IR 05000266/2010007

IR 05000266-10-007, on 03/1/2010 - 03/19/2010; Point Beach, Unit 1, Post Approval Site Inspection for License Renewal

ML101200365
Person / Time
Site:	Point Beach
Issue date:	04/30/2010
From:	Ann Marie Stone NRC/RGN-III/DRS/EB2
To:	Meyer L Point Beach
References
IR-10-007
Download: ML101200365 (19)

Text

ril 30, 2010

SUBJECT:

NEXTERA ENERGY POINT BEACH, LLC UNIT 1 NRC POST APPROVAL SITE INSPECTION FOR LICENSE RENEWAL INSPECTION REPORT 05000266/2010-007

Dear Mr. Meyer:

On March 19, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed Phase I of the Post-Approval Site Inspection for License Renewal at your NextEra Energy Point Beach, LLC.

The enclosed report documents the inspection activities, which were discussed on March 19, 2010, with Mr. and other members of your staff.

This inspection was an examination of activities conducted under your renewed license as they relate to the completion of commitments made during the renewed license application process and compliance with the Commissions rules and regulations and the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel. On the basis of the sample selected for review, there were no findings of significance identified during this inspection. The NRC staff did not identify any instances of incomplete commitments with respect to timeliness or adequacy.

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

Sincerely,

/RA by V. P. Lougheed Acting for/

Ann Marie Stone, Chief Engineering Branch 2 Division of Reactor Safety Docket No. 50-266 License No. DPR-24

Enclosure:

Inspection Report 05000266/2010007 w/Attachment: Supplemental Information

REGION III==

Docket No: 50-266 License No: DPR-24 Report No: 05000266/2010007 Licensee: NextEra Energy Point Beach, LLC Facility: Point Beach Nuclear Plant, Unit 1 Location: Two Rivers, WI Dates: March 1 - March 19, 2010 Inspectors: T. Bilik, Senior Reactor Engineer (Lead)

J. Neurauter, Senior Reactor Engineer M. Jones, Reactor Engineer Approved by: Ann Marie Stone, Chief Engineering Branch 2 Division of Reactor Safety Enclosure

SUMMARY OF FINDINGS

IR 05000266/2010007; 03/1/2010 - 03/19/2010; Point Beach Nuclear Generating Plant Unit 1;

Post Approval Site Inspection for License Renewal The inspection was conducted by three regional based inspectors. No instances were noted of incomplete license renewal commitments with respect to timeliness or adequacy. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

NRC-Identified

and Self-Revealed Findings

Cornerstone: Initiating Events, Mitigating Systems, Barrier Integrity

No violations of significance were identified.

Licensee-Identified Violations

No violations of significance were identified.

REPORT DETAILS

Summary of Plant Status

NextEra Energy Point Beach, LLC Unit 1 was in a refueling outage during the period of this inspection.

4OA5 Other Activities

.1 License Renewal Commitment Implementation and Completion (Phase I) IP 71003

a. Inspection Scope

(1) Review of Newly Identified Structures Systems and Components (SSC)

The inspectors discussed the identification of new SSCs, under the purview of Title 10 of the Code of Federal Regulations (CFR) 54.37(b), with the licensees license renewal staff. The licensee personnel indicated that no new components had been identified that should have been within the scope of its license renewal program.

(2) Review of Revised Commitments As part of reviewing the aging management programs (AMPs) associated with the commitments, the inspectors determined that there were no commitment revisions within scope of the Phase I inspection. The inspectors also reviewed the licensees commitment tracking program to evaluate its effectiveness.

(3) Review of Commitments The inspectors reviewed supporting documents including completed surveillance records, conducted interviews, observed non-destructive examination (NDE) activities, performed visual inspection of structures and components, including those not accessible during power operation, and observed the activities described below to verity the licensee completed the necessary actions to comply with the license conditions that are a part of the renewed operating license. The inspectors verified the licensee implemented the outage related aging management programs included in NUREG-1839, Safety Evaluation Report (SER) related to the license renewal (LR) of the Point Beach Nuclear Plant, Units 1 and 2, in accordance with 10 CFR Part 54, Requirements for the Renewal of Operating Licenses for Nuclear Power Plants. The inspectors also verified a selected sample of corrective actions taken as a consequence of the LR inspection.

b. Results of Detailed Reviews The inspectors reviewed portions of the commitments below, which are referenced to Appendix A of the SER. Activities observed related to these commitments are also listed.

.1 Review of Electrical Cable Commitments Number (No.) 20, No. 55 and No. 56

(1) Cable Condition Monitoring Program (Commitment No. 20)

The inspectors reviewed the licensees activities to implement Commitment Item No. 20, of the Point Beach NRC LR SER. This commitment documents that the licensee agreed to develop and implement a Cable Conditioning Monitoring aging management program prior to the period of extended operation.

