IR 05000266/2021010

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Triennial Inspection of Evaluation of Changes, Tests and Experiments Baseline Inspection Report 05000266/2021010 and 05000301/2021010
ML21182A131
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 07/01/2021
From: Richard Skokowski
Division of Reactor Safety III
To: Strope M
Point Beach
References
IR 2021010
Download: ML21182A131 (11)


Text

July 1, 2021

SUBJECT:

POINT BEACH NUCLEAR PLANT - TRIENNIAL INSPECTION OF EVALUATION OF CHANGES, TESTS AND EXPERIMENTS BASELINE INSPECTION REPORT 05000266/2021010 AND 05000301/2021010

Dear Mr. Strope:

On May 21, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at 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.

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/

Richard A. Skokowski, Chief Engineering Branch 3 Division of Reactor Safety

Docket Nos. 05000266 and 05000301 License Nos. DPR-24 and DPR-27

Enclosure:

As stated

Inspection Report

Docket Numbers:

05000266 and 05000301

License Numbers:

DPR-24 and DPR-27

Report Numbers:

05000266/2021010 and 05000301/2021010

Enterprise Identifier: I-2021-010-0049

Licensee:

NextEra Energy Point Beach, LLC

Facility:

Point Beach Nuclear Plant

Location:

Two Rivers, WI

Inspection Dates:

May 17, 2021 to May 21, 2021

Inspectors:

K. Barclay, Reactor Inspector

J. Bozga, Senior Reactor Inspector

J. Neurauter, Senior Reactor Inspector

Approved By:

Richard A. Skokowski, Chief

Engineering Branch 3

Division of Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a triennial inspection of evaluation of changes, tests and experiments baseline 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

Type Issue Number Title Report Section Status URI 05000266,05000301/2021010-01 Containment Air Recirculation System Design Function Change 71111.17T Open

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), inspectors were directed to begin telework. In addition, regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

REACTOR SAFETY

71111.17T - Evaluations of Changes, Tests, and Experiments Sample Selection (IP Section 02.01)

The inspectors reviewed the following evaluations, screenings, and/or applicability determinations for 10 CFR 50.59 from September 2018.

(1)50.59 Evaluation 2020-002, Extend Surveillance Intervals for Independent Overspeed Protection System (IOPS), Cross-Over Steam Dumps, Turbine Over-Speed Trip Device, and Turbine Trip and Stop Valves (2)50.59 Screening 2018-0159, Revise AOP-9A Step 16.b to Secure Containment Cooling Fans (3)50.59 Screening 2019-0006, 1P-2C Charging Pump Suction Pressure Indicator Throttled (4)50.59 Screening 2019-0067, Raise Flooding High Lake Level Trigger Points (5)50.59 Screening 2019-0094, Install Duplex Strainers in Service Water Supply Lines to the Three Service Water Cooled Air Compressors (K-2A, K-2B, K-3B)

(6)50.59 Screening 2019-0120, HV-487, VNDRM-4512 Temperature Control Valve Outlet Isolation Abnormally Aligned Shut (7)50.59 Screening 2019-0121, HV-606, HX-83A, EL 8, PAB Fan Room Unit Heater Steam Inlet Abnormally Aligned Shut (8)50.59 Screening 2020-0014, 2CV-290, 2P-2C Charging Pump Discharge Valve, Gagged Closed (9)50.59 Screening 2020-0033, 2MS-5501A Packing Leak Sealant Injection (10)50.59 Screening 2020-0035, Isolation of Unit 1 Accident Fan(s) Dependent on Service Water Leakage Detection (11)50.59 Applicability Determination, EC 294090: Final Safety Analysis Report (FSAR)

Update to Sections 7.2.3.5 and 9.8.1 to Clarify Temperature (12)50.59 Applicability Determination, EC 295543: FSAR Table A.5-3 (13)50.59 Applicability Determination, EC 295893; Revise Updated Final Safety Analysis Report (UFSAR) Section 5.6 and Appendix A.5 to Incorporate License Amendment 263 (Unit 1) and 266 (Unit 2) Containment Dome Truss (14)50.59 Screening 2018-0173, Post-Outage Containment Closeout Inspection Unit 1 & 2 (CL-20, CL-20A)

(15)50.59 Screening 2018-0181, EC 292393: Generic Seismic II/I Ladder Storage Bracket (Drawing C-375)

