IR 05000266/2024010

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Age-Related Degradation Inspection Report 05000266/2024010 and 05000301/2024010
ML24191A421
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 07/10/2024
From: Karla Stoedter
NRC/RGN-III/DORS/EB1
To: Durbin M
Point Beach
References
IR 2024010
Download: ML24191A421 (1)


Text

SUBJECT:

POINT BEACH NUCLEAR PLANT - AGE-RELATED DEGRADATION INSPECTION REPORT 05000266/2024010 AND 05000301/2024010

Dear Michael Durbin:

On June 21, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Point Beach Nuclear Plant and discussed the results of this inspection with Eric Schultz, Regulatory Assurance Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.

One finding of very-low safety significance (Green) is documented in this report. This finding did not involve a violation of NRC requirements.

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.

July 10, 2024 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 Stoedter, Branch 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:

05000266/2024010 and 05000301/2024010

Enterprise Identifier:

I-2024-010-0052

Licensee:

NextEra Energy Point Beach, LLC

Facility:

Point Beach Nuclear Plant

Location:

Two Rivers, WI

Inspection Dates:

April 29, 2024 to June 21, 2024

Inspectors:

K. Fay, Senior Reactor Inspector

E. Fernandez, Senior Reactor Inspector

T. Hartman, Senior Project Engineer

Approved By:

Karla Stoedter, Branch Chief

Engineering Branch 1

Division of Operating Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an age-related degradation 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 Inspect the Fire System Accumulator Tank Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green FIN 05000266,05000301/2024010-01 Open/Closed

[H.8] -

Procedure Adherence 71111.21N.

The inspectors identified a finding of very-low safety significance (Green) for the licensees failure to inspect a portion of the fire protection system. Specifically, the licensee failed to ensure the bottom of the fire protection accumulator tank was free of oil, dirt, or other extraneous matter which could obscure surface defects such as pitting, cracking, and erosion prior to examining the tanks internal bottom surface. In addition, an action request was not initiated when indications of corrosion were discovered.

Additional Tracking Items

None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71111.21N.04 - Age-Related Degradation Age-Related Degradation

(1) Cable Spreading Room Air Conditioning Unit Chiller (HX-38A)
(2) Cable Spreading Room Fan Motors (W-13A1/A2)
(3) Fire Protection System Accumulator Tank (T-73)
(4) G-01 Emergency Diesel Generator (EDG) Service Water Strainer (F-215)
(5) G-01/G-02 EDG Air Start Receiver Tanks (T-60/T-61)
(6) G-05 Gas Turbine Battery (D501)
(7) G-05 Gas Turbine Turning Gear (Z-500)
(8) P-32A Service Water Pump Flexible Expansion Joint (XJ-2974A)
(9) Spent Fuel Pool Heat Exchanger Service Water Inlet Valves (SW-2927A/B)
(10) Unit 1 Rod Position Indication System Cabling
(11) Unit 2 Crossover Steam Dump Valve (2-OS-4-DV)
(12) Unit 2 Service Water Outlet Radiation Monitor (2RE-229)

INSPECTION RESULTS

Failure to Inspect the Fire System Accumulator Tank Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green FIN 05000266,05000301/2024010-01 Open/Closed

[H.8] -

Procedure Adherence 71111.21N.0 The inspectors identified a finding of very-low safety significance (Green) for the licensees failure to inspect a portion of the fire protection system. Specifically, the licensee failed to ensure the bottom of the fire protection accumulator tank was free of oil, dirt, or other extraneous matter which could obscure surface defects such as pitting, cracking, and erosion prior to examining the tanks internal bottom surface. In addition, an action request was not initiated when indications of corrosion were discovered.

