IR 05000266/2022010
| 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
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, 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:
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
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/
2022010-01 Potential Inadequate Basis/Justification for Motor-Operated Valve Rate-of-Loading Assumptions 71111.21N.02 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.
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 (Open)
Potential Inadequate Basis/Justification for Motor-Operated Valve Rate-of-Loading Assumptions URI 05000266,05000301/2022010-01 71111.21 N.02
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
Procedure
Type
Designation
Description or Title
Revision or
Date
01109-C-005
Auxiliary Feedwater (AFW) Air Operated Valve (AOV)
Functional and Maximum Expected Differential Pressure
(MEDP) Calculation
01109-C-018
AOV Component Level Calculation; 0AF-04007,
0AF-04014, 1AF-04002, and 2AF-04002
2001-0056
Turbine Driven Auxiliary Feedwater Pump (TDAFP)
Mini-Recirculation Valve (1/2AF-4002) Instrument Air
Accumulator Sizing
2003-0014
Motor Operated Valve (MOV) Operating Parameters,
Group 15
2004-0002
Alternating Current (AC) Electrical System Analysis
97-0041
Functional Times for Emergency Safeguards Equipment to
Be Used in Point Beach Accident Analysis
N-93-086
(2) AF-4000, AF-4001 (Group 30) MOV Differential
Pressure Calculation
& 0A
N-94-019
Determination of Conditions for MOV Pressure Locking
and Thermal Binding
04/13/1994
P-89-031
Voltage Drop Across MOV Power Lines
P-90-017
MOV Undervoltage Stem Thrust and Torque
P-94-004
MOV Thermal Overload Evaluation
P-94-004; EC 294777 Pending
Change A
MOV Overload Heater Evaluation
P-94-005
Motor Stem Thrust Calculation
Calculations
Powell 01-12-
1988
Maximum Thrust Calculations - Point Beach Nuclear Plant
(Wisconsin Electric)
01/12/1988
Corrective Action
Documents
1SI866B Overthrust Event
11/17/2017
Alarm Response Book (ARB) for 2RC-0430, Low
Temperature Over Pressure (LTOP) Defined Incorrectly
01/13/2022
71111.21N.02
Corrective Action
Documents
Resulting from
Inspection
Calculation P-94-005, Use of Torque Reaction Factor
Inversed
01/17/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
1SI-866B 2017 as Left Test Review, as Left Close Thrust
Below Minimum Required and No Evaluation Performed
01/18/2022
The Work Plan for Work Order 4072625-03 Step 5 Directs
Performer to Circle the PMT Done of Two Listed and None
Circled
01/24/2022
Work Order Documentation for 1AF-04000; RMP9376-2
for 03/09/2010 Recorded 180 Foot Pounds for Mounting
Bolts Instead of 88 Foot Pounds
01/24/2022
MOV Design Basis Review of Valve Family 30 Shows
Medium Risk Vs. Actual Low Risk
01/24/2022
Drawing Discrepancy; Stem Speed for 1/2AF-04000
Shown as 4.21 Inches/Minute Vs 7.375 Inches/Minute
01/252022
Training Work Request Written Against Operations
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
01/25/2022
Model Number for New Solenoid 2AF-4002-S Not
Updated in Component Database
01/25/2022
Criterion Error in MOV Test Software
01/25/2022
Air Operated Valve (AOV) Trending Spread Sheet Error,
Close Thrust for AOV 2AF-04002 Listed as 4180 Pounds
Vs 4039 Pounds
01/25/2022
Validate 2AF-04002 Spring Parameters
01/26/2022
No Evaluation for 2011 and 2017 AOV Test Spring Rate
Found Below Acceptance Criteria
01/26/2022
Documentation Provided to NRC in Request for
Information 1.17 for 1AF-4000 Was Medium Risk Vs
Actual Low Risk
01/28/2022
22 Power Operated Valve (POV) Inspection, Calculation
2003-0014 MOV Rate of Loading
2/01/2022
499B466 Sheet
1801
Elementary Wiring Diagram Turbine Driven Auxiliary
Feedwater Pump Discharge 1AF-4000
Drawings
499B466 Sheet
868
Elementary Wiring Diagram Steam to TDAFP 2MS2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
499B466 Sheet
869
Elementary Wiring Diagram Turbine Driven Auxiliary
Feedwater Pump Mini Recirculation Control Valve
M-217 Sheet 1
