ML050620458

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Annual Assessment Letter - Point Beach, 03/02/05
ML050620458
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 03/02/2005
From: Caldwell J
Region 3 Administrator
To: Koehl D
Nuclear Management Co
References
IR-05-001
Download: ML050620458 (8)


Text

March 2, 2005 Mr. Dennis L. Koehl Site Vice President Point Beach Nuclear Plant Nuclear Management Company, LLC 6590 Nuclear Road Two Rivers, WI 54241-9516

SUBJECT:

ANNUAL ASSESSMENT LETTER - POINT BEACH NUCLEAR PLANT (REPORT 05000266/200501; 05000301/200501)

Dear Mr. Koehl:

On February 8, 2005, the NRC staff completed its end-of-cycle plant performance assessment of Point Beach Nuclear Plant. The end-of-cycle review for Point Beach involved the participation of all reactor technical divisions in evaluating performance indicators (PIs) for the most recent quarter and inspection results for the period from January 1 through December 31, 2004. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility so that you will have an opportunity to prepare for these inspections and to inform us of any planned inspections that may conflict with your plant activities.

This performance review and enclosed inspection plan do not include physical protection information. A separate letter designated and marked as "Exempt from Public Disclosure in accordance with 10 CFR 2.390" will include the physical protection review and resultant inspection plan.

Overall, Point Beach operated in a manner that preserved public health and safety. While Point Beach met all cornerstone objectives, it remained within the Multiple/Repetitive Degraded Cornerstone Column of the Action Matrix with longstanding issues or significant degradation in safety performance. Point Beach was placed in this column during the first quarter of 2003.

Placement of Point Beach in this column was based on the Red finding for Unit 1 and Unit 2 associated with the auxiliary feedwater and instrument air systems and the Yellow finding for Unit 1 and the Red finding for Unit 2 associated with the potential failure of the auxiliary feedwater pumps because of plugging of recirculation line orifices. Details of these findings were provided in NRC Inspection Reports (IRs) 50-266/01-17(DRS); 50-301/01-17(DRS), dated April 3, 2002, and 50-266/02-15(DRP); 50-301/02-15(DRP), dated April 2, 2003, and in Final Significance Determination letters dated July 12, 2002, and December 11, 2003.

To address these findings and other identified station performance deficiencies, the Nuclear Management Company (the licensee for Point Beach) committed to take specific actions that have been incorporated into a Confirmatory Action Letter (CAL), issued on April 21, 2004. This CAL will remain open until the NRC has concluded that your actions have resulted in

D. Koehl demonstrated improved performance in the five areas listed in the CAL (Human Performance, Engineering Design Control, Engineering/Operations Interface, Emergency Preparedness, and Corrective Action Program).

In addition to our review of station performance during routine NRC inspection activities, Point Beach performance is being evaluated quarterly. Consistent with Inspection Manual Chapter (IMC) 0305, plants in the Multiple/Repetitive Degraded Cornerstone column of the Action Matrix are given consideration at each quarterly performance assessment review for:

(1) declaring plant performance to be unacceptable in accordance with the guidance in IMC 0305; (2) transferring to the IMC 0350, Oversight of Operating Reactor Facilities in a Shutdown Condition with Performance Problems, process; and (3) taking additional regulatory actions, as appropriate. Our assessment results to date have concluded that Point Beach has operated in a manner that preserved the public health and safety. The plant will remain in Column IV of the NRC Action Matrix. The NRC will continue to closely monitor Point Beach performance consistent with the guidance in IMC 0305.

In our 2003 Annual Assessment Letter, dated March 4, 2004, and in our 2004 Mid-Cycle Performance Review Letter, dated August 30, 2004, we advised you of substantive cross-cutting issues in the areas of problem identification and resolution (PI&R) and human performance. For PI&R, this was based on several findings that involved failures to effectively implement corrective actions. For human performance, this was based on findings involving lack of supervisory oversight, maintaining a questioning attitude, personnel self-checking, conservative decision-making, attention-to-detail, and communications. In response to the identified cross-cutting issues, you incorporated corrective actions in specific Action Plan steps in your comprehensive site-wide improvement plan (the Point Beach Excellence Plan). These steps are included in the commitments of the CAL.