(16)50.59 Screening 2018-0201, LR-AMP-021-OCCW, Open Cycle Cooling (Service)

Water - Revision 9 (17)50.59 Screening 2019-0093, EC 293591 (Service Water) SW Leak Pipe Patch TCC Downstream of SW-371 (18)50.59 Screening 2019-0106, EC 293808 1MS-2027 Flange Leak Repair (19)50.59 Screening 2020-019, Leaving Rigging Links in Containment During Power Operations (20)50.59 Screening 2020-0056, NP 7.7.14 Rev 13, Reactor Vessel Integrity Program (21)50.59 Screening 2019-0089, Radiologic Shielding Improvements U1 and U2 Containment (22)50.59 Applicability Determination, EC 294464 Revise FSAR 7.5 for Simplification of (Leading Edge Flow Meter) LEFM (23)50.59 Screening 2020-0052, 0-SOP-DC-001, 0-SOP-DC-002, 0-SOP-DC-003, 0-SOP-DC-004 and 0-SOP-DC-005 125 VDC System and Components (24)50.59 Screening 2018-0157, Provide Additional Containment Cooling Using 1/2SW-2907 or 1/2SW-2908, Hx-15A - D Cont Recirc (Heat Exchanger) HX Emergency (Flow Control Valve) FCV (25)50.59 Screening 2019-0047, 1(2)P-53 (Motor-Driven Auxiliary Feed Water) MDAFW Pump Seal Leakage Temporary Alternate Drains Through HV-540 Condensate Return (26)50.59 Screening 2020-0003, Revise Safety Classification for 1(2)A-01 and 1(2)A-02 Undervoltage and Underfrequency Circuits (27)50.59 Screening 2019-0023, U1R38 - Temp Power to H-08 & H-09 (28)50.59 Screening 2019-0064, PBTP 268 - Unit 1 Online Verification of Real and Reactive Power Capability for (North American Electric Reliability Corporation) NERC Standard Mod-025-2 (29)50.59 Screening 2020-0057, Abnormal Alignment - 1WL-1728 Aligned Open (30)50.59 Screening 2020-092, TRM 3.7.6 Turbine Overspeed Protection

INSPECTION RESULTS

Unresolved Item (Open)

Containment Air Recirculation System Design Function Change URI 05000266,05000301/2021010-01 71111.17T

Description:

The inspectors reviewed 10 CFR 50.59 Screening 2018-0157, Provide Additional Containment Cooling Using 1/2SW-2907 or 1/2SW-2908, HX-15A-D Cont Recirc HX Emergency FCV, dated August 27, 2018, which evaluated a change to an operating procedure for the containment air recirculation system associated with the alignment of the containment air recirculation system to provide additional containment cooling during normal operations.

The design basis of the Service Water (SW) system is to provide sufficient flow to support the heat removal requirements of components required to mitigate the consequences of a Loss of Coolant Accident (LOCA) in one unit, while supporting the normal flow of the unaffected unit.

Under the conditions of a LOCA and concurrent Loss-of-Offsite Power (LOOP), any three SW pumps are capable of providing the necessary cooling capacity for the essential loads for the affected unit and supply SW for the normal operation of the unaffected unit. When a Safety Injection (SI) signal is present, the containment cooler outlet valves (1/2SW-2907 and 1/2SW-2908) open, non-essential SW load valves close, and all six SW pumps receive start signals on a timed sequence.

The containment air coolers are aligned for emergency cooling by opening one of the containment cooler outlet valves (1/2SW-2907 or 1/2SW-2908) that bypasses the normal flow restricting orifice in the system. The increased SW flow causes an increase in the air cooler capacity to approximately 19 times the normal cooling rate. However, because of SW capacity limitations, opening the containment cooler outlet valves for the containment coolers places the opposite unit in a SW Technical Specification (TS) Action Condition. The SW system flow capacity is not adequate to support emergency containment cooling on one unit, during normal operations, and the SW requirements for a design basis accident with an assumed single failure on the opposite unit.

10 CFR 50.59 Screening 2018-0157 concluded that the change did not adversely affect the SW system design function. However, the inspectors identified that the 10 CFR 50.59 Screening SCR 2018-0157, stated, in part, In this condition, the overall reliability is reduced because a single failure could result in a system configuration which could not assure adequate flow to required equipment.

