IR 05000266/2022010

Design Basis Assurance Inspection (Programs) Inspection Report 05000266/2022010 and 05000301/2022010

ML22040A062
Person / Time
Site:	Point Beach
Issue date:	02/09/2022
From:	Karla Stoedter NRC/RGN-III/DRS/EB2
To:	Strope M Point Beach
References
IR 2022010
Download: ML22040A062 (13)

Text

February 9, 2022

SUBJECT:

POINT BEACH NUCLEAR PLANT - DESIGN BASIS ASSURANCE INSPECTION (PROGRAMS) INSPECTION REPORT 05000266/2022010 AND 05000301/2022010

Dear Mr. Strope:

On February 3, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Point Beach Nuclear Plant and discussed the results of this inspection with Mr. M. Holzmann, Site Operations Director 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, Signed by Stoedter, Karla on 02/09/22 Karla K. Stoedter, Chief Engineering Branch 2 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: 05000266/2022010 and 05000301/2022010 Enterprise Identifier: I-2022-010-0017 Licensee: Nextera Energy Point Beach, LLC Facility: Point Beach Nuclear Plant Location: Two Rivers, WI Inspection Dates: January 10, 2022 to February 03, 2022 Inspectors: K. Barclay, Reactor Inspector J. Benjamin, Senior Reactor Inspector B. Jose, Senior Reactor Inspector Approved By: Karla K. Stoedter, Chief Engineering Branch 2 Division of Reactor Safety Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a design basis assurance inspection (programs) 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/ Potential Inadequate 71111.21N.02 Open 2022010-01 Basis/Justification for Motor-Operated Valve Rate-of-Loading Assumptions

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.

REACTOR SAFETY

71111.21N.02 - Design-Basis Capability of Power-Operated Valves Under 10 CFR 50.55a Requirements POV Review (IP Section 03)

The inspectors:

a. Determined whether the sampled power operated valves (POVs) are being tested and maintained in accordance with NRC regulations along with the licensees commitments and/or licensing bases.

b. Determined whether the sampled POVs are capable of performing their design-basis functions.

c. Determined whether testing of the sampled POVs is adequate to demonstrate the capability of the POVs to perform their safety functions under design-basis conditions.

d. Evaluated maintenance activities including a walkdown of the sampled POVs (if accessible).

(1) 1SI-00866B; Safety Injection (SI) Pump 1P-15 Discharge to Reactor Coolant System (RCS) Cold Leg Motor Operated Valve (MOV)

(2) 1SI-00851A; Residual Heat Removal (RHR) Pump P-10A Suction from Containment Sump B MOV

(3) 2SI-00850A; Unit 2 RHR Pump 10A Suction from Containment Sump B Hydraulically Operated Valve (HOV)

(4) 2AF-04002; Turbine Driven Auxiliary Feedwater (TDAFW) Pump 2P-29 Recirculation Flow Control Air Operated Valve (AOV)

(5) 1AF-04000; AFW Pump 1P-29 Discharge to Steam Generator 1B, Heat Exchanger Inlet Isolation MOV

(6) 2RC-00430; T-1 Pressurizer Power Operated Relief AOV

(7) 2SI-00860A; Unit 2 Containment Spray Pump P-14A Discharge MOV

(8) 2SI-00852B; Unit 2 Low Head SI Core Deluge Isolation MOV

INSPECTION RESULTS

Unresolved Item Potential Inadequate Basis/Justification for Motor-Operated 71111.21 (Open) Valve Rate-of-Loading Assumptions N.02 URI 05000266,05000301/2022010-01

Description:

During the inspection of MOV 1AF-4000, a discharge valve associated with the 1P-29 turbine-driven auxiliary feedwater pump, an Unresolved Item was identified.

During the review of calculation 2003-0014, MOV Operating Parameters, the inspectors found the rate of loading (ROL) value assigned to valve 1AF-4000 was zero. The inspectors questioned the low ROL value and reviewed the supporting reference, licensee internal correspondence PBM 92-1200, "Rate of Loading/Stem-To-Stem Nut Coefficient of Friction, dated October 7, 1992. The inspectors and NRC MOV subject matter experts from the Office of Nuclear Reactor Regulation found the licensees methodology for incorporating the ROL effects into their MOV program was not consistent with existing industry methods.

A review of correspondence between the NRC and the licensee found that the Agencys concern with ensuring proper validation of the ROL methodology dated back to the inspection and closeout of NRC Generic Letter (GL) 89-10, Safety-Related Motor-Operated Valve Testing and Surveillance, and GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves.