Description:

Point Beach Nuclear Plant established procedure LR-AMP-010-FP, Fire Protection Program Basis Document for License Renewal, as one of the implementing procedures for their license renewal (LR) program. The purpose of this procedure is to monitor system aging, specifically for the fire protection system, during the period of extended operation, which they entered in 2010. Procedure LR-AMP-010-FP describes the fire protection system as consisting of a 10 inch ring header fire main laid underground around the plant. The main is connected to the discharge side of each of two fire pumps. This ring header supplies water to the suppression system piping inside the plant. The distribution piping supplies the wet pipe sprinkler systems, dry pipe sprinkler systems, deluge systems, the pre-action system, and hose stations throughout the plant. This system is pressurized by an accumulator and jockey pump, and an air compressor which maintains system pressure and level in the accumulator tank. Attachment B to this procedure specifies implementing preventative maintenance requirement (PMRQ) 60968-01, which requires the licensee to open and inspect the fire system accumulator tank. Per the licensees preventative maintenance program this inspection is performed every 2 years.

The inspectors reviewed the fire protection system accumulator tank (T-73) inspection results and requested the last several completed work orders (WO). Preventative maintenance requirement 60968-01 was most recently implemented by performance of WO 40796864.

The WO included instructions to perform an inspection (LR requirement) in accordance with maintenance instruction (MI) 32.14, Visual Inspections for License Renewal, Revision 6.

Maintenance Instruction 32.14, Step 3.1 states, The examination surface shall be free of oil, dirt or other extraneous matter which could obscure surface defects. Surface preparation may include cleaning with solvents, brushing or other methods that would not gouge or smear the surface so as to mask indications. Step 3.2 defines surface defects as pitting, cracking and erosion.

The completed WO included pictures of the internal surface of the tank after it was cleaned.

The inspectors reviewed the results of the WO and noted the pictures showed several areas of corrosion across a significant portion of the inside of the bottom of the accumulator tank.

This condition could obscure surface defects because it would not allow the licensee to detect, via visual inspection, any pitting, cracking, or erosion occurring beneath the corrosion.

In addition, the WO had instructions to initiate an action request if indications of corrosion are discovered (LR requirement). This step was not performed as indicated by an N/A [not applicable] in the signature field.

The inspectors concluded the inspection was not performed as required and that the identification of corrosion products inside the bottom of the tanks were not entered into their corrective program.

Corrective Actions: The licensee entered this issue into their corrective action program and planned to have the License Renewal Engineer review the Aging Management Program to determine if additional testing is needed to address the aging of the tank.

Corrective Action References: AR 02486433

Performance Assessment:

Performance Deficiency: The licensees failure to inspect the fire system accumulator tank in accordance with LR-AMP-010-FP, Fire Protection Program Basis Document for License Renewal, and to write an action request when corrosion was discovered was a performance deficiency. Specifically, the licensee failed to ensure the internal bottom surfaces of the fire system accumulator tank were free from oil, dirt, or other extraneous matter which could obscure surface defects prior to inspecting the bottom of the tank. As a result, the licensee could not conclude the tanks license renewal inspection was complete. This identification of corrosion inside the tanks bottom was also not documented within the corrective action program.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors 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 inspect the bottom of the fire system accumulator tank reduced the ability to ensure the tank would not fail adversely affecting the fire protection system.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The inspectors screened the finding using IMC 0609, Appendix F, Attachment 1, Part 1: Fire Protection SDP Process Worksheet, and answered yes to Question 1.4.3, Would adequate fire water capacity (flow at required pressure) still be available for protection of equipment important to safe shutdown in the most limiting location onsite? The failure to inspect the fire system accumulator tank did not impact the fire protection systems ability to reach the most limiting location.

Therefore, the inspectors determined that the finding screened as having very-low safety significance (Green).

Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions. Specifically, the licensee failed to properly prepare the surface prior to an inspection as required by MI 32.14 instructions.

Enforcement:

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

EXIT MEETINGS AND DEBRIEFS

The inspectors confirmed that proprietary information was controlled to protect from public disclosure.