The Cable Condition Monitoring Program is a new program that is consistent with NUREG-1801, Generic Aging Lessons Learned (GALL) Report, Sections XI.E1, Electrical Cables and Connections Not Subject To 10 CFR 50.49 Environmental Qualification (EQ) Requirements, and consistent with, but includes exceptions to,Section XI.E2, Electrical Cables Not Subject To 10 CFR 50.49 EQ Requirements Used in Instrumentation Circuits, and XI.E3, Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 EQ Requirements.

The program requires:

(a) visual inspection of a representative sample of accessible electrical cables and connections in adverse localized environments once every 10 years for evidence of jacket surface degradation;

(b) testing of nuclear instrumentation circuits once every ten years to detect a significant reduction in cable insulation resistance; and

(c) testing of a representative sample of In-scope, medium-voltage cables not designed for submergence subject to prolonged exposure to significant moisture and significant voltage once every ten years to detect deterioration of insulation.

The inspectors conducted interviews, observed visual cable inspections in containment, and reviewed the implementing documents. Specific documents are listed in the attachment. The inspectors reviewed the following licensee activities to implement this commitment.

Electrical Cables and Connections Not Subject To 10 CFR 50.49 EQ Requirements The licensee developed a program to identify a representative sample of accessible electrical cables and connections installed in adverse localized environments and visually inspected for cable and connection jacket surface anomalies, such as discoloration, swelling, cracking, or surface contamination. This is an inspection program and no actions are taken as part of this program to prevent or mitigate aging degradation. The sample was based on the severity of the adverse localized environment, as compared to the plant design environment, and other criteria such as accessibility, availability, importance-to-safety, and/or prior inspection results. The inspectors accompanied the licensee during a portion of the walkdowns to identify the sample, and also performed visual examination walkdowns of cables in several adverse environmental areas in the plant and in a 4160V bus duct cross connect in accordance with work order (WO)382193 and WO349424 respectively.

Electrical Cables Not Subject To 10 CFR 50.49 EQ Requirements Used in Instrumentation Circuits This is a testing program and no actions are taken as part of this program to prevent or mitigate aging degradation. Nuclear instrumentation circuits are periodically tested to provide an indication of the condition of the cable insulation. The specific type of test performed is determined prior to testing and capable of detecting a significant reduction in cable insulation resistance. Cables used in nuclear instrumentation circuits are tested once every ten years to provide an indication of the condition of the conductor insulation and the ability of the cable to perform its intended function. If an unacceptable condition or situation is identified, a determination would be made as to whether the same condition or situation is applicable to other cables used in nuclear instrumentation circuits. The inspectors reviewed the program basis documents and observed cable inspections in the control room under WO366896.

(2) Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 EQ Requirements (Commitment No. 55) Including Periodic Visual Inspections of Bus Ducts (Commitment No. 56)

As part of the Cable Condition Monitoring Program, Commitment No. 55 required a representative sample of in-scope, inaccessible Non-EQ medium voltage cables not designed for submergence subject to significant moisture and significant voltage, to be tested once every ten years to provide an indication of the condition of the conductor insulation and the ability of the cable to perform its intended function.

Periodic actions are to be taken to prevent medium-voltage cables not designed for submergence from being subject to prolonged exposure to significant moisture, such as inspecting for water collection in cable manholes and draining water, as needed.

Medium-voltage cables at the Point Beach Nuclear Plant (PBNP) were ordered moisture resistant for direct buried or underground service, but are not used in direct buried applications. Medium-voltage cables used at PBNP are installed in conduit, duct packs/banks, or manholes, which provide a flow path to drain water (e.g., duct packs/banks are sloped). The inspectors reviewed basis documents and accompanied the licensee in performing a tan delta test on the 4KV supply cable to 1P-15B-M, safety injection inaccessible pump motor medium voltage cables per WO372330. The inspectors also observed visual bus duct examinations (Commitment No. 56) of 480V cross connects in accordance with WO364671.

To address a problem with the flooding of manholes related to Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 Environmental Qualification Requirements (Commitment No. 55), the Facilities Group periodically checked the manholes for water based on Passport PMID 15058; Tasks 1, 2, 3, and 4. Tasks 1 and 2 are for inspecting manholes 1 - 21 and manholes A and B. Inspection periodicities had ranged from 1-week to 6 months. Tasks 3 and 4 were for the Z-66 through 68 series manholes and had been performed at 6 month intervals.

A review by the inspectors of manhole inspection results showed frequent flooding of the manholes, indicating that the inspection methodology being employed was not effective.

