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EA-03-059 - Point Beach 1 & 2 (Nuclear Management Company, LLC)April 2, 2003 EA-02-031 Mr. Alfred J. Cayia
Dear Mr. Cayia: On March 24, 2003, the results of two special inspections at your Point Beach Nuclear Plant were discussed with you and members of your staff. The enclosed report presents the results of those inspections. The inspections were examinations of activities conducted under your license as they relate to safety and to compliance with the Commission's rules and regulations and with the conditions of your license. Within these areas, the inspections consisted of a selective review of procedures and representative records, observations of activities, and interviews with personnel. Initially, a special inspection was conducted September 23-26, 2002, to determine whether a Red inspection finding associated with the auxiliary feedwater (AFW) system should be treated as an old design issue as described in NRC Inspection Manual Chapter 0305, "Operating Reactor Assessment Program." This finding was discussed in NRC special Inspection Report 50-266/01-17(DRS); 50-301/01-17(DRS), dated April 3, 2002, and in the NRC's Final Significance Determination letter, dated July 12, 2002. On October 29, 2002, while the results of the September inspection were being reviewed by the NRC, you notified the NRC of a potential for a common mode failure of the AFW pumps from the plugging by debris of the pressure reduction orifices in the AFW recirculation lines. A second special inspection was subsequently conducted, beginning on October 31, 2002, to review the orifice plugging issue and its relation to the earlier Red inspection finding. Based upon the results of these inspections, we have concluded that the Red inspection finding, which involved the potential common mode failure of the AFW pumps due to inadequate operator response to a loss of instrument air (IA), will not be treated as an old design issue. As detailed in Section 6.06.a of Manual Chapter 0305, there are four criteria that must be met for the NRC to classify a problem as an old design issue and thus allow the NRC to not consider the finding in its assessment of Point Beach's overall performance. The inspections identified that the criterion pertaining to corrective action was not met in that the implementation of corrective action associated with your evaluation of the AFW/IA issue did not prevent recurrence of another, separate potential common mode failure of the AFW pumps. The failure to implement thorough and complete corrective actions became apparent during our review of the October 2002 AFW recirculation line orifice plugging issue and the identification of other problems related to AFW design. These problems included the use of a nonsafety-related power supply for relays associated with the proper operation of the AFW recirculation line air-operated flow control valves and the single electrical bus dependencies of three of the four recirculation line air-operated flow control valves and three of the four service water supply motor-operated valves. The failure to implement adequate corrective actions for the AFW/IA issue is a violation of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action." The other old design criterion that may not have been met pertained to the AFW/IA Red finding not being reflective of a current performance deficiency. From our inspections, we concluded that deficiencies in your engineering program that resulted in the AFW/IA issue were likely responsible for the recent problem with the AFW recirculation line orifices and other problems related to AFW design. Because the AFW/IA Red finding did not meet the criteria for consideration as an old design issue, Point Beach is in the Multiple/Repetitive Degraded Cornerstone Column of the Action Matrix of Manual Chapter 0305. Consequently, your plant will be discussed at the upcoming Agency Action Review Meeting. We will notify you via separate correspondence of any agency actions that result from that discussion and as specified in the Action Matrix. This report also discusses the potential plugging of the AFW pump recirculation line orifices during operation of AFW with service water. This issue appears to have high safety significance. During development of modification packages in 1999, your staff recognized the potential for these orifices to plug. However, because of the lack of understanding of AFW design basis, the orifices were installed. In late 2001 and early 2002, the AFW/IA issue presented an opportunity to correct this lack of understanding, but no action was taken until the orifice for the "A" motor-driven AFW pump was found partially plugged on October 24, 2002, after post-maintenance testing of the pump. In February 2003, testing conducted for you by an independent laboratory demonstrated that the orifices would quickly plug when subjected to water-borne debris similar to that found in your service water system. The installation of the orifices is an apparent violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control." This issue was assessed using the NRC's Significance Determination Process (SDP) and was preliminarily determined to be Red, an issue with high safety significance that may result in additional inspection. This issue is of high safety significance because a common mode failure of the AFW pumps would result in substantially reduced mitigation capability for safely shutting down the plant in response to certain accidents. The assumptions and results of our preliminary SDP analysis are in Section 3.4.B of the attached inspection report. Your immediate compensatory and corrective actions for the apparent violation were adequate. These actions included a revalidation of the design basis of the AFW system, and the revision of procedures and training of operators so that the AFW system could be operated