Licensee procedure, EN-AA-203-1201, 10 CFR Applicability and 10 CFR 50.59 Screening Reviews, Revision 21, Section 4.5 10 CFR 50.59 Screening, Step 11 stated, in part, It is necessary and expected that NEI 96-07, Revision 1, including Appendix E, and NEI 01-01, Revision 1 be consulted when performing the regulatory reviews governed by this procedure.

These industry guidance documents elaborate on the specific screening questions and provides a description of the intent of each question and expected level of response. Refer to Section 4.2 of NEI 96-07, Revision 1 for the guidance applicable to performing a 10 CFR 50.59 screen.

NEI 96-07, Guidelines for 10 CFR 50.59 Evaluations, Revision 1, are acceptable to the NRC staff for complying with the provisions of 10 CFR 50.59. Title 10 CFR 50.59(a)(1) defines, in part, a change as a modification or addition to, or removal from, the facility that affects a design function or an evaluation that demonstrates that the intended function will be accomplished. Section 3.3 of NEI 96-07, in part, defines a change as a modification or addition to, or removal from, the facility or procedures that affects an evaluation that demonstrates that intended functions will be accomplished.

In addition, Section 4.2.1, Is the Activity a Change to the Facility or Procedures as Described in the UFSAR?, of NEI 96-07 provides the following guidance: Changes are screened in (i.e., require a 10 CFR 50.59 evaluation) if they adversely affect an SSC design function. A change that decreases the reliability of an SSC design function, including either functions whose failure would initiate a transient/ accident or functions that are relied upon for mitigation would be considered to adversely affect a design function and would screen in.

Hence, the decrease in the reliability of the SW system design function would require a 10 CFR 50.59 evaluation.

This unresolved item is being opened to determine if a violation of NRC requirements exists.

Planned Closure Actions: The inspectors need to review the licensees completed 50.59 evaluation to determine if a finding or a violation of NRC requirements exists, including the requirements found in 10 CFR 50.59 paragraphs (c)(1) or (d)(1).

Licensee Actions: Reassess screening SCR 2018-0157 to address the change activity, and if adverse, address the change as a 50.59 evaluation.

Corrective Action References: AR 2393904: 2021 NRC 50.59 INSP. SCR 2018-0157

AR 2393903: 2021 Potential Containment Temperature Discrepancy

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

  • On May 21, 2021, the inspectors presented the triennial inspection of evaluation of changes, tests and experiments baseline inspection results to Mr. M. Strope, Site Vice President and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.17T Calculations

