IR 05000266/2016003
| ML16300A397 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 10/26/2016 |
| From: | Jamnes Cameron Reactor Projects Region 3 Branch 4 |
| To: | Coffey R Point Beach |
| References | |
| IR 2016001, IR 2016003 | |
| Download: ML16300A397 (42) | |
Text
UNITED STATES tober 26, 2016
SUBJECT:
POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2NRC INTEGRATED INSPECTION REPORT 05000266/2016003; 05000301/2016003; 07200005/20160001
Dear Mr. Coffey:
On September 30, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Point Beach Nuclear Plant, Units 1 and 2. On October 4, 2016, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The enclosed report represents the results of this inspection.
The NRC inspectors did not identify any findings or violations of more than minor significance.
However, inspectors documented a licensee-identified violation which was determined to be Severity Level IV in this report. The NRC is treating this violation as non-cited violation (NCV)
consistent with Section 2.3.2.a of the Enforcement Policy.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records System (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Jamnes Cameron, Chief Branch 4 Division of Reactor Projects Docket Nos: 50-266; 50-301 License Nos: DPR-24; DPR-27
Enclosure:
IR 05000266/2016003; 05000301/2016003
REGION III==
Docket No: 50-266; 50-301;72-005 License No: DPR-24; DPR-27 Report No: 05000266/2016003; 05000301/2016003; 07200005/2016001 Licensee: NextEra Energy Point Beach, LLC Facility: Point Beach Nuclear Plant, Units 1 and 2 Location: Two Rivers, WI Dates: July 1 through September 30, 2016 Inspectors: K. Barclay, Acting Senior Resident Inspector J. Havertape, Acting Resident Inspector M. Learn, Reactor Engineer G. Edwards, Health Physicist Approved by: J. Cameron, Chief Branch 4 Division of Reactor Projects Enclosure
SUMMARY
Inspection Report 05000266/2016003, 05000301/2016003, 07200005/2016001; 07/01/2016 - 09/30/2016; Point Beach Nuclear Plant, Units 1 & 2, Integrated Report.
This report covers a 3-month period of inspection by resident inspectors; announced baseline inspections by regional inspectors; and an inspection by regional inspectors of operational activities associated with an Independent Spent Fuel Storage Installation (ISFSI) at the Point Beach Nuclear Plant. The significance of inspection findings is indicated by their color (i.e.,
greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process," dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310, "Aspects Within the Cross-Cutting Areas," dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated February 4, 2015. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," dated July 2016.
Licensee-Identified Findings A violation of very low safety significance identified by the licensee has been reviewed by the U.S. Nuclear Regulatory Commission (NRC). Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. This violation and corrective action program tracking numbers are listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status
Unit 1 The unit operated at or near full power for the inspection period, except for brief power reductions to conduct planned maintenance and surveillance activities.
Unit 2 The unit operated at or near full power for the inspection period, except for brief power reductions to conduct planned maintenance and surveillance activities.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R04 Equipment Alignment
.1 Quarterly Partial System Walkdowns
a. Inspection Scope
The inspectors performed partial system walkdowns of the following risk-significant systems:
- G-03 emergency diesel generator (EDG) with the G-01 EDG out of service; and
- 2P-53 motor driven auxiliary feedwater (AFW) pump with 1P-29 turbine driven AFW pump out of service.
The inspectors selected these systems based on their risk significance relative to the Reactor Safety Cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could impact the function of the system and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, FSAR, Technical Specification (TS) requirements, outstanding work orders (WOs), condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program (CAP) with the appropriate significance characterization.
Documents reviewed are listed in the Attachment to this report.
These activities constituted three partial system walkdown samples as defined in IP 71111.04-05.
b. Findings
No findings were identified.
1R05 Fire Protection
.1 Routine Resident Inspector Tours
a. Inspection Scope
The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:
- Fire Zone 166; motor control center room - 2B32;
- Fire Zone 237; component cooling water (CCW) heat exchanger room;
- Fire Zone 307; EDG Room - G02; and
- Fire Zone 308; EDG Room - G01.
The inspectors reviewed areas to assess if the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and implemented adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems, or features in accordance with the licensees fire plan.
The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plants ability to respond to a security event.
Using the documents listed in the Attachment to this report, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensees CAP.
Documents reviewed are listed in the Attachment to this report.
These activities constituted four quarterly fire protection inspection samples as defined in IP 71111.05-05.
b. Findings
No findings were identified.
