Point Beach Summary
As discussed at the April 2003 Agency Action Review Meeting (AARM), NRC staff decided to conduct its inspection, following Inspection Procedure 95003 (Issue Date: 01/17/02), "Supplemental Inspection for Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones, Multiple Yellow Inputs, or One Red Input," at Point Beach Nuclear Power Station to determine the breadth and depth of the licensee's performance deficiencies. NRC will conduct this inspection in addition to the baseline inspections already scheduled.
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First Auxiliary Feedwater Issue
Licensee Report. On November 29, 2001, the licensee reported to the NRC the potential for a common mode failure of the auxiliary feedwater (AFW) system pumps caused by inadequate operator actions in response to a loss of instrument air.
NRC Inspections and Action. For this issue, NRC staff conducted a Special Inspection from December 3, 2001, through February 28, 2002, documented in Inspection Report 50-266/01-17(DRS); 50-301/01-17(DRS). Inspectors identified that procedures for the reactor operators were inadequate and had been for many years and that the licensee had seven prior opportunities to identify these inadequacies. Failure to provide adequate procedures and failure to take appropriate corrective actions are both violations of NRC regulatory requirements. In accordance with NRC's Significance Determination Process, NRC preliminarily determined that these violations constituted an issue with high safety significance (that is, a Red finding). The issue has high significance because a common mode failure of AFW system pumps would substantially reduce the operators' capability for safely shutting down the plant in response to certain accidents.
On July 12, 2002, the NRC determined that the potential for a common mode failure of the AFW system pumps caused by a loss of instrument air was a Red finding.
Licensee Corrective Action. The licensee took prompt corrective actions to revise procedures and train operators to address the immediate safety concerns associated with the issue. Additionally, the licensee installed additional equipment to improve the safety of the AFW system design.
Second Auxiliary Feedwater Issue
Licensee Report. On October 29, 2002, the licensee notified the NRC of a potential for a common mode failure of the AFW system pumps from the plugging by debris of the pressure reduction orifices in the AFW system recirculation lines.
NRC Inspections and Action. NRC conducted a second special inspection from October 31, 2002, through March 24, 2003, documented in Inspection Report 50-266/02-15(DRP); 50-301/02-15(DRP).
During development of modification packages in 1999, the licensee recognized the potential for these orifices to plug. However, because of the lack of full understanding of the AFW system design basis, the licensee installed the orifices. NRC found that in late 2001 and early 2002, the previous AFW system issue, associated with instrument air, presented an opportunity for the licensee 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, the licensee had an independent laboratory conduct tests that demonstrated that the orifices would quickly plug when subjected to water-borne debris similar to that found in the licensee's service water system.
NRC determined that the finding of the orifice partially plugged for the "A" motor-driven AFW system pump on October 24, 2002, after post-maintenance testing of the pump was a preliminary Red finding which is pending final significance determination.
On December 11, 2003, the NRC determined that the potential for a common mode failure of the AFW system pumps caused by plugging of the orifices was a Red finding.
Performance Assessment Letters
2005 Performance Assessment Letter
On March 2, 2006, the NRC issued its Annual Assessment Letter to Point Beach. This letter summarized the NRC's assessment of Point Beach for 2005. Point Beach remained within the Multiple/Repetitive Degraded cornerstone of the Action Matrix based on the Red finding for Unit 1 and Unit 2 for the first AFW issue and the Yellow finding for Unit 1 and the Red finding for Unit 2 for the second AFW issue. Additionally, the NRC closed-out the substantive cross-cutting issues in the areas of human performance and problem identification and resolution
2004 Performance Assessment Letter
On March 2, 2005, the NRC issued its Annual Assessment Letter to Point Beach. This letter summarized the NRC's assessment of Point Beach for 2004. Point Beach remained within the Multiple/Repetitive Degraded cornerstone of the Action Matrix based on the Red finding for Unit 1 and Unit 2 for the first AFW issue and the Yellow finding for Unit 1 and the Red finding for Unit 2 for the second AFW issue. Additionally, the NRC again identified substantive cross-cutting issues in the areas of human performance and problem identification and resolution.
