary to the above, replacement of P-32A, a safety-related service water pump, was started on January 28,1998, using Work Order 9711936, a documented instruction not appropriate to the circumstances. Specifically, the work plans associated with the work order did not provide current drawings to support use of a revised pump configuration, did

! not include a comprehensive list of materials for assembling the replacement and reused

pump components, and did not provide for positive identification of the nuclear quality grade components actually used in the final pump assembly, i

l This is a Severity Level IV violation (Supplement I).

2. The requirements of 10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, l and Drawings," state, in part, that activities affecting quality shall be prescribed by I procedures of a type appropriate to the circumstances.

Point Beach Nuclear Plant Unit 1 and Unit 2 Facility Operating Licenses, Section 3.A, state that "The licensee is authorized to operate the facility at reactor core power levels not in excess of 1518.5 megawatts thermal [MWt)."

Contrary to the above, (a) as of February 26,1998, Unit 2 was operated at power, an activity affecting quality, using Operating Procedure (OP) 2A, " Normal Power Operation,"

Revision 28, a procedure inappropriate to the circumstances. Specifically, OP-2A l directed operators to maintain an eight hour average output of 1518 MWt in

! accordance with Reactor Engineering Instruction (REI) 1.0; however, the l instruction did not specifically preclude the operators from exceeding the 1518.5 l

MWt license limit while maintaining the 1518 MWt average power output.

(c) as of February 26,1998, Unit 2 was operated at power, an activity affecting

! quality, using the guidelines of REl 1.0, " Power Level Determination and i Guidelines," Revision 20, a procedure inappropriate to the circumstances.

Specifically, REl 1.0 directed that power be matched to a calculated target reactor thermal output which, by design of the computer based calculation that established the target, could be as high as 1521 MWt.

This is a Severity Level IV violation (Supplement 1).

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3. The requirements of 10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, 1 and Drawings," state, in part, that activit;es affecting quality shall be prescribed by l l procedures of a type appropriate to the circumstances, and shall be accomplished in

accordance with these procedures. l l Nuclear Power Business Unit Procedure 1.9.15, " Danger Tag Procedure," Revision 5, Step 5.1.10d, states that the individual that is signed on the Operating Permit Log shall obtain shift supervision authorization before operating equipment that is controlled by the l operating permit.

Contrary to the above, on February 13,1998, an individual that signed on to an Operating Permit Log, failed to obtain shift supervision authorization prior to operating a safety- ,

related Unit 2 containment fan cooler breaker controlled by the operating permit. j This is a Severity Level IV violation (Supplement 1).

The NRC has concluded that information regarding the reason for the three violations, the j corrective actions taken and planned to correct the violations, and the date when full compliance l will be achieved is already adequately addressed on the docket in the attached Inspection Report i No. 50-266/98003(DRP); 50-301/98003(DRP). This inspection report also provides sufficient information on actions to prevent recurrence of the third violation. Pursuant to the provisions of l 10 CFR 2.201, Wisconsin Electric is hereby required to submit a written statement or explanation I to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. ,

20555 with a copy to the Regional Administrator, Region Ill, and a copy to the NRC Resident '

inspector at the facility that is the subject of this Notice of Viols. tion (Notice), within 30 days of the date of the letter transmitting this Notice. This reply should be clearly marked as a " Reply to a Notice of Violation." The response to the first violation should address the corrective actions planned for ensuring that future safety-related maintenance activities are proscribed by appropriate procedures or documented instructions, and that proper control and accountability of nuclear grade materials and parts are maintained. The response to the second violation should address the corrective actions planned in the reactor engineering group to prevent recurrence of the development of inappropriate procedures. Your response may reference or include previous l docketed correspondence, if the correspondence adequately addresses the required response.

i 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 action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time. No response is required for the third violation. However, you are required to submit a written statement or exti!anation if the l discussion of the three violations contained in the attached inspection report does not accurately l

reflect your corrective actions or your position.

l if you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

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Notice of Violation i Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information, if you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at Lisle, Illinois this 21 day of March 1998 l

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