IR 05000266/2003010
| ML040200784 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 01/16/2004 |
| From: | Julio Lara NRC/RGN-III/DRS/EEB |
| To: | Cayia A Nuclear Management Co |
| References | |
| IR-03-010 | |
| Download: ML040200784 (19) | |
Text
January 16, 2004
SUBJECT:
POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 NRC EVALUATIONS OF CHANGES, EXPERIMENTS, OR TESTS AND PERMANENT PLANT MODIFICATIONS INSPECTION REPORT 05000266/2003010(DRS); 05000301/2003010(DRS)
Dear Mr. Cayia:
On December 19, 2003, the U.S. Nuclear Regulatory Commission (NRC) completed a routine baseline inspection at your Point Beach Nuclear Plant, Units 1 and 2. The enclosed report documents the inspection findings, which were discussed on December 22, 2003, during a telephone exit, with you and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and to compliance with the Commissions rules and regulations and with the conditions of your license.
Specifically, this inspection focused on the baseline biennial inspections for evaluations of changes, tests, or experiments (10 CFR 50.59) and permanent plant modifications. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
Based on this inspection, the team identified a Severity Level IV violation of NRC requirements associated with the failure to perform an adequate safety evaluation review as required by 10 CFR 50.59. Specifically, your staff deleted Technical Requirements Manual (TRM)
Surveillance Requirement TSR 3.5.1.3, which required that a quarterly flowrate test be performed for the charging pumps, but failed to provide a basis for the determination that this deletion was acceptable without a license amendment. Because the violation was non-willful and non-repetitive and because it has been entered into your corrective action program, the NRC is treating this issue as a Non-Cited Violation in accordance with Section VI.A.1 of the NRC's Enforcement Policy.
If you contest this Non-Cited Violation, 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 a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region III, 801 Warrenville Road, Lisle, IL 60532-4351; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Point Beach Nuclear Plant. In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publically Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Julio F. Lara, Chief Electrical Engineering Branch Division of Reactor Safety Docket Nos. 50-266; 50-301 License Nos. DPR-24; DPR-27 Enclosure:
Inspection Report 0500266/2003010(DRS);
w/Attachment: Supplemental Information cc w/encl:
R. Kuester, President and Chief Operating Officer, WEPCo J. Cowan, Executive Vice President Chief Nuclear Officer Nuclear Asset Manager Manager, Regulatory Affairs J. Rogoff, Esquire, Vice President, Counsel & Secretary K. Duveneck, Town Chairman Town of Two Creeks Chairperson Public Service Commission of Wisconsin J. Kitsembel, Electric Division Public Service Commission of Wisconsin State Liaison Officer
SUMMARY OF FINDINGS
IR 05000266/2003010(DRS), 05000301/2003-010(DRS); 12/15/2003 - 12/19/2003; Point Beach
Nuclear Plant, Units 1 & 2; Routine Baseline Inspection Report.
This report covers a five day period of announced baseline inspection on evaluations of changes, tests, or experiments and permanent plant modifications. The inspection was conducted by Region III inspectors. One Severity Level IV Non-Cited Violation was identified.
The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
A.
Inspector-Identified and Self-Revealed Findings
Cornerstone: Initiating Events
- NCV. The inspectors identified a Severity Level IV Non-Cited Violation associated with the failure to perform an adequate safety evaluation review as required by 10 CFR 50.59 for changes made to the facility as described in the Updated Safety Analysis Report (USAR). Specifically, the licensee deleted Technical Requirements Manual (TRM) Surveillance Requirement TSR 3.5.1.3, which required that a quarterly flowrate test be performed for the charging pumps, but failed to provide a basis for the determination that this deletion was acceptable without a license amendment. The safety evaluation failed to address the purpose of the flowrate test which was to ensure that one changing pump could sufficiently compensate for the addition of positive reactivity from the decay of xenon after a reactor trip.
Because the Significance Determination Process (SDP) is not designed to assess the significance of violations that potentially impact or impede the regulatory process, this issue was dispositioned using the traditional enforcement process in accordance with Section IV of the NRC Enforcement Policy. However, the results of the violation, that is, the failure to evaluate the deletion of TSR 3.5.1.3 from the TRM, were assessed using the SDP.