Piping & Instrumentation Diagram (P&ID) Auxiliary
Feedwater System
107
WM Powell
Sheet 035115
FIG 19051WE 3" - 900 Pound "Y" Globe Valve
2/26/1968
Modification for Flow Control to Prevent Residual Heat
Removal (RHR) Pump Excessive Flow with Containment
Spray Aligned during Recirculation Phase
Engineering
Changes
Replace 1(2) DPIS-4002, DPIS-4007, DPIS-4014
Differential Pressure Indicator Switches
EQCK-LIMIT-001
Environmental Qualification (EQ) Assessment of
Limitorque SMB Valve Actuators with H/RH Motor
Insulation
Engineering
Evaluations
PE 433789
Item Equivalency Evaluation; ASCO Valve Part Number
NPEF8300141EF
AOV Margin Review Worksheet; 2AF-04002; Last Valve
Test Data: March 31, 2017
& 1
NRC Request for Information 1.17: Point Beach Power
Operated Valve (POV) Data Submittal
01108-TR-003
Nuclear Management Company Air Operated Valve
Program Calculation Guideline
Operating Experience Evaluation Form; NRC Information Notice 2013-14: Potential Design Deficiency in
Motor-Operated Valve Control Circuitry
10/11/2013
Group 30
AF-4000
Individual MOV Periodic Verification Report
06/06/2007
IST Appendix B
Inservice Testing Program Valve Relief Requests
IST Appendix F
Inservice Testing Program Technical Positions
IST Program
Document
Point Beach Nuclear Plant (PBNP) Inservice Testing
Program 5th Interval
Miscellaneous
IST Program
Table - AF
Inservice Testing Program Table - AF
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Letter from Wisconsin Electric Power Company to U.S.
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
07/30/1992
PBM 92-1200
Rate of Loading / Stem-To-Stem Nut Coefficient of Friction
Evaluation
10/07/1992
Specification
6118-M-91
Motor Operated Valves
2-PT-AF-3
2P-29 Turbine-Driven AFW Pump Backup Air System
Pressure Decay Test (Refueling) Unit 2
ARB 2C042C4-
ARB, 2RC-0430 or 0431C Pressurizer Power Operated
Relief Valve (PORV) Not Shut
CMP 2.2
Motor Operated Valves
CMP 2.2.1
Determination of the Set-Up Parameters for Motor
Operators
CMP 2.2.16
Joint Owners Group (JOG) Periodic Verification (PV)
Classification
CMP 2.2.2
Design Basis Review of Valves Driven by Motor Operators
CMP 2.2.6
Analysis of Test Signatures Taken during Differential
Pressure (DP) Test
CMP 2.2.8.18
MOV Design Basis Review for Valve Family 18
CMP 2.2.8.30
MOV Design Basis Review for Valve Family 30
CMP 2.2.9
MOV Overthrust/Overtorque Review Guidance
CMP 2.5
Point Beach Nuclear Plant AOV Program Document
CMP 2.5.1
Point Beach AOV Scoping Methodology
CMP 2.5.2
Setup Parameters for Air Operated Valves
CMP 2.5.2.1
Setup Parameters for Category 1 Air Operated Valves
Repower Valves for TDAFW PUMP 1P-29
Air Operated Valve Program
Air Operated Valve Program Implementation
AOV Design Basis Review
In-Service Test (IST) Program
Procedures
IT 08A
Cold Start of Turbine-Driven Auxiliary Feedwater Pump
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
and Valve Test (Quarterly) Unit 1
IT 09A
Cold Start of Turbine-Driven Auxiliary Feedwater Pump
and Valve Test (Quarterly) Unit 2
Limitorque MOV Testing and Actuator Inspections
Motor Operated Valve Stem Lube and Actuator Gearbox
Grease Inspection
OI 128
Safety Injection (SI) System Fill and Vent Unit 1
OM 3.20
MOV/AOV/Manual Valve Operating Requirements
RMP 9141
Air-Operated Valve Testing and Adjustment
219460 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
and Globe Valves
03/09/2010
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
Replacement
01/24/2019
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
Work Orders
40726906
2SI-00860A MOV Stem Lube and Gear Box Grease
Inspections
11/30/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
25456-001
Perform Actuator Refurbishment Every 15 Years per
Environmental Qualification Maintenance Request
(EQMR)
11/09/2000
1SI-0086B Repack Valve
09/15/2018
SI-00851A MOV Actuator Checkout
04/01/2004
1SI-00866B Valve Stem Clean and Lube
2/11/2013
WO 40472723 03
SI-00866B-O Actuator Checkout - Inspection and Test
10/07/2017
MOV Actuator Checkout
10/01/2002