IR 05000266/2017002
| ML17220A082 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 08/07/2017 |
| From: | Jamnes Cameron Reactor Projects Region 3 Branch 4 |
| To: | Coffey R Point Beach |
| References | |
| IR 2017002 | |
| Download: ML17220A082 (38) | |
Text
UNITED STATES ust 7, 2017
SUBJECT:
POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2NRC INTEGRATED INSPECTION REPORT 05000266/2017002 AND 05000301/2017002
Dear Mr. Coffey:
On June 30, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Point Beach Nuclear Plant, Units 1 and 2. On July 11, 2017, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
Based on the results of this inspection, the NRC identified one issue that was evaluated under the risk significance determination process as having very low safety significance (Green). The finding did not involve a violation of NRC requirements.
If you disagree with a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC resident inspector at the Point Beach Nuclear Plant. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exceptions, Requests for Withholding.
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 05000266/2017002; 05000301/2017002 cc: Distribution via LISTSERV
SUMMARY
Inspection Report 05000266/2017002, 05000301/2017002; 04/01/2017 - 06/30/2017;
Point Beach Nuclear Plant, Units 1 & 2; Maintenance Effectiveness.
This report covers a 3-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. One Green finding was identified by the inspectors. 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 U.S. Nuclear Regulatory Commission (NRC) requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated November 1, 2016.
The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 6.
Cornerstone: Mitigating Systems
- Green.
A finding of very low safety significance was self-revealed for the failure to follow program description PI-AA-102, Operating Experience Program, Revision 3.
Specifically, the licensee failed to evaluate operating experience that applied to Point Beach that identified the potential for cable connectors to disconnect due to machine vibration. PI-AA-102, Section 5, Instructions, Step 5.1(3), Screening Operating Experience Items, states, If the initial screening indicates potential applicability to a NextEra Energy nuclear plant, program (including corporate administered programs),
policy, process, or procedure; then an evaluation is conducted. Subsequently, a disconnected magnetic speed sensor cable on the G-04 emergency diesel generator caused a failure during a surveillance run attempt. The licensees short-term corrective actions included reconnecting the G-04 emergency diesel generator (EDG) magnetic speed senor cable and installing lock-wire to prevent the connector from unintentionally disconnecting. The licensees long-term corrective actions included changing their maintenance procedures to check connector tightness on the diesels periodically.
The inspectors determined that the failure to evaluate the external operating experience was contrary to licensee program description PI-AA-102 and was a performance deficiency. The finding was determined to be more than minor because the failure to evaluate operating experience was associated with the Mitigating Systems cornerstone attribute of Equipment Reliability and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). The inspectors applied IMC 0609, Attachment 4, Initial Characterization of Findings, issued October 7, 2016, to this finding. The inspectors answered Yes to question A within Table 3, Significance Determination Process Appendix Router, and transitioned to IMC 0609, Appendix G, Attachment 1, Shutdown Operations Significance Determination Process Phase 1 Initial Screening and Characterization of Findings, dated May 9, 2014. The inspectors referenced Exhibit 3Mitigating Systems Screening Questions. The finding screened as of very low safety significance (Green)because the inspectors answered No to the screening questions. The inspectors did not identify a cross-cutting aspect. The cause of the finding occurred in 2012 and was not reflective of present performance. (Section 1R12.1)
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 began the inspection period shutdown for the planned refueling outage U2R35, which began during the previous quarter on March 18, 2107. The unit was started up on April 12, 2017, achieved full power on April 23, 2017, and remained at full power throughout the remainder of the inspection period.
REACTOR SAFETY
Cornerstone: Initiating Events, Mitigating Systems, Barrier Integrity, and
1R01 Adverse Weather Protection
.1 Readiness of Offsite and Alternate Alternating Current Power Systems
a. Inspection Scope
The inspectors verified that plant features and procedures for operation and continued availability of offsite and alternate alternating current (AC) power systems during adverse weather were appropriate. The inspectors reviewed the licensees procedures affecting these areas and the communications protocols between the transmission system operator (TSO) and the plant to verify that the appropriate information was being exchanged when issues arose that could impact the offsite power system. Examples of aspects considered in the inspectors review included:
- coordination between the TSO and the plant during off-normal or emergency events;
- explanations for the events;
- estimates of when the offsite power system would be returned to a normal state; and
- notifications from the TSO to the plant when the offsite power system was returned to normal.
