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Category:Inspection Report
MONTHYEARIR 05000266/20230042024-02-0101 February 2024 Integrated Inspection Report 05000266/2023004 and 05000301/2023004 IR 05000266/20234022023-11-14014 November 2023 Security Baseline Inspection Report 05000266/2023402 and 05000301/2023402 IR 05000266/20230032023-10-16016 October 2023 Integrated Inspection Report 05000266/2023003 and 05000301/2023003 IR 05000266/20235012023-08-29029 August 2023 Emergency Preparedness Biennial Exercise Inspection Report 05000266/2023501 and 05000301/2023501 IR 05000266/20230052023-08-24024 August 2023 Updated Inspection Plan for Point Beach Nuclear Plant (Report 05000266/2023005 and 05000301/2023005) IR 05000266/20230022023-07-18018 July 2023 Integrated Inspection Report 05000266/2023002 and 05000301/2023002 IR 05000266/20234012023-07-13013 July 2023 Public-Point Beach Nuclear Plant-Security Baseline Inspection Report 05000266/2023401; 05000301/2023401; Independent Spent Fuel Storage Security Inspection Report 07200005/2023401 IR 05000266/20230012023-05-0101 May 2023 Integrated Inspection Report 05000266/2023001 and 05000301/2023001 IR 05000266/20233012023-03-28028 March 2023 NRC Initial Examination Report 05000266/2023301 and 05000301/2023301 IR 05000266/20220062023-03-0101 March 2023 Annual Assessment Letter for Point Beach Nuclear Plant, Units 1 and 2 (Report 05000266/2022006 and 05000301/2022006) IR 05000266/20230102023-02-23023 February 2023 Comprehensive Engineering Team Inspection Report 05000266/2023010 and 05000301/2023010 ML23009B7002023-01-24024 January 2023 Review of the Spring 2022 Steam Generator Tub Inspections Report IR 05000266/20220042023-01-24024 January 2023 Integrated Inspection Report 05000266/2022004 and 05000301/2022004 IR 05000266/20224012022-12-0808 December 2022 Security Baseline Inspection Report 05000266/2022401 and 05000301/2022401 IR 05000266/20224042022-12-0202 December 2022 Cyber Security Inspection Report 05000266/2022404 and 05000301/2022404 IR 05000266/20220032022-11-0707 November 2022 Integrated Inspection Report 05000266/2022003 and 05000301/2022003 ML22298A2972022-10-27027 October 2022 Review of the Fall 2021 Steam Generator Tube Inspections Report IR 05000266/20220122022-09-29029 September 2022 Biennial Problem Identification and Resolution Inspection Report 05000266/2022012 and 05000301/2022012 IR 05000266/20220052022-08-26026 August 2022 Updated Inspection Plan for Point Beach Nuclear Plant, Units 1 and 2 (Report 05000266/2022005 and 05000301/2022005) IR 05000266/20220112022-08-0303 August 2022 Triennial Fire Protection Inspection Report 05000266/2022011 and 05000301/2022011 IR 05000266/20220022022-07-27027 July 2022 Integrated Inspection Report 05000266/2022002 and 05000301/2022002 IR 05000266/20220012022-05-0404 May 2022 Integrated Inspection Report 05000266/2022001 and 05000301/2022001 IR 05000266/20210062022-03-0202 March 2022 Annual Assessment Letter for Point Point Beach Nuclear Plant, Units 1 and 2 (Report 05000266/2021006 and 05000301/2021006) IR 05000266/20220102022-02-0909 February 2022 Design Basis Assurance Inspection (Programs) Inspection Report 05000266/2022010 and 05000301/2022010 IR 05000266/20210042022-01-28028 January 2022 Integrated Inspection Report 05000266/2021004 and 05000301/2021004 and Exercise of Enforcement Discretion IR 05000266/20214022021-11-10010 November 2021 Security Baseline Inspection Report 05000266/2021402 and 05000301/2021402 IR 05000266/20210032021-10-20020 October 2021 Integrated Inspection Report 05000266/2021003 and 05000301/2021003 IR 05000266/20215012021-10-0505 October 2021 Emergency Preparedness Biennial Exercise Inspection Report 05000266/2021501 and 05000301/2021501 IR 05000266/20213012021-09-14014 September 2021 NRC Initial License Examination Report 05000266/2021301; 05000301/2021301, and 07200005/2021301 