IR 05000266/2016004
| ML17032A074 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 01/31/2017 |
| From: | Jamnes Cameron Reactor Projects Region 3 Branch 4 |
| To: | Coffey R Point Beach |
| References | |
| IR 2016004, IR 2016501 | |
| Download: ML17032A074 (40) | |
Text
UNITED STATES ary 31, 2017
SUBJECT:
POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2NRC INTEGRATED INSPECTION REPORT 05000266/2016004; 05000301/2016004; 05000266/2016501; AND 05000301/2016501
Dear Mr. Coffey:
On December 31, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Point Beach Nuclear Plant, Units 1 and 2. On January 18, 2017, the NRC inspectors discussed the results of this inspection with you and other members of your staff.
The enclosed report represents the results of this inspection. The NRC also completed its annual inspection of the Emergency Preparedness Program. This inspection began on January 1, 2016, and issuance of this letter closes Inspection Report Number 2016501.
Based on the results of this inspection, the NRC has identified one issue that was evaluated under the risk significance determination process as having very low safety significance (green).
The NRC has also determined that one violation is associated with this issue. Because the licensee initiated condition reports to address this issue, this violation is being treated as a Non-Cited Violation (NCV), consistent with Section 2.3.2 of the Enforcement Policy. The NCV is described in the subject inspection report. Further, inspectors documented a licensee-identified violation that was determined to be of very low safety significance in this report. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.
If you contest the violations or significance of these NCVs, 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: (1) the Regional Administrator, Region III; (2) the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and (3) the NRC Resident Inspector at the Point Beach Nuclear Plant.
In addition, if you disagree with the cross-cutting aspect assignment to any finding 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 Regional Administrator, Region III, and the NRC Resident Inspector at the Point Beach Nuclear Plant. In accordance with 10 CFR 2.390 of the NRC's Rules of Practice, a copy of this letter, its enclosure(s), and your response, (if any), will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy or proprietary information so that it can be made available to the Public without redaction.
Sincerely,
/RA John Rutkowski Acting for/
Jamnes Cameron, Chief Branch 4 Division of Reactor Projects Docket Nos: 50-266; 50-301 License Nos: DPR-24; DPR-27
Enclosure:
IR 05000266/2016004; 05000301/2016004; 05000266/2016501; 05000301/2016501
REGION III==
Docket Nos: 50-266; 50-301 License Nos: DPR-24; DPR-27 Report No: 05000266/2016004; 05000301/2016004; 05000266/2016501; 05000301/2016501 Licensee: NextEra Energy Point Beach, LLC Facility: Point Beach Nuclear Plant, Units 1 and 2 Location: Two Rivers, WI Dates: October 1 through December 31, 2016 Inspectors: K. Barclay, Acting Senior Resident Inspector J. Boettcher, Acting Senior Resident Inspector J. Havertape, Acting Resident Inspector J. Steward, Acting Resident Inspector R. Baker, Operations Engineer M. Garza, Emergency Preparedness Inspector L. Haeg, Senior Resident Inspector, Prairie Island D. Krause, Resident Inspector, Monticello J. Mancuso, Reactor Engineer J. Park, Reactor Inspector J. Rutkowski, Project Engineer Approved by: J. Cameron, Chief Branch 4 Division of Reactor Projects Enclosure
SUMMARY
Inspection Report 05000266/2016004, 05000301/2016004, 05000266/2016501, 05000301/2016501; 10/01/2016 - 12/31/2016; Point Beach Nuclear Plant, Units 1 & 2;
Maintenance Risk Assessments and Emergent Work Control.
This report covers a 3-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors and the annual review of emergency preparedness.
One Green finding was identified by the inspectors. The finding involved a Non-Cited Violation (NCV) of the U.S. Nuclear Regulatory Commission (NRC) requirements. The significance of inspection findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow,
Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process, dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310,
Aspects Within the Cross-Cutting Areas, dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated November 1, 2016. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 6, dated July 2016.
Cornerstone: Mitigating Systems
Green: A finding of very low safety significance and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified by inspectors for the licensees failure to follow step 4.1.3 (2) of procedure MA-AA-100-1002, Scaffold Installation, Modification, and Removal Requests.
Specifically, the licensee failed to obtain and document engineering approval for multiple scaffolds constructed in the cable spreading room that did not meet the separation criteria of Attachment 1 of MA-AA-100-1002. The licensees short-term corrective actions included obtaining the appropriate engineering evaluations for the affected scaffolding and conducting a stand-down and information sharing with the scaffold builders to ensure they were aware of the importance of obtaining engineering approvals.