The inspectors also verified that plant procedures addressed measures to monitor and maintain availability and reliability of both the offsite AC power system and the onsite alternate AC power system prior to or during adverse weather conditions. Specifically, the inspectors verified that the procedures addressed the following:
- actions to be taken when notified by the TSO that the post-trip voltage of the offsite power system at the plant would not be acceptable to assure the continued operation of the safety-related loads without transferring to the onsite power supply;
- compensatory actions identified to be performed if it would not be possible to predict the post-trip voltage at the plant for the current grid conditions;
- re-assessment of plant risk based on maintenance activities which could affect grid reliability, or the ability of the transmission system to provide offsite power; and
- communications between the plant and the TSO when changes at the plant could impact the transmission system, or when the capability of the transmission system to provide adequate offsite power was challenged.
Documents reviewed are listed in the Attachment to this report. The inspectors also reviewed corrective action program (CAP) items to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into their CAP in accordance with station corrective action procedures.
This inspection constituted one readiness of offsite and alternate AC power systems sample as defined in Inspection Procedure (IP) 71111.01-05.
b. Findings
No findings were identified.
1R04 Equipment Alignment
.1 Quarterly Partial System Walkdowns
a. Inspection Scope
The inspectors performed partial system walkdowns of the following risk-significant systems:
- Unit 2 A train residual heat removal system;
- G-04 emergency diesel generator; and
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, Final Safety Analysis Report (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.
.2 Semi-Annual Complete System Walkdown
a. Inspection Scope
The inspectors performed a complete system alignment inspection of the service water system to verify the functional capability of the system. This system was selected because it was considered both safety significant and risk significant in the licensees probabilistic risk assessment. The inspectors walked down the system to review mechanical and electrical equipment lineups; electrical power availability; system pressure and temperature indications, as appropriate; component labeling; component lubrication; component and equipment cooling; hangers and supports; operability of support systems; and to ensure that ancillary equipment or debris did not interfere with equipment operation. A review of a sample of past and outstanding work orders (WOs)was performed to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the corrective action program (CAP)database to ensure that system equipment alignment problems were being identified and appropriately resolved. Documents reviewed are listed in the Attachment to this report.
These activities constituted one complete system walkdown sample 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 775: G-04 emergency diesel generator room;
- Fire Zone 776: G-04 fuel oil day tank and transfer pumps room;
- Fire Zone 238: gas stripper equipment room;
- Fire Zone 272: Unit 1 HVAC fan room; and
- Fire Zone 142: component cooling water pump room.
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 five quarterly fire protection inspection samples as defined in IP 71111.05-05.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Resident Inspector Quarterly Review of Licensed Operator Requalification
a. Inspection Scope
On May 22, 2017, 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 licensee procedures. 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
a. Inspection Scope
On April 12-13, 2017, the inspectors observed the reactor startup for Unit 2 from refueling outage 2R35. 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;
- 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.
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 G-04 emergency diesel generator, a risk-significant system.
The inspectors 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 one quarterly maintenance effectiveness sample as defined in IP 71111.12-05.
b. Findings
- (1) Failure to Evaluate Operating Experience
Introduction:
A finding of very low safety significance was self-revealed for the failure to follow program description PI-AA-102, Operating Experience Program, Revision 3.
Specifically, the licensee failed to evaluate operating experience that applied to Point Beach that identified the potential for cable connectors to disconnect due to machine vibration. PI-AA-102, Section 5, Instructions, Step 5.1(3), Screening Operating Experience Items, states, If the initial screening indicates potential applicability to a NextEra Energy nuclear plant, program (including corporate administered programs),policy, process, or procedure; then an evaluation is conducted.
Description:
On March 29, 2017, the G-04 emergency diesel generator (EDG), failed to reach its rated speed while attempting to start. The licensee found that the diesels magnetic speed sensor was disconnected, which prevented the diesel from achieving its rated speed and would have prevented its generator breaker from closing and loading the EDG. The licensee, after confirming that the symptoms observed during the start attempt were consistent with the loss of speed sensor, reconnected the cables threaded connection to the magnetic speed sensor. The diesel operated properly after the restoration of the cable connection.
