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EA-99-002 - Point Beach 1 (Wisconsin
Electric Power Company)
April 28, 1999
EA 99-002
Mr. M. E. Reddemann
Site Vice President
Wisconsin Electric Power Company
Point Beach Nuclear Plant
6610 Nuclear Road
Two Rivers, WI 54241
SUBJECT: NOTICE OF VIOLATION (NRC SPECIAL INSPECTION
REPORT
50-266/99004(DRP))
Dear Mr. Reddemann:
This refers to the NRC inspection conducted from January 5 through February
22, 1999, at the Wisconsin Electric Power Company's (WEPCo), Point Beach
Unit 1 reactor facility. The inspection examined the circumstances associated
with the ice blockage of the minimum flow recirculation line for the two
safety injection (SI) pumps. The NRC discussed the results of this inspection
with Point Beach site managers on February 22, 1999, and issued the inspection
report on March 12, 1999. A predecisional enforcement conference was held
in the Region III office on March 26, 1999, to discuss the apparent violation
that the NRC identified during this inspection.
Based on information developed during the inspection and the information
WEPCo provided during the conference, the NRC determined that a violation
of NRC requirements occurred. The violation is cited in the enclosed Notice
of Violation. The circumstances surrounding the violation were described
in the subject inspection report, explained in Licensee Event Report 99001,
and discussed during the March 26, 1999, predecisional enforcement conference.
This violation occurred because the on-shift crew, the operations support
group, and the WEPCo site management team failed to acknowledge the validity
of the temperature alarm and appreciate the significance of low temperature
readings for the Unit 1 SI pumps' minimum flow line. The evaluation performed
by the on-shift crew subsequent to receiving the alarm resulted in the
conclusion that, despite sub-zero ambient temperatures, there was not
a freezing problem and the temperature alarm was bypassed. This conclusion
was based on the mild temperature of the refueling water storage tank
(RWST) and normal temperature indications elsewhere on the recirculation
line. However, this conclusion failed to consider known deficiencies with
the piping's heat tracing. In fact, the alarm functioned as designed by
warning operators of the impending freezing of a portion of the Unit 1
SI pumps' minimum flow line. Eventually the water in a portion of the
minimum flow line froze. This impacted the ability of the SI system to
operate using the designed flow paths as analyzed in the Updated Safety
Analysis Report (USAR).
The design function of the SI system is to add water to the reactor coolant
system during reactor coolant line breaks. The minimum flow line is designed
to prevent SI pump damage by ensuring adequate pump cooling during a limited
range of small to intermediate size reactor coolant system breaks. Without
sufficient cooling water flow, in these situations, disabling pump damage
could occur in a short time. A portion of the minimum flow line is located
in an area of the plant that has no area heating and can be exposed to
sub-zero temperatures. In addition, the freeze protection for this portion
of the minimum flow line was a single circuit of heat tracing and insulation.
The evaluation performed when the operators received the alarm was narrowly
focused since it failed to integrate the system function, the alarm, the
known deficiencies with the associated heat tracing, declining pipe temperature
readings, and existing weather conditions. Two weeks after the alarm was
received, an operating crew identified the frozen minimum flow line following
questions by the NRC resident inspectors. Upon discovery, the operating
crew declared the SI system inoperable assuming that the SI system could
not perform its function as analyzed in the USAR.
The NRC concluded that: (1) operations and engineering personnel identified
the frozen line as a result of questions from the NRC resident inspectors;
(2) the plant staff missed a potential opportunity to prevent this violation
when their corrective actions for a maintenance rule violation(1)
did not result in this section of heat tracing being included within the
scope of the maintenance rule; and (3) selected plant staff, during the
performance of a preventive maintenance activity at the start of the 1998/1999
winter season, identified a problem that went unresolved with the SI pump
minimum flow line heat tracing circuit. In addition, several nonsafety-related
components had frozen due to cold temperatures experienced during the
1998/1999 winter season. This provided ample opportunity for the plant
staff to do more in-depth reviews to confirm the condition of safety-related
components exposed to the elements. However, the plant staff did not perform
in-depth reviews until the NRC resident inspectors raised the issue.
During the predecisional enforcement conference, WEPCo demonstrated there
was minimal risk significance associated with the frozen piping. However,
this analysis relied upon fortuitous failures of safety related, low pressure
interfacing valves, creating significant external system leakage. This
portion of the system is normally vented to the atmosphere through the
RWST. In this situation, due to the ice blockage, the interfacing valves
would have been exposed to SI pump discharge pressure - well in excess
of their design pressure - deforming their diaphragm seals and creating
the necessary flow path for SI pump cooling. Although the resultant leakage
would not have created a radiation release path to the environment, this
situation is clearly undesirable and would have compounded operators'
response to an event requiring SI system operation.
The performance of the Point Beach staff before, during, and after they
received the temperature alarm, demonstrated a failure to control licensed
activities that had a significant, credible potential for impacting safety.
The fact that the SI pumps would have performed their safety function
was fortuitous and was not understood or expected at the time of the event.
If not for the failures of interfacing low pressure components, the SI
pumps likely would have sustained disabling damage had they been called
upon to operate. The underlying failure to correctly diagnose the cause
of the alarm and implement adequate corrective action for continuing problems
associated with the heat tracing systems, demonstrated a significant lack
of attention to licensed activities. This failure impacted the ability
of the SI system to perform as designed under certain circumstances. The
SI system was degraded to the extent that a detailed evaluation and testing
were required to determine if the system could perform its intended function.
