IR 05000266/2023010

Comprehensive Engineering Team Inspection Report 05000266/2023010 and 05000301/2023010

ML23053A049
Person / Time
Site:	Point Beach
Issue date:	02/23/2023
From:	Karla Stoedter NRC/RGN-III/DORS/EB1
To:	Strope M Point Beach
References
IR 2023010
Download: ML23053A049 (1)

Text

SUBJECT:

POINT BEACH NUCLEAR PLANT - COMPREHENSIVE ENGINEERING TEAM INSPECTION REPORT 05000266/2023010 AND 05000301/2023010

Dear Michael Strope:

On February 7, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Point Beach Nuclear Plant and discussed the results of this inspection with Michael Rosseau and other members of your staff. The results of this inspection are documented in the enclosed report.

Three findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Point Beach Nuclear Plant.

If you disagree with a cross-cutting aspect assignment or 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 Point Beach Nuclear Plant.February 23, 2023 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 1 Division of Operating 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: 05000266/2023010 and 05000301/2023010

Licensee: NextEra Energy Point Beach, LLC

Facility: Point Beach Nuclear Plant

Location: Two Rivers, WI

Inspection Dates: January 09, 2023 to January 27, 2023

Inspectors: K. Barclay, Senior Reactor Inspector J. Corujo-Sandin, Senior Reactor Inspector K. Fay, Reactor Inspector B. Jose, Senior Reactor Inspector D. Melendez-Colon, Reactor Inspector J. Park, Reactor Inspector L. Rodriguez, Senior Reactor Inspector

Approved By: Karla K. Stoedter, Chief Engineering Branch 1 Division of Operating Reactor Safety

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a Comprehensive Engineering Team 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

Failure to Perform an Adequate Operating Experience Evaluation of NRC Information Notice 2017-06 Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.6] - Design 71111.21M Systems FIN 05000266,05000301/2023010-01 Margins Open/Closed The inspectors identified a finding (FIN) of very low safety significance (Green), for the licensees failure to perform an adequate operating experience evaluation for NRC Information Notice 2017-06, which identified how the site might be vulnerable to the situation described in the IN. This was contrary to Point Beach Procedure PI-AA-102-1001, Operating Experience Program Screening and Responding to Incoming Operating Experience.

Specifically, the licensee failed to evaluate the effects of the additional short circuit current expected from the battery chargers and determine the impact on the direct current distribution buses and interrupting devices.

Failure to Include Valve FO-3983A into Inservice Test (IST) Program Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.1] - 71111.21M Systems NCV 05000266,05000301/2023010-02 Resources Open/Closed The inspectors identified a finding of very low safety significance (Green) and an associated non-cited violation (NCV) of 10 CFR 50.55a(f), Preservice and Inservice Testing Requirements, for the licensees failure to include Emergency Diesel Generator (EDG) Fuel Oil Transfer Pump (FOTP) Discharge Unloader Valve, FO-3983A, into the IST Program in accordance with American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code - 2017 Edition, Subsection ISTA-1100, Scope. Specifically, during the most recent IST Program update, the licensee incorrectly applied the exclusion criteria from the ASME OM Code to the valve, resulting in the exclusion of its safety functions from the scope of the IST Program for testing.

Failure to Verify the Adequacy of Design during Validation of Time Critical Operator Actions Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.3] - 71111.21M Systems NCV 05000266,05000301/2023010-03 Resolution Open/Closed The inspectors identified a finding of very low safety significance (Green) and a Non-Cited Violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to ensure core cooling flow could be maintained and not interrupted during the transition from the injection phase to the recirculation phase assuming a single failure.

Specifically, when verifying the adequacy of design via time critical operator actions, the licensee failed to assume a more limiting single failure of valve SI-856A or SI-856B.

Additional Tracking Items

Type Issue Number Title Report Section Status URI 05000266,05000301/20 Containment Air 71111.21M Closed 21010-01 Recirculation System Design Function Change

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

===71111.21M - Comprehensive Engineering Team Inspection (CETI)

The inspectors evaluated the following components and listed applicable attributes, permanent modifications, and operating experience:

Structures, Systems, and Components (SSCs) (IP section 03.01)===

For each component sample, the inspectors reviewed the licensing and design bases including:

(1) the Final Safety Analysis Report (FSAR), as updated;

(2) the Technical Specifications (TS); and

(3) the Technical Requirements Manual (TRM). The inspectors reviewed a sample of operating procedures (including normal, abnormal, and emergency procedures), overall system/component health (including condition reports and operability evaluations, if any) and associated maintenance effectiveness (e.g., Maintenance Rule, procedures). The inspectors performed visual inspections of the accessible components to identify potential hazards and/or signs of degradation. Additional component specific design attributes reviewed by the inspectors are listed below.

(1) Unit 2: 4.160 KV Bus (2-A05)1. Protection against internal/external events:

a. Flooding, including sump pump b. High Energy Line Break (HELB)c.

Fire 2. Test/inspection procedures, acceptance criteria, and recent results 3. Electrical design calculations and considerations:

a. Loading calculations b. Short circuit calculations c.

Voltage regulation d. Coordination calculations e. Bus capacity 4. Degraded voltage protection 5. Loss of voltage protection

(2) Unit 2: 4.160 KV Breaker (2A52-76)1. Protection against internal/external events:

a. Flooding, including sump pump b. HELB c.

Fire

2. Test/inspection procedures, acceptance criteria, and recent results

3. Electrical design calculations and considerations 4. Available short circuit current at the load side of the breaker & interrupting rating

(3) Unit 2: Safety Injection (SI) Pump (2P-15A)1. Environmental qualification 2. Protection against external events: Seismic 3. Mechanical design calculations and considerations:

a. Flow capacity & balance b. Minimum flow c.

Required submergence i. Net Positive Suction Head (NPSH)ii. Vortexing d. Gas intrusion & accumulation e. Pump cooling 4. Test/inspection procedures, acceptance criteria, and recent results:

a. Pump comprehensive In Service Test (IST) surveillances b. Pump quarterly IST surveillances c.

Full of water verification at suction piping d. Cable ampacity

(4) Unit 2: SI Pump Minimum Flow Valve (2-SI-897A)1. Protection against external events: Seismic 2. Mechanical design calculations and considerations:

a. Weak link analysis b. Maximum allowed leakage c.

Maximum differential pressure 3. Test/inspection procedures, acceptance criteria, and recent results:

a. IST b. Leak Rate Testing c.

Control logic

(5) Emergency Diesel Generator (EDG) G-02 Fuel Oil Transfer Pump (P-207A)1. Protection against internal/external events:

a. Flooding, including sump pump 2. Mechanical design calculations and considerations:

a. Flow capacity b. Room heat up calculations c.

Room cooling d. Strong pump versus weak pump interaction 3. Test/inspection procedures, acceptance criteria, and recent results:

a. Pump comprehensive IST surveillances b. Pump quarterly IST surveillances 4. Electrical design calculations and considerations:

a. Motor b. Protective devices c.

Cable ampacity d. Minimum voltage

(6) Room Exhaust Fan for EDG G-02 (W-184B)1. Protection against external events: Seismic 2. Mechanical design calculations and considerations 3. Test/inspection procedures, acceptance criteria, and recent results:

4. Electrical design calculations and considerations:

a. Motor b. Fan motor voltage drop c.

