ML20043A763

Responds to Notice of Violation & Forwards Civil Penalty in Amount of $87,000 for Violations Noted in Insp Repts 50-266/89-32,50-266/89-33,50-301/89-32 & 50-301/89-33. Addl Employees Added in QA & Corporate Nuclear Engineering

ML20043A763
Person / Time
Site:	Point Beach
Issue date:	05/15/1990
From:	Fay C WISCONSIN ELECTRIC POWER CO.
To:	NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-90-048, CON-NRC-90-48 VPNPD-90-232, NUDOCS 9005230092
Download: ML20043A763 (7)

Text

.-

.p,

.e- i

[*?'# 7' l'

Wisconsin Electnc -

POWER COMP)WY -

231 W M.Chort PO Ecx 2046. Mihuoukee. W L3201 (414)221 2345

.VPNPD-90-232 10 CFR 2.201 NRC-90-048 10 CFR 2.205  :

May 15, 1990 Reaistered Mail i

Director, Office of Enforcement U.-S. NUCLEAR REGULATORY COMMISSION Washington, D. C. 20555 Attention: Document Control Desk l' Mail Station P1-137 Gentlemen  :

I

-DOCKETS'50-266 AND 50-301 REPLY TO NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY NRC INSPECTION REPORTS 50-266-89032!

• 50-301/89032 AND 50-266/89033r50-301/89033 +

POINT BEACH NUCLEAR PLANT. UNITS 1 AND 2 By letter dated April 17, 1990, NRC provided a Notice of  !

Violation and Proposed Imposition of Civil Penalty for concerns identified during inspections conducted from November 7, 1989  ;

through January 18, 1990. In accordancexwith the provisions of 10 CFR'2.205, our check for $87,500 is enclosed. Our response to the Notice of Violation,-in accordance:with 10 CFR 2.201, is provided in the Attachment. We remain committed to the staffing increase as described to NRC infour meeting of February 20, 1990, and referenced in the. Notice of Violation. Other corrective; t actions, both completed and planned, are described in the Attachment.

Please contact us if you'have any questions concerning this response.

Very tru_ yours, ,

,/

C. W. ay -

Vice President J Nuclear-Power l

Attachments-(Check 766397) h $d gj .

-Copies to NRC Regional Administrator, Region III (

NRC Resident Inspector ,

9003230092 900515 "

PDR ADOCK 05000266 ,

lQ ' FDC i A saMM dHisma k'iav &&>o ,

I' 10 CFR 2.201 ATTACHMENT RESPONSE TO NRC NOTICE OF VIOLATION DATED APRIL 17. 1990 MISCONSIN ELECTRIC POWER COMPANY POINT BEACH NUCLEAR PLANT I. Admission of Notico of Violation By Notice of Violation dated April 17, 1990, the NRC cited Wisconsin Electric Power Company for failure to comply with E 10 CFR 50, Appendix D, Criterion XVI, Corrective Action, as )

l implemented by the Wisconsin Electric Power Company, Nuclear i

Power Department, Quality Assurance Manual, Sectis n 16.

I Criterion XVI and Section 16 require that measures be established to assure that conditions adverse to quality, '

such as failures, malfunctions, deficiencies, defective material and equipment, and non-conformances be promptly identified and corrected. The essence of the violation i

relates to the timeliness of~ closing self-identified items l on our own open-item lists. We admit the violation as

! stated in the subject NRC Notice.

L

-II. Reasons for the Violation l

The Point Beach Nuclear Plant is a turnkey plant designed in the late 1960's and in commercial operation since December >

1970. Over the years, Wisconsin Electric has been -

responsive to the changing regulatory environment, and many '

l hardware modifications and procedural changes have been incorporated into the design and operation of the Point i Beach Nuclear Plant. These changes included the extensive modifications and procedural revisions required by the NRC r Three Mile Island Action Plan and a major revision and '

update to our 10 CFR-50, Appendix B Quality Assurance Program during the mid-1980's. ,

Our responsiveness to the regulatory concerns continued in the later-1980's when we determined to build a plant-specific, two-unit simulator; began' evaluation of the need to add an additional diesel generator; identified the need '

to reconstitute the design basis of the plant and obtain as-built drawings; and continued to enhance our Quality Assurance Program. Recent changes to the latter resulted in lowering the threshold for the issuance of self-identified non-conformhnces, These changes encouraged our personnel to write non-conformance reports (NCR's). The resulting increase in NCR's, the performance of a self-initiated Safety System Functional Inspection (SSFI) of the emergency diesel generators and supporting systems in 1988, and self-

L t

L ,' '% .