  • On June 21, 2024, the inspectors presented the age-related degradation inspection results to Eric Schultz, Regulatory Assurance Manager, and other members of the licensee staff.
  • On May 17, 2024, the inspectors presented the age-related degradation initial inspection results to Michael Durbin, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Calculations

2005-0050

Primary Auxiliary Building and Control Building Electrical

Heat Load Calculation

AR 1161654

EDG Air Receiver Tank Min Wall Calculations

11/20/2009

AR 1369617

License Renewal Examination Results for T-073 Tank

11/02/2009

AR 1369629

License Renewal Exam of K-006 Compressor for 0T-073

Tank

04/24/2010

AR 1377291

Acceptance Criteria Not Met on T-060/61 UT Inspection

for LR

11/24/2015

AR 1734606

Inadequate MWO Causes Lack of Schedule Adherence

04/26/2012

AR 2008322

UT Results Below Trigger Value for T-60/T-61 Exams

03/10/2015

AR 2238594

T-60D EDG Air Receiver Wall Thickness Readings Below

T-min

2/08/2017

AR 2249012

1RE229 SWOB Sample Pump Vibration

2/12/2018

AR 2291688

O-Rings not Available for SW Strainer

11/20/2018

AR 2341050

Minor Leak on F-215 EDG Inlet Strainer

01/16/2020

AR 2356877

G01 SW Duplex Strainer Unable to be Cleaned

07/28/2020

AR 2371391

W-13A1 Cable Spreading Room Recirc Fan Will Not Start

2/16/2020

AR 2412809

F-215 G-01 Strainer Cover Seepage

2/31/2021

AR 2428496

G-05 Stop Push Button High Resistance

05/26/2022

AR 2434452

PI-6739 Discharge Pressure Indicator is Reading Low

08/16/2022

AR 2453776

U2 Crossover Dump Valve Will Not Reliably Seat

04/08/2023

AR 2476417

2OS-4-DV Not Tested

01/11/2024

AR 2476805

D-501 Cells Are Not Within 5 Degrees

01/17/2024

AR 2477312

2OS-4-DV Test/Troubleshoot for 2R40

01/23/2024

AR 2478801

D-501 125V Station Battery is Reach Its End of Life

2/09/2024

PCR 2087546

(S) RMP 9216-2A - Service Water Pump Removal,

Installation

10/31/2015

PCR 2090218

(P) RMP 9216-2A - Service Water Pump Removal,

Installation

11/10/2015

Corrective Action

Documents

RWT 2065016

Pump Disch Expansion Joint Insps May be Inadequate

08/05/2015

71111.21N.04

Corrective Action

AR 2485245

24 NRC ARD Missing Insulation Lagging on SW Pipe

04/30/2024

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

AR 2485303

24 ARD Inspection G-05 Axial Compressor Oil Leak

04/30/2024

AR 2485496

24 NRC ARD Start and Run Hour Meters Not Working

On HX-38A

05/02/2024

AR 2485519

24 NRC ARD - WO Record Missing Sign-offs

05/03/2024

AR 2485559

24 NRC ARD - XJ-2974A, P-32A Expansion Joint,

Showing Sign

05/03/2024

AR 2485694

24 NRC ARD Inspection - Incorrect G-501 Voltage

Documented

05/06/2024

AR 2485734

24 NRC ARD - Power Strip Within Cabinet C-120A and

C-121

05/06/2024

AR 2485739

24 NRC ARD - D-501 Past Procedure Performance

Issue

05/06/2024

AR 2485799

Work Order Closeout Quality

05/07/2024

AR 2486377

24 NRC ARD - Missing Signature in WO Record

05/15/2024

AR 2486433

24 NRC ARD - Condition Reports not Submitted for

Corrosion

05/15/2024

AR 2486436

24 ARD - NRC Observation - Worker Practices,

Reviews

05/15/2024

Documents

Resulting from

Inspection

AR 2486563

24 NRC ARD - Fan Bearing Greasing - Critical Step

05/17/2024

499B466 Sh.