The licensee performed an equipment apparent cause evaluation of the EDG failure and concluded that the long-term vibration of the diesel generator likely caused the disconnected magnetic pickup. The licensees corrective actions included applying lock-wire to the connections and adding a requirement to inspect the connection every two years. The evaluation found the preventative maintenance implementation attribute unsatisfactory, stating that external operating experience from a similar EDG failure in 2011 was not incorporated. It further stated that incorporation of the operating experience (OE) would have initiated an action to check the tightness of the connectors periodically.
The associated maintenance rule functional failure evaluation also identified that the safety-related preventative maintenance procedures for the EDGs were inconsistent.
The procedures for the G-01/G-02 EDGs required the magnetic pickup mounting hardware and cable connections checked for tightness every two years. The same procedures for the G-03/G-04 EDGs did not have that requirement. The extent-of-condition walkdown performed by the licensee found that the connectors on the G-01 and G-02 EDGs were tight and the connectors on the G-03 EDG were lock-wired. The G-04 EDG had a different style connector that was not designed with a lock-wire feature. Ultimately, the G-04 EDG did not get checked for tightness by preventative maintenance and also did not have lock-wire to prevent the connection from vibrating loose over long-term operation.
The inspectors performed a historical review of the licensees corrective action program and found the operating experience screening meeting notes from January 17, 2012. At that meeting, the licensee screened the 2011 EDG external operating experience. The OE described the failure of an emergency diesel generator to start when the speed pickup sensor cable connector disconnected as the result of long-term vibration. The licensee dispositioned the operating experience as preliminary and did not evaluate the operating experience. The licensee could not find any additional screening or evaluation of that operating experience. The inspectors found that the lessons learned described in the preliminary operating experience included a discussion that adding lock-wire to the connectors would prevent the connectors from disconnecting. Additionally, the OE described the corrective actions of the originating licensee as walking down all of their EDGs and inspection the connections for integrity and tightness.
The inspectors reviewed the licensees initial assessment of the issue, which concluded that the failure occurred when the EDG failed to start and operability prior to that time did not need to be evaluated. Based on the vibration failure mechanism, the inspectors disagreed with the licensees conclusions and discussed their concerns with the licensee. The inspectors believed that if the EDG had started prior to the failure, the connector could have fallen off during that starting sequence, or if the EDG had reached rated speed and subsequently loaded, the connector could have fallen off while operating. The licensee agreed with the inspectors perspective and performed a formal past operability assessment, which concluded that the G-04 EDG would have failed to start from March 26 through March 29. The G-04 EDGs last successful start was on March 20, and the licensee had maintained the G-04 EDG out-of-service from March 20 through March 26 for an unrelated issue. The licensee also assessed the period prior to March 20, which considered the failure of the magnetic speed sensor during EDG operation. The failure of the sensor during EDG operation would not have caused the diesel stop or fail; however, two of its three radiator fans would stop running. The loss of the two radiators would have led to a high temperature alarm on the EDG and alerted operators to the stopped fans. The licensee concluded that enough time was available for operators to implement their alarm response procedures and start the two fans in manual prior to the EDG reaching a temperature that could affect continued operation.
The inspectors reviewed the licenses heat-up calculations and independently determined that enough time was available for the licensee to respond to the high temperature alarm and restart the radiator fans in manual.
Analysis:
The inspectors determined that the failure to evaluate the 2011 EDG external operating experience was contrary to licensee program description PI-AA-102 and was a performance deficiency. The finding was determined to be more than minor because the failure to evaluate operating experience was associated with the Mitigating Systems cornerstone attribute of Equipment Reliability and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). The inspectors applied Inspection Manual Chapter (IMC) 0609, Attachment 4, Initial Characterization of Findings, issued October 7, 2016, to this finding. The inspectors answered Yes to question A within Table 3, Significance Determination Process Appendix Router, and transitioned to IMC 0609, Appendix G, Attachment 1, Shutdown Operations Significance Determination Process Phase 1 Initial Screening and Characterization of Findings, dated May 9, 2014. The inspectors referenced Exhibit 3Mitigating Systems Screening Questions. The finding screened as of very low safety significance (Green) because the inspectors answered No to the screening questions. The inspectors did not identify a cross-cutting aspect. The cause of the finding occurred in 2012 and was not reflective of present performance.
Enforcement:
No violation of regulatory requirements are associated with this finding (FIN 05000266/2017002-01; 05000301/2017002-01, Failure to Evaluate Operating Experience).
