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

                     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.

    Original Signed By
    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


Wisconsin Electric Power Company Point
Point Beach Nuclear Plant
  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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