Although we have noted improvement in the human performance area during the 3rd and 4th quarters of this assessment period, sustained improvement performance remains to be demonstrated. In addition, in the PI&R area, we continued to identify findings in the 3rd and 4th quarters of the assessment period. Consequently, we have determined that the two substantive cross-cutting issues continue to apply for the 2004 assessment period. We will continue to review your progress in addressing the cross-cutting issues during our baseline and CAL-followup inspections. We request that you discuss your efforts to address the cross-cutting issues at the public end-of-cycle review meeting, scheduled for April 19, 2005. In addition, we would like to discuss these issues during our routine public CAL progress meetings.

Additionally, on March 17, 2004, a Notice of Violation and Civil Penalty of $60,000 was issued for a Severity Level III violation involving unapproved changes to the Emergency Action Level scheme. As discussed in our 2003 Annual Assessment Letter, dated March 4, 2004, and in our 2004 Mid-Cycle Performance Review Letter, dated August 30, 2004, Point Beach management had stated that immediate corrective actions were taken. These actions have been verified by our inspectors. Implementation of longer-term corrective action to update the scheme to an industry standard will be reviewed during a future inspection.

D. Koehl In accordance with IMC 0305, Operating Reactor Assessment Program, your plant will be discussed at the upcoming Agency Action Review Meeting. We will notify you via separate correspondence if any agency actions change as an outcome of the meeting.

This letter advises you of our planned inspection effort resulting from the Point Beach end-of-cycle review. The enclosed plan details the inspections, less those related to physical protection, scheduled through September 30, 2006. The inspection plan is provided to minimize the resource impact on your staff and to allow for scheduling conflicts and personnel availability to be resolved in advance of inspector arrival onsite. Routine resident inspections are not listed due to their ongoing and continuous nature. Please note, that in addition to baseline inspections, inspections will be conducted to ensure the actions committed to in the CAL are completed and station performance is improving. The inspections in the last nine months of the inspection plan are tentative and may be revised at the mid-cycle review meeting.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure 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). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

If circumstances arise which cause us to change this inspection plan, we will contact you to discuss the change as soon as possible. Please contact Mr. Patrick Louden at (630) 829-9627 with any questions you may have regarding this letter or the inspection plan.

Sincerely,

/RA/

James L. Caldwell Regional Administrator Docket Nos. 50-266; 50-301 License Nos. DPR-24; DPR-27

Enclosure:

Point Beach Inspection/Activity Plan See Attached Distribution

D. Koehl In accordance with IMC 0305, Operating Reactor Assessment Program, your plant will be discussed at the upcoming Agency Action Review Meeting. We will notify you via separate correspondence if any agency actions change as an outcome of the meeting.

This letter advises you of our planned inspection effort resulting from the Point Beach end-of-cycle review. The enclosed plan details the inspections, less those related to physical protection, scheduled through September 30, 2006. The inspection plan is provided to minimize the resource impact on your staff and to allow for scheduling conflicts and personnel availability to be resolved in advance of inspector arrival onsite. Routine resident inspections are not listed due to their ongoing and continuous nature. Please note, that in addition to baseline inspections, inspections will be conducted to ensure the actions committed to in the CAL are completed and station performance is improving. The inspections in the last nine months of the inspection plan are tentative and may be revised at the mid-cycle review meeting.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure 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). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

If circumstances arise which cause us to change this inspection plan, we will contact you to discuss the change as soon as possible. Please contact Mr. Patrick Louden at (630) 829-9627 with any questions you may have regarding this letter or the inspection plan.

Sincerely,

/RA/

James L. Caldwell Regional Administrator Docket Nos. 50-266; 50-301 License Nos. DPR-24; DPR-27

Enclosure:

Point Beach Inspection/Activity Plan See Attached Distribution *SEE PREVIOUS CONCU RRENCES DOCUMENT NAME: G:\Branch TSS\EOC Ltrs\eoc 030205\Point Beach.wpd To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy OFFICE RIII RIII RIII NRR NAME JGiessner/cco* MKunowski* PLouden* LRaghavan*

(via phone) (via email) (via telecon)

DATE 02/15/05 02/16/05 02/16/05 02/24/05 OFFICE RIII RIII RIII NAME RCaniano for SReynolds* JCaldwell CPederson*