NRC Inspection Report 50-266/95007 (DRS); 50-301/95007 (DRS), dated July 13, 1995, which inspected the licensees response to GL 89-10, stated, The licensee developed a method to predict the effects of rate of loading for valves without a dynamic test; however, in-plant test data was inconclusive to fully support the method. Based on dp [differential pressure] test results, the method used plots taken during static testing which correlated torque from the stem thrust versus spring pack deflection. The inspectors encouraged the licensee to continue their research but were concerned with the inconclusive data from the valves that had been tested and the lack of data used to verify the method. The licensee committed to continue to compile data from periodic verification tests, both static and dynamic, to validate the rate of loading assumptions and prediction methodology.

On March 17, 1997, the licensee submitted a letter titled, "Response to NRC Generic Letter 96-05 Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves," to the NRC. This letter stated, in part, NRC Inspection Reports 50-266/95007 (DRS) and 50-301/95007 (DRS), dated July 13,1995, document our commitments in response to the GL 89-10 closeout inspection items. As documented in this report, the following commitments were made and will be completed within five years of that inspection report:, 3. We will collect and trend further static and dynamic periodic results to validate the valve factor study and rate of loading assumptions and prediction methodology.

NRC Inspection Reports 50-266/99012 (DRS) and 50-301/99012 (DRS), dated July 14, 1999, which inspected the licensees response to GL 96-05, stated, The inspectors reviewed the status of the long-term MOV actions planned following completion of GL 89-10 close-out inspection. In particular, the licensee had not completed the overall review of the assumptions for valve factor and load sensitive behavior because of the limited progress made in performing dynamic testing as part of the long-term MOV program. The report stated further, With respect to the long-term GL 89-10 issues, the licensee had not adhered to its efforts to implement planned dynamic tests, to perform an overall evaluation of program assumptions for valve factor or load sensitive behavior, or to perform qualitative and quantitative trending of MOV performance.

The inspectors requested the information and data used to validate the ROL assumptions and prediction methodology. The licensee found historical MOV program trend reports that stated there were no valves identified that exhibited rate-of-loading effects; however, the licensee was unable to locate formal documentation detailing the methods used to make these determinations or details of the test data evaluations that validated the rate-of-loading assumptions and predication methodology.

Planned Closure Actions: The inspectors need to review the data, methodology and results of the licensee's rate-of-loading study to determine if assigning a ROL value of zero is appropriate and whether a performance deficiency exists.

Licensee Actions: The licensee entered the issue into their Corrective Action Program (CAP)and created an initial corrective action to perform a Rate-of-Loading (ROL) study to document the basis for the ROL assumptions in calculation 2003-0014. Additionally, the licensee applied an MOV margin penalty to support a reasonable assurance of operability while the ROL study is being performed.

Corrective Action References: AR 2417688; 2022 POV Inspection - Calc 2003-0014 RE.

MOV Rate of Loading

EXIT MEETINGS AND DEBRIEFS

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

On February 3, 2022, the inspectors presented the design basis assurance inspection (programs) inspection results to Mr. M. Holzmann, Site Operations Director and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.21N.02 Calculations 01109-C-005 Auxiliary Feedwater (AFW) Air Operated Valve (AOV) 1

Functional and Maximum Expected Differential Pressure

(MEDP) Calculation

01109-C-018 AOV Component Level Calculation; 0AF-04007, 1

0AF-04014, 1AF-04002, and 2AF-04002

2001-0056 Turbine Driven Auxiliary Feedwater Pump (TDAFP) 5

Mini-Recirculation Valve (1/2AF-4002) Instrument Air

Accumulator Sizing

2003-0014 Motor Operated Valve (MOV) Operating Parameters, 8

Group 15

2004-0002 Alternating Current (AC) Electrical System Analysis 6

97-0041 Functional Times for Emergency Safeguards Equipment to 3

Be Used in Point Beach Accident Analysis

N-93-086 1 (2) AF-4000, AF-4001 (Group 30) MOV Differential 0 & 0A

Pressure Calculation

N-94-019 Determination of Conditions for MOV Pressure Locking 04/13/1994

and Thermal Binding

P-89-031 Voltage Drop Across MOV Power Lines 13

P-90-017 MOV Undervoltage Stem Thrust and Torque 23

P-94-004 MOV Thermal Overload Evaluation 14

P-94-004; EC MOV Overload Heater Evaluation 14

294777 Pending

Change A

P-94-005 Motor Stem Thrust Calculation 11

Powell 01-12- Maximum Thrust Calculations - Point Beach Nuclear Plant 01/12/1988

1988 (Wisconsin Electric)

Corrective Action AR 2231511 1SI866B Overthrust Event 11/17/2017

Documents

Corrective Action AR 2416029 Alarm Response Book (ARB) for 2RC-0430, Low 01/13/2022

Documents Temperature Over Pressure (LTOP) Defined Incorrectly

Resulting from AR 2416280 Calculation P-94-005, Use of Torque Reaction Factor 01/17/2022