1R06 Flooding
.1 Internal Flooding
a. Inspection Scope
The inspectors reviewed selected risk important plant design features and licensee procedures intended to protect the plant and its safety-related equipment from internal flooding events. The inspectors reviewed flood analyses and design documents, including the FSAR, engineering calculations, and abnormal operating procedures to identify licensee commitments. The specific documents reviewed are listed in the to this report. In addition, the inspectors reviewed licensee drawings to identify areas and equipment that may be affected by internal flooding caused by the failure or misalignment of nearby sources of water, such as the fire suppression or the circulating water systems. The inspectors also reviewed the licensees corrective action documents with respect to past flood-related items identified in the corrective action program to verify the adequacy of the corrective actions. The inspectors performed a walkdown of the following plant area(s) to assess the adequacy of watertight doors and verify drains and sumps were clear of debris and were operable, and that the licensee complied with its commitments:
- turbine building AFW pump room; and
Documents reviewed during this inspection are listed in the Attachment to this report.
This inspection constituted two internal flooding samples as defined in IP 71111.06-05.
b. Findings
No findings were identified.
1R07 Annual Heat Sink Performance
.1 Heat Sink Performance
a. Inspection Scope
The inspectors reviewed the licensees testing of the 1HX-12B CCW heat exchanger to verify that potential deficiencies did not mask the licensees ability to detect degraded performance, to identify any common cause issues that had the potential to increase risk, and to ensure that the licensee was adequately addressing problems that could result in initiating events that would cause an increase in risk. The inspectors reviewed the licensees observations as compared against acceptance criteria, the correlation of scheduled testing and the frequency of testing, and the impact of instrument inaccuracies on test results. Inspectors also verified that test acceptance criteria considered differences between test conditions, design conditions, and testing conditions. Documents reviewed for this inspection are listed in the Attachment to this document.
This annual heat sink performance inspection constituted one sample as defined in IP 71111.07-05.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Resident Inspector Quarterly Review of Licensed Operator Requalification
a. Inspection Scope
On August 29, 2016, the inspectors observed a crew of licensed operators in the plants simulator during licensed operator requalification training. The inspectors verified that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and that training was being conducted in accordance with licensees training scenario. The inspectors evaluated the following areas:
- licensed operator performance;
- crews clarity and formality of communications;
- ability to take timely actions in the conservative direction;
- prioritization, interpretation, and verification of annunciator alarms;
- correct use and implementation of abnormal and emergency procedures;
- control board manipulations;
- oversight and direction from supervisors; and
- ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications.
The crews performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one quarterly licensed operator requalification program simulator sample as defined in IP 71111.11-05.
b. Findings
No findings were identified.
.2 Resident Inspector Quarterly Observation During Periods of Heightened Activity or Risk
(71111.11Q)
a. Inspection Scope
On August 24, 2016, the inspectors observed the Unit 1 Control Room operating crew response during implementation of AOP-2B, Feedwater System Malfunction, following a steam generator level perturbation. This was an activity that required heightened awareness or was related to increased risk.
On September 13, 2016, the inspectors observed control room operations during main feedwater regulating valve control troubleshooting. This was an activity that required heightened awareness or was related to increased risk.
The inspectors evaluated the following areas:
- licensed operator performance;
- crews clarity and formality of communications;
- ability to take timely actions in the conservative direction;
- prioritization, interpretation, and verification of annunciator alarms (if applicable);
- correct use and implementation of procedures;
- control board (or equipment) manipulations;
- oversight and direction from supervisors; and
- ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications (if applicable).
The performance in these areas was compared to pre-established operator action expectations, procedural compliance and task completion requirements. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one quarterly licensed operator heightened activity/risk sample as defined in IP 71111.11-05.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
.1 Routine Quarterly Evaluations
a. Inspection Scope
The inspectors evaluated degraded performance issues involving the following risk-significant systems:
- K-3B service air compressor; and
- G-05 gas turbine.
The inspectors reviewed events such as where ineffective equipment maintenance had resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:
- implementing appropriate work practices;
- identifying and addressing common cause failures;
- scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule;
- characterizing system reliability issues for performance;
- charging unavailability for performance;
- trending key parameters for condition monitoring;
- ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and
- verifying appropriate performance criteria for structures, systems, and components (SSCs)/functions classified as (a)(2), or appropriate and adequate goals and corrective actions for systems classified as (a)(1).
The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report.
This inspection constituted two quarterly maintenance effectiveness samples as defined in IP 71111.12-05.
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
.1 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed the licensee's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:
- July 25; reactor protection system testing with K-3A station air compressor failure;
- August 11; K-3B station air compressor and 1DY-04 inverter OOS with turbine driven AFW suction trip testing in-progress;
- September 6; 1P-15 SI pump OOS with reactor protection and engineered safety features red channel testing in-progress and a National Weather Service flood watch in effect.
These activities were selected based on their potential risk significance relative to the Reactor Safety Cornerstones. As applicable for each activity, the inspectors verified that risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate and complete. When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.
