IR 05000266/2020010
| ML20269A287 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  (DPR-024, DPR-027) |
| Issue date: | 09/24/2020 |
| From: | Nestor Feliz-Adorno NRC/RGN-III/DRP/RPB4 |
| To: | Strope M Point Beach |
| References | |
| IR 2020010 | |
| Download: ML20269A287 (16) | |
Text
September 24, 2020
SUBJECT:
POINT BEACH NUCLEAR PLANT - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000266/2020010 AND 05000301/2020010
Dear Mr. Strope:
On August 28, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Point Beach Nuclear Plant and 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.
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
No findings or violations of more than minor significance were identified during this inspection. 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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Néstor J. Féliz Adorno, Chief Branch 4 Division of Reactor Projects
Docket Nos. 05000266 and 05000301 License Nos. DPR-24 and DPR-27
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000266 and 05000301
License Numbers:
Report Numbers:
05000266/2020010 and 05000301/2020010
Enterprise Identifier: I-2020-010-0035
Licensee:
NextEra Energy Point Beach, LLC
Facility:
Point Beach Nuclear Plant
Location:
Two Rivers, WI
Inspection Dates:
August 10, 2020 to August 28, 2020
Inspectors:
T. Gardner, Physical Scientist
C. Hunt, Resident Inspector, Byron Station
V. Meghani, Reactor Inspector
R. Ng, Senior Project Engineer
Approved By:
Néstor J. Féliz Adorno, Chief
Branch 4
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at Point Beach Nuclear Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html.
Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), regional inspectors were directed to begin telework. Regional based inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. For the inspection documented below portions of the IP were completed remotely as well as on site and all the objections and requirements for completion of the IP were met.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)
- (1) The inspectors performed a biennial assessment of the licensees Corrective Action Program (CAP), use of operating experience, self-assessments and audits, and safety-conscious work environment.
- CAP Effectiveness: The inspectors assessed the CAP effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the instrument and service air systems.
- Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments.
- Safety-Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B Corrective Action Program Effectiveness:
Based on the samples reviewed, the inspectors determined that the licensee's performance in each of these areas adequately supported nuclear safety.
- Problem Identification: Overall, the licensee was effective at identifying issues at a low threshold and was properly entering them into the CAP as required by fleet procedures. The inspectors determined that the station was generally effective at identifying negative trends that could potentially impact nuclear safety. During their review, the inspectors noted that the total number of condition reports (CRs) initiated at the site has declined over the past five years. Additional details are discussed in the observation section of this report. For the areas inspected, the team did not identify any concerns in the area of problem identification.
- Problem Prioritization and Evaluation: In-depth reviews of a risk-informed sampling of action requests (ARs), work orders (WOs), and cause evaluations were completed, including a 5-year review of issues associated with the instrument and service air systems. The inspectors concluded that, in general, the licensee appropriately prioritized and evaluated issues for resolution.
- Corrective Actions: The team concluded that the licensee was generally effective in developing corrective actions (CAs) that were appropriately focused to correct conditions adverse to quality. The inspection team identified several examples where the documentation of a CA closure or due date extension was not in accordance with licensee procedure PI-AA-104-1000, "Condition Reporting." Additional details are discussed in the observation section of this report. The team also identified a minor performance deficiency associated with the creation and tracking of a corrective action to preclude repetition (CAPR) associated with CR 02324133. Additional details are discussed in the minor performance deficiency section of this report.
Operating Experience, Self-Assessments and Audits:
Based on the samples reviewed, the team determined that the licensee's performance in these areas adequately supported nuclear safety.
Safety-Conscious Work Environment:
The team found no evidence of challenges to the licensee's safety-conscious work environment. Through one-on-one interviews with a representative cross-section of station personnel, the team determined that workers were willing to identify issues through any of the available means. The team remotely observed various station meetings, including those in which new CRs were reviewed, and determined that there was adequate emphasis placed on prioritizing resources to address issues of higher risk to plant safety. Additionally, the team assessed the overall health of the Employee Concerns Program. Specifically, the team interviewed the Employee Concerns Coordinator, reviewed recent case logs and case files, and considered statements received during interviews with station personnel. The inspectors found the Employee Concerns Program to be effectively implemented at the site.