The cables in the manholes are not meant to be submerged in water for extended and repeated periods of time. As a result, PMCR 1168719 has been initiated to revise the Model Work Order Instruction for Tasks 1 and 2 and to take a more proactive approach to inspecting and pumping manholes. Phase II of 71003 will follow-up on these actions being taken.

The licensee stated and the inspectors concluded that Commitments No. 20, No. 55, and No. 56 have not been completed to date.

.2 Review of One-Time Inspection Commitments No. 21, No. 24, No. 25, No. 45, No. 59)

(1) One-Time Inspection Program (Commitment No. 25)

The inspectors reviewed the licensees activities to implement Commitment Item No. 25, of the Point Beach Unit 1 NRC license renewal SER. This Commitment documents that the licensee agreed to develop an aging management program consistent with, but includes exceptions to, NUREG-1801, Generic Aging Lessons Learned,Section XI.M32, One-Time Inspection, and Section XI.M33, Selective Leaching of Materials. The program also includes enhancements.

The One-Time Inspection Program is a new program that addresses potentially long incubation periods for certain aging effects and provides a means of verifying that an aging effect is either not occurring or progressing so slowly as to have negligible effect on the intended function of the structure or component. Hence, the One-Time Inspection Program provides measures for verifying an aging management program is not needed, verifying the effectiveness of an existing program, or determining that degradation is occurring, which will require evaluation and corrective action.

The program elements include:

(a) determination of appropriate inspection sample size;

(b) identification of inspection locations;

(c) selection of examination technique, with acceptance criteria; and

(d) evaluation of results to determine the need for additional inspections or other corrective actions. The inspection sample includes locations where the most severe aging effect(s) would be expected to occur. Inspection methods may include visual (or remote visual), surface or volumetric examinations, or other established NDE techniques.

To verify the effectiveness the inspectors interviewed the program owner, reviewed implementing procedures and records of completed inspections, and performed direct observation of NDE examinations in the field. Specific documents reviewed are listed in the Attachment.

The program also includes a number of other programs which credit the One-Time Inspection Program to perform an inspection and condition assessment of various components in the sub-systems.

This program is used for the following:

• To verify the effectiveness of water chemistry control for managing the effects of aging in stagnant or low-flow portions of piping, or occluded areas of components, exposed to a treated water environment;

• To manage the aging effects of loss of material due to galvanic corrosion and selective leaching;

• To manage aging effects in infrequently accessed areas, such as high radiation, high temperature, confined spaces, and submerged areas;

• To verify the effectiveness of fuel oil chemistry control for managing the effects of aging of various components in systems that contain fuel oil; and

• To verify aging effects are not occurring in various components (e.g., reactor vessel internals hold-down spring, letdown orifices, steam traps, and miscellaneous heat exchangers).

The inspectors observed a number of NDE examinations as part of the One-Time Inspection Program. These included: ultrasonic testing (UT) of letdown piping CH-601R in accordance with WO381910, visual testing (VT) of aux feedwater pump discharge drain AF-95A in accordance with WO354655, VT of component cooling pump suction drain 1CC-790B in accordance with WO354043 and VT of the Reactor Coolant Pump (RCP) oil collection system in accordance with WO372666.

(2) Selective Leaching of Materials (Commitment No. 45)

As part of License Renewal Application (LRA) Section B.2.1.13, One Time Inspection Program, a one-time visual and if possible hardness measurements will be performed on accessible locations of a select set of components of each material type (i.e., cast iron and brasses) to determine whether selective leaching has occurred and whether the resulting loss of strength and/or material will affect the intended functions of those components during the period of extended operation.

The inspectors reviewed program documents and observed NDE examinations in accordance with WO353872, a VT and hardness test of 1HX-176A, Safety Injection pump seal water heat exchanger. Hardness tests were inconclusive and additional analysis needed to be performed.

(3) Residual Heat Removal (RHR) Heat Exchanger Eddy Current (EC) Testing (Commitment No. 59)

The licensee committed to perform EC inspection under the One-Time Inspection Program of the tubing of one RHR heat exchanger or replace the RHR heat exchanger tube bundles prior to the period of extended operation if eddy current testing of the tubing of at least one RHR heat exchanger is not completed.

The inspectors observed the EC examination of the RHR Heat Exchanger 1-HX-11A heat exchanger in accordance with WO351995. This was the first inspection of this heat exchanger, and multiple (42 tubes/8.8 percent) fretted tubes (with wear greater than or equal to (GTE) 10 percent through wall at the tube support structure) were identified.