Inspection Inversed

Inspection Type Designation Description or Title Revision or

Procedure Date

AR 2416353 1SI-866B 2017 as Left Test Review, as Left Close Thrust 01/18/2022

Below Minimum Required and No Evaluation Performed

AR 2416888 The Work Plan for Work Order 4072625-03 Step 5 Directs 01/24/2022

Performer to Circle the PMT Done of Two Listed and None

Circled

AR 2416904 Work Order Documentation for 1AF-04000; RMP9376-2 01/24/2022

for 03/09/2010 Recorded 180 Foot Pounds for Mounting

Bolts Instead of 88 Foot Pounds

AR 2416916 MOV Design Basis Review of Valve Family 30 Shows 01/24/2022

Medium Risk Vs. Actual Low Risk

AR 2416967 Drawing Discrepancy; Stem Speed for 1/2AF-04000 01/252022

Shown as 4.21 Inches/Minute Vs 7.375 Inches/Minute

AR 2416984 Training Work Request Written Against Operations 01/25/2022

Procedure OM 3.20 to Remind Operators that 24 Demand

Valves Have No Seal-In Contacts, Therefore Hold the

Control Switch until Full Open/Close

AR 2416997 Model Number for New Solenoid 2AF-4002-S Not 01/25/2022

Updated in Component Database

AR 2417022 Criterion Error in MOV Test Software 01/25/2022

AR 2417028 Air Operated Valve (AOV) Trending Spread Sheet Error, 01/25/2022

Close Thrust for AOV 2AF-04002 Listed as 4180 Pounds

Vs 4039 Pounds

AR 2417137 Validate 2AF-04002 Spring Parameters 01/26/2022

AR 2417139 No Evaluation for 2011 and 2017 AOV Test Spring Rate 01/26/2022

Found Below Acceptance Criteria

AR 2417419 Documentation Provided to NRC in Request for 01/28/2022

Information 1.17 for 1AF-4000 Was Medium Risk Vs

Actual Low Risk

AR 2417688 2022 Power Operated Valve (POV) Inspection, Calculation 02/01/2022

2003-0014 MOV Rate of Loading

Drawings 499B466 Sheet Elementary Wiring Diagram Turbine Driven Auxiliary 0

1801 Feedwater Pump Discharge 1AF-4000

499B466 Sheet Elementary Wiring Diagram Steam to TDAFP 2MS2020 24

868

Inspection Type Designation Description or Title Revision or

Procedure Date

499B466 Sheet Elementary Wiring Diagram Turbine Driven Auxiliary 14

869 Feedwater Pump Mini Recirculation Control Valve

2AF-4002

M-217 Sheet 1 Piping & Instrumentation Diagram (P&ID) Auxiliary 107

Feedwater System

WM Powell FIG 19051WE 3" - 900 Pound "Y" Globe Valve 02/26/1968

Sheet 035115

Engineering EC 11683 Modification for Flow Control to Prevent Residual Heat 3

Changes Removal (RHR) Pump Excessive Flow with Containment

Spray Aligned during Recirculation Phase

EC 292094 Replace 1(2) DPIS-4002, DPIS-4007, DPIS-4014 5

Differential Pressure Indicator Switches

Engineering EQCK-LIMIT-001 Environmental Qualification (EQ) Assessment of 4

Evaluations Limitorque SMB Valve Actuators with H/RH Motor

Insulation

PE 433789 Item Equivalency Evaluation; ASCO Valve Part Number 0

NPEF8300141EF

Miscellaneous AOV Margin Review Worksheet; 2AF-04002; Last Valve 0&1

Test Data: March 31, 2017

NRC Request for Information 1.17: Point Beach Power

Operated Valve (POV) Data Submittal

01108-TR-003 Nuclear Management Company Air Operated Valve 1

Program Calculation Guideline

AR 1901191 Operating Experience Evaluation Form; NRC Information 10/11/2013

Notice 2013-14: Potential Design Deficiency in

Motor-Operated Valve Control Circuitry

Group 30 Individual MOV Periodic Verification Report 06/06/2007

AF-4000

IST Appendix B Inservice Testing Program Valve Relief Requests 2

IST Appendix F Inservice Testing Program Technical Positions 12

IST Program Point Beach Nuclear Plant (PBNP) Inservice Testing 9

Document Program 5th Interval

IST Program Inservice Testing Program Table - AF 8

Table - AF

Inspection Type Designation Description or Title Revision or

Procedure Date

NRC-92-085 Letter from Wisconsin Electric Power Company to U.S. 07/30/1992

NRC; Dockets 50-266 and 50-301 In-Service Testing

Pump and Valve Program Third 10-Year Program Safety

Evaluation Report Point Beach Nuclear Plant, Units 1 and

PBM 92-1200 Rate of Loading / Stem-To-Stem Nut Coefficient of Friction 10/07/1992