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:
- March 31; yellow risk with Unit 1 480-Volt safeguards bus out-of-service;
- May 30; maintenance activities on 1DY-04 yellow inverter; and
- week of May 15; maintenance activities on G-05 gas turbine in excess of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
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 three 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:
- loose instrument line in containment;
- relay for turbine overspeed protection found not installed;
- G-04 switchgear room fan suction damper does not fully open;
- D-05 and D-06 battery room halon systems nonconformance;
- GKT ground fault relays installed in 4160-volt safeguards switchgear found not seismically qualified; and
- G-04 EDG governor tuning did not meet design calculation criteria.
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 Final Safety Analysis Report (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 Attachment to this report.
These operability determination and/or functionality assessment inspections 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:
- EC 288890; 2AF-61D Drain Line Extension; Revision 0 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. 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 activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:
- G-04 EDG testing after governor tuning;
- G-05 gas turbine after 10-year inspection; and
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 Nuclear Regulatory Commission (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.
These inspections constituted four post-maintenance testing samples as defined in IP 71111.19-05.
b. Findings
No findings were identified.
1R20 Outage Activities
.1 Refueling Outage Activities
a. Inspection Scope
The inspectors reviewed the Outage Safety Plan (OSP) and contingency plans for the Unit 2 refueling outage (RFO), conducted March 18 to April 12, 2017, to confirm that the licensee had appropriately considered risk, industry experience, and previous site-specific problems in developing and implementing a plan that assured maintenance of defense-in-depth. During the RFO, the inspectors observed portions of the shutdown and cooldown processes and monitored licensee controls over the outage activities listed below:
- licensee configuration management, including maintenance of defense-in-depth commensurate with the OSP for key safety functions and compliance with the applicable TS when taking equipment out of service;
- implementation of clearance activities and confirmation that tags were properly hung and equipment appropriately configured to safely support the work or testing;
- installation and configuration of reactor coolant pressure, level, and temperature instruments to provide accurate indication, accounting for instrument error;
- controls over the status and configuration of electrical systems to ensure that TS and OSP requirements were met, and controls over switchyard activities;
- monitoring of decay heat removal processes, systems, and components;
- controls to ensure that outage work was not impacting the ability of the operators to operate the spent fuel pool cooling system;
- reactor water inventory controls including flow paths, configurations, and alternative means for inventory addition, and controls to prevent inventory loss;
- controls over activities that could affect reactivity;
- maintenance of secondary containment as required by TS;
- licensee fatigue management, as required by 10 CFR 26, Subpart I;
- refueling activities, including fuel handling;
- startup and ascension to full power operation, tracking of startup prerequisites, walkdown of the drywell (primary containment) to verify that debris had not been left which could block emergency core cooling system suction strainers, and reactor physics testing; and
- licensee identification and resolution of problems related to RFO activities.
Documents reviewed are listed in the Attachment to this report.
This inspection, and the partial inspection results documented in inspection report 05000266/2017001; 05000301/2017001, constituted one refueling outage sample as defined in IP 71111.20-05.
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:
- Unit 1 reactor protection and safeguards containment pressure calibration (routine);
- ORT 3B; safety injection actuation with loss of engineered safeguards alternating current (AC) (Train B) Unit 2 (routine); and
- IT 09A; cold start of turbine-driven auxiliary feed pump and valve test Unit 2 (inservice testing).
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.
These inspections constituted two routine surveillance testing samples and one inservice 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 inspectors observed a simulator training evolution for licensed operators on May 22, 2017, that 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 71114.06-05.
b. Findings
No findings were identified.
RADIATION SAFETY
2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and
Transportation (71124.08)
.1 Radioactive Material Storage (02.02)
a. Inspection Scope
The inspectors selected areas where containers of radioactive waste are stored, and evaluated whether the containers were labeled in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 20.1904, or controlled in accordance with 10 CFR 20.1905.
The inspectors assessed whether the radioactive material storage areas were controlled and posted in accordance with the requirements of 10 CFR Part 20. For materials stored or used in the controlled or unrestricted areas, the inspectors evaluated whether they were secured against unauthorized removal and controlled in accordance with 10 CFR 20.1801 and 10 CFR 20.1802.
The inspectors evaluated whether the licensee established a process for monitoring the impact of low-level radioactive waste storage that was sufficient to identify potential unmonitored, unplanned releases or nonconformance with waste disposal requirements.
The inspectors evaluated the licensees program for container inventories and inspections. The inspectors selected containers of stored radioactive material, and assessed for signs of swelling, leakage, and deformation.