Fan motor degraded voltage d. Fan motor brake horsepower e. Cable ampacity

(7) Unit 2: Component Cooling Water (CCW) Pump (2-P11A)1. Translation of vendor specifications 2. Environmental qualification 3. Protection against internal/external events:

a. Flooding, including sump pump b. Seismic c.

Fire 4. Mechanical design calculations and considerations:

a. Flow capacity b. Flow balance c.

Minimum flow d. Required submergence: NPSH 5. Gas intrusion 6. Test/inspection procedures, acceptance criteria, and recent results:

a. Pump comprehensive IST surveillances b. Pump quarterly IST surveillances c.

Emergency water make-up 7. Electrical design calculations and considerations:

a. Motor b. Pump motor voltage drop c.

Pump motor degraded voltage d. Protective devices e. Cable ampacity f.

Minimum voltage g. Control logic 8. Chemistry Control

(8) Unit 2: Residual Heat Removal (RHR) Heat Exchanger (2-HX-011A)1. Protection against external events: Seismic 2. Design calculations and considerations:

a. Minimum cooling water flowrate b. Maximum cooling water temperature 3. Tube plugging limit 4. Heat transfer capacity 5. Test/inspection procedures, acceptance criteria, and recent results:

a.

Flowrates b. Inspection or thermal performance test c.

Eddy current 6. Chemistry Controls

(9) Unit 2: CCW to RHR Heat Exchanger Supply Motor Operated Valve (MOV)

(CC-0738A)1. Environmental qualification 2. Protection against internal/external events:

a. Flooding, including sump pump b. Fire c.

Weak link analysis d. Required thrust (torque)e. Pressure locking and/or thermal binding f.

Closure/Opening time g. Maximum allowed leakage h. Maximum differential pressure 3. Test/inspection procedures, acceptance criteria, and recent results:

a. IST b. Thermal overload testing c.

TS Surveillance Required 4. Motor power requirements:

a. Voltage drop b. Control logic c.

Control voltage drop d. Thermal overload e. Required minimum voltage f.

Degraded voltage effects g. Brake horsepower h. Motor thermal overload protection i.

Cable ampacity j.

Protective devices k.

Emergency power (EDG, battery)

Modifications (IP section 03.02) (6 Samples)

(1) Engineering Change (EC) 295131 - Electrical Calculations for SI-850 Motors

(2) EC 295002 - 2004-0025 Rev. 2 Cable Ampacity and Overload Protection Methodology

(3) EC 293182 - IWL Containment Tendon Inspection Lift-Off Calculations Containment Tendon Predicted Lift-Off Force for the 48th Through 63rd Year Surveillance (N-4460-79)

(4) EC 295288 - Calculation N-93-076 Revision 2 1(2) SI-851A, 851B 1(2) SI-856A, 856B (Group 16) MOV Differential Pressure Calculation

(5) EC 295798 - Time Available to Locally Close SI-856 in a Loss of Coolant Accident

(6) EC 294514, Evaluation of EDGs G-03 and G-04 Frequency Response during U1R38 10 CFR 50.59 Evaluations/Screening (IP section 03.03) (13 Samples)

(1) Evaluation (EVAL) 2021-001 - Procedure Operating Instruction (OI) 72, Containment Air Recirculation System

(2) EVAL 2018-003 - Calculation EC289805, Owners Acceptance Review and Incorporation of Corrected Westinghouse Calculations CN-CRA-12-26 and CN-CRA-12-27

(3) Screening (SCR) 2022-0015 - 50.59 Screening for EC 297391; FSAR Change for Spray Additive Tank without Nitrogen Blanket

(4) SCR 2021-0001 - 50.59 Screening for EC 295641; 4160V Cross-Tie Breaker Control Power Fuse Configuration Control

(5) SCR 2021-0006 - 50.59 Screening for Procedure Change Request (PCR) 2356873; 1-SOP-CC-002, Component Cooling System Drain and Refill

(6) SCR 2021-0026 - 50.59 Screening for PCR 2373485; Changes to U1 and U2 OP-1C

(7) SCR 2021-0062 - 50.59 Screening for AR 02395097; Clearance 1 RH-713B REACH ROD 01

(8) SCR 2021-0068 - 50.59 Screening for LICA 02397067-01; TS B 3.6.3, Containment Isolation Valves Bases Change

(9) SCR 2021-0089 - 50.59 Screening for LIC 02403960; TRM 4.12 Diesel Fuel Oil for Allowable Biodiesel

(10) SCR 2020-0020 - 50.59 Screening for PCR 02314774; Exemption of FSGs from requirements of 10CFR50.59

(11) SCR 2020-0040 - 50.59 Screening for EC 294728; EC 294728 TMOD D-501 Battery Charger

(12) SCR 2019-0097 - 50.59 Screening for EC 00291482; EC 291482 SI Pump Gas Void Monitoring Sensors

(13) SCR 2019-0103 - 50.59 Screening for EC 293505; Leading Edge Flow Meter Electronics Upgrade

Operating Experience Samples (IP section 03.04) (3 Samples)

(1) NRC Information Notice (IN) 2017-06 - Battery and Battery Charger Short-Circuit Current Contributions to a Fault on the Direct Current (DC) Distribution System

(2) NRC IN 2009-22 - Biodiesel in Fuel Oil Impact on Diesels

(3) NRC IN 2019-02 - EDG Excitation System Diode Failures

INSPECTION RESULTS

Failure to Perform an Adequate Operating Experience Evaluation of NRC Information Notice 2017-06 Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.6] - Design 71111.21M Systems FIN 05000266,05000301/2023010-01 Margins Open/Closed The inspectors identified a finding (FIN) of very low safety significance (Green), for the licensees failure to perform an adequate operating experience evaluation for NRC Information Notice 2017-06 which identified how the site might be vulnerable to the situation described in the IN. This was contrary to Point Beach Procedure PI-AA-102-1001, Operating Experience Program Screening and Responding to Incoming Operating Experience.

Specifically, the licensee failed to evaluate the effects of the additional short circuit current expected from the battery chargers and determine the impact on the direct current distribution buses and interrupting devices.

Description:

Information Notice (IN) 2017-06 discussed test results published in NUREG/CR-7229 by Brookhaven National Laboratories on different types of battery chargers under short circuit conditions. The test results showed short circuit current contribution from a silicon-controlled rectifier (SCR) type battery charger could be as high as 7 to 10 times the charger's full load rating during the first 100 milliseconds. Point Beach has 500 ampere SCR type battery chargers and therefore, the short circuit current could contribute approximately 3500 to 5000 amperes if a fault occurred in the direct current (DC) system. During the Comprehensive Engineering Team Inspection (CETI), NRC inspectors asked the licensee for their response to IN 2017-06 and learned the licensee had not performed an adequate evaluation of the IN for applicability to their site, even though multiple action requests had been written by corporate and site engineering personnel regarding the IN.

Action Request (AR) 02227317 was initiated on September 28, 2017, by the licensees corporate engineering group. This AR recommended actions which required each site to review their fault and coordination calculations for their DC systems to determine how they will be impacted by the newly published NRC information as documented in NRC IN 2017-06.

The Point Beach specific closure notes for this AR stated, "DC fault and coordination calculation was reviewed against NRC IN 2017-06 and NUREG/CR-7229. Calculation (N-92-005) may be impacted thus action 05 was created specifically for Point Beach to formally review the calculation and determine if revision is required. Perform revision as appropriate. AR has been cross referenced. No further actions required in this Operating Experience

Analysis.