2003 Performance Assessment Letter
On March 4, 2004, the NRC issued its Annual Assessment Letter to Point Beach. This letter summarized the NRC's assessment of Point Beach performance during 2003. Point Beach remained within the Multiple/Repetitive Degraded cornerstone column of the Action Matrix based on the Red finding for Unit 1 and Unit 2 for the first AFW issue and the Yellow finding for Unit 1 and the Red finding for Unit 2 for the second AFW issue. Additionally, the NRC identified substantive cross-cutting issues in the areas of human performance and problem identification and resolution.
2002 Performance Assessment Letter
NRC Report. The licensee for the Point Beach Nuclear Station had a substantive crosscutting issue in the area of Problem Identification and Resolution.
NRC Inspections and Action. In the March 4, 2003, Annual Assessment Letter to the licensee for Point Beach Nuclear Station, the NRC documented this crosscutting issue with Problem Identification and Resolution. This was based on the White Findings, (indicated on the plant's Reactor Oversight Process matrix) for the Safety Injection pump failure, described in Inspection Report No. 50-266/02-03(DRP); 50-301/02-03(DRP) ), and deficiencies involving Emergency Preparedness, described in Inspection Report No. 50-266/02-04(DRS); 50-301/02-04(DRS)), in addition to four Green findings (see Inspection Manual Chapter 0305 (Issue Date: 12/21/04)). The four Green findings involved the flooding of manholes containing plant equipment, repeat problems with cold weather preparations, delayed maintenance rule action for the G05 gas turbine, and an inadequate extent of condition review when addressing a steam generator narrow range level detector problem. As a result of this final Red finding and the discussion at the AARM meeting, NRC will conduct its 95003 supplemental inspection.
95003 Inspection Report
The NRC Inspection Procedure 95003 supplemental inspection was conducted at Point Beach from late-July to mid-December 2003 to review the two AFW issues. It was conducted in three phases: corrective actions, emergency preparedness, and engineering; and involved inspectors from all four NRC Regional Offices and Headquarters. In general, the inspection identified 1) ineffective implementation of the corrective action program, 2) emergency preparedness program weaknesses, 3) engineering design control issues, and 4) operations/engineering interface issues. Specifically, 11 low-level Non-Cited Violations and 1 potential high-level violation were identified. The high-level violation involved unauthorized changes made by the licensee to its emergency preparedness emergency action level scheme. The results of the 95003 inspection are documented in Inspection Report 05000266/2003007; 05000301/2003007, dated February 4, 2004.
Predecisional Enforcement Conference
On January 13, 2004, the NRC conducted a predecisional enforcement conference with Point Beach to review the violation identified during the 95003 inspection involving the unauthorized changes to the emergency action level scheme. A summary of that conference was documented in a letter dated January 27, 2004. As a result of NRC deliberations on this issue, the NRC issued a Notice of Violation and proposed the imposition of a $60,000 civil penalty in a letter to the licensee, dated March 17, 2004.
Confirmatory Action Letter
To address the problems identified during the 95003 inspection and problems identified through self-assessments, the licensee committed to the NRC to complete specific individual steps and action plans in its overall performance improvement "Excellence Plan." These commitments were documented in a letter from the licensee to the NRC, dated March 22, 2004. The NRC then incorporated these commitments in a Confirmatory Action Letter that was issued to the licensee on April 21, 2004. Extra inspections and expanded routine baseline inspections will be conducted in 2004 and 2005 as part of the NRC's followup on how the licensee meets these commitments. The revised commitments were submitted in an updated Excelence Plan dated April 1, 2004.