IR 05000266/20210052021-09-0101 September 2021 Updated Inspection Plan for Point Beach Nuclear Plant, Units 1 and 2 (Report 05000266/2021005 and 05000301/2021005) IR 05000266/20214032021-08-0404 August 2021 Security Baseline Inspection Report 05000266/2021403 and 05000301/2021403 IR 05000266/20210022021-07-29029 July 2021 Integrated Inspection Report 05000266/2021002, 05000301/2021002, and 07200005/2021001 IR 05000266/20210102021-07-0101 July 2021 Triennial Inspection of Evaluation of Changes, Tests and Experiments Baseline Inspection Report 05000266/2021010 and 05000301/2021010 IR 05000266/20210012021-04-21021 April 2021 Integrated Inspection Report 05000266/2021001 and 05000301/2021001 IR 05000266/20214012021-03-16016 March 2021 Security Baseline Inspection Report 05000266/2021401; 05000301/2021401; Independent Spent Fuel Storage Security Inspection Report 07200005/2021401 IR 05000266/20200062021-03-0404 March 2021 Annual Assessment Letter for Point Beach Nuclear Plant, Units 1 and 2 (Report 05000266/2020006 and 05000301/2020006) IR 05000266/20200902021-02-0909 February 2021 Final Significance Determination of a Green Finding; NRC Inspection Report 05000266/2020090 and 05000301/2020090 IR 05000266/20200042021-02-0808 February 2021 Integrated Inspection Report 05000266/2020004 and 05000301/2020004 IR 05000266/20204022020-12-14014 December 2020 Security Baseline Inspection Report 05000266/2020402 and 05000301/2020402 IR 05000266/20200032020-11-0404 November 2020 Integrated Inspection Report 05000266/2020003 and 05000301/2020003 IR 05000266/20200102020-09-24024 September 2020 Biennial Problem Identification and Resolution Inspection Report 05000266/2020010 and 05000301/2020010 IR 05000266/20200052020-09-0101 September 2020 Updated Inspection Plan for Point Beach Nuclear Plant, Units 1 and 2 (Report 05000266/2020005 and 05000301/2020005) IR 05000266/20200022020-08-0606 August 2020 Integrated Inspection Report 05000266/2020002 and 05000301/2020002 IR 05000266/20200122020-08-0303 August 2020 NRC Inspection Report 05000266/2020012 and 05000301/2020012; Preliminary White Finding and Apparent Violations IR 05000266/20200112020-07-29029 July 2020 Design Basis Assurance Inspection (Teams) Inspection Report 05000266/2020011 and 05000301/2020011 IR 05000266/20200012020-05-13013 May 2020 Integrated Inspection Report 05000266/2020001 and 05000301/2020001 ML20100G8902020-04-0707 April 2020 Request for Information for an NRC Triennial Baseline Design Bases Assurance Inspection (Team): Inspection Report 05000266/2020-011 and 05000301/2020-011 IR 05000266/20204012020-03-30030 March 2020 Security Baseline Inspection Report 05000266/2020401 and 05000301/2020401 IR 05000266/20190062020-03-0303 March 2020 Annual Assessment Letter for Point Beach Nuclear Plants, Units 1 and 2 (Report 05000266/2019006 and 05000301/2019006) IR 05000266/20190042020-02-0505 February 2020 Integrated Inspection Report 05000266/2019004 and 05000301/2019004 2024-02-01
[Table view] Category:Letter
MONTHYEARML24036A2652024-02-0505 February 2024 Notice of Inspection and Request for Information for the NRC Age-Related Degradation Inspection: Inspection Report 05000266/2024010 and 05000301/2024010 IR 05000266/20230042024-02-0101 February 2024 Integrated Inspection Report 05000266/2023004 and 05000301/2023004 ML24030A0352024-01-30030 January 2024 Information Request for the Cyber-Security Baseline Inspection, Notification to Perform Inspection L-2024-001, Relief Request CISl-03-01 for Relief Concerning Containment Unbonded Post-Tensioning System Inservice Inspection Requirements2024-01-26026 January 2024 Relief Request CISl-03-01 for Relief Concerning Containment Unbonded Post-Tensioning System Inservice Inspection Requirements L-2024-010, Point Units 3 and 4, Seabrook, Duane Arnold, and Point Beach Units 1 and 2, Nuclear Property Insurance - 10 CFR 