Evaluation

Specification Motor Operated Valves 2

6118-M-91

Procedures 2-PT-AF-3 2P-29 Turbine-Driven AFW Pump Backup Air System 12

Pressure Decay Test (Refueling) Unit 2

ARB 2C042C4- ARB, 2RC-0430 or 0431C Pressurizer Power Operated 5

Relief Valve (PORV) Not Shut

CMP 2.2 Motor Operated Valves 9

CMP 2.2.1 Determination of the Set-Up Parameters for Motor 2

Operators

CMP 2.2.16 Joint Owners Group (JOG) Periodic Verification (PV) 1

Classification

CMP 2.2.2 Design Basis Review of Valves Driven by Motor Operators 2

CMP 2.2.6 Analysis of Test Signatures Taken during Differential 2

Pressure (DP) Test

CMP 2.2.8.18 MOV Design Basis Review for Valve Family 18 4

CMP 2.2.8.30 MOV Design Basis Review for Valve Family 30 5

CMP 2.2.9 MOV Overthrust/Overtorque Review Guidance 0

CMP 2.5 Point Beach Nuclear Plant AOV Program Document 5

CMP 2.5.1 Point Beach AOV Scoping Methodology 2

CMP 2.5.2 Setup Parameters for Air Operated Valves 2

CMP 2.5.2.1 Setup Parameters for Category 1 Air Operated Valves 15

EC 13398 Repower Valves for TDAFW PUMP 1P-29 0

ER-AA-100 Air Operated Valve Program 4

ER-AA-100-1000 Air Operated Valve Program Implementation 0

ER-AA-100-1001 AOV Design Basis Review 3

ER-AA-103 In-Service Test (IST) Program 3

IT 08A Cold Start of Turbine-Driven Auxiliary Feedwater Pump 86

Inspection Type Designation Description or Title Revision or

Procedure Date

and Valve Test (Quarterly) Unit 1

IT 09A Cold Start of Turbine-Driven Auxiliary Feedwater Pump 77

and Valve Test (Quarterly) Unit 2

MA-AA-100-1014 Limitorque MOV Testing and Actuator Inspections 6

MA-AA-100-1021 Motor Operated Valve Stem Lube and Actuator Gearbox 1

Grease Inspection

OI 128 Safety Injection (SI) System Fill and Vent Unit 1 21

OM 3.20 MOV/AOV/Manual Valve Operating Requirements 19

RMP 9141 Air-Operated Valve Testing and Adjustment 19

Work Orders 00219460 03 SI-00850-0 Inspection/Rebuild 10/10/2006

366848 MOV Actuator Check-Out 03/28/2010

366848 RMP 9376-2 Limitorque MOV Static/DP Testing for Gate 03/09/2010

and Globe Valves

383027 01 MCTW-141 Calibration 08/24/2010

389729 2AF-04002-O / Replace Actuator Base Capscrews 06/17/2011

208015 2AF-4002-S - Replace Solenoid Valve 04/05/2014

253633 1AF-04000-O - Valve Stem Clean & Lubricate 10/19/2014

40418959 2AF-04002 / Minor Air Leak Around Diaphragm 05/10/2017

40453229 2AF-4002-O - Diagnostic Check 04/20/2017

40543620 Diagnostic Test Valve 2SI-00852B 10/15/2018

40543723 2SI-00852B; Stem Lube and Actuator Gear Box Grease 01/24/2019

Replacement

40573109 1AF-04000-O - MOV Actuator Check-Out 04/26/2019

40573109 02 1AF-04000-O / OPS RTS-PMT 04/11/2019

40573198 1AF-04000-O / Stem Lube & Actuator Gearbox Grease 04/11/2019

40644388 2RC-00430 - Rebuild Valve Actuator 04/30/2020

40693383 01 1AF-04000-O; Clean and Inspect Torque Switch Contacts 10/18/2020

40693383 02 1AF-04000-O: OPS RTS-PMT 10/19/2020

40706080 1AF-04002-O/Replace Air Supply Hose 05/26/2020

40726250 2AF-4002-S - Replace Solenoid Valve 10/13/2021

40726905 2SI-00860A MOV Actuator Diagnostics and Inspections 10/31/2021

40726906 2SI-00860A MOV Stem Lube and Gear Box Grease 11/30/2021

Inspections

Inspection Type Designation Description or Title Revision or

Procedure Date

25456-001 Perform Actuator Refurbishment Every 15 Years per 11/09/2000

Environmental Qualification Maintenance Request

(EQMR)

WO 00354830 1SI-0086B Repack Valve 09/15/2018

WO 0215178 SI-00851A MOV Actuator Checkout 04/01/2004

WO 0387601 1SI-00866B Valve Stem Clean and Lube 02/11/2013

WO 40472723 03 SI-00866B-O Actuator Checkout - Inspection and Test 10/07/2017

WO 9948609 MOV Actuator Checkout 10/01/2002

11