DATE 02/16/05 02/24/05 02/ /05 OFFICIAL RECORD COPY

D. Koehl cc w/encl: F. Kuester, President and Chief Executive Officer, We Generation J. Cowan, Executive Vice President Chief Nuclear Officer D. Cooper, Senior Vice President, Group Operations J. McCarthy, Site Director of Operations D. Weaver, Nuclear Asset Manager Plant Manager Regulatory Affairs Manager Training Manager Site Assessment Manager Site Engineering Director Emergency Planning Manager J. Rogoff, Vice President, Counsel & Secretary K. Duveneck, Town Chairman Town of Two Creeks Chairperson Public Service Commission of Wisconsin J. Kitsembel, Electric Division Public Service Commission of Wisconsin State Liaison Officer

D. Koehl ADAMS Distribution:

WDR HKC RidsNrrDipmIipb GEG KGO CAA1 DRPIII DRSIII PLB1 JRK1 ROPreports@nrc.gov (inspection reports, final SDP letters, any letter with an IR number)

Institute of Nuclear Power Operations (INPO)

Page 1 of 2 Point Beach 02/28/2005 08:20:09 Inspection / Activity Plan Report 22 03/01/2005 - 09/30/2006 Unit No. of Staff Planned Dates Inspection Number Inspection Activity Title on Site Start End Type LRI - LICENSE RENEWAL INSPECTION - AGING EVAL 5 1, 2 IP 71002 License Renewal Inspection 03/07/2005 04/01/2005 License Renewal Insp ISI - UNIT 2 ISI/RPV HEAD FAB REVIEW 2 2 IP 71007 Reactor Vessel Head Replacement Inspection 04/04/2005 05/29/2005 Other Routine 2 IP 7111102 Evaluation of Changes, Tests, or Experiments 04/04/2005 05/29/2005 Baseline Inspections 2 IP 7111108P Inservice Inspection Activities - PWR 04/04/2005 05/29/2005 Baseline Inspections IP 71121 - RP OUTAGE ACCESS CTRL/ALARA INSPECTION 1 1, 2 IP 7112101 Access Control to Radiologically Significant Areas 04/11/2005 04/15/2005 Baseline Inspections 1, 2 IP 7112102 ALARA Planning and Controls 04/11/2005 04/15/2005 Baseline Inspections 1, 2 IP 7112202 Radioactive Material Processing and Transportation 04/11/2005 04/15/2005 Baseline Inspections BR5 - CAL--ENGINEERING CLOSEOUT 3 1, 2 IP 95003 Inspection For Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones, Multiple 07/18/2005 08/19/2005 Supplemental Program MAINTEFF - MAINTENANCE EFFECTIVENESS 1 1, 2 IP 7111112B Maintenance Effectiveness 09/12/2005 09/16/2005 Baseline Inspections 71114 - BASELINE EP INSP 1 1, 2 IP 7111402 Alert and Notification System Testing 08/08/2005 08/12/2005 Baseline Inspections 1, 2 IP 7111403 Emergency Response Organization Augmentation Testing 08/08/2005 08/12/2005 Baseline Inspections 1, 2 IP 7111405 Correction of Emergency Preparedness Weaknesses and Deficiencies 08/08/2005 08/12/2005 Baseline Inspections 1, 2 IP 71151 Performance Indicator Verification 08/08/2005 08/12/2005 Baseline Inspections 71111.11 - LIC OPERATOR REQUAL PROGRAM EVALUATION 2 1, 2 IP 7111111B Licensed Operator Requalification Program 08/22/2005 08/26/2005 Baseline Inspections BR7 - PI&R 4 1, 2 IP 71152B Identification and Resolution of Problems 09/12/2005 09/30/2005 Baseline Inspections DESIGN - HEAD REPLCMT MODIFICATION INSPECTION 3 1 IP 71007 Reactor Vessel Head Replacement Inspection 10/03/2005 11/18/2005 Other Routine 1 IP 7111102 Evaluation of Changes, Tests, or Experiments 10/03/2005 11/18/2005 Baseline Inspections 1 IP 7111117B Permanent Plant Modifications 10/03/2005 11/18/2005 Baseline Inspections ISI - UNIT 1 ISI/RPV HEAD PRESERVICE REVIEW 3 1 IP 71007 Reactor Vessel Head Replacement Inspection 10/10/2005 11/18/2005 Other Routine 1 IP 7111108P Inservice Inspection Activities - PWR 10/10/2005 11/18/2005 Baseline Inspections FY 2006 - POINT BEACH INIT PREP 10/2005 3 1 W90127 OL - INITIAL EXAM - POINT BEACH - OCT/NOV 2005 10/17/2005 10/21/2005 Not Applicable IP 71121 - OUTAGE ALARA PLUS REMP & TRANSP 3 1, 2 IP 7112101 Access Control to Radiologically Significant Areas 10/17/2005 10/21/2005 Baseline Inspections 1, 2 IP 7112102 ALARA Planning and Controls 10/17/2005 10/21/2005 Baseline Inspections This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.