The finding was determined to be more than minor because the finding, if left uncorrected, had the potential to become a more significant safety concern. Specifically, if the licensee continued to construct scaffolding without obtaining required engineering approvals, scaffolding could be constructed that was not seismically qualified and adversely affect the operability of surrounding structures, systems, and components (SSCs). The inspectors concluded this finding was associated with the Mitigating Systems cornerstone. The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process,
Attachment 0609.04, Initial Characterization of Findings, issued on October 7, 2016.
Specifically, the inspectors used IMC 0609, Appendix A, SDP for Findings At-Power, issued June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions to screen the finding. The finding screened as of very low safety significance (Green) because the inspectors answered "No" to the screening questions. This finding has a cross-cutting aspect of Teamwork (H.4), in the area of Human Performance, for the failure of individuals and work groups to communicate and coordinate their activities across organizational boundaries to ensure nuclear safety is maintained. Specifically, the scaffold building team failed to communicate with the engineering organization to ensure the engineering evaluations were complete. (Section 1R13.1)
Licensee-Identified Findings A violation of very low safety or security significance or Severity Level IV that were identified by the licensee has been reviewed by the NRC. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program (CAP). The violation and CAP tracking number is listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status
Unit 1 The unit operated at or near full power for the inspection period, except for brief power reductions to conduct planned maintenance and surveillance activities.
Unit 2 The unit operated at or near full power for the inspection period, except for brief power reductions to conduct planned maintenance and surveillance activities.
REACTOR SAFETY
Cornerstone: Initiating Events, Mitigating Systems, Barrier Integrity, and
1R01 Adverse Weather Protection
.1 Winter Seasonal Readiness Preparations
a. Inspection Scope
The inspectors conducted a review of the licensees preparations for winter conditions to verify that the plants design features and implementation of procedures were sufficient to protect mitigating systems from the effects of adverse weather. Documentation for selected risk-significant systems was reviewed to ensure that these systems would remain functional when challenged by inclement weather. During the inspection, the inspectors focused on plant specific design features and the licensees procedures used to mitigate or respond to adverse weather conditions. Additionally, the inspectors reviewed the Final Safety Analysis Report (FSAR) and performance requirements for systems selected for inspection, and verified that operator actions were appropriate as specified by plant specific procedures. Cold weather protection, such as heat tracing and area heaters, was verified to be in operation where applicable. The inspectors also reviewed corrective action program (CAP) items to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into their CAP in accordance with station corrective action procedures. Documents reviewed are listed in the Attachment to this report. The inspectors reviews focused specifically on the following plant systems due to their risk significance or susceptibility to cold weather issues:
- G-05 gas turbine engine; and
- service water system.
This inspection constituted one winter seasonal readiness preparations sample as defined in inspection procedure (IP) 71111.01-05.
b. Findings
No findings were identified.
1R04 Equipment Alignment
.1 Quarterly Partial System Walkdowns
a. Inspection Scope
The inspectors performed partial system walkdowns of the following risk-significant systems:
- Unit 2 turbine driven auxiliary feedwater (AFW) pump with associated motor driven AFW pump out of service;
- G-04 emergency diesel generator; and
- Unit 2, train B safety injection system.
The inspectors selected these systems based on their risk significance relative to the Reactor Safety Cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could impact the function of the system and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, FSAR, Technical Specification (TS) requirements, outstanding work orders (WOs), condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the CAP with the appropriate significance characterization. Documents reviewed are listed in the to this report.
These activities constituted three partial system walkdown sample as defined in IP 71111.04-05.
b. Findings
No findings were identified.
.2 Semi-Annual Complete System Walkdown
a. Inspection Scope
On October 3, 2016 to October 5, 2016, the inspectors performed a complete system alignment inspection of the emergency diesel generator (EDG) system to verify the functional capability of the system. This system was selected because it was considered both safety significant and risk significant in the licensees probabilistic risk assessment.
The inspectors walked down the system to review mechanical and electrical equipment lineups; electrical power availability; system pressure and temperature indications, as appropriate; component labeling; component lubrication; component and equipment cooling; hangers and supports; operability of support systems; and to ensure that ancillary equipment or debris did not interfere with equipment operation. A review of a sample of past and outstanding WOs was performed to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the CAP database to ensure that system equipment alignment problems were being identified and appropriately resolved. Documents reviewed are listed in the to this report.
These activities constituted one complete system walkdown sample as defined in IP 71111.04-05.
b. Findings
No findings were identified.
1R05 Fire Protection
.1 Routine Resident Inspector Tours
a. Inspection Scope
The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:
- Fire Zone 320; condensate storage tank area with welding in progress;
- Fire Zone 770; G-03 EDG room;
- Fire Zone 304N; turbine driven auxiliary feedwater pump room (North); and
- Fire Zone 304S; turbine driven auxiliary feedwater pump room (South).
The inspectors reviewed areas to assess if the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and implemented adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems, or features in accordance with the licensees fire plan.