50.54(w)(3)2024-01-25025 January 2024 Point Units 3 and 4, Seabrook, Duane Arnold, and Point Beach Units 1 and 2, Nuclear Property Insurance - 10 CFR 50.54(w)(3) ML24005A3242024-01-24024 January 2024 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0040 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) ML23352A2752024-01-23023 January 2024 Issuance of Amendment Nos. 274 and 276 Regarding Revision to Technical Specification 5.5.17, Pre-Stressed Concrete Containment Tendon Surveillance Program L-2023-173, Quality Assurance Topical Report (FPL-1) Revision 30 Update2023-12-15015 December 2023 Quality Assurance Topical Report (FPL-1) Revision 30 Update L-2023-174, Subsequent License Renewal Application - Third Annual Update2023-12-13013 December 2023 Subsequent License Renewal Application - Third Annual Update L-2023-176, Supplement to Exemption Request Regarding Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Final Rule2023-11-29029 November 2023 Supplement to Exemption Request Regarding Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Final Rule L-2023-155, Supplement to Response to Request for Additional Information, Revised NextEra Common Emergency Plan, and Revised Site-Specific Emergency Plan Annexes Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-06542023-11-28028 November 2023 Supplement to Response to Request for Additional Information, Revised NextEra Common Emergency Plan, and Revised Site-Specific Emergency Plan Annexes Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, L-2023-159, Part 3 Exemption Request Regarding Enhanced Weapons, Firearms Background Checks and Security Event Notifications Final Rule2023-11-16016 November 2023 Part 3 Exemption Request Regarding Enhanced Weapons, Firearms Background Checks and Security Event Notifications Final Rule IR 05000266/20234022023-11-14014 November 2023 Security Baseline Inspection Report 05000266/2023402 and 05000301/2023402 ML23279A0672023-11-0909 November 2023 Issuance of Relief Request I6 RR 02 - Examination of the Unit 2 Steam Generator Feedwater Nozzle Extension to Nozzle Weld Sixth 10 Year Inservice Inspection Program Interval IR 05000266/20230032023-10-16016 October 2023 Integrated Inspection Report 05000266/2023003 and 05000301/2023003 ML23346A1322023-10-0606 October 2023 Communication from C-10 Research & Education Foundation Regarding NextEra Common Emergency Fleet Plan License Amendment Request and Related Documents Subsequently Published L-2023-128, License Amendment Request to Revise TS 5.5.17, Pre-Stressed Concrete Containment Tendon Surveillance Program2023-09-19019 September 2023 License Amendment Request to Revise TS 5.5.17, Pre-Stressed Concrete Containment Tendon Surveillance Program ML23243A9102023-09-0606 September 2023 Closeout of Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors IR 05000266/20235012023-08-29029 August 2023 Emergency Preparedness Biennial Exercise Inspection Report 05000266/2023501 and 05000301/2023501 ML23208A2262023-08-28028 August 2023 Exemption from the Requirements of 10 CFR 50,46, Acceptance Criteria for Emergency Core Cooling Systems for Light Water Nuclear Power Reactors (EPID L-2022-LLE-0026) - Letter ML23208A0952023-08-28028 August 2023 Issuance of Amendment Nos. 273 and 275 Regarding Revising Licensing Basis to Address Generic Safety Issue-191 and Respond to Generic Letter 2004-02 Using a Risk Informed Approach IR 05000266/20230052023-08-24024 August 2023 Updated Inspection Plan for Point Beach Nuclear Plant (Report 05000266/2023005 and 05000301/2023005) ML23160A0642023-08-21021 August 2023 Issuance of Amendment Nos. 272 and 274 Regarding Revision to Use Beacon Power Distribution Monitoring System L-2023-114, Proposed Turkey Point Units 6 and 7; Seabrook Station; Point Beach Units 1 and 2 - Official Service List Update2023-08-17017 August 2023 Proposed Turkey Point Units 6 and 7; Seabrook