These inspection activities constituted one complete sample as defined in Inspection Procedure (IP) 71124.0-05.
b. Findings
No findings were identified.
.2 Radioactive Waste System Walk-Down (02.03)
a. Inspection Scope
The inspectors walked down accessible portions of select radioactive waste processing systems to assess whether the current system configuration and operation agreed with the descriptions in plant and/or vendor manuals.
The inspectors reviewed administrative and/or physical controls to assess whether equipment, which is not in service or abandoned in place would not contribute to an unmonitored release path and/or affect operating systems or be a source of unnecessary personnel exposure. The inspectors assessed whether the licensee reviewed the safety significance of systems and equipment abandoned in place in accordance with 10 CFR 50.59.
The inspectors reviewed the adequacy of changes made to the radioactive waste processing systems since the last inspection. The inspectors evaluated whether changes from what is described in the Final Safety Analysis Report were reviewed and documented in accordance with 10 CFR 50.59 or that changes to vendor equipment were made in accordance with vendor manuals. The inspectors also assessed the impact of these changes on radiation doses to occupational workers and members of the public.
The inspectors selected processes for transferring radioactive waste resin and/or sludge discharges into shipping/disposal containers and assessed whether the waste stream mixing, sampling, and waste concentration averaging were consistent with the process control program, and provided representative samples of the waste product for the purposes of waste classification.
The inspectors evaluated whether tank recirculation procedures provided sufficient mixing.
The inspectors assessed whether the licensees process control program correctly described the current methods and procedures for dewatering and waste stabilization.
These inspection activities constituted one complete sample as defined in IP 71124.08-05.
b. Findings
No findings were identified.
.3 Waste Characterization and Classification (02.04)
a. Inspection Scope
For select waste streams, the inspectors assessed whether the licensees radiochemical sample analysis results were sufficient to support radioactive waste characterization as required by 10 CFR Part 61. The inspectors evaluated whether the licensees use of scaling factors and calculations to account for difficult-to-measure radionuclides was technically sound and based on current 10 CFR Part 61 analysis.
The inspectors evaluated whether changes to plant operational parameters were taken into account to:
- (1) maintain the validity of the waste stream composition data between the sample analysis update; and
- (2) assure that waste shipments continued to meet the requirements of 10 CFR Part 61.
The inspectors evaluated whether the licensee had established and maintained an adequate quality assurance program to ensure compliance with the waste classification and characterization requirements of 10 CFR 61.55 and 10 CFR 61.56.
These inspection activities constituted one complete sample as defined in IP 71124.08-05.
b. Findings
No findings were identified.
.4 Shipment Preparation (02.05)
a. Inspection Scope
The inspectors reviewed the technical instructions presented to workers during routine training. The inspectors assessed whether the licensees training program provided training to personnel responsible for the conduct of radioactive waste processing and radioactive material shipment preparation activities. The inspectors assessed whether shippers were knowledgeable of the shipping regulations and demonstrated adequate skills to accomplish package preparation requirements. The inspectors evaluated whether the licensee was maintaining shipping procedures in accordance with current regulations. The inspectors assessed whether the licensee was meeting the expectations in U.S. Nuclear Regulatory Commission (NRC)Bulletin 79-19, Packaging of Low-Level Radioactive Waste for Transport and Burial, and 49 CFR Part 172, Subpart H, Training.
The inspectors evaluated whether the requirements for Type B shipment Certificates of Compliance had been met. The inspectors determined whether the user was a registered package user and had an NRC-approved quality assurance program. The inspectors assessed whether procedures for cask loading and closure were consistent with vendor procedures.
The inspectors assessed whether non-Type B shipments were made in accordance with the package quality documents.
The inspectors assessed whether the receiving licensee was authorized to receive the shipment packages.
These inspection activities constituted one complete sample as defined in IP 71124.0-05.
b. Findings
No findings were identified.
.5 Shipping Records (02.06)
a. Inspection Scope
The inspectors reviewed select shipments to evaluate whether the shipping documents indicated the proper shipper name; emergency response information and a 24-hour contact telephone number; accurate curie content and volume of material; and appropriate waste classification, transport index, and UN number. The inspectors assessed whether the shipment marking, labeling, and placarding was consistent with the information in the shipping documentation.
These inspection activities constituted one complete sample as defined in IP 71124.08-05.
b. Findings
No findings were identified.