Documents reviewed during this inspection are listed in the Attachment to this report.
These maintenance risk assessments and emergent work control activities constituted four samples as defined in IP 71111.13-05.
b. Findings
No findings were identified.
1R15 Operability Determinations and Functional Assessments
.1 Operability Evaluations
a. Inspection Scope
The inspectors reviewed the following issues:
- Unexpected feed regulating valve oscillations on Unit 1;
- Unit 2 2PT-449 pressurizer pressure transmitter drifting;
- AR 02150150; 1T-34A May Require Three Fills in August;
- AR 02152431; Red Tavg Channel (2T-401) on Unit 2 Noisy;
- AR 02154199; Corrosion on Cells 43, 51, 53, and 51 of D-105; and
- AR 02138501; Prompt Operability Determination for Reactor Protection System DANA Amplifier Electrolytic Capacitors.
The inspectors selected these potential operability issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS and FSAR to the licensees evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Documents reviewed are listed in the to this report.
This operability inspection constituted six samples as defined in IP 71111.15-05.
b. Findings
No findings were identified.
1R18 Plant Modifications
.1 Plant Modifications
a. Inspection Scope
The inspectors reviewed the following modification(s):
- EC 286161; 1MS-2017, HX-1B SG Header Main Steam Stop Control Valve Leak Sealant Repair; Revision 1; and
- EC 286224; 1MS-2017, HX-1B SG Header Main Steam Stop Control Valve Bearing Housing Flange Leak Enclosure; Revision 1.
The inspectors reviewed the configuration changes and associated 10 CFR 50.59 safety evaluation screening against the design basis, the FSAR, and the TS, as applicable, to verify that the modification did not affect the operability or availability of the affected system(s). The inspectors, as applicable, observed ongoing and completed work activities to ensure that the modifications were installed as directed and consistent with the design control documents; the modifications operated as expected; post-modification testing adequately demonstrated continued system operability, availability, and reliability; and that operation of the modifications did not impact the operability of any interfacing systems. As applicable, the inspectors verified that relevant procedure, design, and licensing documents were properly updated. Lastly, the inspectors discussed the plant modification with operations, engineering, and training personnel to ensure that the individuals were aware of how the operation with the plant modification in place could impact overall plant performance. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one temporary modification sample as defined in IP 71111.18-05.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
.1 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the following post-maintenance (PM) activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:
- 1DY-04 yellow channel inverter testing after maintenance;
- Unit 1 1P-2C coolant charging pump testing after internal check valve replacement and signal conditioner replacement;
- K-3A service air compressor testing after motor replacement;
- Unit 2 2P-2B coolant charging pump testing after maintenance; and
- 1SI-889B check valve testing after seat lapping.
These activities were selected based upon the structure, system, or component's ability to impact risk. The inspectors evaluated these activities for the following (as applicable):
the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as written in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing (temporary modifications or jumpers required for test performance were properly removed after test completion); and test documentation was properly evaluated. The inspectors evaluated the activities against TSs, the FSAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with post-maintenance tests to determine whether the licensee was identifying problems and entering them in the CAP and that the problems were being corrected commensurate with their importance to safety. Documents reviewed are listed in the Attachment to this report.
This inspection constituted six post-maintenance testing samples as defined in IP 71111.19-05.
b. Findings
No findings were identified.
1R22 Surveillance Testing
.1 Surveillance Testing
a. Inspection Scope
The inspectors reviewed the test results for the following activities to determine whether risk-significant systems and equipment were capable of performing their intended safety function and to verify testing was conducted in accordance with applicable procedural and TS requirements:
- TS-81; G-01 Emergency Diesel Generator Operability Test (Routine); and
The inspectors observed in-plant activities and reviewed procedures and associated records to determine the following:
- did preconditioning occur;
- the effects of the testing were adequately addressed by control room personnel or engineers prior to the commencement of the testing;
- acceptance criteria were clearly stated, demonstrated operational readiness, and were consistent with the system design basis;
- plant equipment calibration was correct, accurate, and properly documented;
- as-left setpoints were within required ranges; and the calibration frequency was in accordance with TSs, the FSAR, procedures, and applicable commitments;
- measuring and test equipment calibration was current;
- test equipment was used within the required range and accuracy; applicable prerequisites described in the test procedures were satisfied;
- test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; jumpers and lifted leads were controlled and restored where used;
- test data and results were accurate, complete, within limits, and valid;
- test equipment was removed after testing;
- where applicable for inservice testing activities, testing was performed in accordance with the applicable version of Section XI, American Society of Mechanical Engineers code, and reference values were consistent with the system design basis;
- where applicable, test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable;
- where applicable for safety-related instrument control surveillance tests, reference setting data were accurately incorporated in the test procedure;
- where applicable, actual conditions encountering high resistance electrical contacts were such that the intended safety function could still be accomplished;
- prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test;
- equipment was returned to a position or status required to support the performance of its safety functions; and
- all problems identified during the testing were appropriately documented and dispositioned in the CAP.