29187-M-0022

Verification of Adequacy of Containment Fan Cooler Units

during Normal Operations under Extended Power Uprate

(EPU) Conditions

Corrective Action

Documents

295255

EC 292506 Repair of 1CW-3502 Needs a Screening or

Evaluation

2/19/2018

2302879

P-53 Packing Leakage System Installed without a TCC

2/21/2019

2305891

Missed Required Procedure Reviews

03/15/2019

23666

50.59 Screening on Scaffolds Up Over 90 Days

08/07/2019

29686

Revise 20 CFR 50.59 Screening 2019-001

09/30/2019

2337234

Safety Classification Discrepancy

2/03/2019

2337968

Incomplete Bases Documentation for EOP Changes

2/11/2019

2338267

EOPs Revised without Sufficient Applicability and Screening

2/13/2019

2340361

50.59 Screening on Scaffolds Up Over 90 Days

01/08/2020

2341458

LIA Assessment: PCRs Inadvertently Missed Reviews

01/16/2020

2351425

2MS-5501A Packing Leak

04/05/2020

2361666

Abnormal Alignment: 1WL-1728

07/02/2020

2387160

Scaffold 1942 Documented as Removed by Remains in

Place

03/17/2021

Corrective Action

Documents

Resulting from

Inspection

2393718

21 NRC 50.59 INSP. SCR 2018-0157

05/19/2021

2393817

21 50.59 Inspection - Unable to Locate Design Documents

05/20/2021

2393832

21 NRC 50.59 INSP., EC 295629, Acoustic Emission

Testing

05/20/2021

2393903

21 NRC 50.59 INSPEC., Potential Ctmt. Temp.

Discrepancy

05/20/2021

2393904

21 NRC 50.59 INSP. SCR 2018-0157

05/20/2021

Drawings

499B466 Sheet

2

Elementary Wiring Diagram 4160V Switchgear 1A01 CUB-3

Incoming Line 1A03-PT/1A01

499B466 Sheet

204

Elementary Wiring Diagram 4160V Switchgear, CUB.16 Bus

Tie to 1A-04 At 1A52-55

499B466 Sheet

207

Elementary Wiring Diagram 4160V Switchgear 2A01,

CUB. 18 Bus Tie from 2A-03 At 2A52-44

499B466 Sheet

Elementary Wiring Diagram 2A02 Bus Tie 2A52-48 to Bus

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

209

2A-04 2A00-34

E-11 Sheet 2

Schematic Meter & Relay Diagram 4160V Auxiliary System

E-2011 Sheet 1

Schematic Meter & Relay Diagram 4160V Auxiliary System

E-2011 Sheet 2

Schematic Diagram Meter & Relay Diagram 4160V Auxiliary

System

E-2011 Sheet 3

Schematic Meter & Relay Diagram 4160V Auxiliary System

E-2011 Sheet 4

Three Line Diagram EDG G-04 4160V Bus 2-A06 Relay &

Metering

Engineering

Changes

291748

Install Duplex Strainers in Service Water Supply Lines to the

Three Service Water Cooled Air Compressors (K-2A, K-2B,

K-3B)

293515

Radiologic Shielding Improvements U1 and U2 Containment

294090

FSAR Update to Sections 7.2.3.5 and 9.8.1 to Clarify

Temperature

294316

2CV-290, 2P-2C Discharge Valve Stem Gag

294621

Installation of Leak Injection Sealant for Packing of

2MS-5501A

294916

Chapter 14.1.12 Update with New Turbine Overspeed

Calculation

295629

Use of Acoustic Emission Technology as an Alternate

Method for NDE of Special Lifting Devices EE 2020-0020

01/20/2021

Engineering

Evaluations

EE 2020-0020

Use of Acoustic Emission Technology as an Alternate

Method for NDE of Special Lifting Devices

Miscellaneous

Unit 2 Circulating Water - Service Water Temperatures

08/18-

2/2018

Units 1 & 2; Containment Temperatures

08/18-

2/2018

Unit 2; Graph of Containment Air and Circulating Water

Temperatures

08/18-

2/2018

EC-UCR 294090

UFSAR Change Request: FSAR Update to Sections 7.2.3.5

AND 9.8.1 to Clarify Temperature

PCR 2269200

Procedure Change Request: Revise AOP-9A

06/20/2018

PCR 2319200

Procedure Change Request: PBF-2124a - Average

Converted Lake Level

06/25/2019

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

PCR 2319202

Procedure Change Request: AOP-13C - Severe Weather

Conditions

06/25/2019

PCR 2355135

Procedure Change Request: Change TRM, TSR 3.7.6.1,.2,

.3,.4 Surveillance Intervals

04/30/2020

Procedures

1-SOP-4KV-001

4KV System Operation Unit 1

AOP-0.0

Abnormal Operating Procedure: Vital DC Malfunction

AOP-40D

Abnormal Operating Procedure: Response to Fire in PAB 26

FT North of Monitor Tanks

EN-AA-203-1100

Engineering Evaluations

EN-AA-203-1102

Safety Classification Determination

EN-AA-203-1201

CFR Applicability and 10 CFR 50.59 Screening Reviews

EN-AA-203-1202

CFR 50.59 Evaluation

EN-AA-205-1100

Design Change Packages

EN-AA-205-1102

Temporary Configuration Changes

LI-AA-101-1003

Updated Final Safety Analysis Report (UFSAR) Revision

NP 7.2.30

Quality-Basis Values and Quality Group Codes

OI 72

Containment Air Recirculation System

OP 2B

345 KV Transmission System Impacts Upon PBNP Station

Operations

PBTP 268

Unit 1 Online Verification of Real and Reactive Power

Capability for NERC Standard MOD-025-2

RMP 9359-5C

D-305 Station Battery, D-09 Battery Charger Maintenance

and Surveillances

RMP 9359-6C

D-305 Station Battery, D-109 Battery Charger Maintenance

and Surveillances

TS 33

Containment Accident Recirculation Fan-Cooler Units Unit 1

Work Orders

WO 40713603 07

OPS WP 2020-016: 1HX-15C, Containment Accident

Recirculation Heat Exchanger Isolation

04/27/2020