The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plants ability to respond to a security event.
Using the documents listed in the Attachment to this report, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensees CAP.
Documents reviewed are listed in the Attachment to this report.
These activities constituted four quarterly fire protection inspection samples as defined in IP 71111.05-05.
a. Findings
No findings were identified.
.2 Annual Fire Protection Drill Observation
a. Inspection Scope
On October 11, 2016, the inspectors observed a fire brigade activation in response to a simulated fire in the technical support center ventilation room. Based on this observation, the inspectors evaluated the readiness of the plant fire brigade to fight fires.
The inspectors verified that the licensee staff identified deficiencies openly discussed them in a self-critical manner at the drill debrief, and took appropriate corrective actions.
Specific attributes evaluated were:
- employment of appropriate firefighting techniques;
- sufficient firefighting equipment brought to the scene;
- effectiveness of fire brigade leader communications, command, and control;
- search for victims;
- smoke removal operations;
- utilization of pre-planned strategies;
- adherence to the pre-planned drill scenario;
- effectiveness of the control room response; and
- drill objectives.
Documents reviewed are listed in the Attachment to this report.
These activities constituted one annual fire protection inspection sample as defined in IP 71111.05-05.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Resident Inspector Quarterly Review of Licensed Operator Requalification
a. Inspection Scope
On November 1, 2016, the inspectors observed a crew of licensed operators in the plants simulator during licensed operator requalification training. The inspectors verified that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and that training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:
- licensed operator performance;
- crews clarity and formality of communications;
- ability to take timely actions in the conservative direction;
- prioritization, interpretation, and verification of annunciator alarms;
- correct use and implementation of abnormal and emergency procedures;
- control board manipulations;
- oversight and direction from supervisors; and
- ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications.
The crews performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one quarterly licensed operator requalification program simulator sample as defined in IP 71111.11-05 and satisfied the inspection program requirement for the resident inspectors to observe a portion of an in-progress annual requalification operating test during a training cycle in which it was not observed by the NRC during the biennial portion of this IP.
b. Findings
No findings were identified.
.2 Resident Inspector Quarterly Observation During Periods of Heightened Activity or Risk
(71111.11Q)
a. Inspection Scope
On December 14, 2016 and December 16, 2016, the inspectors observed performance of reactor protection system surveillance activities and control rod exercises. This was an activity that required heightened awareness or was related to increased risk. The inspectors evaluated the following areas:
- licensed operator performance;
- crews clarity and formality of communications;
- ability to take timely actions in the conservative direction;
- prioritization, interpretation, and verification of annunciator alarms (if applicable);
- correct use and implementation of procedures;
- control board (or equipment) manipulations;
- oversight and direction from supervisors; and
- ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications (if applicable).
The performance in these areas was compared to pre-established operator action expectations, procedural compliance and task completion requirements. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one quarterly licensed operator heightened activity/risk sample as defined in IP 71111.11-05.
b. Findings
No findings were identified.
.3 Annual Testing Results
a. Inspection Scope
The inspectors reviewed the overall pass/fail results of the Annual Operating Test, as administered by the licensee from October 3, 2016, through November 11, 2016, and required by Title 10 of the Code of Federal Regulations (10 CFR), Part 55.59(a).
The results were compared to the thresholds established in Inspection Manual Chapter 0609, Appendix I, Licensed Operator Requalification Significance Determination Process," to assess the overall adequacy of the licensees Licensed Operator Requalification Training Program to meet the requirements of 10 CFR 55.59.
(Section 02.02).
This inspection constituted one annual licensed operator requalification inspection sample as defined in Inspection Procedure 71111.11A.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
.1 Routine Quarterly Evaluations
a. Inspection Scope
The inspectors evaluated degraded performance issues involving the following risk-significant systems:
- component cooling water (CCW);
- station air compressors; and
The inspectors reviewed events such as where ineffective equipment maintenance had resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:
- implementing appropriate work practices;
- identifying and addressing common cause failures;
- scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule;
- characterizing system reliability issues for performance;
- charging unavailability for performance;
- trending key parameters for condition monitoring;
- ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and
- verifying appropriate performance criteria for structures, systems, and components (SSCs)/functions classified as (a)(2), or appropriate and adequate goals and corrective actions for systems classified as (a)(1).
The inspectors performed a quality review with the CCW sample, as discussed in IP 71111.12, Section 02.02.
The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report.
This inspection constituted two quarterly maintenance effectiveness samples and one quality control sample as defined in IP 71111.12-05.
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
.1 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed the licensee's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:
- maintenance activities on 1SI-889B, 1P-15B safety injection pump discharge check valve, with P-32C service water pump and 1DY-04 inverter out of service.