Documents reviewed are listed in the Attachment to this report.
This inspection constituted one routine surveillance testing samples and one in-service test sample as defined in IP 71111.22, Sections-02 and-05.
b. Findings
No findings were identified.
1EP6 Drill Evaluation
.1 Training Observation
a. Inspection Scope
The inspector observed a simulator training evolution for licensed operators on September 12, 2016, which required emergency plan implementation by a licensee operations crew. This evolution was planned to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the post-evolution critique for the scenario. The focus of the inspectors activities was to note any weaknesses and deficiencies in the crews performance and ensure that the licensee evaluators noted the same issues and entered them into the corrective action program. As part of the inspection, the inspectors reviewed the scenario package and other documents listed in the Attachment to this report.
This inspection of the licensees training evolution with emergency preparedness drill aspects constituted one sample as defined in IP 71114.06-06.
b. Findings
No findings were identified.
RADIATION SAFETY
2RS2 Occupational AS-Low-As-Reasonably-Achievable Planning and Controls
.1 Radiological Work Planning (02.02)
a. Inspection Scope
The inspectors selected three to five work activities of the highest exposure significance or involve work in high dose rate areas.
The inspectors reviewed the radiological work planning as-low-as-reasonably-achievable (ALARA) evaluations, initial and revised exposure estimates, and exposure mitigation requirements. The inspectors determined if the licensee had reasonably grouped the radiological work into work activities.
The inspectors assessed whether the licensees planning identified appropriate dose reduction techniques; appropriately considered alternate reduction features; and defined reasonable dose goals. The inspectors evaluated whether the licensees ALARA assessment had taken into account decreased worker efficiency from use of respiratory protective devices and/or heat stress mitigation equipment. The inspectors determined if the licensees work planning considered the use of remote technologies and dose reduction insights from industry and plant-specific operating experience. The inspectors assessed whether these ALARA requirements were integrated into work procedure and/or radiation work permit documents.
The inspectors compared the results achieved with the intended dose established in the ALARA planning. The inspectors compared the person-hour estimates provided by work groups to the radiation protection group with the actual work activity time results, and evaluated the accuracy of these time estimates. The inspectors evaluated the reasons for any inconsistencies between intended and actual work activity doses.
The inspectors evaluated whether post-job reviews were conducted to identify lessons learned and entered into the licensees Corrective Action Program.
These inspection activities supplemented those documented in Inspection Report (IR)05000266/2016001; 05000301/2016001 constituted one complete sample as defined in Inspection Procedure (IP) 71124.02-05.
b. Findings
No findings were identified.
.2 Verification of Dose Estimates and Exposure Tracking Systems (02.03)
a. Inspection Scope
The inspectors assessed whether the assumptions and basis for the current annual collective exposure estimate were reasonably accurate. The inspectors assessed source term reduction effectiveness and reviewed applicable procedures for estimating exposures from specific work activities.
The inspectors reviewed the assumptions and bases in ALARA work planning documents for selected activities and verified that the licensee has established measures to track, trend, and if necessary to reduce, occupational doses for ongoing work activities.
The inspectors determined whether a dose threshold criteria was established to prompt additional reviews and/or additional ALARA planning and controls and evaluated the licensees method of adjusting exposure estimates, or re-planning work, when unexpected changes in scope or emergent work were encountered. The inspectors determined if adjustments to exposure estimates were based on sound radiation protection and ALARA principles or if they are just adjusted to account for failures to control the work. The inspectors evaluated whether there was sufficient station management review and approval of adjustments to exposure estimates and that the reasons for the adjustments were justifiable.
The inspectors reviewed selected occasions with inconsistent or incongruent results from the licensees intended radiological outcomes to determine whether the cause was attributed to a failure to adequately plan work activities, or failure to provide sufficient management oversight of in-plant work activities, or failure to conduct the work activity without significant rework, or failure to implement radiological controls as planned.
These inspection activities supplemented those documented in IR 05000266/2016001; 05000301/2016001 and constituted one complete sample as defined in IP 71124.02-05.
b. Findings
No findings were identified.
.3 Problem Identification and Resolution (02.06)
a. Inspection Scope
The inspectors reviewed self-assessments and/or audits performed of the ALARA Program and determined if these reviews identified problems or areas for improvement.