"

NextEra Corporate initiated AR 02246548 on January 26, 2018, to track a planned revision to IEEE Standard 946-2004 and review the revised standard to determine new industry guidance for calculating battery charger fault current contribution in applicable DC calculations at the St. Lucie plant. The completion notes in this AR stated, in part, "Compliance with the new IEEE standard is not a regulatory requirement and is considered an enhancement. Any future modifications to the systems will be performed in accordance with the applicable regulatory requirements. Note Point Beach is planning replacement of safety-related battery chargers under EC 297024. Part of the design will be to ensure the calculations are performed in accordance with the applicable regulatory requirements and standards."

On January 29, 2018, Point Beach initiated AR 02246825 which stated, "NRC Information Notice (IN) 2017-06, Battery and Battery Charger Short-Circuit Current Contributions to a fault on the Direct Current Distribution System, is dated September 26, 2017. Corporate had created OE02227317, with Assignment -05 to document relevance to Point Beach; however, AR 02246548 is created for Site Engineering to further track conduct of needed actions." The closure comments in this AR stated, "actions needed for the follow up review of the industry revised IEEE Standard 946-2004 is already captured and administratively tracked via AR02246548 for all sites. Closing to AR 02246548 to avoid duplicative work."

On February 6, 2018, Point Beach Design Engineering initiated AR 02248004 which stated, "DC fault and coordination calculations were reviewed against NRC IN 2017-06 and NUREG/CR-7229. Calculation (N-92-005) may be impacted thus action was created to formally review calculation and determine if revision is required. Perform revision as appropriate. Reference OE 2227317." The closure comments in this AR stated, "OE AR 2246825 was created for Point Beach to review this OE. This routine work task should be closed to actions being taken via AR 2246825."

As part of the licensee's pre-inspection self-assessment, AR 02443596 was initiated on December 12, 2022. This AR stated, "Review IEEE 946 - 2020. This AR does not challenge any plant equipment functions - this AR requests review of existing DC calculations against updated code guidance, for possible revisions." In the Operability Notes section of this AR, the senior reactor operator wrote, "The condition does not constitute a new degraded or unanalyzed condition involving an SSC (Systems Structures or Component) that is either required to be OPERABLE per TS (Technical Specifications) or required to perform a support function for such SSCs. Therefore, an OPERABILITY determination is not required. Also, the condition does not constitute a new degraded or unanalyzed condition that involves the ability of a non-TS SSC to perform its specified CLB (Current Licensing Basis) function. Therefore, a Functionality assessment is not required. The condition does not meet the reporting criteria of 10 CFR 50.72."

Based upon the review of the ARs discussed above and the responses to questions posed by the inspectors, Point Beach initiated AR 02445800 to evaluate the effects of the additional fault current contribution from the battery chargers to the interrupting devices (fuses) inside the chargers and the DC distribution panels. The licensee also planned to evaluate the current carrying capacity of DC distribution panel buses. The inspectors reviewed the licensee's completed evaluation dated January 12, 2023, and noted two DC distribution panel buses (D-31 and D-41) exceeded their maximum rated current carrying capacity by approximately 600 amperes. However, when the data was input into ETAP (Electrical Transient Analyzer Program), which accounted for the cable resistance up to the panel buses, the fault currents remained less than the bus ratings. The inspectors independently assessed the coordination between various fuses and did not identify any issues of concern.

The inspectors reviewed PI-AA-102-1001, Operating Experience Program Screening and Responding to Incoming Operating Experience, Revision 19. This was the licensees procedure for processing, screening, reviewing, evaluating, and taking actions in response to OE information. Revision 19 was the procedure revision in effect at the time the IN was issued. In reviewing procedure PI-AA-102-1001, the inspectors identified several sections of the procedure requiring an adequate evaluation of OE. Section 4.1.4.B of the procedure states, If new information is received for an event or an issue that was previously reviewed, additional review should be performed to ensure that any new issues, information, or concerns are considered. Section 4.2.1 states, Ensure the adequacy of scope of the evaluation: Summarize the basic issue. Document applicability and potential consequences to the site. Describe how the event relates to applicable plant processes, practices or equipment (barriers currently affected). Identify how the site might be vulnerable to this situation (barriers that need strengthening), what lessons might be learned, and what actions are to be taken. Actions, recommendations, lessons learned and prevent events questions in the source document should be evaluated and addressed. The inspectors also reviewed the subsequent revisions of the procedure (Revision 20 through 29) and found similar or identical statements to those in Revision 19.

The inspectors determined the licensee did not follow Sections 4.1.4.B and 4.2.1 of procedure PI-AA-102-1001. Specifically, the licensee had not performed an OE review of the information provided in IN 2017-06 which adequately documented the applicability, vulnerability, and potential consequences to the site even though site and corporate engineering personnel had written multiple ARs discussing the IN. The inspectors concluded the failure to follow procedure PI-AA-102-1001, a self-imposed standard, was a performance deficiency. No violations of NRC requirements were identified since procedure PI-AA-102-1001 was not safety-related and therefore, not subject to 10 CFR Part 50, Appendix B requirements.

Corrective Actions: The licensee performed the OE evaluation for IN 2017-06 on January 12, 2023, and concluded the larger short circuit current contribution from the charger did not exceed the interrupting ratings of isolation devices and maximum current carrying capacity of DC distribution panel buses. The licensee planned to update calculations N-93-058 and N-93-059 to ensure the Bus D-301 short-circuit was consistent with specification PB 501 and calculation N-92-005.

Corrective Action References: AR 02445800; 2023 CETI - Document Analysis for IN 2017-06.

Performance Assessment:

Performance Deficiency: The inspectors determined the licensees failure to perform an adequate OE evaluation for IN 2017-06 which adequately documented the applicability, vulnerability, and potential consequences of the situation described in the IN was contrary to Section 4.2.1 of procedure PI-AA-102-1001, Operating Experience Program Screening and Responding to Incoming Operating Experience, Revision 19, and was a performance deficiency. Specifically, the licensee failed to evaluate the effects of additional short circuit current expected from the battery chargers and determine the impact on the DC distribution buses and interrupting devices.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to perform an adequate OE evaluation for NRC IN 2017-06 resulted in a condition where there was a reasonable doubt that equipment and isolation devices (DC distribution panel buses and fuses) were able to safely withstand and interrupt the larger short circuit conditions provided by the chargers as described in the IN.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.

Specifically, the finding screened as very low safety significance (Green) because the DC distribution panel buses and fuses maintained their operability and/or probabilistic risk assessment functionality.

Cross-Cutting Aspect: H.6 - Design Margins: The organization operates and maintains equipment within design margins. Margins are carefully guarded and changed only through a systematic and rigorous process. Special attention is placed on maintaining fission product barriers, defense-in-depth, and safety-related equipment. Specifically, the licensee failed to ensure the design margins for safety-related equipment were guarded and maintained. This resulted in the failure to properly consider the effects of additional short circuit contribution from the safety-related battery chargers to the interrupting devices (both internal and external) and the DC distribution panel buses.

Enforcement:

Inspectors did not identify a violation of regulatory requirements associated with this finding.