Page 2 of 2 Point Beach 02/28/2005 08:20:09 Inspection / Activity Plan Report 22 03/01/2005 - 09/30/2006 Unit No. of Staff Planned Dates Inspection Number Inspection Activity Title on Site Start End Type IP 71121 - OUTAGE ALARA PLUS REMP & TRANSP 3 1, 2 IP 7112202 Radioactive Material Processing and Transportation 10/17/2005 10/21/2005 Baseline Inspections 1, 2 IP 7112203 Radiological Environmental Monitoring Program 10/17/2005 10/21/2005 Baseline Inspections 1, 2 IP 71151 Performance Indicator Verification 10/17/2005 10/21/2005 Baseline Inspections FY 2006 - POINT BEACH INIT EXAM 11/2005 3 1 W90127 OL - INITIAL EXAM - POINT BEACH - OCT/NOV 2005 11/07/2005 11/18/2005 Not Applicable MOD/5059 - MODIFICATIONS/50.59 INSPECTION 3 1, 2 IP 7111102 Evaluation of Changes, Tests, or Experiments 12/05/2005 12/09/2005 Baseline Inspections 1, 2 IP 7111117B Permanent Plant Modifications 12/05/2005 12/09/2005 Baseline Inspections HS - HEAT SINK INSPECTION 1 1, 2 IP 7111107B Heat Sink Performance 02/06/2006 02/10/2006 Baseline Inspections ISFSI - OPERATION OF AN ISFSI 1 1, 2 IP 60855.1 Operation of an Independent Spent Fuel Storage Installation at Operating Plants 02/01/2006 03/31/2006 Other Routine IP 71121 - RP POST OUTAGE ACCESS CTRL & ALARA INSP 1 1, 2 IP 7112101 Access Control to Radiologically Significant Areas 03/20/2006 03/24/2006 Baseline Inspections 1, 2 IP 7112102 ALARA Planning and Controls 03/20/2006 03/24/2006 Baseline Inspections 1, 2 IP 71151 Performance Indicator Verification 03/20/2006 03/24/2006 Baseline Inspections SSDPC - SSDPC INSPECTION 6 1 IP 7111121 Safety System Design and Performance Capability 05/08/2006 05/26/2006 Baseline Inspections IP 71121 - RP INSTRUMENTATION & PPE INSPECTION 1 1, 2 IP 7112103 Radiation Monitoring Instrumentation and Protective Equipment 06/26/2006 06/30/2006 Baseline Inspections IP 71122 - RP LIQ/GAS EFFLUENTS INSPECTION 1 1, 2 IP 7112201 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems 07/31/2006 08/04/2006 Baseline Inspections 1, 2 IP 71151 Performance Indicator Verification 07/31/2006 08/04/2006 Baseline Inspections ISI - POINT BEACH UNIT 2 ISI INSPECTION 1 2 IP 7111108P Inservice Inspection Activities - PWR 09/18/2006 10/14/2006 Baseline Inspections IP 71121 - RP OUTAGE ACCESS CTRL/ALARA INSPECTION 1 1, 2 IP 7112101 Access Control to Radiologically Significant Areas 09/25/2006 09/29/2006 Baseline Inspections 1, 2 IP 7112102 ALARA Planning and Controls 09/25/2006 09/29/2006 Baseline Inspections This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.