IR 05000266/2016007

NRC Problem Identification and Resolution Inspection Report 05000266/2016007; 05000301/2016007

ML16356A098
Person / Time
Site:	Point Beach
Issue date:	12/20/2016
From:	Jamnes Cameron Reactor Projects Region 3 Branch 4
To:	Coffey R Point Beach
References
IR 2016007
Download: ML16356A098 (26)

Text

ember 20, 2016

SUBJECT:

POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000266/2016007; 05000301/2016007

Dear Mr. Coffey:

On November 17, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution (PI&R) biennial inspection at your Point Beach Nuclear Plant. The enclosed report documents the results of this inspection, which were discussed on November 17, 2016, with you and other members of your staff.

The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety. However, the team identified several instances of poor documentation of corrective actions taken to address some issues.

The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety. However, the team also identified several instances of weaknesses in the documentation of your incorporation of lessons learned from industry and NRC operating experience.

Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available. In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management 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 Kenneth Riemer Acting for/

Jamnes L. Cameron, Chief Branch 4 Division of Reactor Projects Docket Nos. 50-266; 50-301 License Nos. DPR-24; DPR-27

Enclosure:

IR 05000266/2016007; 05000301/2016007

REGION III==

Docket Nos: 05000266; 05000301 License Nos: DPR-24; DPR-27 Report No: 05000266/2016007; 05000301/2016007 Licensee: NextEra Energy Point Beach, LLC Facility: Point Beach Nuclear Plant, Units 1 and 2 Location: Two Rivers, WI Dates: October 31 through November 17, 2016 Inspectors: J. Rutkowski, Project Engineer, Team Lead B. Jose, Senior Reactor Inspector, DRS J. Park, Reactor Inspector, DRS K. Barclay, Senior Resident Inspector (Acting)

Approved by: J. Cameron, Chief Branch 4 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

Inspection Report (IR) 05000266/2016007; 05000301/2016007; 10/31/2016 - 11/17/2016;

Point Beach Nuclear Plant, Units 1 and 2; Biennial Problem Identification and Resolution Inspection Report This inspection was performed by three NRC regional inspectors and the Point Beach Nuclear Plant (PBNP) acting senior resident inspector. No findings of significance or violations of NRC requirements were identified during this inspection. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 6, dated July 2016.

Problem Identification and Resolution On the basis of the sample selected for review, the team determined that implementation of the corrective action (CA) program and associated processes at the PBNP support nuclear safety.

The licensee demonstrated a low threshold for identifying problems and entering them in the CA program. Items entered into the CA program were screened and prioritized in a timely manner using established criteria; were generally evaluated commensurate with their safety significance; and corrective actions were generally implemented in a timely manner, commensurate with the safety significance. The team noted that the licensee reviewed operating experience for applicability to station activities. Audits and self-assessments were performed at a level sufficient to identify most deficiencies. On the basis of interviews conducted during the inspection, workers at the site expressed freedom to raise and enter safety concerns directly into the CA program or through their supervisors.

NRC-Identified

and Self-Revealed Findings None

Licensee-Identified Violations

None

REPORT DETAILS

4OA2 Problem Identification and Resolution

The activities documented in Sections

.1 through .4 constituted one biennial sample of

problem identification and resolution as defined in IP 71152.

Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the licensees corrective action (CA) program implementing procedures and attended CA program meetings to assess the implementation of the CA program by site personnel.

The inspectors reviewed risk and safety significant issues in the licensees CA program since the last NRC Problem Identification and Resolution (PI&R) inspection in July 2015.

The selection of issues ensured an adequate review of issues across NRC cornerstones. The inspectors used issues identified through NRC generic communications, department self-assessments, licensee audits, operating experience reports, and NRC documented findings as sources to select issues. Additionally, the inspectors reviewed action requests/condition reports (CRs) generated during facility personnels performance in daily plant activities. The inspectors also reviewed a selection of work orders (WOs), self-assessment results, audits, performance indicator reports, system health reports, and completed investigations from the licensees various investigation methods, which included root cause evaluations (RCE), apparent cause evaluations (ACE), and condition evaluations (CE).