Station; Point Beach Units 1 and 2 - Official Service List Update ML23221A0522023-08-0909 August 2023 Confirmation of Initial License Examination, March 2024 L-2023-098, and Point Beach Units 1 and 2 - Response to Request for Additional Information Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 22023-08-0707 August 2023 and Point Beach Units 1 and 2 - Response to Request for Additional Information Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 2 ML23201A0872023-08-0303 August 2023 Audit Plan in Support of Review of License Amendment L-2023-089, Refueling Outage Owner'S Activity Report (OAR-1) Unit 2 for Inservice Inspections2023-07-24024 July 2023 Refueling Outage Owner'S Activity Report (OAR-1) Unit 2 for Inservice Inspections IR 05000266/20230022023-07-18018 July 2023 Integrated Inspection Report 05000266/2023002 and 05000301/2023002 IR 05000266/20234012023-07-13013 July 2023 Public-Point Beach Nuclear Plant-Security Baseline Inspection Report 05000266/2023401; 05000301/2023401; Independent Spent Fuel Storage Security Inspection Report 07200005/2023401 L-2023-087, Florida Power & Light/Nextera Energy, Results of the Safety Culture Program Effectiveness Review, March 20, 2023 (ADAMS Accession No. ML22340A452)2023-06-29029 June 2023 Florida Power & Light/Nextera Energy, Results of the Safety Culture Program Effectiveness Review, March 20, 2023 (ADAMS Accession No. ML22340A452) ML23178A2422023-06-28028 June 2023 Reassignment of the U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch III L-2023-088, 10 CFR 50.55a Requests, Relief Requests I6-RR-1, I6-RR-2, and I6-RR-3 Sixth Ten-Year Inservice Inspection Program Interval2023-06-27027 June 2023 10 CFR 50.55a Requests, Relief Requests I6-RR-1, I6-RR-2, and I6-RR-3 Sixth Ten-Year Inservice Inspection Program Interval ML23171B1062023-06-21021 June 2023 Info Meeting with a Question and Answer Session to Discuss NRC 2022 EOC Plant Performance Assessment of Ptbh, Units 1 and 2 ML23163A2422023-06-13013 June 2023 Notification of NRC Baseline Inspection and Request for Information; Inspection Report 05000266/2023004 L-2023-075, Response to Request for Additional Information (RAI) Regarding Exemption Request, License Amendment Request and Revised Response in Support of a Risk-Informed Resolution of Generic Letter 2004-022023-06-0909 June 2023 Response to Request for Additional Information (RAI) Regarding Exemption Request, License Amendment Request and Revised Response in Support of a Risk-Informed Resolution of Generic Letter 2004-02 L-2023-073, Subsequent License Renewal Application, Second Annual Update Request for Additional Information Set 1 Response2023-06-0101 June 2023 Subsequent License Renewal Application, Second Annual Update Request for Additional Information Set 1 Response ML23103A1332023-06-0101 June 2023 Issuance of Amendment Nos. 271 and 273 Regarding Technical Specifications to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b L-2023-071, NextEra Energy Quality Assurance Topical Report (FPL-1) Revision 29 and Florida Power and Light Company Quality Assurance Program Description for 10 CFR Part 52 Licenses (FPL-2) Revision 11, Annual Submittal2023-05-22022 May 2023 NextEra Energy Quality Assurance Topical Report (FPL-1) Revision 29 and Florida Power and Light Company Quality Assurance Program Description for 10 CFR Part 52 Licenses (FPL-2) Revision 11, Annual Submittal ML23118A1762023-05-0404 May 2023 Audit Summary for License Amendment Request Regarding Risk-Informed Approach for Closure of Generic Safety Issue 191 IR 05000266/20230012023-05-0101 May 2023 Integrated Inspection Report 05000266/2023001 and 05000301/2023001 ML23114A1222023-04-25025 April 2023 Information Request to Support the NRC Annual Baseline Emergency Action Level and Emergency Plan Changes Inspection L-2023-058, 2022 Annual Monitoring Report2023-04-10010 April 