The inspectors assessed whether problems associated with ALARA planning and controls were being identified by the licensee at an appropriate threshold and properly addressed for resolution.
These inspection activities supplemented those documented in IR 05000266/2016001; 05000301/2016001 and constituted one complete sample as defined in IP 71124.02-05.
b. Findings
No findings were identified.
2RS6 Radioactive Gaseous and Liquid Effluent Treatment
.1 Walkdowns and Observations (02.02)
a. Inspection Scope
The inspectors walked down select effluent radiation monitoring systems to evaluate whether the monitor configurations aligned with Offsite Dose Calculation Manual (ODCM)descriptions and to observe the materiel condition of the systems.
The inspectors walked down selected components of the gaseous and liquid discharge systems to evaluate whether equipment configuration and flow paths align with plant documentation and to assess equipment materiel condition. The inspectors also assessed whether there were potential unmonitored release points, building alterations which could impact effluent controls, and ventilation system leakage that communicated directly with the environment.
For equipment or areas associated with the systems selected for review that were not readily accessible, the inspectors reviewed the licensee's materiel condition surveillance records.
The inspectors walked down filtered ventilation systems to assess for conditions such as degraded high-efficiency particulate air/charcoal banks, improper alignment, or system installation issues that would impact the performance or the effluent monitoring capability of the effluent system.
As available, the inspectors observed selected portions of the routine processing and discharge of radioactive gaseous effluent to evaluate whether appropriate treatment equipment was used and the processing activities aligned with discharge permits.
The inspectors determined if the licensee has made significant changes to their effluent release points.
As available, the inspectors observed selected portions of the routine processing and discharging of liquid waste to determine if appropriate effluent treatment equipment was being used and that radioactive liquid waste was being processed and discharged in accordance with procedure requirements and aligned with discharge permits.
These inspection activities constituted one complete sample as defined in Inspection Procedure (IP) 71124.06-05.
b. Findings
No findings were identified.
.2 Calibration and Testing Program (02.03)
a. Inspection Scope
The inspectors reviewed calibration and functional tests for select effluent monitors to evaluate whether they were performed consistent with the ODCM. The inspectors assessed whether National Institute of Standards and Technology traceable sources were used, primary calibration represented the plant nuclide mix, secondary calibrations verified the primary calibration, and calibration encompassed the alarm set points.
The inspectors assessed whether effluent monitor alarm set points were established as provided in the ODCM and procedures.
The inspectors evaluated the basis for changes to effluent monitor alarm set points.
These inspection activities constituted one complete sample as defined in IP 71124.06-05.
b. Findings
No findings were identified.
.3 Sampling and Analyses (02.04)
a. Inspection Scope
The inspectors reviewed select effluent sampling activities and assessed whether adequate controls had been implemented to ensure representative samples were obtained.
The inspectors reviewed select effluent discharges made with inoperable effluent radiation monitors and assess whether controls were in place to ensure compensatory sampling was performed consistent with the ODCM and that those controls were adequate to prevent the release of unmonitored effluents.
The inspectors determined whether the facility was routinely relying on the use of compensatory sampling in lieu of adequate system maintenance.
The inspectors reviewed the results of the Inter-Laboratory Comparison Program to evaluate the quality of the radioactive effluent sample analyses and assessed whether the Inter-Laboratory Comparison Program included hard-to-detect isotopes as appropriate.
These inspection activities constituted one complete sample as defined in IP 71124.06-05.
b. Findings
No findings were identified.
.4 Instrumentation and Equipment (02.05)
a. Inspection Scope
The inspectors reviewed the methodology used to determine the effluent stack and vent flow rates to determine if the flow rates were consistent with plant documentation, and that differences between assumed and actual stack and vent flow rates did not affect the results of the projected public doses.
The inspectors assessed whether surveillance test results for Technical Specification required ventilation effluent discharge systems met Technical Specification acceptance criteria.
The inspectors assessed calibration and availability for select effluent monitors used for triggering emergency action levels or for determining protective action recommendations.
These inspection activities constituted one complete sample as defined in IP 71124.06-05.
b. Findings
No findings were identified.
.5 Dose Calculations (02.06)
a. Inspection Scope
The inspectors reviewed significant changes in reported dose values compared to the previous Radiological Effluent Release Report to evaluate the factors which may have resulted in the change.
The inspectors reviewed radioactive liquid and gaseous waste discharge permits to assess whether the projected doses to members of the public were accurate.
Inspectors evaluated the isotopes that are included in the source term to assess whether analysis methods were sufficient to satisfy detectability standards. The review included the current Part 61 analyses to ensure hard-to-detect radionuclides are included in the source term.