This resulted in plugging and stabilizing 10 (2.1 percent) tubes based on Engineering Evaluation EC 15334. Seventeen tubes were reported with tube-to-tube wear (ODT)

GTE 10 percent through wall. All of the ODT calls were reported in the u-bend region of the tube near the shell side inlet. Two tubes were also restricted for examination due to denting at the 04C support plate. The condition of the tubes of the A heat exchanger prompted expanding the examination to the B heat exchanger as required by the commitment. The B heat exchanger tubing did not experience the same degradation as the A and required no tube plugging.

The inspectors also reviewed a number of completed work orders related to commitments, which credit the One-Time Inspection Program to perform an inspection and condition assessment of various components in the sub-systems. Those commitments include the following:

(4) Closed-Cycle Cooling Water System Surveillance Program (Commitment No. 21)

The licensee committed to implant an enhanced Closed-Cycle Cooling Water System Surveillance Program. The inspectors review a number of competed work orders associated with the One-Time Inspection Program. These work orders are included in the list of documents reviewed.

(5) Fuel Oil Chemistry Control Program (Commitment No. 24)

The licensee committed to implant an enhanced Fuel Oil Chemistry Control Program.

The inspectors review a number of competed work orders associated with the One-Time Inspection Program. These work orders are included in the list of documents reviewed

(6) One-Time Inspection Program Methodology (LR-TR-519, Commitment No. 61)

One-Time Inspection Methodology Generic Guidance, LR-TR-519, was to detail the sample size selection and specific component identification criteria within that sample.

Inspectors had previously conducted a follow up inspection that was documented in inspection report (IR) 2005015, dated September 9, 2005. That inspection focused on open items generated as a result of LR inspection activities that identified the licensee had not identified the number of samples, the locations, or the examination techniques for the majority of the onetime inspections.

During follow up, the regional inspectors had concluded that that the open item could be closed based on the review of the revised program basis document that provided additional information regarding the scope, methods of evaluation, and acceptance criteria. The inspector reviewed the preliminary implementation documents along with the licensees initial proposal for sample size and location, and determined that the applicant appeared to provide reasonable justification for component grouping and selecting sample sizes and locations. Based on this review, the inspectors concluded there was sufficient information provided to determine that the program would adequately detect aging degradation for the components and systems for which it was created.

The Phase I inspectors determined that while the LR-TR-519 methodology provides generic guidance for picking the individual components to inspect, it does not provide an overall justification for ensuring that the most susceptible environments have been tested with the selected samples. As a result the licensee issued CAP1168385, which ensures overall justification will be performed prior to the Phase II inspection, to provide the documentation that will establish that the samples selected provide reasonable assurance that the areas most susceptible to aging effects were actually inspected.

The licensee stated and the inspectors concluded that Commitments No. 21, No. 24, No. 25, No. 45, No. 59 have not been completed to date.

.3 Steam Generator (SG) Integrity Program (Commitment No. 50)

The SG Integrity Program is an existing program that is consistent with NUREG-1801, Generic Aging Lessons Learned (GALL) Report,Section XI.M19, Steam Generator Tube Integrity, with regards to managing the aging effects of SG tubes, and tube plugs or other tube repairs. The SG Integrity Program is also an existing plant-specific program that consists of the appropriate ten elements described in Branch Technical Position RLSB-1, Aging Management Review-Generic, which is included in Appendix A of NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants, for managing the aging effects of various steam generator secondary-side internal components.

The SG Integrity Program incorporates the guidance of NEI 97-06 and maintains the integrity of the SGs, including tubes, tube plugs or other tube repairs, and various secondary-side internal components. The program manages aging effects through a balance of prevention, inspection, evaluation, repair, and leakage monitoring measures.

Component degradation is mitigated by controlling primary and secondary water chemistry. Eddy Current testing is used to detect steam generator tube flaws and degradation. Visual inspections are performed to identify degradation of various secondary side SG internal components.

As part of the SG Integrity Program, visual inspections of accessible areas to verify the integrity of SG secondary-side components will be performed at least every six years, with one SG being inspected every three years on an alternating basis. Any indications of degradation or unacceptable conditions will be evaluated through the corrective action program, including the extend of condition. The inspectors observed NDE activities (VT and EC testing) of Containment Fan Cooler 1 HX-15C, in accordance with WO367148.

The licensee stated and the inspectors concluded that Commitment No. 50 has not been completed to date.

4OA6 Management Meetings

.1 Exit Meeting Summary

On March 19, 2010, the inspectors presented the inspection results to Mr. L. Meyer 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.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

L. Meyer, Site Vice-President

F. Flentje, Licensing Supervisor

W. Jensen, Principal Analyst-Programs Engineer

S. Forsha, Programs Engineer

T. Mielke, License Renewal Engineer

A. Watry, Programs Engineer

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

Opened, Closed,

Discussed

None Attachment