These activities were selected based on their potential risk significance relative to the Reactor Safety Cornerstones. As applicable for each activity, the inspectors verified that risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate and complete. When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.
Documents reviewed during this inspection are listed in the Attachment to this report.
These maintenance risk assessments and emergent work control activities constituted two samples as defined in IP 71111.13-05.
b. Findings
- (1) Scaffolds Constructed Without Required Engineering Approval
Introduction:
A finding of very low safety significance and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified by inspectors for the licensees failure to follow step 4.1.3
- (2) of procedure MA-AA-100-1002, Scaffold Installation, Modification, and Removal Requests.
Specifically, the licensee failed to obtain and document engineering approval for multiple scaffolds constructed in the cable spreading room that did not meet the separation criteria of Attachment 1 of MA-AA-100-1002.
Description:
The inspectors, while performing a tour of the cable spreading room for the maintenance risk inspection on November 30, identified scaffolding in contact with the 2C-167 safeguards train B channels 2 and 4 relay rack and other examples where scaffolding was less than two inches from safety-related equipment. The inspectors reviewed the attached scaffold paperwork and found that engineering approvals had not been completed as required by the licensees scaffold procedure MA-AA-100-1002.
Specifically, MA-AA-100-1002, requires that the licensee obtain engineering approval for scaffolding constructed that does not meet the separation criteria listed in Attachment 1 of MA-AA-100-1002. The scaffolding in the cable spreading room had been constructed on November 2, 3, and 8. The separation criteria for the safety-related components of concern was two inches. The inspectors discussed their concerns with the licensee. As a result, the licensee modified the scaffolding that was in contact with a safeguards cabinet and the licensees engineers inspected and approved the scaffolds of concern. Additionally, the licensee performed an extent of condition walk-down and identified additional examples, which were subsequently evaluated and documented.
The licensee performed a condition evaluation to understand how the scaffolds were constructed without an engineering approval and determined that the group who constructed and inspected the scaffolding attempted to contact engineering, but did not follow through to ensure engineering was aware of the need to evaluate and approve the scaffolding. The licensee conducted a stand-down and information sharing session with the scaffold builders to ensure they were aware of the importance obtaining engineering approvals.
Analysis:
The inspectors determined that not obtaining engineering approval for scaffold constructed within 2 inches of safety-related equipment was contrary to MA-AA-100-1002, step 4.1.3
- (2) and was a performance deficiency. The finding was determined to be more than minor because the finding, if left uncorrected, had the potential to become a more significant safety concern. Specifically, if the licensee continued to construct scaffolding without obtaining required engineering approvals, scaffolding could be constructed that adversely affected the operability of surrounding SSCs. The inspectors concluded this finding was associated with the Mitigating Systems Cornerstone.
The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, issued on October 7, 2016. Specifically, the inspectors used IMC 0609 Appendix A SDP for Findings At-Power, issued June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions to screen the finding. The finding screened as of very low safety significance (Green) because the inspectors answered "No" to the screening questions. Specifically, the licensee completed the required evaluations and concluded that the scaffolding issues identified did not cause a loss of operability for the associated SCCs. This finding has a cross-cutting aspect of Teamwork (H.4), in the area of Human Performance, for the failure to individuals and work groups to communicate and coordinate their activities across organizational boundaries to ensure nuclear safety is maintained. Specifically, the scaffold building team failed to communicate with the engineering organization to ensure the engineering evaluations were complete. (Section 1R13.1)
Enforcement:
Title 10 CFR Part 50, Appendix B, Criterion V, requires, in part, that activities affecting quality be prescribed and accomplished by procedures appropriate to the circumstance and in accordance with those instructions and procedures. Procedure MA-AA-100-1002, Revision 4, step 4.1.3
- (2) requires, in part, that for scaffolding that cannot meet the separation criteria in Attachment 1, engineering approval must be documented.
Contrary to the above, on November 2-3, 2016 and November 8, 2016, the licensee failed to obtain and document engineering approval for multiple scaffolds constructed in the cable spreading room that did not meet the separation criteria of Attachment 1 of MA-AA-100-1002. Specifically, the components of concern, which included the 2C-167 safeguards train B channels 2 and 4 relay racks, had scaffold constructed within the two inch Attachment 1 separation criteria without engineering approval. The licensees short-term corrective actions included obtaining the appropriate engineering evaluations for the affected scaffolding and conducting a stand-down and information sharing with the scaffold builders to ensure they were aware of the importance obtaining engineering approvals. Because this violation is of very low safety significance and the licensee entered it into the CAP as AR 02171922, it is being treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy.