Page 2 initiated vertical slice audits of the RHR system in 1988 and containment systems in 1989 contributed significantly to the large number of open items on our action lists. Our operating experience review program, which is effective in i evaluating INPO SOER's, SER's, and other industry disclosures, has also resulted in the generation of open items and corrective action requests (CAR's). ,

Although the process has not been well documented, initial assessment of open items by Department maragement provided '

basic prioritization for open items and identified those items of immediate safety significance. In general, identified items with immediate potential safety impacts are

• given the staff resources and attention necessary to promptly resolve the issue. Examples of such iscues from the past year include resolution of concerns with the diesel generator stack supports, the RHR relief valves, the DC breakers, boron dilution, sump pH, spray line orifices, and the 13.8 kV relay spurious operation.

Historically our regulatory responsiveness has not been limited by the availability of financial resources. At the same time, we adhered to the philosophy that a small but -

competent staff was in large part responsible for our successful past performance in both the regulatory and  ;

operational areas. For this reason, we have been slow to add staffing resources unless a clear and permanent need could be demonstrated. Notwithstanding this perspective, l l the senior management personnel of the Nuclear Power Department began to feel schedular pressure as the number of commitments began to overtake staff resources.

1 The list of open items of less immediacy has continued a slow increase. Due primarily to staff resource limitations, open items were sometimes.not closed out on the schedules initially projected when the' items-were first entered on our tracking lists, thus resulting in missed completion dates or

• l frequent rescheduling. Unlike our experience with the requirements resulting from Three Mile Island, our staff gradually found itself unable to keep up with its normally optimistic schedular projections. In summary, we failed to add to our small staff early enough to accommodate the large number of new commitments and our own dedication to identifying non-conformances, i In early December 1989, senior Nuclear Power Department management personnel asked for and received from the I

Company's Chairman and President a commitment to add substantial unbudgeted staff resources. This action, however, commenced too late to affect the results of the

's . i 1

Page 3 I

! i subject inspection which culminated in the Notice of "

l Violation.

III. Corrective Actions Airpadv Initiated or comoleted

1. Staffina Increast ,

As mentioned above, in early December 1989, a commitment was made by Wisconsin Electric to add substantial staff resources. In late January, the senior Nuclear Power Department management team met tc ,

define specific position additions required throughout  ;

the Department. In a general meeting with the NRC 1 a' staff on February 20, 1990, we indicated the i forthcoming addition of approximately fifty people. At ]

this time, the number of planned personnel additions is a '

sixty-eight, an increase in our staff size of about 16%. These staffing additions include additions to our l plant organization, the corporate nuclear engineering organizations, and the quality assurance organization. 1 We have begun the recruiting process to identify.

candidates to fill these newly created permanent staff positions. We expect the first of these new hires to ,

be added by July 1, 1990; approximately 50% of the positions to be filled by December 31, 1990; and essentially 100% by July 1, 1991.

2. Safety Evaluation Groun At the January staffing meeting of senior nuclear management personnel, the desirability of forming a  ;

Safety Evaluation Group (SEG) was also identified.  !

Although a detailed description of SEG duties and l responsibilities was not developed, the initial concept ,

of SEG activities included the performance of 50.59 reviews and the documented screening of open items to identify those of potential safety = significance. We expect the SEG to screen and prioritize open items and 6

to assure that items of possible safety significance l are being properly and promptly addressed. The responsibilities of the SEG will be complementary to the existing quality assurance program and will i significantly enhance our self-assessment capabilities and our corrective action program. Because of recruiting problems and reassignment difficulties, we L are scheduling the SEG to be operational by the end of 1 1990. In the interim, the focus of reducing action items has been assigned to an ad hos Action Team as described in Items 3 and IV.1, below. "

l o

. i Page 4-  ;

i

3. Action Team In response to executive directives to reduce open items, the formation of an Action Team was proposed on ,

January 15, 1990, approved on January 18, 1990, and implemented on January 26, 1990. The Action Team

• consisted of six members: two from the Quality ,

Assurance Section, one from Point Beach Operations, one i from Point Beach Maintenance, one from Nuclear Systems >