Failure to Include Valve FO-3983A into Inservice Test (IST) Program Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.1] - 71111.21M Systems NCV 05000266,05000301/2023010-02 Resources Open/Closed The inspectors identified a finding of very low safety significance (Green) and an associated non-cited violation (NCV) of 10 CFR 50.55a(f), Preservice and Inservice Testing Requirements, for the licensees failure to include Emergency Diesel Generator (EDG) Fuel Oil Transfer Pump (FOTP) Discharge Unloader Valve, FO-3983A, into the IST Program in accordance with American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code - 2017 Edition, Subsection ISTA-1100, Scope. Specifically, during the most recent IST Program update, the licensee incorrectly applied the exclusion criteria from the ASME OM Code to the valve, resulting in the exclusion of its safety functions from the scope of the IST Program for testing.

Description:

Point Beach Nuclear Plant (PBNP) Final Safety Analysis Report (FSAR), Section 8.8, Diesel Generator (DG) System, delineated the tanks and piping needed for emergency diesel operation as safety related. PBNP IST Program Appendix F, Technical Positions - TP-06, Revision 12, delineated valve FO-3983A as Code Class 3 and IST Category B. The valve is located in the recirculation line from the discharge line of the associated FOTP, P-207A, back to Diesel Fuel Oil Storage Tank T-175A. This valve had been designated by the licensee as a pressure-regulating valve with a setpoint of 26 psig in order to limit the fuel oil flow rate and maintain constant flow velocity. Additionally, this valve was considered by the licensee to be skid-mounted based on it being sufficiently exercise tested during the EDG transfer pump test.

ASME OM Code, 2017 Edition, Subsection ISTC-1200(a)(2) stipulated, in part, that valves used only for system control, such as pressure-regulating valves are excluded from the IST scope. Subsection ISTC-1200(b) stipulated, in part, that skid-mounted valves that are tested as part of the major component and are justified by the Owner to be adequately tested are excluded from the IST scope. Based on these exclusion criteria, the licensee excluded FO-3983A from their IST Program during the most recent IST Program update for the sixth interval. As part of the update, the IST Program Appendix F, Technical Position - TP-06, was subsequently removed in Revision 13.

The inspectors were concerned with the licensees application of the exclusion criteria. Specifically, although the inspectors agreed that FO-3983A performed the system control function as stipulated in ISTC-1200(a)(2), the inspectors did not agree that the system control was the only function performed by this valve. For example, Section 3.2.12 of the emergency diesel generator design-basis document, DBD-16, described that this valve also functions to limit the pressure build up on the discharge line to prevent the transfer pump from over pressurizing the discharge piping. The IST Program Appendix F, Technical Positions - TP-06, Revision 12, described this valve as performing an active safety function in the throttled (i.e., open) position to provide overpressure protection for the transfer pumps and discharge piping. Although transfer pump P-207A was equipped with its own internal relief valve, FO-3972A, which provides overpressure protection for the pump, the PBNP IST Background Valve Data Sheet for Valve FO-3972A stipulated its capacity is limited such that continued operation of the pump with recirculation via this relief valve only would result in damage to the pump due to overheating.

Furthermore, both the IST Program Appendix F, Technical Positions - TP-06, Revision 12, and the PBNP IST Background Valve Data Sheet for Valve FO-3983A described this valve as also performing a passive safety function in the closed position. Both documents further explained that valve FO-3983A failing to properly function to maintain back pressure because of premature lifting could allow a significant amount of pump discharge flow to be diverted back to storage tank T-175A in lieu of being properly directed to the respective day tank. Therefore, the inspectors concluded that in addition to valve FO-3983A performing a system control function, it also performed the safety-related pressure relief function (i.e., open) as well as the safety function in the closed direction.

The inspectors determined the licensee lacked sufficient basis for concluding valve FO-3983A could be considered skid-mounted in accordance with Subsection ISTC-1200(b),and hence excluded from the IST Program. Specifically, the definition for skid-mounted pumps and valves in Subsection ISTA-2000, Definitions, did not include the diesel fuel oil transfer pumps and valves as one of the examples of the skid-mounted components. The inspectors also noted valve FO-3983A and pump P-207A were provided by different vendors.

Furthermore, NUREG-1482, Guidelines for Inservice Testing at Nuclear Power Plants, Revision 2, Table 2.1, Typical Systems and Components in an Inservice Testing Program for a Pressurized-Water Reactor, specifically included the fuel oil storage and transfer pumps and valves as those components that are typically included in an IST program. Therefore, the inspectors concluded that exclusion of the subject valve from the IST Program based on the ISTC-1200(b) criterion was inappropriate.

Corrective Actions: The licensee corrective actions included reviewing Procedures IT 14 G-02, Inservice Test of Fuel Oil Transfer System Pump and Valves G-02, and IT 14B, "Setpoint Test of EDG G-02 FOTP Unloader Valve," for any changes as a result of the IST Program update. The licensee determined there were no operability concerns with FO-3983A. The licensee determined this condition also applied to valve FO-3982A, "G-01 EDG FOTP Discharge Unloader Valve."

Corrective Action References: AR 2446907, 2023 CETI - FO-3983A Identified Not Included in IST Program

Performance Assessment:

Performance Deficiency: The licensee's failure to include valve FO-3983A into the IST Program in accordance with ASME OM Code - 2017 Edition, Subsection ISTA-1100, "Scope," was contrary to 10 CFR 50.55a(f)(4) and was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, absent NRC's intervention, the failure to include FO-3983A into the IST Program could have led to the licensee not performing ASME OM Code required testing to demonstrate the valve can perform its required safety functions.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.

Specifically, the inspectors answered no to all the questions in Exhibit 2.A. A review of recent test results provided reasonable assurance valve FO-3983A would continue to perform its required safety functions.

Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety.

Specifically, leaders did not ensure thorough review and oversight of the IST program change for adequacy to support testing the safety functions of valve FO-3983A.

Enforcement:

Violation: Title 10 CFR 50.55a(f), Preservice and inservice testing requirements, required, in part, that systems and components of boiling and pressurized water-cooled nuclear power reactors must meet the requirements for preservice and inservice testing of the ASME BPV Code and ASME OM Code as specified in this paragraph (f).

Title 10 CFR 50.55a(f)(4), Inservice testing standards requirement for operating plants, required, in part, that throughout the service life of a boiling or pressurized water-cooled nuclear power facility, pumps and valves that are within the scope of the ASME OM Code must meet the inservice test requirements set forth in the ASME OM Code.

Title 10 CFR 50.55a(f)(4)(ii), Applicable IST Code: Successive 120-month interval, required, in part, that inservice tests to verify operational readiness of pumps and valves, whose function is required for safety, conducted during successive 120-month intervals must comply with the requirements of the latest edition and addenda of the ASME OM Code incorporated by reference in paragraph (a)(1)(iv) of this section 18 months before the start of the 120-month interval.

PBNP IST Program Document, Revision 11, delineated the code of record for the sixth 10-year IST interval as the 2017 Edition ASME OM Code as referenced by paragraph (a)(1)(iv)(C).

ASME OM-2017 Edition, Subsection ISTA-1100, Scope, stated in part, that Section IST establishes the requirements for preservice and inservice testing and examination of certain components to assess their operational readiness in water-cooled reactor nuclear power plants. It identifies the components subject to test or examination, responsibilities, methods, intervals, parameters to be measured and evaluated, criteria for evaluating the results, corrective actions, personnel qualification, and record keeping. These requirements apply to:

(a) pumps and valves that are required to perform a specific function in shutting down a reactor to the safe shutdown condition, in maintaining the safe shutdown condition, or in mitigating the consequences of an accident

(b) pressure relief devices that protect systems or portions of systems that perform one or more of the three functions identified in subpara.