(NCV 05000266/2016004-001; 05000301/2016004-001; Scaffolds Constructed Without Required Engineering Approvals)
1R15 Operability Determinations and Functional Assessments
.1 Operability Evaluations
a. Inspection Scope
The inspectors reviewed the following issues:
- AR 2160698; AFW pump suction pressure channel check;
- AR 2152508; PBN TFPI 2016 FSA 2080426 - Fire Penetration Seals Not Inspected;
- AR 2169657; unevaluated potential PAB flood source; and
- AR 2160569; DY-0D inverter blown A3 fuse during start up after A3 board inspection.
The inspectors selected these potential operability issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS and FSAR to the licensees evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Documents reviewed are listed in the to this report.
This operability inspection constituted four samples as defined in IP 71111.15-05.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
.1 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the following post-maintenance (PM) activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:
- G-02 EDG after fuel injector replacement;
- K-2A IA compressor after maintenance;
- DY-0D inverter after maintenance; and
These activities were selected based upon the structure, system, or component's ability to impact risk. The inspectors evaluated these activities for the following (as applicable):
the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as written in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing (temporary modifications or jumpers required for test performance were properly removed after test completion); and test documentation was properly evaluated. The inspectors evaluated the activities against TSs, the FSAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with post-maintenance tests to determine whether the licensee was identifying problems and entering them in the CAP and that the problems were being corrected commensurate with their importance to safety. Documents reviewed are listed in the Attachment to this report.
This inspection constituted four post-maintenance testing samples as defined in IP 71111.19-05.
b. Findings
No findings were identified.
1R22 Surveillance Testing
.1 Surveillance Testing
a. Inspection Scope
The inspectors reviewed the test results for the following activities to determine whether risk-significant systems and equipment were capable of performing their intended safety function and to verify testing was conducted in accordance with applicable procedural and TS requirements:
- PC 29, Gas Turbine and Auxiliary Diesel Load Test (routine);
- IT 07D, P-32D Service Water Pump (routine);
- 1ICP 02.003B, Reactor Protection System Logic Train B Surveillance Test (routine);
- 1ICP 02.005B, Engineered Safety Features System Logic Train B Staggered Actuation Logic Test (routine); and
The inspectors observed in-plant activities and reviewed procedures and associated records to determine the following:
- did preconditioning occur;
- the effects of the testing were adequately addressed by control room personnel or engineers prior to the commencement of the testing;
- acceptance criteria were clearly stated, demonstrated operational readiness, and were consistent with the system design basis;
- plant equipment calibration was correct, accurate, and properly documented;
- as-left setpoints were within required ranges; and the calibration frequency was in accordance with TSs, the USAR, procedures, and applicable commitments;
- measuring and test equipment calibration was current;
- test equipment was used within the required range and accuracy; applicable prerequisites described in the test procedures were satisfied;
- test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; jumpers and lifted leads were controlled and restored where used;
- test data and results were accurate, complete, within limits, and valid;
- test equipment was removed after testing;
- where applicable for inservice testing activities, testing was performed in accordance with the applicable version of Section XI, American Society of Mechanical Engineers code, and reference values were consistent with the system design basis;
- where applicable, test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable;
- where applicable for safety-related instrument control surveillance tests, reference setting data were accurately incorporated in the test procedure;
- where applicable, actual conditions encountering high resistance electrical contacts were such that the intended safety function could still be accomplished;
- prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test;
- equipment was returned to a position or status required to support the performance of its safety functions; and
- all problems identified during the testing were appropriately documented and dispositioned in the CAP.
Documents reviewed are listed in the Attachment to this report.
This inspection constituted four routine surveillance testing samples and one reactor coolant system leak detection inspection sample as defined in IP 71111.22, Sections-02 and-05.
b. Findings
No findings were identified.
1EP2 Alert and Notification System Evaluation
.1 Alert and Notification System Evaluation
a. Inspection Scope
The inspectors reviewed documents and held discussions with Emergency Preparedness (EP) staff regarding the operation, maintenance, and periodic testing of the primary and backup Alert and Notification System (ANS) in the plume pathway Emergency Planning Zone. The inspectors reviewed monthly trend reports and siren test failure records from October of 2014 to October 2016. Information gathered during document reviews and interviews were used to determine whether the ANS equipment was maintained and tested in accordance with Emergency Plan commitments and procedures. Documents reviewed are listed in the Attachment to this report.
This ANS evaluation inspection constitutes one sample as defined in Inspection Procedure (IP) 71114.02-06.
b. Findings
No findings were identified.
1EP3 Emergency Response Organization Staffing and Augmentation System
.1 Emergency Response Organization Staffing and Augmentation System
a. Inspection Scope
The inspectors reviewed and discussed with plant EP management and staff the Emergency Plan commitments and procedures that addressed the primary and alternate methods of initiating an Emergency Response Organization (ERO) activation to augment the on-shift staff as well as the provisions for maintaining the plants ERO team and qualification lists. The inspectors reviewed reports and a sample of CAP records of unannounced off-hour augmentation drills and pager tests, which were conducted from October 2014 to October 2016, to determine the adequacy of the drill critiques and associated corrective actions. The inspectors also reviewed a sample of the training records of approximately six ERO personnel, who were assigned to key and support positions, to determine the status of their training as it related to their assigned ERO positions. Documents reviewed are listed in the Attachment to this report.