The team considered this issue of more than minor significance, because if left uncorrected, the finding could become a more significant safety concern. The inspectors determined that the issue was of very low safety significance, because the licensee was still measuring quarterly charging pump flow rates for the testing of the pumps discharge check valves. The resultant flow rates bounded the requirements of the deleted TRM Surveillance Requirement. Therefore, the results of the violation were determined to be of very low safety significance and the violation of 10 CFR 50.59 was classified as a Severity Level IV violation.
Because this non-willful violation was non-repetitive, and was captured in the licensees corrective action program, this issue is being treated as a Non-Cited Violation, consistent with the NRC Enforcement Policy (Section 1R02).
Cornerstone: Mitigating Systems
No findings of significance were identified.
Cornerstone: Barrier Integrity
No findings of significance were identified.
Licensee-Identified Violations
No findings of significance were identified.
REPORT DETAILS
Summary of Plant Status
Units 1 and 2 operated at or near full power throughout the inspection period.
REACTOR SAFETY
Cornerstone: Initiating Events, Mitigating Systems, and Barrier Integrity
1R02 Evaluations of Changes, Tests, or Experiments
.1 Review of 50.59 Evaluations and Screenings
a. Inspection Scope
The inspectors reviewed eight evaluations performed pursuant to 10 CFR 50.59. The evaluations related to permanent plant modifications, setpoint changes, procedure changes, conditions adverse to quality, and changes to the updated final safety analysis report. The inspectors confirmed that the evaluations were thorough and that prior NRC approval was obtained as appropriate. The inspectors also reviewed 15 screenings where the licensee had determined that a 10 CFR 50.59 evaluation was not necessary.
In regard to the changes reviewed where no 10 CFR 50.59 evaluation was performed, the inspectors verified that the changes did not meet the threshold to require a 10 CFR 50.59 evaluation. These evaluations and screenings were chosen based on risk significance of samples from the different cornerstones.
b. Findings
Introduction:
The inspectors identified that the licensee failed to perform an adequate safety evaluation in accordance with 10 CFR 50.59 before making changes to the Updated Safety Analysis Report (USAR). The issue was considered to be of very low safety significance and was dispositioned as a Severity Level IV NCV.
Description:
On October 16, 2001, the licensee completed Safety Evaluation (SE)2001-0057. This safety evaluation deleted Technical Requirements Manual (TRM)
Surveillance Requirement TSR 3.5.1.3, which required that the licensee verify, every 92 days, that the charging pumps develop required flow rate, as specified by the Inservice Testing [IST] Program. Because the TRM is part of the plant USAR, the performance of a safety evaluation was required.
In the safety evaluation, the licensee justified the deletion of the requirement by stating, Based on the fact that the PBNP Charging Pumps are not credited with an active safety function that would require IST Program testing, the Charging Pump IST surveillance requirement need not be carried over to the TRM. The reasoning for the change was entirely based upon the charging pumps having no safety function. While this appeared to be adequate justification to delete the IST requirement for the pumps, it did not justify the deletion of the TRM Surveillance Requirement. As stated in the PBNP Bases for TRM TLCO 3.5.1, the function of the charging pumps in support of the Chemical and Volume Control System (CVCS) is described as follows, The amount of boric acid injection must be sufficient to compensate for the addition of positive reactivity from the decay of xenon after a reactor trip from full power in order to maintain the required shutdown margin. This can be accomplished through the operation of one charging pump taking suction from the RWST. TSR 3.5.1.3 measured the flow rate to ensure that the charging pumps could support this function. When TSR 3.5.1.3 was deleted, this function was not evaluated in the safety evaluation. Consequently, the discussion, as presented in SE 2001-0057, only evaluated the removal of the IST requirements for the charging pumps, but did not evaluate the effects of removing the TRM Surveillance Requirement.
The inspectors determined that this was a violation of 10 CFR 50.59 in that the licensee did not provide bases that the deletion of TSR 3.5.1.3 was acceptable without a license amendment. However, even though TSR 3.5.1.3 had been deleted, the licensee had still been performing a quarterly flow rate test of the charging pumps for the purpose of testing the charging pump discharge check valves. The inspectors determined that the flow rate measured in this quarterly test was sufficient to meet the requirements in TSR 3.5.1.3.