The inspectors selected electronic board components, specifically various types of electrolytic capacitors, in the Reactor Protection System to review in detail. The inspectors review was to determine whether the licensee staff were properly monitoring and evaluating the performance of these and associated components through effective implementation of station monitoring and periodic component replacement programs.

The inspectors also did a five-year review of the system to assess the licensee staffs efforts in monitoring for system degradation due to aging aspects. The inspectors also performed a partial system walkdown of the reactor protection system and associated spare components in the instrument technician shop, the safety injection system, and portions of the auxiliary feedwater system to review if equipment conditions were appropriately represented in the CA program, work orders, and system health documents.

During the reviews, the inspectors determined whether the licensee staffs actions complied with the facilitys CA program and 10 CFR Part 50, Appendix B requirements.

Specifically, the inspectors determined whether licensee personnel were identifying station issues at the proper threshold, entering the station issues into the stations CA program in a timely manner, and assigning the appropriate prioritization for resolution of the issues. The inspectors also determined whether the licensee staff assigned the appropriate investigation method to ensure the proper determination of root, apparent, and contributing causes. The inspectors also evaluated the timeliness and effectiveness of corrective actions for selected issue reports, completed investigations, and eight NRC previously identified findings that included principally non-cited violations.

The inspectors also reviewed corrective actions from licensees RCEs 01883633, White Finding-Flooding, and 01896156, Common Cause Degraded Cornerstone-Mitigating Systems, Two White Findings, which were not completed by the licensee as of July 2015.

Documents reviewed are listed in the Attachment to this report.

b. Assessment

(1) Effectiveness of Problem Identification Based on the information reviewed, including initiation rates of CRs and information from interviews, the inspectors determined that the licensee has a low threshold for initiating CRs, and from the CRs reviewed, the threshold was appropriate. The inspectors did not identify any safety significant item that was not entered into the CA program. The inspectors assessed the effectiveness of problem identification as adequate to support nuclear safety.

Observations Although there is a low threshold for identifying and entering into the CA program, the inspectors found that the licensee continues to identify opportunities for improvement through their self-assessment process. The previous PI&R inspection report indicated that the licensees self-assessment process identified instances when CRs should have been written per site expectations but were not. The licensees focused self-assessment of the CA program in preparation of this years NRC PI&R inspection (SAR 02097987)identified similar instances where CRs had not been initiated where they should have.

The licensee also identified instances of late initiation of CRs. Each of those examples were either of minor significance or did not constitute violations of NRC regulatory requirements.

The inspectors reviewed open corrective WOs, open corrective action items, and system health reports from the two most recent quarters for the Safety Injection (SI) system. A portion of the system was walked down with the SI system engineer. The inspectors found the system to be in overall good health with a reasonable number of open corrective WOs and corrective action items. A sample of issues identified in the system health reports were reviewed and found to have interim compensatory measures and corrective actions to address them. The inspectors did not find any conflicts between the conditions represented by the open WOs, corrective action documents, and system health reports and the actual system conditions.

Findings No findings were identified.

(2) Effectiveness of Prioritization and Evaluation of Issues The inspectors concluded that the licensees overall performance in the prioritization and evaluation of issues was generally appropriate. In particular, the inspectors observed that while the majority of issues identified were at a low level of significance, those issues and issues of more significance were assigned a review and action level appropriate for the identified condition evaluation and in accordance with governing procedures. Issues were being appropriately screened by the originating departments, the Management Review Board, and Operations shift management for items potentially impacting equipment operability. Evaluations in apparent cause and root cause reports reviewed by the inspectors appropriately supported nuclear safety.

The inspectors identified no items in the backlogs of the CA program or maintenance WO system that were risk significant, either individually or collectively. The inspectors reviewed the licensees WO backlog and associated performance metric data and concluded that equipment issues were generally being addressed appropriately.

Observations The inspectors determined, from data supplied by the licensee that as of October 5, 2016, the CA program had approximately 400 open CRs that had been approved for follow-up investigation. Approximately 285 of those CRs were initiated in 2016; 31 of the open CRs originated in 2010 or earlier. The licensee information also listed that 4268 CRs had been closed during the period of April 2016 to October 5, 2016.