.6 Identification and Resolution of Problems (02.07)
a. Inspection Scope
The inspectors assessed whether problems associated with radioactive waste processing, handling, storage, and transportation, were being identified by the licensee at an appropriate threshold, were properly characterized, and were properly addressed for resolution. Additionally, the inspectors evaluated whether the corrective actions were appropriate for a selected sample of problems documented by the licensee that involve radioactive waste processing, handling, storage, and transportation.
These inspection activities constituted one complete sample as defined in IP 71124.08-05.
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 (PI) Point Beach Nuclear Plant, Units 1 and 2 for the period from the third quarter of 2016 through the first quarter of 2017. 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, maintenance work orders, CAP documents, event reports and NRC Integrated Inspection Reports for the period of July 2016 through March 2017 to validate the accuracy of the submittals. The inspectors also reviewed the licensees CAP 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.
These inspections constituted two safety system functional failures samples as defined in IP 71151-05.
b. Findings
No findings were identified.
.2 Reactor Coolant System Leakage
a. Inspection Scope
The inspectors sampled licensee submittals for the Reactor Coolant System (RCS)
Leakage performance indicator for Point Beach Nuclear Plant, Units 1 and 2 for the period beginning second quarter 2016 through the first quarter 2017. 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, were used. The inspectors reviewed the licensees operator logs, RCS leakage tracking data, CAP documents, event reports and NRC Integrated Inspection Reports for the period of April 2016 through March 2017 to validate the accuracy of the submittals. The inspectors also reviewed the licensees CAP 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.
These inspections constituted two reactor coolant system leakage samples 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 are 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.
.2 Semi-Annual Trend Review
a. Inspection Scope
The inspectors performed a review of the licensees corrective action program and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors review was focused on repetitive equipment issues, but also considered the results of daily inspector corrective action program item screening discussed in Section 4OA2.1 above, licensee trending efforts, and licensee human performance results. The inspectors review nominally considered the 6-month period of November 2016 through April 2017 although some examples expanded beyond those dates where the scope of the trend warranted.
The review also included issues documented outside the corrective action program in major equipment problem lists, repetitive and/or rework maintenance lists, departmental problem/challenges lists, system health reports, self-assessment reports, and NRC Integrated Inspection Reports. The inspectors compared and contrasted their results with the results contained in the licensees corrective action program trending reports.
Corrective actions associated with a sample of the issues identified in the licensees trending reports were reviewed for adequacy.
This review constituted one semi-annual trend review inspection sample as defined in IP 71152.
b. Findings
No findings were identified.
c. Observations:
Fuel Handling The inspectors performed a semiannual review to identify licensee trends. As part of the trend review, inspectors assessed a potential trend related to the licensees fuel handling practices and human performance errors. The inspectors had previously assessed this area during the 2nd quarter 2016 semiannual trend review after multiple fuel handling errors were identified by both the licensee and inspectors. This current review timeframe exceeded the typical six month interval based on the low frequency of fuel movements, therefore, the inspectors included the last three significant fuel move opportunities in the trend review. The three most significant fuel movement windows were the 2016 Unit 1 refueling outage, the 2016 dry fuel storage campaign, and the 2017 Unit 2 refueling outage. The inspectors trend review found:
- During fuel moves associated with the 2016 Unit 1 spring outage, the NRC identified that the licensee failed to follow their fuel move planning procedure and placed a spent fuel assembly that had a cooling time of less than 295 days into a spent fuel rack foot location. This issue was determined to be a finding and is discussed in Section 1R20.1 of NRC Integrated Inspection Report 05000266/2016002; 05000301/2016002. The licensees corrective actions included completing additional fuel moves, which placed the fuel assembly into an appropriate configuration.
- During fuel moves associated with the 2016 dry fuel storage campaign, the licensee incorrectly loaded a dry shielded canister (DSC) using a fuel movement authorization designated for a different DSC. Three fuel assemblies were loaded into the incorrect DSC before the licensee identified it. This issue was determined to be a violation of NRC requirements and is discussed in Section 4OA7 of NRC Integrated Inspection Report 05000266/2016003; 05000301/2016003; 07200005/2016001. The licensee returned the three fuel assemblies to the spent fuel pool.