2023 2022 Annual Monitoring Report L-2023-021, Units, 1 and 2, Turkey Point, Units 3 and 4, Seabrook Station and Point Beach, Units 1 and 2 - Decommissioning Funding Status Reports / Independent Spent Fuel Storage Installation (ISFSI) Financial Assurance Update2023-03-28028 March 2023 Units, 1 and 2, Turkey Point, Units 3 and 4, Seabrook Station and Point Beach, Units 1 and 2 - Decommissioning Funding Status Reports / Independent Spent Fuel Storage Installation (ISFSI) Financial Assurance Update L-2023-028, and Point Beach Units 1 and 2, 10 CFR 50.46 Annual Reporting of Changes to, or Errors in Emergency Core Cooling System Models or Applications2023-03-27027 March 2023 and Point Beach Units 1 and 2, 10 CFR 50.46 Annual Reporting of Changes to, or Errors in Emergency Core Cooling System Models or Applications 2024-02-05
[Table view] Category:Notice of Violation
MONTHYEARIR 05000266/20200122020-08-0303 August 2020 NRC Inspection Report 05000266/2020012 and 05000301/2020012; Preliminary White Finding and Apparent Violations IR 05000266/20130122013-08-0909 August 2013 IR 05000266-13-012 and 05000301-13-012, and Notice of Violation, Point Beach, Units 1 and 2, Final Significance Determination of a White Finding with Assessment Follow-up IR 05000266/20120102013-01-0202 January 2013 EA-12-220, Point Beach Nuclear Plant, Unit 1, Final Significance Determination of a White Finding with Assessment Followup and Notice of Violation; NRC Inspection Report No. 05000266-12-010 IR 05000266/20125042012-07-24024 July 2012 EA-12-106, Point Beach, Final Significance Determination of a White Finding with Assessment Followup and Notice Of Violation ML12206A5142012-07-24024 July 2012 EA-12-106, Point Beach, Final Significance Determination of a White Finding with Assessment Followup and Notice of Violation IR 05000266/20100102010-04-0707 April 2010 Inspection Report (IR) 05000266-10-010, 05000301-10-010; February 17, 2010; Point Beach Nuclear Plant, Units 1 and 2; Results of NRC Investigation Report No. 3-2009-011 and Notice of Violation IR 05000266/20090092009-06-24024 June 2009 EA-09-012, Point Beach Nuclear Generating Plant, Units 1 and 2, NRC Inspection Report Nos. 05000266-09-009(DRS), 05000301-09-009(DRS) IR 05000266/20060112007-01-29029 January 2007 EA-06-274, Point Beach Nuclear Plant, Units 1 and 2, Notice of Violation (NRC Special Inspection Report 05000266/2006011; 050000301/2006011) ML0701001382006-08-22022 August 2006 Dennis L. Koehl Ltr. Apparent Violation of Employee Protection Requirements (Office of Investigations Report No. 3-2005-010) ML0334900222003-12-11011 December 2003 EA-03-057, Point Beach, Final Significance Determination for a Red Finding and Notice of Violation IR 05000266/20020152003-04-0202 April 2003 IR 05000266-02-015 (Drp); IR 05000301-02-015 (Drp), on 9/23 -26/2002 and 10/31/2002 - 3/24/2003, Nuclear Management Company, LLC; Point Beach Nuclear Plant, Unit 1 and Unit 2. Special Inspections to Evaluate a Red Inspection Finding ML0307701832002-07-12012 July 2002 Final Significance Determination for Red Finding & Notice of Violation NRC Special Inspection Report IR 05000266-01-017 & IR 05000301-01-017(DRS) ML0307701782002-07-12012 July 2002 Final Significance Determination for Red Finding & Notice of Violation NRC Special Inspection Report IR 05000266-01-017 & IR 05000301-01-017(DRS) ML0219601242002-07-12012 July 2002 EA-02-031, Point Beach Nuclear Plant, NOV and Red Finding 07/12/2002 ML0307701042002-07-0808 July 2002 Undated Letter from NRC to Point Beach Regarding Final Significance Determination for Red Finding and Notice of Violation IR 05000266/20020032002-06-13013 June 2002 Final Significance Determination for a White Finding and Notice of Violation (IRs 05000266-02-03, 05000301-02-03, 05000266-02-05 & 05000301-02-05) ML0307603352002-05-15015 May 2002 Draft of the Final Significance Letter for the Point Beach Red Finding & Notice of Violation ML0307603302002-05-15015 May 2002 Draft of the Final Significance Letter for the Point Beach Red Finding and Notice of Violation 2020-08-03