(a) Contrary to the above, as of January 27, 2023, the licensees inservice testing program, during the successive 120-month intervals, failed to comply with the requirements of the latest edition and addenda of the ASME OM Code incorporated by reference in paragraph (a)(1)(iv) of section 50.55a, applicable to the Point Beach Nuclear Plant. Specifically, the licensee failed to include valve FO-3983A into the scope of the IST program as required by Section ISTA-1100 of the ASME OM-2017 Edition.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Verify the Adequacy of Design During Validation of Time Critical Operator Actions Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.3] - 71111.21M Systems NCV 05000266,05000301/2023010-03 Resolution Open/Closed The inspectors identified a finding of very low safety significance (Green) and a Non-Cited Violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to ensure core cooling flow could be maintained and not interrupted during the transition from the injection phase to the recirculation phase assuming a single failure.

Specifically, when verifying the adequacy of design via time critical operator actions, the licensee failed to assume a more limiting single failure of valve SI-856A or SI-856B.

Description:

During the inspectors review of Operations Manual (OM) 4.3.8, "Control of Time Critical and Time Sensitive Operator Actions," they observed the expected completion time for time critical operator action (TCOA) #12 was 12.25 minutes. The inspectors also noted the expected completion time only had 15 seconds of margin to the 12.5-minute requirement.

The emergency operating procedure (EOP) actions measured in TCOA #12 are performed to transfer the residual heat removal (RHR) pump suction sources from the reactor water storage tank (RWST) to the containment sump during a loss of coolant accident. The EOP actions start when the RWST level reaches 34 percent and must be completed prior to the RWST level reaching 10 percent to ensure the RHR pumps are not damaged due to the low tank level. Successfully transferring the RHR pump suction without interrupting core flow is necessary for the licensee to maintain the design assumptions discussed in FSAR Section 6.2.2 and FSAR Section 6.2.3.

FSAR 6.2.2, System Design and Operation, establishes the changeover from injection to recirculation is affected by the operator in the control room and the operator in the field via a series of manual operations. It also establishes core cooling flow is maintained and not interrupted during the transition.

FSAR 6.2.3, Evaluation, establishes the analysis supporting that the failure of any single active component will not prevent fulfilling the design function.

The inspectors also reviewed the licensees response to an NRC request for additional information, dated May 20, 2010, which was associated with the evaluation of a large break LOCA after extended power uprate implementation. The response stated, in part, low head safety injection flow to the reactor vessel upper plenum is transferred, without interruption, from the injection mode to sump recirculation mode.

The inspectors, through discussions with the licensee, determined the TCOA #12 validation had modeled the SI-856B valve failure to occur prior to or as the valve switch was operated. The modeled failure provided almost immediate feedback the valve had failed. The inspectors determined that failing SI-856B after it begins to move, which is a credible failure, is a more limiting case because indicating lights would display an intermediate valve state.

The operators would need to wait the typical valve travel time before suspecting and then diagnosing a valve failure. The typical stroke time for SI-856A or B is approximately 100 seconds, which when added to the expected completion time, would have exceeded the required time limit. The inspectors concluded TCOA #11 also had the same SI-856B modeling issue; however, because it assumes success with manual repositioning of SI-856B it had considerably more margin.

The licensee documented the TCOA #12 modeling issue in their corrective action program and concluded RHR operability was maintained. The licensee determined the assumptions used in calculation 2021-0001, Time Available to Locally Close SI-856 During a LOCA, which calculated the required time found in OM 4.3.8, contained enough margin to allow for the additional valve diagnosis time. The inspectors independently reviewed the calculation and identified the licensee had not modeled charging flow in the calculation. The inspectors independently calculated that only 93 GPM of margin remained in the 15 second difference between the required and expected values found in OM 4.3.8. Additionally, the EOPs directed the operators to establish maximum charging after a LOCA, which likely would have used up most or all of the 93 GPM margin. Overall, the inspectors concluded the calculational assumptions did contain additional margin and did not identify any errors with the licensees operability conclusion.

Corrective Actions: The licensee's long-term corrective actions include evaluating the issue through their corrective action program and correcting the issue through procedure changes, analytical methods, or both.

Corrective Action References: AR 2447003; CETI 2023; OM 4.3.8 Time Critical Action 12 Methodology

Performance Assessment:

Performance Deficiency: The licensee failed to ensure core cooling flow could be maintained and not interrupted during the transition from the injection phase to the recirculation phase, assuming a single failure. This was contrary to FSAR Sections 6.2.2, Section 6.2.3, and a performance deficiency. Specifically, when verifying the adequacy of design via TCOA #11 and #12, the licensee failed to assume a more limiting single failure of valves SI-856A or SI-856B.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the performance deficiency was similar to example 3.i of IMC 0612 Appendix E, where the licensee was able to justify the additional time, but in evaluating the as-found condition, the licensee revised assumptions solely to obtain favorable results.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors screened this finding against the Mitigating Systems screening questions in Exhibit 2 and determined this finding was of very low safety significance (Green) because although it was a deficiency affecting the design of a mitigating structure, system, or component (SSC), the SSC maintained its operability. Specifically, using the additional margin available in Calculation 2021-0001, the RHR system remained capable of performing its safety function.

Cross-Cutting Aspect: P.3 - Resolution: The organization takes effective corrective actions to address issues in a timely manner commensurate with their safety significance. Specifically, the potential failure of SI-856 to close and cause accelerated RWST drain-down was documented in AR 2361545, "DBAI: Potential For Accelerated RWST Draw-Down," in July 2020. The licensee's corrective actions associated with AR 2361545 were not effective at creating validations for TCOA #11 and #12 which properly verified the adequacy of their design.

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that the licensee provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program.

FSAR 6.2.2, System Design and Operation, establishes the changeover from injection to recirculation is effected by the operator in the control room and the operator in the field via a series of manual operations. It also establishes core cooling flow is maintained and not interrupted during the transition.

FSAR 6.2.3, Evaluation, establishes the analysis showing the failure of any single active component will not prevent fulfilling the design function.

Calculation 2021-0001, Time Available to Locally Close SI-856 During a LOCA, Revision 0, establishes 12.5 minutes as the time available for operators to complete the transition to containment sump recirculation with a failure of SI-856A or B and maintain core cooling flow uninterrupted.

OP-AA-109, Control of Time Critical Operator Actions and Time Sensitive Actions, Revision 6, Section 1.1.A and 1.3 establishes the Point Beach Nuclear Plant (PBNP) program which ensures the licensee complies with the assumptions made during the analysis of design bases events.

OM 4.3.8, Control of Time Critical and Time Sensitive Operator Actions, Revision 18, contains additional guidance and the list of PBNP Time Critical Actions as required by OP-AA-109. It includes TCOA #11 (Manually close valve SI-856A or B) and TCOA #12 (Swap trains if SI-856A or B doesnt close leaving valve SI-851A or B open). Successful completion of these TCOAs ensures the site complies with the design established in the FSAR and the time assumptions in Calculation 2021-0001.