The licensee provided information that the largest backlog of open actions was in the engineering groups and several involved plant design.

Licensee data indicated that, as of September 2016, the station had a work order (WO)backlog of 3611 with 186 activities classified as corrective maintenance. Approximately 70 activities were created in 2010 or earlier. The station uses the industry classification scheme in AP-928, Work Management Process Description, for grouping WOs. The inspectors review concluded that the numbers appeared consistent with industry averages and classifications. From the documents reviewed, the inspectors did not identify any current significant corrective maintenance issues.

The inspectors reviewed several available RCEs and ACEs. ACEs reviewed varied from detailed and intrusive to quick reviews that used the Why Staircase. In the 2015 PI&R inspection, the inspectors found several examples of the use of the Why Staircase as the only analysis tool and questioned that practice and some of the resultant conclusions. During the current inspection, the inspectors did not identify any issues with the analysis methods.

The licensee informed the inspectors that with recent changes to the CA program, in response to industry efforts to improve efficiency, condition investigations will now be assigned as Severity Level 1 or Severity Level 2. The inspectors did not evaluate the potential impact of these recently implemented changes. The inspectors noted that the licensee has implemented a non-CA program (NCAP) option as recommended in industry efficiency improvement suggestions.

(3) Effectiveness of Corrective Actions On the basis of the corrective action documents reviewed, the inspectors concluded that the CAs appeared generally appropriate for the identified issues. Those CAs addressing selected NRC documented violations were also determined to be generally effective and timely.The inspectors review of the previous five years of the licensees efforts to address issues with the Reactor Protection System did not identify any recent negative trends or inability by the licensee to address long-term issues. The inspectors questioned the quality of the closeout of several corrective actions.

Observations The inspectors identified several examples of corrective action completion that did not provide details or objective evidence of the method of corrective action closure. The licensee initiated CR 02170181, Quality Closeout of Action Requests.

The inspectors performed a review of the licensees CA Program and associated documents focusing on the Reactor Protection System, with emphasis on installed electrolytic capacitors, to determine whether any obsolescence and aging issues existed for the last five years. The inspectors review and evaluation were focused on obsolescence and aging issues to ensure corrective actions were: complete, accurate, and timely; considered extent of condition; provided appropriate classification and prioritization; provided identification of root and contributing causes; appropriately focused actions taken that resulted in the correction of the identified problem; identified negative trends; operating experience was adequately evaluated for applicability; and applicable lessons learned were communicated to appropriate organizations. The inspectors determined that the licensee established an Obsolescence Monitoring Program to periodically refurbish and/or replace reactor protection system components and was adequately addressing the types of electrolytic capacitors installed in the system.

Findings No findings were identified.

(4) Corrective Actions Associated with Root Cause Evaluations for the Degraded Cornerstone Resulting From Potential Flooding Issues In February 2015, the NRC completed a supplemental inspection (NRC Inspection Report 05000266/2015009; 05000301/2015009 (ADAMS Accession Number ML15077A007)) in accordance with Inspection Procedure (IP) 95002, Inspection for One Degraded Cornerstone or Any Three White Inputs in a Strategic Performance Area, to assess the licensees evaluation of one White inspection finding that affected the Mitigating Systems Cornerstone. The NRC, during that inspection, reviewed completed corrective actions from licensees root cause evaluations 01883633, White Finding-Flooding, and 01896156, Common Cause Degraded Cornerstone-Mitigating Systems, Two White Findings. Numerous corrective actions were not completed by the end of that inspection. The inspectors reviewed the corrective actions that were not completed then in subsequent inspections. During this inspection, the inspectors reviewed completed corrective actions from those root causes that were not previously reviewed.

For RCE 01883633, the NRC during this inspection reviewed corrective actions number 48, 49, 53, 58 and 62. Corrective actions that remained open and were not closed at the time of this inspection were number 45 and 70.

For RCE 01896156, the NRC during this inspection reviewed corrective actions number 49, 53, 54, 59, 62, 63, 64, 65, 66, 68, 69, and 71. All corrective actions were closed at the time of this inspection.

Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed the licensees implementation of the facilitys operating experience (OE) program. Specifically, the inspectors reviewed OE program implementing procedures, attended CA program meetings, reviewed completed evaluations of OE issues and events, and selected assessment of the OE performance indicators. The inspectors review was to determine whether the licensee was effectively integrating OE into the performance of daily activities, whether evaluations of issues were proper and conducted by qualified personnel, and whether the licensees program was sufficient to prevent future occurrences of previous industry events. The inspectors also assessed whether CAs, as a result of OE, were identified and implemented in an effective and timely manner.

Assessment Overall, the inspectors determined that the licensee was generally effective at evaluating NRC and industry OE for relevance to the facility. The inspectors also verified that the use of OE in formal CA program products such as root cause evaluations and apparent cause evaluations was appropriate and adequately considered. The OE that was applicable to the facility was appropriately evaluated and actions were implemented in a timely manner to address any issues that resulted from the evaluations.

Observations The inspectors noted that closeout of actions that resulted from their review of OE was not always of quality. The inspectors had difficulty determining what actions were performed due to lack of documented trail of actions. Specifically,

• A licensee evaluation of regulatory OE associated with Monticello Dry Shielded Canisters resulted in this action statement: Engineering and Dry Fuel Storage Project Manager will review and implement any required actions as part of outage prep and upcoming dry fuel work. However, the inspectors were not able to determine what the required actions were and how they were or will be implemented.

• A licensee evaluation of Regulatory Issues Summary (RIS) 2015-17 resulted, in part, in an action statement that a coordination will be made for changes to the Fire Plan that will satisfy the RIS. However, there was a lack of details from this evaluation on what and when coordination activities will be performed.

The inspectors determined, from discussions with the licensee, that there were no safety concerns as a result of this condition and no associated conditions adverse to quality were identified. Due to the quality of closeout documentation issues as noted above, the licensee initiated condition report CR 02169485, 2016 PI&R: Quality Closeout of OE Actions.

b. Findings

No findings were identified.

Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors assessed the licensee staffs ability to identify and enter issues into the CA program, prioritize and evaluate issues, and implement effective corrective actions, through efforts from departmental assessments and audits. The inspectors reviewed several forms of assessment reports and audits that varied from in depth to limited scope assessments.

Assessment The inspectors concluded that self-assessments and audits were typically accurate, thorough, and effective at identifying most issues and enhancement opportunities at an appropriate threshold with some exceptions. The inspectors concluded that personnel involved in audits and self-assessments were knowledgeable in the subject area they audited or assessed. In many cases, self-assessments and audits identified issues that were not previously recognized by the licensee.

Observations In each of the assessment reports reviewed, the licensee determined that action items were necessary to address identified gaps and enhancement items. However, in some instances, the inspectors had difficulty following how the licensee addressed them due to either unclear or lack of detailed documented actions. Some examples were:

• SAR 1921241, Lifting, Rigging, and Material Handling, assessed whether the lifting and rigging program standards were being used to provide for safe rigging and material handling evolutions. It identified five enhancement items; however, it did not indicate what actions were initiated to address them. The inspectors did note, after an interview with the licensee staff, that three enhancement items were addressed under follow-on assignments created under the same SAR number. Two separate CRs were created to address the remaining two enhancement items, which were referenced within the body of the assessment report but not under the Enhancements section.

• CR 02090853, EPD Alarm Roll Up, is a Quick-Hit assessment that performed a rollup of the employee radiation dose alarms during a plant outage. The assessment identified one fleet gap and five site gaps; however, it did not indicate what actions were initiated to address them. This was inconsistent with another Quick-Hit assessment report reviewed by the inspectors, AR 02016762, Quick Hit of Rework Program, which included a separate section indicating what actions were initiated to address the identified gaps. After an interview with the staff involved in the radiation dose alarm assessment, the inspectors were able to identify how most gaps were addressed.