[Table view] |
Text
EA-02-031 Mr. M. Warner Site Vice President Kewaunee and Point Beach Nuclear Plants Nuclear Management Company, LLC 6610 Nuclear Road Two Rivers, Wl 54241
SUBJECT:
POINT BEACH NUCLEAR PLANT FINAL SIGNIFICANCE DETERMINATION FOR A RED FINDING AND NOTICE OF VIOLATION NRC INSPECTION REPORT NO. 50-266/01-17(DRS); 50-301/01-17(DRS)
Dear Mr. Warner:
The purpose of this letter is to provide you with the final results of our review of the apparent violations and preliminary significance determination of the finding identified in the subject inspection report. The finding and violations involved the potential common mode failure of the auxiliary feedwater (AFW) pumps during specific accident scenarios that you discovered during your efforts to update your probabilistic risk assessment (PRA) of the Point Beach Nuclear Plant. The inspection report described apparent violations of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for inadequate procedures and 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Actions," for seven instances where you should have identified and corrected the vulnerability. The inspection finding was assessed using the significance determination process and was preliminarily characterized as Red, i.e., a finding of high importance to safety that could result in increased NRC inspection and other NRC action.
At your request, a Regulatory Conference was held on April 29, 2002, to further discuss your views on the apparent violations and preliminary risk significance determination. A copy of the handouts used at this conference are enclosed. During the conference, you provided your assessment of the significance of the finding and detailed your staff's corrective actions, including the root cause evaluations. You agreed with the NRC's preliminary assessment of the risk significance associated with the finding and the apparent violation of 10 CFR Part 50, Appendix B, Criterion V; however, you disagreed with the violation of 10 CFR Part 50, Appendix B, Criterion XVI. You argued that the proposed instances of inadequate corrective actions either did not specifically relate to the root cause of the problem or that it was not reasonable to expect appropriate corrective actions because the PRA techniques used to discover the problems were not used as a formal tool until 1999. Additionally, you proposed that the finding be treated as an old design issue as specified in NRC Inspection Manual Chapter (MC) 0305, "Operating Reactor Assessment Program," and that there was no need for additional inspection.
We recognize that your staff identified the issue and took prompt corrective actions to revise procedures and train operators to address the immediate safety concerns associated with the issue. Additionally, your staff installed backup pneumatic supplies for the recirculation valves to
improve the safety of the AFW system design. After considering the information developed during the inspection and the information your staff provided at the conference, we have concluded that a violation of 10 CFR Part 50, Appendix B, Criterion XVI, is appropriate for two of the originally proposed seven examples. The root cause of the finding was your failure to recognize that the AFW system minimum flow recirculation valves must be able to open to respond to the full spectrum of event scenarios. The valves must close during certain scenarios to allow full flow to the steam generators and open in other scenarios to allow adequate recirculating flow to protect the running AFW pumps. Until recently, your procedures and system design only considered operation in the closed safety function for event response.