- During fuel moves associated with the 2017 Unit 2 refueling outage, the licensee latched and raised an incorrect fuel assembly. Specifically, while unloading the core, the licensee raised the fuel assembly located at core location L-6 instead of the fuel assembly located at core location L-7. The licensee received an overload alarm while moving the fuel assembly because the fuel manipulator settings were not set for a fuel assembly that contained the additional weight of a control rod. Fuel handlers stopped fuel movement when the error was recognized. The licensee completed their process for modifying the fuel move authorization sheets and placed the fuel assembly into its appropriate location in the spent fuel pool. The licensees causal evaluation found that multiple human performance barriers failed and the errors involved personnel from both operations and reactor engineering. The failed barriers included oversight, procedure use and adherence, place keeping, and peer checking. The inspectors assessed the issue and concluded that a violation of 10 CFR Part 50, Appendix B, Criterion V, Procedures occurred for the licensees failure to follow procedure radiation protection (RP) 1C, Refueling. The inspectors determined that the performance deficiency associated with the violation was minor because the fuel assembly was moved a short distance before the error was identified and it was not placed into an incorrect location in the spent fuel pool.
The licensee had previously performed a condition evaluation in August 2016 to evaluate a potential adverse trend in fuel handling. The evaluation concluded that an adverse trend existed in fuel handling and was related to procedures, guidance documents, and human performance. The procedure and guidance issues identified in the condition evaluation were assigned procedure change requests. The human performance challenges were described as attention to detail, coordination of simultaneous activities, and oversight/field presence. The condition evaluation stated that the human performance aspects were corrected by reinforcing expectations for roles and responsibilities and the use of human performance tools. The licensee performed a follow-on apparent cause evaluation of the adverse trend, which identified the apparent cause as proficiency with fuel handling oversight and practical performance with existing equipment/tools had diminished with time. The primary corrective action to resolve the apparent cause was to add fuel handling just-in-time training, which included practice for the fuel handers in the spent fuel pool with the training mock fuel assembly.
Overall, the inspectors observed that the number of low level fuel handling issues decreased in the 2017 Unit 2 outage. However, as evidenced by the number of human performance barriers that failed while moving the wrong fuel assembly, it appears that the human performance challenges identified in the licensees 2016 condition evaluation may not have been corrected by the licensees efforts to address the adverse trend in fuel handling.
.3 Annual Follow-Up of Selected Issues: Control Rod C-5 Failed to Withdrawal
a. Inspection Scope
The inspectors selected the following condition report for in-depth review:
- 02198547; Rod C-5 Indicating 0 Steps During Reactor Startup.
As appropriate, the inspectors verified the following attributes during their review of the licensee's corrective actions for the above condition reports and other related condition reports:
- complete and accurate identification of the problem in a timely manner commensurate with its safety significance and ease of discovery;
- consideration of the extent of condition, generic implications, common cause, and previous occurrences;
- evaluation and disposition of operability/functionality/reportability issues;
- classification and prioritization of the resolution of the problem commensurate with safety significance;
- identification of the root and contributing causes of the problem;
- identification of corrective actions, which were appropriately focused to correct the problem; and
- completion of corrective actions in a timely manner commensurate with the safety significance of the issue; The inspectors discussed the corrective actions and associated evaluations with licensee personnel.
This review constituted one in-depth problem identification and resolution inspection sample as defined in IP 71152.
b. Findings
No findings were identified.
4OA6 Management Meetings
.1 Exit Meeting Summary
On July 11, 2017, 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. Welty, Radiation Protection Manager, on May 5, 2017.
The inspectors confirmed that none of the potential report input discussed was considered proprietary.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- R. Coffey, Site Vice President
- R. Craven, Plant General Manager
- R. Higgins, Operations Assistant Manager
- G. LeClair, Radwaste Manager
- T. Lesniak, Site Maintenance Director
- C. Neuser, Systems Engineering Manager
- E. Schmidt, Programs Engineering Manager
- T. Schneider, Senior Engineer
- J. Wilson, Operations Director
- P. Wild, Projects Engineering Manager
- B. Woyak, Engineering Director
U.S. Nuclear Regulatory Commission
- J. Cameron, Chief, Reactor Projects Branch 4
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
- 05000266/2017002-01 FIN Failure to Evaluate Operating Experience
- 05000301/2017002-01 (Section 1R12.1)
Closed
- 05000266/2017002-01 FIN Failure to Evaluate Operating Experience
- 05000301/2017002-01 (Section 1R12.1)