Analysis:
Because violations of 10 CFR 50.59 are considered to be violations that potentially impede or impact the regulatory process, they are dispositioned using the traditional enforcement process instead of the SDP. In this case, the licensees failure to perform an adequate safety evaluation in accordance with 10 CFR 50.59 resulted in a TRM Surveillance Requirement, TSR 3.5.1.3, being removed inappropriately.
This finding is more than minor because if left uncorrected, the finding would become a more significant safety concern. However, based upon the inspectors review, it was determined that the licensees failure to provide the required basis for the 50.59 safety evaluation was an issue of very low safety significance. This was based upon the inspector determining that the measured quarterly charging pump flow rate for the discharge check valves test was sufficient to meet the requirements of the deleted TRM Surveillance Requirement.
Enforcement:
Title 10 CFR 50.59(d)(1) states, in part, that the licensee shall maintain records of changes in the facility, of changes in procedures, and of tests and experiments. 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.
Contrary to the above, in their safety evaluation, SE 2001-0057, dated October 16, 2001, the licensee failed to provide a basis for the determination that the deletion of the TRM Surveillance Requirement, part of the plants USAR, was acceptable without a license amendment. The results of this violation were determined to be of very low safety significance; therefore, this violation of the requirements in 10 CFR 50.59 was classified as a Severity Level IV Violation. However, because this non-willful violation was non-repetitive, and was captured in the licensees corrective action program (CAP052416),it is considered a Non-Cited Violation (NCV05000266, 05000301/200310-01(DRS))
consistent with VI.A.1 of the NRC Enforcement Policy.
1R17 Permanent Plant Modifications
.1 Review of Recent Modifications
a. Inspection Scope
The inspectors reviewed eight permanent plant modifications. The modifications were chosen based upon their affecting systems that had high probabilistic risk analysis (PRA) significance in the licensee's Individual Plant Evaluation (IPE) or high maintenance rule safety significance. The inspectors reviewed the modifications to verify that the completed design changes were in accordance with the specified design requirements and the licensing bases and to confirm that the changes did not affect any systems safety function. Design and post-modification testing aspects were verified to ensure the functionality of the modification, its associated system, and any support systems. The inspectors also verified that the modifications performed did not place the plant in an increased risk configuration.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES (OA)
4OA2 Identification and Resolution of Problems
.1 Routine Review of Condition Reports
a. Inspection Scope
The inspectors reviewed a selected sample of condition reports associated with Point Beach Nuclear Plants permanent plant modifications and concerning 10 CFR 50.59 evaluations and screenings. The inspectors reviewed these issues to verify an appropriate threshold for identifying issues and to evaluate the effectiveness of corrective actions. In addition, condition reports written on issues identified during the inspection were reviewed to verify adequate problem identification and incorporation of the problem into the corrective action system. The specific corrective action documents that were sampled and reviewed by the team are listed in the attachment to this report.
b. Findings
No findings of significance were identified.
4OA6 Meetings
.1 Exit Meeting
The inspectors presented the inspection results to Mr. Cayia and other members of licensee management by a telephone exit on December 22, 2003. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
.2 Interim Exit Meetings
No interim exits were conducted.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- D. Black, 50.59 Process Owner
- J. Connolly, Regulatory Affairs Manager
- F. Flentje, Principal Regulatory Affairs Analyst
- K. Holt, Configuration Management Supervisor
- C. Krause, Senior Regulatory Affairs Engineer
- J. Marean, Mechanical Design Supervisor
- T. Petrowsky, Design Engineering Manager
- M. Rosseau, Electrical/I&C Design Supervisor
- J. Schweitzer, Engineering Director
- R. Scott, Licensing Supervisor
Nuclear Regulatory Commission
- P. Krohn, Point Beach Senior Resident Inspector
- J. Lara, Region III Electrical Engineering Branch Chief
- M. Morris, Point Beach Resident Inspector
- T. Vegel, Chief, Reactor Projects Branch 7
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
- 05000266,
- 05000301/2003010-01 NCV Failure to Perform an Adequate Safety Evaluation for Changes to the Plant as Described in the USAR (Section 1R02)
Closed
- 05000266,
- 05000301/2003010-01 NCV Failure to Perform an Adequate Safety Evaluation for Changes to the Plant as Described in the USAR (Section 1R02)
Discussed
None.