Therefore, this violation has been categorized in accordance with NUREG-1600,
"General Statements of Policy and Procedure for NRC Enforcement Actions
(Enforcement Policy)," at Severity Level III.
In accordance with the Enforcement Policy, a base civil penalty of $55,000
was considered for this Severity Level III violation. Because the Point
Beach facility has not been the subject of escalated enforcement actions
within the last two years,(2) the NRC considered
whether credit was warranted for Corrective Action in accordance
with the civil penalty assessment process in Section VI.B.2 of the Enforcement
Policy. Corrective Action credit was warranted based on the significant
resources and management attention focused to resolve the frozen pipe
issue and to address facade freeze protection material condition discrepancies
since the event. Therefore, to acknowledge the corrective actions that
the licensee implemented and the management attention that the licensee
directed to ensure that the SI system was capable of performing its design
function under all circumstances, I have been authorized, after consultation
with the Director, Office of Enforcement, not to propose a civil penalty
in this case.
The NRC has concluded that information regarding the reason for this violation;
the corrective actions taken, planned to correct the violation, and prevent
recurrence; and the date when full compliance will be achieved is already
adequately addressed on the docket in Inspection Report 50-266/99004(DRP)
and Licensee Event Report 99001. Therefore, you are not required to respond
to this letter unless the description therein does not accurately reflect
your corrective actions or your position. In that case, or if you choose
to provide additional information, you should follow the instructions
specified in the enclosed Notice.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy
of this letter, its enclosure, and your response (if you choose to submit
one) will be placed in the NRC Public Document Room.
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Sincerely,
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Original Signed By
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James E. Dyer
Regional Administrator |
Docket No. 50-266
License No. DPR-24
Enclosure: Notice of Violation
cc w/encl:
R. Grigg, President and Chief Operating Officer, WEPCO
M. Sellman, Senior Vice President, Chief Nuclear Officer
R. Mende, Plant Manager
J. O'Neill, Jr., Shaw, Pittman, Potts & Trowbridge
K. Duveneck, Town Chairman, Town of Two Creeks
B. Burks, P.E., Director, Bureau of Field Operations
J. Mettner, Chairman, Wisconsin, Public Service Commission
S. Jenkins, Electric Division, Wisconsin Public Service Commission
State Liaison Officer
NOTICE OF VIOLATION
Wisconsin Electric Power Company Point
Point Beach Nuclear Plant
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Docket No. 50-266
License No. DPR-24
EA 99-002 |
During NRC inspections conducted from January 5 through February 22,
1999, a violation of NRC requirements was identified. In accordance with
the NUREG-1600, "General Statement of Policy and Procedure for NRC Enforcement
Actions," the violation is discussed below.
10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," requires,
in part, that measures shall be established to assure that conditions
adverse to quality are 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.
Contrary to the above, measures were not established to promptly correct
or determine the cause of a significant condition adverse to quality associated
with the Unit 1 safety injection pumps. Specifically, between December
22, 1998 and January 5, 1999, a low temperature condition with the potential
to cause freezing of the common minimum flow line was not identified nor
its cause determined. This was a significant condition adverse to quality
because freezing and blockage of the minimum flow line may have prevented
adequate cooling of the pumps causing pump failure during certain loss
of coolant accidents.
This is a Severity Level III violation (Supplement I).
The NRC has concluded that information regarding the reason for the violation,
the corrective actions taken and planned to correct the violation and
prevent recurrence and the date when full compliance will be achieved
is already adequately addressed on the docket in Inspection Report 50-266/99004(DRP)
and Licensee Event Report 99001. However, you are required to submit a
written statement or explanation pursuant to 10 CFR 2.201 if
the description therein does not accurately reflect your corrective actions
or your position. In that case, or if you choose to respond, clearly mark
your response as a "Reply to a Notice of Violation" and send it to the
U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington,
DC 20555, with a copy to the Regional Administrator, Region III, and a
copy to the NRC Resident Inspector, within 30 days of the date of the
letter transmitting this Notice of Violation.
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 State Nuclear Regulatory Commission, Washington,
DC 20555-0001.
If you choose to provide a response, it 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.
In accordance with 10 CFR 19.11, you may be required to post this Notice
within two working days.
Dated this 28th of April 1999
1. The December 1997 maintenance rule baseline inspection
(MRBI) identified a scoping violation (50-266/301/97025-01) when the licensee
failed to include the Facade Freeze Protection System within the scope
of the maintenance rule. WEPCo's corrective actions were narrowly focused
and resulted in the failure to include the SI minimum flow line freeze
protection in the maintenance rule. If WEPCo had pursued a comprehensive
resolution to the MRBI scoping violation, the events leading to the freezing
of the minimum flow line could have been averted.
2. Although a Notice of Violation was issued August
8, 1997, for Several Severity Level III problems involving the failure
to promptly identify and correct conditions adverse to quality (EA 97-075),
WEPCo implemented corrective actions for the majority of the violations
associated with EA 97-075 in December 1996. This places EA 97-075 outside
the two year period of consideration for this enforcement action.
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