This ERO augmentation testing inspection constitutes one sample as defined in IP 71114.03-06.
b. Findings
No findings were identified.
1EP4 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
The regional inspector performed an in-office review of the latest revisions to the Emergency Plan, Emergency Action Levels (EALs), and EAL Bases document to determine if these changes decreased the effectiveness of the Emergency Plan.
The inspector also performed a review of the licensees Title 10 of the Code of Federal Regulations, (10 CFR) Part 50.54(q) change process, and Emergency Plan change documentation to ensure proper implementation for maintaining Emergency Plan integrity.
The U.S. Nuclear Regulatory Commission review was not documented in a safety evaluation report, and did not constitute approval of licensee-generated changes; therefore, this revision is subject to future inspection. The specific documents reviewed during this inspection are listed in the Attachment to this report.
This EAL and Emergency Plan Change inspection constituted one sample as defined in Inspection Procedure 71114.04-06.
b. Findings
No findings were identified.
1EP5 Maintenance of Emergency Preparedness
.1 Maintenance of Emergency Preparedness
a. Inspection Scope
The inspectors reviewed the nuclear oversight staffs 2014 and 2015 audit of the Point Beach Nuclear Plants EP Program to determine that the independent assessments met the requirements of 10 CFR, Part 50.54(t). The inspectors reviewed samples of CAP records associated with the 2015 biennial exercise, as well as various EP drills conducted in 2015 and 2016, in order to determine whether the licensee fulfilled drill commitments and to evaluate the licensees efforts to identify and resolve identified issues. The inspectors reviewed a sample of EP items and corrective actions related to the stations EP program, and activities to determine whether corrective actions were completed in accordance with the sites CAP. Documents reviewed are listed in the to this report.
This maintenance of EP inspection constitutes the completion of one sample as defined in IP 71114.05-06.
b. Findings
No findings were identified.
OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security
4OA1 Performance Indicator Verification
.1 Mitigating Systems Performance IndexEmergency AC Power System
a. Inspection Scope
The inspectors sampled licensee submittals for the Mitigating Systems Performance Index (MSPI) Emergency AC Power System performance indicator, Units 1 and 2, for the period from the third quarter 2015 through the second quarter 2016. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 31, 2013, were used. The inspectors reviewed the licensees operator narrative logs, MSPI derivation reports, issue reports, event reports and NRC Integrated Inspection Reports to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the to this report.
This inspection constituted two MSPI emergency AC power system sample as defined in IP 71151-05.
b. Findings
No findings were identified.
.2 Mitigating Systems Performance IndexHigh Pressure Injection Systems
a. Inspection Scope
The inspectors sampled licensee submittals for the Mitigating Systems Performance Index High Pressure Injection Systems performance indicator, Units 1 and 2, for the period from the third quarter 2015 through the second quarter 2016. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 31, 2013, were used. The inspectors reviewed the licensees operator narrative logs, issue reports, MSPI derivation reports, event reports and NRC Integrated Inspection Reports to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified.
Documents reviewed are listed in the Attachment to this report.
This inspection constituted two MSPI high pressure injection system sample as defined in IP 71151-05.
b. Findings
No findings were identified.
.3 Mitigating Systems Performance IndexHeat Removal System
a. Inspection Scope
The inspectors sampled licensee submittals for the Mitigating Systems Performance Index Heat Removal System performance indicator, Units 1 and 2, for the period from the third quarter 2015 through the second quarter 2016. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 31, 2013, were used. The inspectors reviewed the licensees operator narrative logs, issue reports, event reports, MSPI derivation reports, and NRC Integrated Inspection to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report.
This inspection constituted two MSPI heat removal system sample as defined in IP 71151-05.
b. Findings
No findings were identified.
.4 Mitigating Systems Performance IndexResidual Heat Removal System
a. Inspection Scope
The inspectors sampled licensee submittals for the Mitigating Systems Performance Index Residual Heat Removal System performance indicator Units 1 and 2, for the period from the third quarter 2015 through the second quarter 2016. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 31, 2013, were used. The inspectors reviewed the licensees operator narrative logs, issue reports, MSPI derivation reports, event reports and NRC Integrated Inspection Reports to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified.
Documents reviewed are listed in the Attachment to this report.
This inspection constituted two MSPI residual heat removal system sample as defined in IP 71151-05.
b. Findings
No findings were identified.