Contrary to the above, as of February 7, 2023, the licensee failed to verify the adequacy of the design. Specifically, the licensee did not verity, within the time established by Calculation 2021-0001, operators could manually realign the RHR system, a safety-related SSC, from the injection phase to the recirculation phase, following a LOCA and limiting single failure. The licensees validation contained an active single failure of SI-856A or SI-856B; however, the failure was not limiting. The valve was assumed to fail immediately upon demand instead of in an intermediate state. Based on the available control room indication this would have added the valve stroke time plus diagnosis time to the validation scenario. This would result in exceeding the time allowed by Calculation 2021-0001, requiring the RHR pumps to be secured and its core cooling flow interrupted.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

URI Containment Air Recirculation System Design Function 71111.21M Change URI 05000266,05000301/2021010-01

Description:

The inspectors completed their review of 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, Revision 1, and the associated 10 CFR 50.59 Evaluation 2021-001, OI 72, Containment Air Recirculation System. The inspectors concluded that a minor violation of 10 CFR 50.59(d)(1) occurred, which is documented separately in this report. This URI is closed.

Minor Violation 71111.21 M

Minor Violation: The inspectors determined the conclusions in SCR 2018-0157, Provide Additional Containment Cooling Using 1/2SW-2907 or 1/2SW-2908, HX-15A-D Cont Recirc HX Emergency FCV, Revision 0, were not correct and the change was a decrease in the reliability of the service water system design function, and therefore adverse. The licensee, after performing an additional review of SCR 2018-0157, also concluded the change was adverse. The licensee revised SCR 2018-0157 and performed evaluation 2021-001, "OI 72 Containment Air Recirculation System." The inspectors reviewed evaluation 2021-001 and did not identify any additional performance deficiencies.

Screening: The inspectors determined the performance deficiency was minor. In accordance with NRC's Enforcement Manual Section 2.1.3.D.5.a, this violation is considered minor because the failure to prepare an adequate written evaluation was considered isolated (i.e., non-repetitive).

Enforcement:

Section 50.59(d)(1) of 10 CFR states, "The licensee shall maintain records of changes in the facility, of changes in procedures, and of tests and experiments made pursuant to paragraph

(c) of this section. These records must include a written evaluation which provides the bases for the determination that the change, test, or experiment does not require a license amendment pursuant to paragraph (c)(2) of this section." Contrary to the above, from August 27, 2018, to August 6, 2021, the licensee failed to maintain records of changes to the facility involving the containment air recirculation system which included a written evaluation providing the bases for determining the change did not require a license amendment. This failure to comply with 10 CFR 50.59(d)(1) constitutes a minor violation that is not typically subject to enforcement action in accordance with the NRCs Enforcement Policy. However, this minor violation is being documented as part of closing Unresolved Item 05000266,05000301/2021010-01. This unresolved item is closed.

EXIT MEETINGS AND DEBRIEFS

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

On February 7, 2023, the inspectors presented the Comprehensive Engineering Team Inspection results to Michael Rosseau, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.21M Calculations 10.4.148 2" Class 1500 Air Operated Control Valve Thrust and 1

Limiting Component Calculations - 1(2) SI-897A(B)

1999-0118 Maximum Allowable Flow Through a RHR Heat Exchanger 0

Based on Partition Plate Design

2003-0007 480 V Motor Control Center (MCC) Master Input Calculation11

2003-0014 MOV Operating Parameters 8A

2004-0001 AC Electrical System Analysis 11

2004-0002 Degraded Voltage Analysis 6

2004-0025 Cable Ampacity and Overload Protection Methodology 1

2004-0030 480V MCC and Power Panel Coordination Calculation 0 and 1

2004-0033 Electrical Input Calculation 345kV to 480V Switchgear 10

Circuits

2005-0008 Minimum Voltage Requirements for SR MCC Control 0

Circuits

2005-0048 Overload Heater Sizes for Thermal Overload Relays Needed 1

to Protect All 480 V, Non-MOV Safety-Related Motors

2005-0054 Control Building Gothic Temperature Calculation 9

2006-0021 ECCS System Accident Analysis Flow Inputs 0

2010-0001 NPSH and Max Suction Temperature for Component 2

Cooling Pumps

2011-08340 Gravity Drain Curves for Severe Accident Management 5

Guidelines Procedures

20-0006 Voltage Analysis of SI-850 Motors 0

91C2696-C-006 USI A-46/IPEEE, Equipment Fragilities for W-12A, W-12B, 0

W-12C and W-12D

91C2696-C-020 USI A-46, Seismic Evaluation for 1HX-11A, 1HX-11B, 0

2HX-11A, and 2HX-11B

96-0284 Minimum IST Acceptance Criteria for CC Pumps 3

CN-CRA-07-55 GOTHIC Containment Model for LOCA and MSLB Analysis 0

E-09334-399-Fire Stop Ampacity Derating Factors 0

AP.3

M-09334-298-ECCS Proto-Flo Thermal Hydraulic Flow Model 7

Inspection Type Designation Description or Title Revision or

Procedure Date

ECCS.1

N-92-086 ECCS Pump Protection 5

N-93-056 D05 DC System Sizing, Voltage Drop and Short Circuit 8

Calculation

N-93-70 MOV Differential Pressure Calculation 01/05/1994

N-94-019 Determination of Conditions for MOV Pressure Locking and 0

Thermal Binding

N-94-142 Emergency Diesel Generator, Gas Turbine and Fire Pump 8

Diesel Engine Fuel Oil Systems

P-94-005 MOV Stem Thrust Calculation for Gate and Globe Valves 11

TM-2491 Flow Induced Vibration Calculations for the RHR Heat 0

Exchangers

Corrective Action 0000660 Valve Tightening Causes Casing to Break 05/02/2001

Documents 1226467 Non-Compliance with FSAR For Cable Overload Protection 01/22/2003

1362400 IN 2009-02, Biodiesel in Fuel Oil Could Adversely Impact 03/25/2009

Diesel Engine Performance

2035020 2015 CDBI: Track Ampacity Issues 03/25/2015

2035680 2015 CDBI Green NCV Timeliness of Corrective Action 03/27/2015

217112 Gothic Model Error - Design Limits Not Exceed - No 07/26/2017

Operability

27317 Review IN 2017-06 for Potential Impacts on DC Faults 09/28/2017

246548 Track New Revision of IEEE 946-2004 for Fleet Sites 01/26/2018

246825 NRC IN 2017-06 Battery and Charger Short Circuit Current 01/29/2018

248004 Review IN-92-005 as a Result of IN 2017-06 02/06/2018

262609 L1A: License Renewal Program Effectiveness Reviews 05/03/2018

287468 Operating Experience Evaluation: Emergency Diesel 10/23/2018

Generator Excitation Diode Failures

2317727 Operating Experience Evaluation: NRC IN 2019-02: 06/12/2019

EDG Excitation System Diode Failures

25538 Proactively Replace G-03 Voltage Regulator Diodes 08/23/2019

25542 Proactively Replace G-04 Voltage Regulator Diodes 08/23/2019

28063 Added Oil to 2P-15A, SI Pump, Inboard Oiler 09/16/2019

2331712 2P15A Safety Injection Pump Motor Vibration 10/16/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