The inspectors reviewed the licensees observations and corrective actions from the last Chemistry Department Nuclear Oversight audit and selected a sample of corrective actions to verify that they were implemented and effective. The inspectors identified one minor issue during their assessment of the licensees audit program. Specifically, the previous audit identified weaknesses in documentation of standard stock lot numbers in the preparation of calibration standards for chemistry equipment. The inspectors reviewed a sample of calibration curve books and found two cases where chemical lot numbers were not included on the calibration curves. The licensee initiated CR 02170025, Instrument CAL Standards Lot Numbers.

b. Findings

No findings were identified.

Assessment of Safety Conscious Work Environment

a. Inspection Scope

The inspectors assessed the licensees safety conscious work environment (SCWE)through the reviews of the facilitys employee concerns program (ECP) implementing procedures, discussions with the coordinator of the ECP, interviews with personnel from various departments, and reviews of issue reports. The inspectors also reviewed the results from a 2015 culture survey, the results from a 2016 Employee Engagement Survey, and results from licensee-initiated Health Checks surveys.

As part of the overall inspection effort, inspectors discussed department and station programs with a variety of people. In addition, the inspectors held scheduled interviews with 25 non-supervisory individuals and 6 first-line supervisors, in groups of four to seven people, from various departments to assess their willingness to raise nuclear safety issues. Additionally, other personnel were randomly asked their views of the effectiveness of the CA program.

The individuals for the scheduled interviews were randomly selected to provide a distribution across the various departments at the site. In addition to assessing individuals willingness to raise nuclear safety issues, the interviews included discussion of any changes in the plant work environment over the last 12 months. Other items discussed included:

• knowledge and understanding of the CA program;

• effectiveness and efficiency of the CA program;

• willingness to use the CA program; and

• knowledge and understanding of ECP.

The inspectors also discussed the functioning of the ECP with the program coordinator, reviewed program logs from 2015 and 2016, and reviewed four case files.

Assessment The inspectors did not identify any issues of concern regarding the licensees SCWE.

Information obtained during the interviews indicated that an environment was established where the majority of licensee personnel felt free to raise nuclear safety issues without fear of retaliation. Licensee personnel were aware of and generally familiar with the CA program and other processes, including the ECP and the NRCs allegation process, through which concerns could be raised; safety significant issues could be freely communicated to supervision. The inspectors did not observe and were not provided any examples where there was retaliation for the raising of nuclear safety issues. Documents provided to the inspectors regarding surveys and monitoring of the safety culture and SCWE generally supported the conclusions from the interviews even with survey issues identifying conditions that might act to inhibit discussion of items including, in several departments, a mistrust of management and lack of effective communications and coordination among groups and departments.

Observations A survey report completed in December 2015 documented that several plant departments had potential issues with effective communications and coordination among work groups and downward flow of information from management. Personnel in the interviewed arranged groups, when presented with the December 2015 survey results, stated that at their level there were no issues with working with and communicating with workers in other groups. The majority of the groups expressed their opinion that communications and coordination issues, if they existed, were at levels above them.

However, all of the interviewed groups stated that conditions on communication had improved.

A 2016 engagement survey by a licensees contract organization indicated that employee engagement had improved since 2014 but was below the industry norm in several of the engagement scores.

All interviewees indicated that they could and would bring up safety issues with supervision, management, and through the CA program. None of the interviewed personnel stated that there was intimidation or retaliation when they brought up issues.

Those same interviewees predominantly said they would use the ECP but saw no need to have to resort to the ECP for issue reporting.

b. Findings

No findings were identified.

4OA6 Management Meeting

.1 Exit Meeting Summary

On November 17, 2016, the inspectors presented the inspection results to the Site Vice President, Mr. Coffey, 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 and that all material considered proprietary by the licensee was returned to the licensee.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

R. Coffey, Site Vice President

D. DeBoer, Plant General Manager

S. Aerts, Performance Improvement Manager

J. Glaser, Performance Improvement Senior Analyst

C. Mynhier, System Engineering

J. Olson, Operations Senior Performance

S. Pfaff, Performance Improvement

R. Richards, Senior Chemistry Analyst

T. Riha, Training

B. Scherwinski, Licensing

J. Yindra, Procedures

U.S. Nuclear Regulatory Commission

J. Cameron, Chief, Reactor Projects Branch 4

LIST OF ITEMS

Opened

None.

Closed

None.