Status of Confirmatory Action Letter
On September 6, 2005, the NRC issued a letter to Point Beach stating that Point Beach's completed actions in two of the five Areas of Regulatory Concern from the April 21, 2004, Confirmatory Action Letter were sufficient to warrant no further special review of these areas by the NRC. These areas were Engineering/Operations Interface and Emergency Preparedness. Further NRC reviews would continue of the remaining three areas: Human Performance, Engineering Design Control, and Corrective Action Program
Revision of the Confirmatory Action Letter
On April 14, 2006, the NRC issued a revision of the April 21, 2004, Confirmatory Action Letter. In this revision, the NRC stated that Point Beach's completed actions in two of the three remaining open Areas of Regulatory Concern were sufficient to warrant no further special review of these areas by the NRC. These areas were Human Performance and Corrective Action Program. Further NRC reviews would continue of the remaining area of Engineering Design Control.
Closure of the Confirmatory Action Letter
On November 30, 2006, the NRC closed the April 21, 2004, Confirmatory Action Letter. In this closure letter, the NRC stated that Point Beach had demonstrated a reasonable assurance of sustainability in the area of Engineering Design Control. In addition, the NRC concluded that the three Red inspection findings and one Yellow inspection finding related to the auxiliary feedwater system identified in 2003 would be closed after the 4th quarter of 2006. As a result, NRC oversight of Point Beach will be reduced from that of the Multiple/Repetitive Degraded Cornerstone (Column IV) of the NRC Action Matrix to a level consistent with the licensee's current performance, which at this time, is the Licensee Response Column (Column I).
Final Safety Analysis Report Update Apparent Violation
On November 21, 2006, the NRC issued an inspection report identifying an apparent violation from 1983 when the licensee did not update the Final Safety Analysis Report (FSAR) with the results of an analysis of a hypothetical drop of the reactor vessel head unto a reactor vessel loaded with fuel. This failure to update the FSAR was identified by NRC inspectors in early 2005 during a review of the licensee's preparations to replace the Unit 1 and Unit 2 reactor vessel heads. The licensee has since updated the FSAR and did institute administrative controls during the replacement of the vessel heads in 2005.
Emergency Action Level Civil Penalty
In a letter dated April 8, 2004, the licensee paid the emergency action level $60,000 civil penalty. As of January 16, 2004, the licensee had corrected the unauthorized changes. The licensee is also planning to revise and upgrade, later this year, the existing emergency action levels to a more current, NRC-approved industry scheme.
Emergency Preparedness Civil Penalty
In a letter dated December 16, 2005, the NRC proposed issuance of a civil penalty of $60,000 to Point Beach for an instance in August 2002 where two plant staff deliberately provided inaccurate information to the NRC about an emergency preparedness drill. Point Beach paid the civil penalty on January 13, 2006. The NRC did not consider the problem from 2002 indicative of current performance at Point Beach.
Meeting with the EDO
On February 20, 2004, the NRC's Executive Director for Operations (EDO) and other NRC representatives met with Point Beach management in Manitowoc, Wisconsin to discuss recent performance. A summary of this meeting was documented in a letter dated March 11, 2004.
Public Meeting on Safety Culture
On March 23, 2006, the NRC met with Point Beach at a public meeting to discuss actions being taken to address the results of a plant-wide safety culture survey conducted in late 2004. A brief summary of the meeting and the handouts provided by Point Beach staff are contained in a letter dated April 3, 2006.
Apparent Violation of Employee Protection Requirements
In a letter dated August 22, 2006, the NRC informed Point Beach that an NRC investigation had identified that a senior reactor operator was discrimination against, in part, by Point Beach management, for identifying in a corrective action program document potential technical specification violations. Because of this discrimination, the NRC has identified an apparent violation for which it will be making an enforcement decision.
Removal from the Multiple/Repetitive Degraded Cornerstone Column
On March 2, 2007, the NRC issued its Annual Assessment Letter for the Point Beach Nuclear Plant for 2006. This letter reasserts what was discussed in the November 30, 2006, letter to the licensee that sufficient, sustained improvement has been shown by the licensee. As a result, the NRC is closing out the one Yellow inspection finding and the three Red inspection findings related to the auxiliary feedwater system and is reducing NRC oversight from that of the Multiple/Repetitive Degraded Cornerstone column (Column IV) of the NRC Action Matrix to a level consistent with the licensee's current performance, the Licensee Response column (Column I).