.5 Mitigating Systems Performance IndexCooling Water Systems
a. Inspection Scope
The inspectors sampled licensee submittals for the Mitigating Systems Performance Index Cooling Water Systems performance indicator, Units 1 and 2, for the period from the third quarter 2015 through the second quarter 2016. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, dated August 31, 2013, were used. The inspectors reviewed the licensees operator narrative logs, issue reports, MSPI derivation reports, event reports and NRC Integrated Inspection Reports to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report.
This inspection constituted two MSPI cooling water system sample as defined in IP 71151-05.
b. Findings
No findings were identified.
.6 Drill and Exercise Performance
a. Inspection Scope
The inspectors sampled licensee submittals for the Drill and Exercise Performance (DEP) Indicator for the period from the third quarter 2015 through the third quarter 2016.
To determine the accuracy of the Performance Indicator (PI) data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, were used. The inspectors reviewed the licensees records associated with the PI to verify that the licensee accurately reported the DEP indicator, in accordance with relevant procedures and NEI guidance. Specifically, the inspectors reviewed licensee records and processes, including procedural guidance on assessing opportunities for the PI; assessments of PI opportunities during pre-designated control room simulator training sessions; performance during the 2015 biennial exercise; and performance during other drills.
Documents reviewed are listed in the Attachment to this report.
This inspection constitutes one DEP sample as defined in IP 71151-05.
b. Findings
No findings were identified.
.7 Emergency Response Organization Drill Participation
a. Inspection Scope
The inspectors sampled licensee submittals for the ERO Drill Participation PI for the period from the third quarter 2015 through third quarter 2016. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, were used. The inspectors reviewed the licensees records associated with the PI to verify that the licensee accurately reported the indicator, in accordance with relevant procedures and NEI guidance. Specifically, the inspectors reviewed licensee records and processes, including procedural guidance on assessing opportunities for the PI; participation during the 2015 biennial exercise and other drills; and revisions of the roster of personnel assigned to key ERO positions. Documents reviewed are listed in the Attachment to this report.
This inspection constitutes one ERO drill participation sample as defined in IP 71151-05.
b. Findings
No findings were identified.
.8 Alert and Notification System Reliability
a. Inspection Scope
The inspectors sampled licensee submittals for the ANS PI for the period from the third quarter 2015 through third quarter 2016. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, were used.
The inspectors reviewed the licensees records associated with the PI to verify that the licensee accurately reported the indicator, in accordance with relevant procedures and NEI guidance. Specifically, the inspectors reviewed licensee records and processes, including procedural guidance on assessing opportunities for the PI and results of periodic ANS operability tests. Documents reviewed are listed in the Attachment to this report.
This inspection constitutes one ANS sample as defined in IP 71151-05.
b. Findings
No findings were identified.
4OA2 Identification and Resolution of Problems
.1 Routine Review of Items Entered into the Corrective Action Program
a. Inspection Scope
As discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify they were being entered into the licensees corrective action program at an appropriate threshold, adequate attention was being given to timely corrective actions, and adverse trends were identified and addressed. Some minor issues were entered into the licensees corrective action program as a result of the inspectors observations; however, they are not discussed in this report.
These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure they were considered an integral part of the inspections performed during the quarter.
b. Findings
One licensee-identified NCV of very low safety significance was identified and is documented in Section 4OA7 of this report.
.2 Semi-Annual Trend Review
a. Inspection Scope
The inspectors performed a review of the licensees corrective action program and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors review was focused on repetitive equipment issues, but also considered the results of daily inspector corrective action program item screening discussed in Section 4OA2.1 above, licensee trending efforts, and licensee human performance results. The inspectors review nominally considered the 6-month period of April 2016 through September 2016, although some examples expanded beyond those dates where the scope of the trend warranted.
The review also included issues documented outside the corrective action program in major equipment problem lists, repetitive and/or rework maintenance lists, departmental problem/challenges lists, system health reports, quality assurance audit/surveillance reports, self-assessment reports, and Maintenance Rule assessments. The inspectors compared and contrasted their results with the results contained in the licensees corrective action program trending reports. Corrective actions associated with a sample of the issues identified in the licensees trending reports were reviewed for adequacy.
This review constituted one semi-annual trend review inspection sample as defined in IP 71152.
b. Observations As part of the semi-annual trend sample, the inspectors assessed the licensees progress in addressing an adverse trend in Operations department human performance events. The licensee identified that the adverse trend began in the fourth quarter of 2015 after an increase in the number of human performance events, most notably the main transformer lockout and loss of non-vital 4KV buses, documented in LER 05000301/2015-005-01. The licensee, to correct the trend, created an Operations excellence plan with an emphasis on improving procedure use and adherence, effective use of human performance tools, and enhancing senior reactor operator leadership traits. The inspectors continued to note human performance errors in the first half of 2016, but efforts by station leadership appeared to result in improvements in Operations human performance beginning in the August timeframe, and which continued through the remainder of the year.
c. Findings
No findings were identified.