Minor Performance Deficiency 71152B Minor Performance Deficiency: On August 12, 2019, control rod F-6 dropped into the core during rod exercise testing. The licensee documented this issue in CR 02324133 and screened it as a Significance Level 1, Significant Condition Adverse to Quality (SCAQ), per PI-AA-104-1000, "Condition Reporting," Attachment 4, because it resulted in an unplanned down power of more than 20 percent for greater than two hours. The inspectors noted that a CAPR was not assigned to CR 02324133 in the Nuclear Asset Management System (NAMS).
Instead, the licensee made reference to WO 40641721 being a CAPR in the documentation of form PI-AA-104-1000-F02, "RCE/Issue Investigation Non-Performance Basis Form,"
associated with the CR.
PI-AA-104-1000, Section 4.9.2.A, stated, in part, that CAPRs were actions to eliminate the root cause of an SCAQ issue. It also stated that CAPRs shall be assigned from SCAQ Root Cause Evaluations (RCE) or, if the RCE was waived, the CAPR identified as part of the waiver basis. It further stated that CAPRs shall be sustainable and institutionalized within existing controlled processes/programs to ensure the CAPR is not nullified by subsequent actions. It clarified the intent was that an action designated as a CAPR be preserved for the life of the station unless a change was approved by the Management Review Committee.
Contrary to the above, the team determined that the licensee did not create a CAPR that was sustainable and institutionalized within existing controlled processes/programs to ensure the CAPR is not nullified by subsequent actions. Specifically, WO40641721 was a one-time work order to address the damaged wiring and reroute the wiring to a configuration that made it less susceptible to wear. The inspectors determined that the licensee had not taken any sustainable or institutionalized actions that would prevent future work from nullifying the actions completed by WO40641721, such as rerouting the wiring again to a configuration that makes them more susceptible to wear.
Although, per procedure, the licensee labeled the issue captured in CR 02324133 as an SCAQ, the inspectors determined that the requirements of 10 CFR 50, Appendix B, did not apply because the function of the control rod drive mechanisms to withdraw and insert the rod cluster control assemblies for reactivity management was not a safety related function. The ability of the control rod to insert into the core when a trip signal was received was a safety related function and was unaffected by the damaged wiring associated with CR 02324133.
The licensee captured this issue in the CAP under CR 02366511.
Screening: The inspectors determined the performance deficiency was minor. Specifically, the licensee corrected the condition by repairing the damaged wires and rerouting the wiring to reduce its vulnerability to wear. The failure to institutionalize this corrective action cannot be reasonably viewed as a precursor to a significant event, would not have the potential to lead to a more significant safety concern, and does not adversely affect the objective of any cornerstones listed in IMC 0612, Appendix B.
Observation: Corrective Action Assignment Documentation Issues 71152B During the inspection, the team identified a number of examples where the documentation for the closure or due date extension of a CA was not in accordance with licensee procedure PI-AA-104-1000, "Condition Reporting." These examples include:
- CR 02344267 CA assignments 5 and 7 were created to track validated fit tests for site personnel. The intent of the CA assignments was later changed via the completion notes in the CR and the CAs were closed out without revising the original CA assignments to reflect the change in intent.
- CR 02345403 CA assignment 2 was marked complete without the action being completed. Specifically, the intent of the CA assignment was changed via the completion notes in the CR and the CA was closed out without revising the original CA assignment to reflect the change in intent.
- CR 02316214 CA assignment 3 was closed out without documentation to show that the actions taken addressed the condition adverse to quality. Specifically, the CA assignment stated that a department level challenge review should be completed for tier 1 systems to identify any low margin or quality issues for resolution. The closeout documentation mentioned a review being completed, the systems that were reviewed, and that feedback was provided. However, the documentation did not address whether any low margin or quality issues were identified or how those issues were addressed.