The inspectors reviewed changes in the licensees offsite dose calculations to evaluate whether changes were consistent with the ODCM and Regulatory Guide 1.109. Inspectors reviewed meteorological dispersion and deposition factors used in the ODCM and effluent dose calculations to evaluate whether appropriate factors were being used for public dose calculations.
The inspectors reviewed the latest Land Use Census to assess whether changes have been factored into the dose calculations.
For select radioactive waste discharges, the inspectors evaluated whether the calculated doses where within the Title 10 of the Code of Federal Regulations, Part 50, Appendix I, and Technical Specification dose criteria.
The inspectors reviewed select records of abnormal radioactive waste discharges to ensure the discharge was monitored by the discharge point effluent monitor. Discharges made with inoperable effluent radiation monitors, or unmonitored leakages were reviewed to ensure that an evaluation was made to account for the source term and projected doses to the public.
These inspection activities constituted one complete sample as defined in IP 71124.06-05.
b. Findings
No findings were identified.
.6 Problem Identification and Resolution (02.07)
a. Inspection Scope
Inspectors assessed whether problems associated with the Effluent Monitoring and Control Program were being identified by the licensee at an appropriate threshold and were properly addressed for resolution. In addition, they evaluated the appropriateness of the corrective actions for a selected sample of problems documented by the licensee involving radiation monitoring and exposure controls.
These inspection activities constituted one complete sample as defined in IP 71124.06-05.
b. Findings
No findings were identified.
OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security
4OA1 Performance Indicator Verification
.1 Safety System Functional Failures
a. Inspection Scope
The inspectors sampled licensee submittals for the safety system functional failures performance indicator for Units 1 and 2 for the period from the fourth quarter of 2015 to the second quarter of 2016. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 31, 2013, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73" definitions and guidance, were used. The inspectors reviewed the licensees operator narrative logs, operability assessments, maintenance rule records, condition reports, event reports and NRC Integrated Inspection Reports for the period of October 2015 through June 2016 to validate the accuracy of the submittals.
The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report.
This inspection constituted two safety system functional failure samples as defined in IP 71151-05.
b. Findings
No findings were identified.
.2 Reactor Coolant System Specific Activity
a. Inspection Scope
The inspectors sampled licensee submittals for the reactor coolant system specific activity Performance Indicator (PI) for Point Beach Nuclear Plant, Units 1 and 2, for the period from the third quarter 2015 through the second quarter 2016. The inspectors used PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 2013, to determine the accuracy of the PI data reported during those periods. The inspectors reviewed the licensees reactor coolant system chemistry samples, technical specification requirements, issue reports, event reports and U.S. Nuclear Regulatory Commission Integrated IRs to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. In addition to record reviews, the inspectors observed a chemistry technician obtain and analyze a reactor coolant system sample. Documents reviewed are listed in the Attachment to this report.
This inspection constituted two reactor coolant system specific activity samples as defined in IP 71151-05.
b. Findings
No findings were identified.
.3 Occupational Exposure Control Effectiveness
a. Inspection Scope
The inspectors sampled licensee submittals for the Occupational Exposure Control Effectiveness PI for the period from the third quarter 2015 through the second quarter 2016. The inspectors used PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 2013, to determine the accuracy of the PI data reported during those periods. The inspectors reviewed the licensees assessment of the PI for occupational radiation safety to determine if the indicator related data was adequately assessed and reported. To assess the adequacy of the licensees PI data collection and analyses, the inspectors discussed with radiation protection staff the scope and breadth of its data review and the results of those reviews. The inspectors independently reviewed electronic personal dosimetry dose rate and accumulated dose alarms and dose reports and the dose assignments for any intakes that occurred during the time period reviewed to determine if there were potentially unrecognized occurrences. The inspectors also conducted walkdowns of numerous locked high and very-high radiation area entrances to determine the adequacy of the controls in place for these areas.
Documents reviewed are listed in the Attachment to this report.
This inspection constituted one occupational exposure control effectiveness sample as defined in IP 71151-05.
b. Findings
No findings were identified.
.4 Radiological Effluent Technical Specification/Offsite Dose Calculation Manual
Radiological Effluent Occurrences
a. Inspection Scope
The inspectors sampled licensee submittals for the Radiological Effluent Technical Specification/Offsite Dose Calculation Manual radiological effluent occurrences PI for the period from the third quarter 2015 through the second quarter 2016. The inspectors used PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 2013, to determine the accuracy of the PI data reported during those periods. The inspectors reviewed the licensees issue report database and selected individual reports generated since this indicator was last reviewed to identify any potential occurrences such as unmonitored, uncontrolled, or improperly calculated effluent releases that may have impacted offsite dose. The inspectors reviewed gaseous effluent summary data and the results of associated offsite dose calculations for selected dates to determine if indicator results were accurately reported. The inspectors also reviewed the licensees methods for quantifying gaseous and liquid effluents and determining effluent dose. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one radiological effluent technical specification/offsite dose calculation manual radiological effluent occurrences sample as defined in IP 71151-05.
b. Findings
No findings were identified.