4OA6 Management Meetings
.1 Exit Meeting Summary
On January 18, 2017, the inspectors presented the inspection results to Mr. R. Coffey, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.
.2 Interim Exit Meetings
Interim exits were conducted for:
- the results of an EP Program inspection with Mr. R. Coffey, Site Vice President, conducted at the site on October 27, 2016;
- the results of the Licensed Operator Requalification Program and Licensed Operator Performance inspection with Mr. R. Amundson, Operations Training Regulatory Exam Coordinator, conducted over the phone on November 11, 2016; and
- the results of an EP Program inspection with Mr. R. Seizer, Emergency Preparedness Manager, conducted over the phone on December 22, 2016.
The inspectors confirmed that none of the potential report input discussed was considered proprietary. Proprietary material received during the inspection was returned to the licensee or destroyed.
4OA7 Licensee-Identified Violations
The following violation of very low significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as an NCV.
The licensee identified a finding of very low safety significance (Green) and an NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, due to the failure to properly implement instructions in Work Order (WO) 40461957 for the replacement of the power range nuclear instrument (NI) 1N-43 gain potentiometer vernier dial. Specifically, step 5 of the WO stated, Replace the gain pot vernier with the preset spare. Prevent movement of the potentiometer shaft as much as possible.
Contrary to the WO instructions, the technician performing the work believed it was necessary to dial the gain potentiometer to zero before replacing the dial and in doing so caused the 1N-43 NI high flux trip function to become inoperable. This was identified when the control room operators observed the indicated NI power reading for 1N-43 decrease to 82 percent and questioned the technician performing the work about the observed power change.
Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings required, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Contrary to the above, on December 2, 2016, the licensee did not accomplish activities affecting quality in accordance with the documented instructions. Specifically, the licensee did not follow step 5 of the work instructions in WO 40461957, causing the NI high flux trip function for 1N-43 to become inoperable. The licensee entered this issue into the CAP as AR 02172378. The inspectors determined that this issue was of very low safety significance (Green) after reviewing IMC 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, dated October 7, 2016 and IMC 0609, Appendix A, The Significance Determination Process (SDP) For Findings At-Power, dated July 1, 2012. The inspectors answered no to all questions in Exhibit 2, Section C, Reactivity Control Systems. This resulted in the finding screening as Green.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- R. Coffey, Site Vice President
- D. DeBoer, Plant General Manager
- S. Aerts, Performance Improvement Manager
- R. Amundson, Operations Training Regulatory Exam Coordinator
- A. Bussiere, Information Technology Project Manager
- R. Clark, Licensing Engineer
- A. Fitzgerald, Emergency Preparedness Specialist
- J. Gerondale, Security Supervisor
- B. Gierach, Information Technology Manager
- J. Golding, System Engineering Supervisor
- B. Griffin, Communications Specialist
- A. Gustafson, Operations Training General Supervisor
- D. Halverson, Information Technology Specialist
- R. Harrsch, Engineering Director
R. Hastings Operations Assistant Manager
- J. Henrickson, Emergency Preparedness Coordinator
- R. Higgins, Operations Assistant Manager
- K. Hilliker, Emergency Preparedness Coordinator
- T. Lesniak, Maintenance Director
- B. Leonhardt, Emergency Preparedness Coordinator
- K. Locke, Licensing Engineer
- S. Manthei, Licensing Engineer
- M. Millen, Senior Project Manager
- C. Neuser, Site Engineering Manager
- P. Polfleit, Emergency Preparedness - Corporate Functional Area Manager
- J. Ramski, Outage Manager
- B. Scherwinski, Licensing
- E. Schmidt, Site Engineering Manager
- T. Schneider, Senior Engineer
- R. Seizert, Emergency Preparedness Manager
- B. Smith, Independent Spent Fuel Storage Installation Project Manager
- G. Strharsky, Site Quality Manager
- S. Wall, Emergency Preparedness Training
- R. Webber, Site Operations Director
- R. Welty, Radiation Protection Manager
- P. Wild, Site Engineering Manager
- J. Wilson, Site Operations Director
- B. Wolf, Safety Manager
- B. Woyak, Licensing Manager
U.S. Nuclear Regulatory Commission
- J. Cameron, Chief, Reactor Projects Branch 4
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
- 05000266/2016004-01 NCV Scaffolds Constructed Without Required Engineering
- 05000301/2016004-01 Approval (Section 1R13.1)
Closed
- 05000266/2016004-01 NCV Scaffolds Constructed Without Required Engineering
- 05000301/2016004-01 Approval (Section 1R13.1)