The specific examples included in the violation occurred in 1997 at a time when your design bases document for the AFW system identified both open and closed safety functions as appropriate for the recirculation valves. In March 1997 you identified that loss of instrument air to the AFW flow control valves could cause system failure and reported this in Licensee Event Report 97-014-00. An appropriate extent of condition review should have identified the same vulnerability for the recirculation valves given their stated open safety function identified in the AFW system design bases document. Similarly, in October 1997, Condition Report 97-3363 identified a discrepancy with your inservice test program and the design bases document concerning the open safety function of the recirculation valves. An inadequate evaluation of this report resulted in revising the design bases document to delete the open safety function.
We also concluded that the PRA techniques you utilized in 2001 to identify this issue were a valuable engineering tool to assess its significance, but was not required-to identify this AFW system vulnerability.
Although not cited, your response to Generic Letter 88-14, "Instrument Air Supply Problems Affecting Safety Related Equipment," could also have identified and addressed the AFW system vulnerability associated with loss of instrument air. Generic Letter 88-14 requested that licensees verify that emergency procedures and training were adequate to ensure that safety related equipment would function as intended on a loss of instrument air and to verify that safety-related components will perform as expected on a loss of the instrument air system, including that air-operated component failure positions were correct for assuring required safety functions. This generic correspondence should have directed your attention to this very vulnerability with the air-operated AFW system recirculation valves.
As such, the NRC has determined that the potential common mode failure of the Point Beach AFW pumps is a violation of 10 CFR Part 50, Appendix B, Criteria V and XVI, as cited in the enclosed Notice. The circumstances surrounding the violation are described in detail in the subject inspection report. In accordance with the NRC Enforcement Policy, NUREG-1600, the Notice of Violation is considered escalated enforcement action because it is associated with a Red finding. You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response.
Based on the information contained in the subject inspection report and obtained during the regulatory conference, the NRC has concluded that the finding is appropriately characterized as Red. A finding characterized as Red is an issue of high importance to safety that normally could result in substantially increased NRC inspection and other NRC action. You have 30 calendar days from the date of this letter to appeal the staff's determination of significance for the identified Red Finding. Such appeals will be considered to have merit only if they meet the criteria given in MC 0609, Attachment 2. We also considered your proposal that this issue be treated as an old design issue as specified in MC 0305. We recognize that although opportunities existed to identify the issue, they occurred several years ago and are not necessarily indicative of current performance. However, we believe that additional information is needed for us to complete our evaluation of whether or not it is appropriate to treat this issue
as an old design issue. Specifically, a follow-up inspection will be conducted to evaluate the corrective actions your staff has taken, or that will be taken, to prevent recurrence. We will inform you, by separate correspondence, of our plans for this inspection. Following that inspection, we will complete our evaluation of whether or not it is appropriate to treat the issue as an old design issue and inform you of our decision and what actions (including which appropriate supplemental inspection, if any) are warranted based on this decision.
If we determine that treatment as an old design issue is appropriate, then, in accordance with Section 6.06.a. of MC 0305, the NRC will not aggregate this finding in the Action Matrix for the purpose of determining the appropriate level of agency response. This means that the issue will be considered Red and posted on the NRC's Web site for a period of 4 quarters. However, Point Beach will not be placed in the Multiple/Repetitive Degraded Cornerstone Column of the Action Matrix nor will the specified actions associated with this column be taken as would normally occur for a Red finding. We would, however, plan to conduct some limited additional inspection. Such inspection effort would be limited to an evaluation of your proposed corrective actions and your assessment that similar issues would be appropriately addressed in your corrective action program. Additionally, we would review your plans to