2B

Elementary Wiring Diagram Cable Spreading Room

Recirculation Fan W-13A2

Drawings

M-144 Sh. 2

Heating & Ventilation Temperature Control P&ID

Temperature Control

Engineering

Changes

294538

1/2 RE-229 and RE-230 Fuse Replacement

DBD-29

Auxiliary Building and Control Building HVAC

FPTE 2016-003

NFPA 805 Nuclear Safety Capability Assessment

LR-AMP-004-

PSPM

Periodic Surveillance and Preventive Maintenance

Program for License Renewal

LR-AMP-010-FP

Fire Protection Program Basis Document for License

Renewal

LR-AMP-014-

CCMON

Cable Conditioning Monitoring Program for License

Renew

Miscellaneous

LR-AMP-019-

Tank Internal Inspection Program Basis Document for

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

TNKINT

License Renewal

PB-EPU-09-1168

Transmittal of Siemens Report for EC-08109

05/19/2009

VTM 00277

25 V DC Station Batteries

VTM 01105 Book

Trane HVAC Composite Book

0-SOP-VNCSR-

2

Cable Spreading Room Ventilation System Normal

Operation

2-PT-MS-003

Crossover Steam Dump

IT 72

Service Water Valves (Quarterly)

LM 2.1

Lubrication Manual

MI 32.14

Visual Inspection for License Renewal

PC 10 Part 3

SW to SFP MOVs and Radwaste System AOVs Leak

Check

PC 29

Gas Turbine and Auxiliary Diesel Load Test

Procedures

RMP 9216-2A

Service Water Pump Removal, Installation, and

Maintenance

238021-01

Replace Expansion Joint

11/28/2001

40073979-01

Inspect and Maintain Pump

09/10/2012

40103522

P-032A Replace Pump per EC272153

10/17/2017

291866-01

T-073 Open and Inspect Accumulator Tank

08/12/2014

299630

VNCSR-Damper Blade Seal Cleaning

09/22/2014

40384004

Damper Operability

2/10/2016

40419943-01

T-073 Open and Inspect Accumulator Tank

08/18/2016

40583160

D-501 Quarterly GT125V Battery Inspection

01/23/2019

40614733

IT-72, Service Water Valves

06/10/2019

40616169

D-501 Annual GT125V Battery Inspection

05/22/2019

40630621

IT-72, Service Water Valves

08/20/2019

40643260-01

D-501 Quarterly GT125V Battery Inspection

10/23/2019

40746007

W-13A1 Troubleshoot Fan Not Starting

03/12/2021

40752947-05

1RPI/Engineering CHAR Data Evaluation

04/18/2022

40766773

HX-038A Inspect and Maintain AC Unit

05/16/2022

40767675

W-013A1-M Perform MCE Test

08/25/2022

Work Orders

40767676

AC Induction Motor MCE Testing Procedure

08/25/2022

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

40770266

Perform UT Thickness Exam in Accordance with NDE-104

for License Renewal Program

03/27/2021

40775544-01

F-222/Perform Internal Inspection of Strainer

2/15/2022

40785442

HX-038A3/A4 Operations PMT/RTS

01/31/2022

40795162

RE-229/229B Calibration

06/28/2022

40796864-01

T-073 Open and Inspect Accumulator Tank

08/08/2022

40800611-01

F-215/Perform Internal Inspection of Strainer

08/24/2022

40801515

2-OS-00004-DV Overhaul to Replace Disc Rings and

Seals

04/10/2023

40813762-01

2RE-229 Not Going to Fail EX with No Flow

2/21/2022

40846323

G-05 Gas Turbine Generator Load Testing

05/26/2023

40856206

W-013A1 Inspect Fan and Lube Bearings

08/28/2023

40876035

HPIP 7.51.8 - Quarterly Functional Test of RMS

01/30/2024

40878262-01

F-222/Perform Internal Inspection of Strainer

2/13/2024

40884372-01

HPIP 7.51.10 Functional Test of the Radiation Monitoring

System

03/24/2024

40887679-01

2-PT-MS-003 U2 Crossover Steam Dump Test

01/11/2024

40964815

HPIP 7.51 Monthly RMS Operational Test HPIP 7.51

04/07/2024