during accidents without dependence on pump recirculation flow. The apparent violation 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. The current Enforcement Policy is included on the NRC's website at www.nrc.gov. Before the NRC makes a final decision on this matter, we are providing you an opportunity to request a Regulatory Conference where you would be able to provide your perspectives on the significance of the findings, the bases for your position, including any revised or new information associated with your risk analysis, and whether you agree with the apparent violation. If you choose to request a conference, it should be held within 30 days of the receipt of this letter and we encourage you to submit your evaluation and any differences with the NRC evaluations at least one week prior to the conference in an effort to make the conference more efficient and effective. If a conference is held, it will be open for public observation. The NRC will also issue a press release to announce the conference. If you decide to submit only a written response, such submittal should be sent to the NRC within 30 days of the receipt of this letter. Please contact Mr. Kenneth Riemer at (630) 829-9757 within seven days of the date of this letter to notify the NRC of your intentions. If we have not heard from you within 10 days, we will continue with our significance determination and enforcement decision and you will be advised by separate correspondence of the results of our deliberations on these matters. Since the NRC has not made a final determination in this matter, no Notice of Violation is being issued for the inspection finding related to design control at this time. In addition, please be advised that the number and characterization of apparent violations described in the enclosed inspection report may change as a result of further NRC review. The NRC has determined that the inadequate correction actions taken for the root cause of the AFW/IA issue is a violation of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," as cited in the enclosed Notice of Violation (Notice). This violation is associated with a previously identified Red finding (EA-02-031). The circumstances surrounding the violation are described in detail in the subject inspection report. You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In accordance with NRC Inspection Manual Chapter 0305, "Operating Reactor Assessment Program," Section 06.06.d, the original performance issue (AFW/IA Red finding, EA-02-031) will remain open and will not be removed from consideration in the assessment program until the corrective action violation has been corrected. Based on the results of these inspections, the NRC has also identified two issues that were evaluated under the risk Significance Determination Process as having very low risk significance (Green). The two findings also involved violations of NRC requirements; however, because the violations were non-willful and non-repetitive and because the findings were entered into your corrective action program, the NRC is treating these issues as Non-Cited Violations, in accordance with Section VI.A.1 of the NRC's Enforcement Policy. If you contest the violation in the Notice or the subject or severity of the Non-Cited Violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region III, 801 Warrenville Road, Lisle, IL 60532-4351; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Point Beach Nuclear Plant facility. In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, its enclosures, and your response will be available electronically for public inspection in the NRC Public Document Room or from the NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction.
Docket Nos. 50-266; 50-301 Enclosures:
cc w/encl: NOTICE OF VIOLATION
During two NRC inspections conducted between September 23, 2002, and March 24, 2003, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below: Criterion XVI, "Corrective Action," of 10 CFR Part 50, Appendix B, requires, in part, that conditions adverse to quality be promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. Contrary to the above, as of December 12, 2002, the licensee failed to implement corrective actions to preclude repetition of a significant condition adverse to quality associated with an AFW system potential common mode failure. Specifically, the licensee failed to identify potential common mode failures that existed involving power supplies to the recirculation line air-operated valve and other system components. In addition, the licensee's corrective actions for the potential common mode failure associated with a loss of instrument air did not preclude repetition. Specifically, the licensee's corrective actions, to upgrade the safety function of the air-operated recirculation valve, failed to ensure that successful operation of the recirculation line air-operated valve was dependent only on safety-related support systems. Following the corrective actions, successful operation of the valve was still dependent upon nonsafety-related power to an interposing relay. This violation is associated with a previously identified Red SDP finding (EA-02-031). Pursuant to the provisions of 10 CFR 2.201, Nuclear Management Company, LLC, is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555, with a copy to the Regional Administrator, Region 3, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation; EA-03-059" and should include: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. 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. If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001. Because your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public 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. In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days. Dated this 2nd day of April 2003 |
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