continue the initiative to update the Point Beach Nuclear Plant Probabilistic Risk Assessment so that other potential risk significant issues may be identified if they exist. The purpose of this approach is to place a premium on licensees initiating efforts to identify and correct safety-significant issues that are not likely to be identified by routine efforts before degraded safety systems are called upon to work. However, if treatment as an old design issue is not determined to be appropriate, then the issue will be considered Red and posted on the NRC's Web site for a period of 4 quarters, Point Beach will be placed in the Multiple/Repetitive Degraded Cornerstone Column of the Action Matrix, and the NRC will take the appropriate actions in accordance with the guidance provided in MC 0305.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosures will be available electronically for public inspection in the NRC Public Document Room or from the Publically Available Records (PARS) component of NRC's 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, J. E. Dyer Regional Administrator Docket Nos. 50-266; 50-301 License Nos. DPR-24; DPR-27
Enclosures:
- 1. Notice of Violation
- 2. NRC April 29, 2002 Regulatory Conference Slides
- 3. NMC April 29, 2002 Regulatory Conference Slides
- 4. NMC Photograph of Recirculation Valve
- 5. NMC April 29, 2002 Regulatory Conference Timeline cc w/encls: R. Grigg, President and Chief Operating Officer, WEPCo
R. Anderson, Executive Vice President and Chief Nuclear Officer T. Webb, Licensing Manager D. Weaver, Nuclear Asset Manager T. Taylor, Plant Manager A. Cayia, Site Director J. O'Neill, Jr., Shaw, Pittman, Potts & Trowbridge K. Duveneck, Town Chairman Town of Two Creeks D. Graham, Director Bureau of Field Operations A. Bie, Chairperson, Wisconsin Public Service Commission S. Jenkins, Electric Division Wisconsin Public Service Commission State Liaison Officer
M. Warner -
ADAMS Distribution:
WDR DFT BAW RidsNrrDipmlipb HBC PGK1 C. Ariano (hard copy)
DRPIII DRSIII PLB1 JRK1 SECY OCA M. Banerjee, NRR G. Tracy, Chief, Division of Inspection Program Management, IOLB, NRR H. Nieh, Region III Coordinator, OEDO W. Travers, EDO W. Kane, DEDRP F. Congel, OE J. Dixon-Herrity, OE J. Dyer, RIII:RA L. Chandler, OGC D. Dambly, OGC S. Collins, NRR R. Borchardt, NRR D. Holody, RI Enforcement Coordinator C. Evans, RII Enforcement Coordinator G. Sanborn, RIV Enforcement Coordinator L. Dudes, NRR P. Krohn, SRI S. Gagner, OPA H. Bell, OIG G. Caputo, 01 F. Combs, OSTP D. Dandois, OCFO/DAF/LFARB J. Strasma, RIII:PA V. Mitlyng R. Lickus, Rill J. Lynch, Rill OEWEB OEMAIL
NOTICE OF VIOLATION Nuclear Management Company, LLC. Docket Nos. 50-266; 50-301 Point Beach Nuclear Plant License Nos. DPR-24; DPR-27 EA-02-031 During an NRC inspection conducted on December 3, 2001, through February 28, 2002, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:
10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings,"
requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances.
10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," requires, in part, that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective actions taken to preclude repetition.
Contrary to the above, as of November 29, 2001, activities affecting quality were not prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances. Specifically, procedures EOP-0.1 Unit 1, "Reactor Trip Response," Revision 24, and EOP-0.1 Unit 2, "Reactor Trip Response," Revision 23, did not provide adequate operator instructions to verify that the auxiliary feedwater (AFW) minimum flow recirculation valves were open while controlling AFW flow upon low instrument air header pressure. Low header pressure would cause the AFW minimum flow recirculation valves to fail closed, a significant condition adverse to quality which resulted in potential failure of the AFW pumps as a result of blocking the discharge flow path. From at least 1997 to 2001, the licensee failed to promptly identify and correct a condition adverse to quality. Prior opportunities to identify this failure mode included:
In October 1997, the safety function of the minimum flow recirculation valves was considered in response to Condition Report 97-3363.
In March 1997, the licensee identified a failure mode of the AFW system due to the loss of instrument air as discussed in Licensee Event Report 97-14-00.
This violation is associated with a Red SDP finding.
Notice of Violation Pursuant to the provisions of 10 CFR 2.201, Nuclear Management Company, LLC., is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, Region Ill, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response.
If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.
Because your response will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/readin--rm.html (the Public Electronic Reading Room). If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days.
Dated this - day of July 2002