- CR 02322292 CA assignment 5 stated that the maintenance department was to reinforce expectations associated with transient combustibles with their personnel through assignment of computer-based training. The assignment was marked complete after training was assigned to the effected personnel but before the training was actually completed by all individuals. The inspectors determined that closing the CA assignment in this manner was equivalent to closing the assignment to "training that will be provided, which was specifically not allowed by procedure PI-AA-104-1000.
- CR 2287706 CA assignment 2 and CR 2198772 CA assignment 3 both had due date extension paperwork completed and approved which was not in accordance with procedure PI-AA-104-1000. Specifically, the paperwork for both extensions did not contain a discussion about the potential risk and safety significance of deferring the action to the next proposed due date.
Overall, the CA documentation issues identified by the inspection team were of low-level significance and were similar to those discovered by the licensee during a Nuclear Assurance Performance Improvement Audit that was performed in October 2019 and documented in CR 02330346. The team discussed the items identified with members of the licensee staff and management to emphasize the importance of correcting the behaviors behind these administration issues before they potentially become significant and adversely impact the effectiveness of the CAP.
Observation: Decline in Total Number of Condition Report Initiated 71152B The inspectors reviewed CR data for the CAP over the past five years and noted a steady decline in the total number of CRs initiated over this period. Specifically, in 2015 there were 9,661 CRs initiated. That number decreased to 5,866 for 2019, which represented a 39 percent reduction in CR initiations. The most significant reduction occurred between 2017 and 2018 when a 19 percent reduction was observed. The inspectors discussed the trend with the licensee as well as several factors that could be attributed to the trend such as organizational changes, industry initiatives, and staff reductions. Based on the samples reviewed by the team, both low and high safety significant issues were being entered in the CAP. Through interviews with the licensee's staff, the team concluded that individuals at the site are willing to raise safety issues through the CAP by writing CRs when needed.
Therefore, the decreasing trend in CR initiation did not appear to have an adverse effect on plant safety.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On August 28, 2020, the inspectors presented the biennial problem identification and resolution inspection results to Mr. M. Strope, Site Director, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
Non-Compliance with FSAR for Cable Overload Protection
01/22/2003
CDBI: Unvalidated Assumptions in Calculation N-92-086
03/24/2015
U1 Reactor Startup Aborted
11/30/2015
Upper Cavity - Remove/Repaint Level Indication Marking
04/11/2017
Potential Part 21 for ABB Relays
04/13/2017
03/01/2018
Individuals Without Corrective Lens Inserts in OSC
03/21/2018
Shared Ownership Gaps - Respiratory Protection Program
03/28/2018
07/24/2018
Potential Adverse Trend w/Recognition of Seismic Work
Reqs
08/02/2018
Procedure Step Performed Out of Sequence
08/30/2018
Security System Parts Availability
09/06/2018
Cyber Vendor Identified Cyber Vulnerabilities
09/13/2018
Unavailability Hours Exceeded for Reactor Protection
System
09/26/2018
Vendor Identified Cyber Vulnerabilities Require Assessment
10/15/2018
Lowering Refueling Cavity Level (PWE)
03/25/2019