4OA2 Identification and Resolution of Problems
.1 Routine Review of Items Entered into the Corrective Action Program
a. Inspection Scope
As discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify they were being entered into the licensees corrective action program at an appropriate threshold, adequate attention was being given to timely corrective actions, and adverse trends were identified and addressed. Some minor issues were entered into the licensees corrective action program as a result of the inspectors observations; however, they not discussed in this report.
These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure they were considered an integral part of the inspections performed during the quarter.
b. Findings
No findings were identified.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion
.1 (Closed) Licensee Event Report 05000266/2016-02-00: Operation or Condition
Prohibited by Technical Specifications On April 2, 2016, at 2:29 a.m., Unit 1 entered Mode 4 from Mode 5 without satisfying all of Technical Specification 3.6.6 Containment Spray and Cooling System Limiting Conditions for Operation as required by LCO Applicability 3.0.4. The licensee recognized the error and, at 3:08 a.m., the affected control switches for the two containment accident recirculation fans were positioned to auto, which restored operability and met the conditions for LCO 3.6.6.
Corrective actions for the event included the immediate restoration of operability for the containment accident recirculation fans, as well as, planned training for operations crews that will cover command and control, implementation of technical specifications, operating experience of the event, and revision to the cold to hot shutdown procedure.
The licensee reported this event in accordance with 10 CFR 50.73(a)(2)(i)(B) for an operation or condition prohibited by technical specifications. One finding of very low safety significance (Green) and associated NCV of Technical Specification 3.0.4 was identified and previously documented in Inspection Report 05000266/2016002; 05000301/2016002, Section 1R20 Outage Activities, (ADAMS No. ML16214A128).
Documents reviewed are listed in the Attachment to this report. This licensee event report (LER) is closed.
.2 (Closed) Licensee Event Report 05000266/2016-03-00: Operation or Condition
Prohibited by Technical Specifications On April 1, 2016, the Unit 1 345/13.8kV high voltage station transformer (1X-03) tripped on a differential current relay actuation when the licensee attempted to start a reactor coolant pump motor. An automatic bus transfer occurred, as designed, which maintained power to the Unit 1 4.16kV safeguards buses. The licensee found that a wiring error, which had occurred in April 2013, caused the relay to actuate at values below its design setpoint.
Corrective actions for the event included the immediate restoration of equipment affected by the transformer lockout; correction of the differential relay wiring error; and planned training for contractors on the proper use of plant processes for lifting and landing wires or leads on equipment.
The licensee reported this event in accordance with 10 CFR 50.73(a)(2)(i)(B) for an operation or condition prohibited by technical specifications. The licensees evaluation identified that there were three instances over the past three years were the required action completion time for LCO 3.8.1 (AC Sources - Operating) or LCO 3.8.2 ( AC Sources - Shutdown) would have been exceeded with the wiring error present. One finding of very low safety significance (Green) and associated NCVs of Technical Specification 3.8.1 and 3.8.2 were identified and previously documented in Inspection Report 05000266/2016002; 05000301/2016002, Section 1R20 Outage Activities.
Documents reviewed are listed in the Attachment to this report. This LER is closed.
4OA5 Other Activities
.1 Operation of an ISFSI at Operating Plants (60855.1)
a. Inspection Scope
The inspectors reviewed documents, interviewed plant personnel, and performed in-field observations to assess the licensees performance as it relates to the operation of the ISFSI. The inspectors evaluated whether changes made to the programs and procedures since the last inspection were consistent with the license or Certificate of Compliance, and did not reduce the effectiveness of the program. The inspectors also reviewed whether changes were evaluated in accordance with the requirements stated in 10 CFR 72.212(b), 10 CFR 50.59, and 10 CFR 72.48. The inspectors independently assessed whether dry cask storage activities were performed in a safe manner and in compliance with approved procedures. The inspectors verified that the licensee has identified each fuel assembly placed in the ISFSI, has recorded the parameters and characteristics of each fuel assembly, and has maintained a record of each fuel assembly as a controlled document.
Specifically, the inspectors observed the licensee perform the following activities:
remove the transfer cask containing the canister from the spent fuel pool; remove water from the canister; decontaminate the cask; closure weld and non-destructively test the canister; vacuum dry the canister; helium backfill the canister; place the transfer cask on the transfer trailer; move the transfer trailer from the Fuel Handling Building to the ISFSI, and transfer the canister from the transfer cask to the Horizontal Storage Module. The inspectors also reviewed the following documents: periodic radiological surveys, environmental monitoring reports that demonstrate radiological conditions were in accordance with the Technical Specifications and 10 CFR 72.104 limits, and records of fuel assemblies and physical inventories.