Engineering and Analysis, and one from Nuclear Plant i' Engineering and Regulation; thus representing all major divisions of the Nuclear Power Department. The Team's charter was to make a concentrated effort to review all '

the open items.on the Monthly Open Item Status Report (MOISR) and to close out as many as possible. (The MOISR includes open items from Non-Conformance Reports (NCR's), Audit Finding Reports (AFR's], and Corrective Action Requests (CAR's).) It was recognized that certain items could be closed'by determining a course -

of action (such as the issuance of a modification request, a drawing change notice, an engineering change request, or a request for change to the FSAR), in which '

case the actual work might not take place immediately. ->

To avoid losing sight or the importance of such items, a monitor list was created for future tracking of these resolved issues.

The Action Team has already achieved.a substantial amount since its inception. Of the 357 items on the MOISR as of January 24, 1990, 181 items (51%) were closed, including 35 (10%) that were able to be moved  :

l- to the monitor list by April 1, 1990. In their l reviews, the Action Team did not identify any items that required immediate attention or posed an-l operability concern.

IV. Corrective Actions Planned L

Further Action Team Resoonsibilities 1.

The Action Team has now been assigned to develop a more effective and uniform method of prioritizing our open item deficiencies. This process will include a better mechanism for documentation of the initial safety significance and operability assessments of open items.

The Action Team is expected to produce a prioritization procedure for preliminary application by June 1, 1990.

After approval and issuance of this prioritization procedure, the Action Team will apply the process to those items on our current MOISR. By July 1, 1990, the t

i

'Page 5 I o- open items on the MOISR will be identified with an  ;

appropriate priority listing. It is anticipated that '

the application of the priority procedure to the i initial MOISR listing may result in the need for  :

revisions to the procedure. These revisions will be ,

accommodated as required. At that time, the j prioritizing process will next be applied to the Commitment Tracking System (COMTAC) and the ,

Administrative Punchlist (APL). This effort will be  ;

completed by September 1,.1990. In summary, the Action Team will fulfill, on an interim basis, many of the i responsibilities eventually intended for the Safety Evaluation Group when staffed and operational. ,l

2. Quality Assurance Instruction Revision ,

Quality Assurance Instruction (QAI) 10.2 (formerly QAI i 7.1 as referenced in the Notice of Violation) is in the i process of being revised. This instruction defines the process used by the Quality Assurance Section to identify delinquent corrective actions (in response to Non-Conformance Reports, Audit Finding Reports, and  !

Corrective Action Requests) and to escalate the actions 7 to appropriate levels of management to effect their '

resolution. The revision will establish a graded escalation process consistent with the significance (priority) of each respective open item, i.e.,

delinquent top priority items will be escalated faster i L and to higher levels of management. The schedule for ,

completion of this action is dependent upon establisnment of the priority system. Consistent with that schedule, the revisions of QAI 18.2 should be ,

?

issued and implemented by July 1, 1990.

3. Consolidated Open Item Trackina higt ,

L "

! Presently our three open-item " work" lists, the APL, l the-MOISR, and COMTAC, are resident in separate

" INQUIRE"-based mainframe data bases. We have for some time been examining means to consolidate or interface these data bases such that we can effectively generate L a " Master" list. This will further aid in the ^ !:

[" prioritization and rescheduling of open item activities '

in the Nuclear Power Department and will eliminate duplication between lists. It will also permit the Department to better sort specific section or group- "

related lists and provide the individual group heads L and project managers with a single listing of the work ,

efforts dependent on their direction. Methods and l' procedures for controlling such a list are anticipated L to be developed by September 1, 1990. Integration of these procedures and controls into the existing data

. 1

4. $ $ '

+

l

)

Page 6 bases and the software development necessary to achieve )

a consolidated listing with suitable sorting '

capabilities is projected to be completed by the end of the year. Steps are now being taken to coordinate the ,

support required from our corporate Computer i Department.

V. Proiected Dates for como11ance l 1

We believe the corrective actions discussed herein will be effective in establishing better management of those-conditions identified as being adverse to quality within the 4 meaning of Criterion XVI to 10 CFR 50, Appendix B. We i anticipate we will be in full compliance with this concern by the end of 1990, except that not all staffing additions ,

will be completed until approximately mid-1991. In the i' event that open item resolution cannot be handled adequately by the interim Action Team, contractor assistance will be obtained, j

i t

i k

n