Siren 018 Heater Fuse Alarm
10/18/2018
Documenting the Cracks in the Forebay Concrete
10/18/2018
AOP40A Ctrl Room Abandonment Procedure and Feasibility
Issue
10/24/2018
OE Review - Beaver Valley Indications on RV Head
11/05/2018
Phone Issues Identified with Quarterly Communications Test
11/13/2018
Root Cause Evaluation - 1CW-3502, 1P-30A Circulating
Water Pump Discharge Valve Failure Resulted in a Manual
Unit 1 Reactor Trip
01/17/2019
1E-02 Voltage Regulator Abnormal Response
2/05/2018
During Troubleshooting, Unexpected Alarm Received in
Control
2/10/2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
December 2018 Vendor Cyber Security Screening
2/17/2018
OE Review - INPO ICES OE 444926 - Ineffective Aging
Mgmt Prgm
01/03/2019
OE-Waterford RCS Weld Deficiency Found During N-770
Exam
01/24/2019
Phone Issues Identified with Quarterly Communications Test
2/05/2019
ERO Facility Managers did Not Schedule DEP Sessions
2/08/2019
NA Finding: Cyber Security Program Non-Compliances
2/13/2019
L1A - Maintenance Outage Backlogs
2/14/2019
Cyber - Audit and Accountability (Periodics) Completion
2/18/2019
Z-015 X-SAM Clutch Assembly Cable Worn
2/21/2019
Level 1 Assessment Security Department Cyber Readiness
2/21/2019
PBNP Security Work Quality Assessment - Jan-Feb 2019
03/05/2019
Clarification Required Regarding Implementation of LCO 3.4.3
04/09/2019
Cognitive Trend: PBN Dose-Rate Alarms
04/10/2019
1P-030A Circ Water Pump Casing Not Plumb
04/11/2019
Unposted High Radiation Are Identified
04/13/2019
Cyber - PMD Sampling Q4 2018
04/18/2019
Unit 1 Enters LCO 3.4.1 PZR Press Less Than 2205 PSIG
04/21/2019
FAC Locations Need Tmin Calc
04/24/2019
Phone Issues Identified with Quarterly Communications Test
05/07/2019
Inadequate Support from EMNET Phone Vendor
05/10/2019
Area 8 - VSDS Hard Copy in HRA Briefing Binder Not Up to
Date
05/17/2019
Tap Settings for B52-DB25-026 Were Found to be Incorrect
05/29/2019
Cognitive Trend: Increase in Equipment Deficiencies
05/30/2019
1P-11A Parallel Offset Coupling Alignment OOT
06/12/2019
2019 NRC EX - PAR Determination DEP Not Met
06/13/2019
Cyber-Review of Cyber Assessment Needed for Z-108E
06/14/2019
Declining Trend - ERO Performance
06/20/2019
Cyber - E5 Control Deficiency
06/24/2019
Corrective Action
Worker Underestimated His Break Causing Work Hour
06/26/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
Violation
Negative Trend: Inadequate FP-Related CAP Closure
07/24/2019
2Q19 LID Violation of Technical Specification LC 4.F
07/25/2019
Dropped F-6 Rod
08/12/2019
Phone Issues Identified with Quarterly Communications Test
08/23/2019
L1A FIN Effectiveness Review of Scheduled Maintenance
Items
09/05/2019
Inconsistent Reporting in Facilities Monitoring Report
09/11/2019
PBNP Maintenance Rule a(1) System Action Plan Review
09/11/2019
Potential Trend: QC Hold Points
09/18/2019
MFIV Design Low Temperature Value of -20 Deg F
Questioned
09/23/2019
Human Performance Error During DY-0D Wire Bypass Work
10/03/2019
Gaps in CAQ CR Completion Documentation
10/04/2019
2AF-4000 Failed to Close
11/07/2019
Phone Issues Identified with Quarterly Communications Test
11/22/2019
Nuclear Safety Culture Assessment
11/27/2019
2RE-229 SW Overboard Sample Pump Failed
11/30/2019
Inverter Parts Installed in 1DY-03 Don't Meet Req'd Q-Level
2/11/2019
Determine if EP Response Instruments are Available for Use
2/18/2019
Review of PBN 19-010 Audit Scope Regarding SCAQ
2/19/2019
RM-14 Frisker Found in Use but Out of Calibration
2/31/2019
Foreign Material Found on G-02 EDG Main Lube Oil Filter
2/10/2020
Respirator Fit Test Exercise Not Performed Per 29 CFR 1910 02/11/2020
Air Sample Missed Required LLA Counting