2334539 2AF-4000 Failed to Close 11/07/2019

2337609 Dry, White, Light Boric Acid on 2SI-897A 12/06/2019

2349405 MCE Gold Test Unit 6 03/21/2020

2349799 Softfoot Correction not Performed on 2P-011A CCW Pump 03/25/2020

2350538 Added Oil to 2P-15A Safety Injection Pump Inner Bearing 03/30/2020

Oiler

2350761 2P-15A Oil Level Indications on the Inbd. Brg. 04/01/2020

2354478 Temp Battery Charger For G-05 DC System Found 04/27/2020

Overheated

2361017 2020 DBAI: Substandard MOV Design Basis Calculation 06/25/2020

2361545 DBAI: Potential for Accelerated RWST Draw-Down 07/01/2020

2384969 Procedure Change Request: OM 4.3.8 - Control of Time 02/23/2021

Critical and (DOCDIST)

2385536 Work Request to Upgrade 2P-011A CC Pump Seals 03/01/2021

2392130 2P-15A, Inboard Oiler is at 1/2 Full 05/03/2021

2397067 TS B 3.6.3 - Containment Isolation, Incorporate the use of 06/28/2021

TSTF-502-T

2403638 Revise Calc 2003-0014 to Correct 1/2CC-738A/B Weak Link 09/09/2021

2406659 Boric Acid Found on 2SI-897A Packing During 2-PT-SI-4 10/08/2021

2407377 2P-15A O/B Pump Oiler Found at an Angle 10/13/2021

28426 Adjust 2P-15A Sensors to Support EC 291482 Turnover 05/25/2022

2440923 Bubble Found Empty on 1P-015B 11/02/2022

2443596 CETI Level 1 Assessment, Review IEEE 946 - 2020 12/12/2022

Corrective Action 2445684 2023 CETI - Inactive Boric Acid Leak on 2FIT-659 01/11/2023

Documents 2445743 2023 CETI - Track Update of DBD-02 for NFPA 805 01/12/2023

Resulting from 2445800 2023 CETI Document Analysis for IN 2017-06 01/12/2023

Inspection 2445862 2023 CETI - Potential Discrepancy with Anchorage for 01/13/2023

2HX-11A

2446100 Aging Management Program Not Reviewed for CR 2385693 01/17/2023

2446330 2023 CETI - Calculation N-93-076 Corrections 01/19/2023

2446434 2023 CETI: 1/2SI-897A/B LPRM / IST Testing 01/20/2023

Considerations

2446436 2023 CETI - Aging Management Caulking Failure 01/20/2023

Inspection Type Designation Description or Title Revision or

Procedure Date

2446439 2023 CETI: 1/2SI-897A/B Documentation Issues 01/20/2023

2446836 2023 CETI - High Head SI Pump EOP Stop Criteria 01/26/2023

2446859 2023 CETI - 50.59 SCRs Lack Sufficient Details for 01/26/2023

Conclusion

2446860 2023 CETI: 1SI-897A Weak Link Analysis and Part 21 01/26/2023

Review

2446862 2023 CETI - DBD-02 Lacks Clarity on CCW License Basis 01/26/2023

2446905 2023 CETI - Biodiesel Fuel Oil Test Method 01/26/2023

2446907 2023 CETI - FO-3983A Identified Not Included in IST 01/26/2023

Program

2446910 2023 CETI - OE Item Due Date Not in Accordance with 01/26/2023

Procedure PI-AA-102-1001

2446936 2023 CETI - High Head SI Pump EOP Stop Criteria 01/26/2023

2447003 2023 CETI - OM 4.3.8 Time Critical Action 12 Methodology 01/27/2023

Drawings 110E017 Sh 2 P&ID Safety Injection System 68

110E018 Sh 3 P&ID Auxiliary Coolant System 45

110E029 Sh 1 P&ID Auxiliary Coolant System 57

110E029 Sh 3 P&ID Auxiliary Coolant System 47

110E029 Sh 4 P&ID Auxiliary Coolant System 0

499B466 Sh. Safety Injection Pump 2P-015A Cubicle 2A52-74 1

201K

499B466 Sh. Elementary Wiring Diagram 4160V SWGR. 2A05 Cubicle-74 8

23A Safety Injection Pump 2P-015A

499B466 Sh. Elementary Wiring Diagram G-02 Exhaust Fan W-12C 6

596B

499B466 Sh. 669 Schematic Diagram 480V MCC IB-30 (2B-30) F.O. Transfer 4

Pump P-206A-M (P-207A-M)

499B466 Sh. Elementary Wiring Diagram SI Test Line Return 2SI-00897A 4

770C

4YE1700-Y7-01 Diesel Generator Fuel Tank Steel Liner Miscellaneous Steel0

D-55-1630S Schematic Diagram, Power Conversion Products 500 4

Ampere Battery Chargers

EAPK 000001 480 V One Line Diagram 35

Inspection Type Designation Description or Title Revision or

Procedure Date

ECCS 1650101 Elementary Wiring Diagram Component Cooling Water 18

(CCW) Pumps

PB 12308 400 A Battery Charger Schematic Diagram 2

Engineering 273506 Unit 2 CC Pump Replacement - Upgrades of Pump for 19

Changes Reliability

293182 IWL Containment Tendon Inspection Lift Off Calculations for 0

the 48th Through 63rd Year Surveillance (N-4460-79)

294138 ISI Classification Boundary Drawing Updates for Safety 0

Injection System Accumulators Instrumentation

294514 G-03 and G-04 Frequency Response Evaluation 0

295002 2004-0025 Rev 2 Cable Ampacity and Overload Protection 0

Methodology

295131 Electrical Calculations for SI-850 Motors 0

295288 Calculation N-93-076 Revision 2 0

295304 FSAR Update for CC Pump Replacement 0

296740 Point Beach IST Program Sixth Interval Update Code 0

Reconciliation

297391 FSAR Update for Spray Additive Tank Description 1

MR 97-085 U2 Add Motor Operators to SI-857A(B) and SI-897A(B) 0

Engineering EVAL 2018-003 Correct Errors in the LOCA and Steam Line Break 0

Evaluations Containment Response Analyses (CN-CRA-12-26 and

CN-CRA-12-27)