A review of corrective action reports written since the last ISFSI inspection indicated that the licensee was effectively identifying and correcting conditions adverse to quality.
b. Findings
No findings were identified.
4OA6 Management Meetings
.1 Exit Meeting Summary
On October 4, 2016, the inspectors presented the inspection results to Mr. R. Coffey, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.
.2 Interim Exit Meetings
Interim exits were conducted for:
- The inspection results for the Radiation Safety Program review with Mr. R. Coffey, Site Vice President, on August 12, 2016, and Mr. D. DeBoer, Plant Manager, on September 15, 2016;
- The inspection results for the ISFSI Program review were held with Mr. R. Coffey, Site Vice President on August 4, 2016, and Mr. R. Clark on September 21, 2016.
The inspectors presented the inspection results to members of the licensee management and staff. Licensee personnel acknowledged the information presented.
The inspectors confirmed that none of the potential report input discussed was considered proprietary. Proprietary material received during the inspection was returned to the licensee.
4OA7 Licensee-Identified Violations
The following violation of very low significance (Severity Level IV) was identified by the licensee and is a violation of NRC requirements; it meets the criteria of the NRC Enforcement Policy for being dispositioned as a non-cited violation.
- The licensee identified a non-cited violation of very low safety significance of 10 CFR 72.150,Instructions, Procedures, and Drawings. Title 10 CFR 72.150, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality be prescribed by documented procedures of a type appropriate to the circumstances and be accomplished in accordance with these procedures.
The licensee established PBF-5101, Fuel/Insert/Component Movement Authorization, Revision 17, as the implementing procedure for dry fuel storage fuel loading, an activity affecting quality. Procedure PBF-5101 contains instructions for fuel handlers to move specific fuel assemblies from specific spent fuel pool locations into specific dry shielded canisters (DSCs) and DSC locations.
Contrary to the above, on July 18, 2016, the licensee failed to follow PBF-5101.
Specifically, the licensee was utilizing a PBF-5101 labeled for DSC-25 during the loading of DSC-24. This resulted in three fuel assemblies being incorrectly loaded into DSC-24. The license entered the issue into its corrective action program under AR 02144237, dated July 18, 2016, and initiated actions to perform an apparent causal evaluation. The inspectors identified that DSC-24 and DSC-25 have identical design characteristics and therefore there was no actual safety significance to this event.
Consistent with the guidance in Section 2.2 of the NRC Enforcement Policy, ISFSIs are not subject to the Significance Determination Process and, thus, traditional enforcement will be used for this issue. However, the inspectors determined that the violation significance could be informed by the significance determination process as no similar violations existed in the enforcement policy violations examples. The inspectors determined that the violation could be evaluated using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A, Exhibit 3, Barrier Integrity Screening Questions. This resulted in the violation screening as Severity Level IV.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- R. Coffey, Site Vice President
- D. DeBoer, Plant General Manager
- S. Aerts, Performance Improvement Manager
- A. Bussiere, Information Technology Project Manager
- R. Clark, Licensing Engineer
- J. Gerondale, Security Supervisor
- B. Gierach, Information Technology Manager
- J. Golding, Inspection Lean and System Engineering Supervisor
- B. Griffin, Communications Specialist
- A. Gustafson, Operations Training General Supervisor
- D. Halverson, Information Technology Specialist
- R. Harrsch, Engineering Director
R. Hastings Operations Assistant Manager
- R. Higgins, Operations Assistant Manager
- K. Johansen, ODCM Specialist
- K. Locke, Licensing Engineer
- S. Manthei, Licensing Engineer
- M. Millen, Senior Project Manager
- C. Neuser, Site Engineering Manager
- J. Ramski, Outage Manager
- E. Schmidt, Site Engineering Manager
- T. Schneider, Senior Engineer
- R. Seizert, Emergency Preparedness Manager
- G. Strharsky, Site Quality Manager
- R. Webber, Site Operations Director
- R. Welty, Radiation Protection Manager
- P. Wild, Site Engineering Manager
- J. Wilson, Site Maintenance Director
- B. Woyak, Licensing Manager
U.S. Nuclear Regulatory Commission
- J. Cameron, Chief, Reactor Projects Branch 4
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Closed
- 05000266/2016-002-00 LER Unit 1 Operation or Condition Prohibited by Technical Specifications (Section 4OA3.1)
- 05000266/2016-003-00 LER Unit 1 Operation or Condition Prohibited by Technical Specifications (Section 4OA3.2)