2/19/2020
Chemistry Electronic QA Records with Errors
2/20/2020
RP Sentinel Program Instruments Inaccurate Service
Records
2/27/2020
Two Unanticipated Dose Rate Alarms in U2 RHR Cubicle
2/27/2020
Criteria for RCE Non-Performance Not Met
03/02/2020
PBN Significant Conditions Adverse to Quality Review
03/04/2020
Declining Housekeeping Attributes T PCE, FME, Safety
Concern
03/08/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
Declining Housekeeping Attributes T PCE, FME, Safety
Concern
03/08/2020
Evaluate PCEs for Trends
03/11/2020
Perform Trend Review of Rework Issues Listed
03/31/2020
Leak Identified on 1HX-15C
04/11/2020
Replace Setpoint 1 Yellow Channel (2TM-404B)
04/13/2020
E-Plan Dosimeters Near Miss on Calibration Due Dates
04/28/2020
Fixed Contamination Detected in RCA Yard
06/03/2020
ER 02288242-01
UNIT1 Facade Panel 1FFCP-02A
10/27/2018
ER 02299779-01
Z-15, PAB Crane Stopped Working During New Fuel Receipt 01/29/2019
ER 02334539-01
2AF-4000 Failed to Close
11/07/2019
HU 02301932
PUA Event During Drill/Exercise Performance Tabletop
2/14/2019
OR 02273644-02
Adverse Trend - Managing EP Call-Up Tasks/ Fleet
Procedure Compliance
07/26/2018
OR 02318631-03
Declining Trend - ERO Performance
06/20/2019
Corrective Action
Documents
Resulting from
Inspection
PB NRC PI&R 2020: Cancelled AR Assignments Not Fully
Archived
08/21/2020
PB NRC PI&R 2020: Quality of Closeout Challenges
08/25/2020
PB NRC PI&R 2020: Quality Closeout
08/25/2020
PB NRC PI&R 2020: No Institutionalized CAPR for
CR 02324133
08/25/2020
PB NRC PI&R: Two ERs Not Fully Investigated
08/25/2020
PB NRC PI&R 2020: Assignments Not Meeting Extension
Reqs
08/27/2020
PB NRC PI&R 2020: Untimely Completion of CR 02287706
08/27/2020
PB NRC PI&R 2020: Untimely Completion of CR 01226467
08/27/2020
Action Tracking Management
Miscellaneous
NRC IN 2018-07: Pump/Turbine Bearing Oil Sight Glass
Problem
06/15/2018
NRC IN 2018-08: Failure to Enter Required TSAC for Surv
Test
06/18/2018
NRC IN 2018-11: Kobe Steel QA Record Falsification
09/27/2018
NRC RIS 2018-05: Supplier Oversight Issues - Vendor
10/10/2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Inspection
Miscellaneous
NRC RIS 2018-06: RPV Upper Head Bare Metal Visual
Exams
2/17/2018
NRC RIS 2019-02: Prep & Sched of Operator Licensing
Exams
04/22/2019
NRC IN 2019-03: Clearance Process Issues
06/06/2019
NRC IN 2019-02: EDG Excitation System Diode Failures
06/12/2019
NRC IN 2019-05: Potential Over Pressurization of High
Alpha-E
09/06/2019
NRC IN 2019-08: Flow-Accelerated Corrosion Events
10/15/2019
Procedures
Findings
Nuclear Assurance Corrective Action
Root Cause Analysis
Issue Investigation
LEVEL 2 Independent Assessment Planning, Conduct and
Reporting
LEVEL 1 Core Business Assessments
Condition Reporting
RP 1D - Unit 1
Filling and Draining the Unit 1 Refueling Cavity and Unit 1
Cavity Purification
RP 1D - Unit 2
Filling and Draining the Unit 2 Refueling Cavity and Unit 2
Cavity Purification
Self-Assessments AR 02271673
Radiological Survey Performance
08/13/2018
PBN Snubber Program
09/17/2018
L1A -Effective Design Changes
03/22/2019
U1R38 1HX-15A/B/D Containment Fan Cooler Inspection
Assessment
05/22/2019
2019 RP RWP Set Points Assessment
11/25/2019
STP Assessment Regarding Elevated BOD and TSS in
Effluent
03/09/2020
RP Instrument Review
05/26/2020
PBN 18-003
Radiological Protection and Radwaste
04/18/2018
PBN 18-006
08/11/2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
PBN 19-002
Engineering
03/19/2019
PBN 19-010
Performance Improvement
10/23/2019
PBN 20-003
Radiological Protection and Radwaste
03/12/2020
Work Orders
40530911
EC 288954: Repl Relay 50G/A52-92 & Jumper T-S1 on
GND
06/03/2020