SCR 2019 - 0103 Leading Edge Flow Meter Electronics Upgrade 0

SCR 2019-0097 EC 291482 SI Pump Gas Void Monitoring Sensors 0

SCR 2020-0020 Exemption of FSGs from Requirements of 10 CFR 50.59 0

SCR 2020-0040 EC 294728 TMOD D-501 Battery Charger 0

SCR 2021-0001 10 CFR 50.59 Screening - 4160 V Cross-Tie Breaker 0

Control Power Fuse Configuration Control

SCR 2021-0006 Component Cooling System Drain and Refill 02/02/2021

SCR 2021-0026 Startup to Power Operation 0

SCR 2021-0062 1RH-713B Reach Rod 01 0

SCR 2021-0068 TS B 3.6.3 Containment Isolation Valves Bases Change 0

SCR 2021-0089 Revision to TRM 4.12 Diesel Fuel Oil for Allowable Biodiesel0

Inspection Type Designation Description or Title Revision or

Procedure Date

SCR 2022-0015 FSAR Update for Spray Additive Tank Description 0

SQ-000580 Screening Evaluation Work Sheet (SEWS) for W-12C, 0

G-02 Room Exhaust Fan

SQ-001835 Screening Evaluation Work Sheet (SEWS) for 2HX-11A, 1

Residual Heat Removal Heat Exchanger

Miscellaneous G-05 Station Logs; April 20-30, 2020 04/30/2020

Q3-2022 PB - System Health Report - Component Cooling 12/12/2022

Unit 2 - CC

00130 Vendor Manual: Fans, Air Handling Units, Heater Coils and 27

Water Chillers

01038-TR-019 AOV Ranking Worksheet - SI-00897A 1

0106-01735 Failure Analysis of a SI-897 Actuator Manual Override 07/30/2001

Housing per PO 4500386448

01533 Vendor Manual: IMO Pump Instructions and Parts List 0

CMP 2.2.8.10 MOV Design Basis Review for Valve Family 10 5

DBD-02 Component Cooling Water System Design Basis Document 18

DBD-16 Emergency Diesel Generator System Design Basis 20

Document

IST Appendix F Inservice Testing Program Technical Positions 12 and 13

IST Appendix F PBNP Inservice Testing Background Document for Diesel 2

Fuel Oil System

LR-AMP-002-Fuel Oil Chemistry Control Program Basis Document for 8

FOCHEM License Renewal

LR-AMP-023-Closed-Cycle Cooling Water System Surveillance Program 9

CCCW Basis Document for License Renewal

NRC 92-114 Letter Dockets 50-266 and 50-301 Classification of Auxiliary 12/22/1992

Systems Necessary to Assure Safe Plant Shutdown at Point

Beach, Units 1 and 2

PCR 2415500 IT-14 G-02 - Inservice Test of Fuel (EC296740) - Rev. 8 01/11/2023

Q4-2022 PB - System Health Report - Residual Heat Removal 12/12/2022

Unit 2 - RH

Q4-2022 PB - System Health Report - Safety Injection 12/12/2022

Unit2 - SI

QF-1128 Time Critical Operator Actions Time Validation: TCOA #11; 3

Inspection Type Designation Description or Title Revision or

Procedure Date

Completed February 12, 2021

QF-1128 Time Critical Operator Actions Time Validation: OM 4.3.8 3

TCOA #12; Completed February 12, 2021

RFS-M-5703 Westinghouse Fluid and Steam Systems Failure Criteria 11/05/1970

TLB 10 Tank Level Book 10; Refueling Water Storage Tank 7

VTM 00638 Vendor Manual for Power Conversion Products Battery 6

Charger

VTM 01533 IMO Pump Instructions and Parts List 0

Procedures 1-SOPC-CC-002 Component Cooling System Drain and Refill 24

AOP-22 Unit 2 EDG Load Management 20

CAMP 101 Daily Routine Sampling Schedule for Operating, Refueling, 73

or Shutdown Units

ECA-1.1 Unit 1 Loss of Containment Sump Recirculation 45

ECA-1.3 Unit 1 Containment Sump Blockage 17

EN-AA-100-1004 Calculations 10

EOP-0 Unit 1 Reactor Trip or Safety Injection 71

EOP-1 Unit 1 Loss of Reactor or Secondary Coolant 48

EOP-1.2 Unit 1 Post LOCA Cooldown and Depressurization 38

EOP-1.3 Unit 1 Transfer to Containment Sump Recirculation - Low Head 59

Injection

EOP-1.4 Unit 1 Transfer to Containment Sump Recirculation - High Head 33

Injection

EOP-1.4 Unit 2 Transfer to Containment Sump Recirculation - High Head 30

Injection

NP 3.2.2 Primary Water Chemistry Monitoring Program 29

NP 3.2.9 Diesel Fuel Oil Program 3

NP 8.4.16 Procedures Manual for Point Beach High Energy Line Break 27

Barriers/Vent Paths

NP 8.4.17 Procedures Manual for Point Beach Flooding Program 36

OI 145 Fuel Oil Transfer Between Storage Tanks 6

OI 35A Standby Emergency Power Alignment 16

OI 92A Fuel Oil Ordering, Receipt Sampling, and Offloading 31

OM 3.27 Operations Manual for Control of Fire Protection and 82

Inspection Type Designation Description or Title Revision or

Procedure Date

National Fire Protection Association (NFPA) 805 Equipment

OM 4.3.8 Control of Time Critical and Time Sensitive Operator Actions18

OP 1C Startup to Power Operation, Unit 1 44

OP 7A Placing Residual Heat Removal System in Operation 57

OP 7A Placing Residual Heat Removal System in Operation 57

PBF-3005 Blended #1 and #1 Fuel Oil Acceptance Criteria 17

PBF-3006 #2 Fuel Oil Acceptance Criteria 21

PI-AA-102-1001 Operating Experience Program Screening and Responding 20 and 29

to Incoming Operating Experience

RMP 9366 Routine Maintenance for Vacuum Breakers 29

RMP 9370 Routine Maintenance Procedure for Bus Inspection and 7

Cleaning

Work Orders 00358370 2A-05 Bus Work Inspection Per Routine Maintenance 10/27/2009

Procedure (RMP) 9370

351229 IT 14B, Setpoint Test of EDG G-02 FOTP Unloader Valve 12/21/2008

2098-03 RHR HX Eddy Current Work Standard 03/19/2011

40096365 W-012C-M, MCE Analyze Motor (2B52-323M/2B-32) W/O 02/12/2013

RIC

40443087 W-012-C-M, MCE Analyze Motor (2B52-328M/2B-32) W/O 02/12/2018

RIC

40450601-01 IT-14B, Setpoint Test of EDG G-02 FOTP Unloader Valves 12/15/2016

40551658 G-02, W-012C and D EDG Room Exhaust Fan Flow Data 02/16/2018

40635256 IT-215, Unit 2 Safety Injection Vlvs. 03/23/2020

40635597 IT-515B, U2 SI Test / Spy. Add. Educt. 04/07/2020

40644475 Perform Maintenance on Breaker A52-DHVR 1200 Per RMP 07/13/2021

9366

40680280 01 G-04: Proactively Replace Voltage Regulator Diodes 06/02/2020

40680280 04 G-04: Bench Test Removed Diodes 06/11/2020

40697593 IT 02 Train A / 2 Year Comprehensive 05/01/2021

40715271 W-012C-M, MCE Analyze Motor (2B52-328M/2B-32), W/O 02/15/2021

RIC

40715272 W-012C-M, E-Max G-02 Room Exh. Fan Motor (2B52- 02/24/2021

28M/2B-32)

Inspection Type Designation Description or Title Revision or

Procedure Date

40715989 09 D-500; Install Temporary Charger Per EC 294728 04/24/2020

40726520 IT-215, Unit 2 Safety Injection Vlvs. 10/11/2021

40726835 IT-515B, U2 SI Test / Spy. Add. Educt. Lkg. Reduction / PM11/17/2021

40783535 01 Review & Access Time Critical Operator Response Actions 02/09/2022

40789459 Ops Perform 2-TS-ECCS-002 Train A 06/06/2022

40790279 Ops Perform IT 13 Train A 06/14/2022

40793373 Ops Perform IT 02 Train 'A' 07/14/2022

40802953 IT 13 Train A Comprehensive / Biennial Testing 09/13/2022

40809349 Ops Perform IT 02 Train 'A' 10/17/2022

40813628 IT-14, FO Transfer System Pumps/Valves for G-02 11/13/2022

9815436 2HX-11A Inspect Anchorage/Repair 06/14/1999

28