IR 05000266/2017001

NRC Integrated Inspection Report 05000266/2017001 and 05000301/2017001

ML17128A307
Person / Time
Site:	Point Beach
Issue date:	05/08/2017
From:	Jamnes Cameron Reactor Projects Region 3 Branch 4
To:	Coffey R Point Beach
References
IR 2017001
Download: ML17128A307 (63)

Text

May 8, 2017

SUBJECT:

POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2-NRC INTEGRATED INSPECTION REPORT 05000266/2017001 AND 05000301/2017001

Dear Mr. Coffey:

On March 31, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Point Beach Nuclear Plant, Units 1 and 2. On April 4, 2017, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The enclosed report represents the results of this inspection.

The NRC inspectors did not identify any findings or violations of more than minor significance. However, the inspectors documented a licensee-identified violation, which was determined to be of very low safety significance in this report.

The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy. If you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC resident inspector at the Point Beach Nuclear Plant. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, "Public Inspections, Exceptions, Requests for Withholding."

Sincerely,

/RA/ Jamnes Cameron, Chief Branch 4 Division of Reactor Projects

Docket Nos: 50-266; 50-301 License Nos: DPR-24; DPR-27

Enclosure: IR 05000266/2017001; 05000301/2017001 cc: Distribution via LISTSERV

SUMMARY

Inspection Report 05000266/2017001, 05000301/2017001; 01/01/2017 - 03/31/2017; Point Beach Nuclear Plant, Units 1 & 2; Routine Integrated Inspection Report. This report covers a 3-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. The significance of inspection findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using

Inspection Manual Chapter (IMC) 0609, "Significance Determination Process," dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310, "Aspects Within the Cross-Cutting Areas," dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRC's Enforcement Policy, dated November 1, 2016. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Ov ersight Process," Revision 6.

Licensee-Identified Findings A violation of very low safety significance identified by the licensee has been reviewed by the U.S. Nuclear Regulatory Commission (NRC). Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program. This violation and corrective action program tracking numbers are listed in Section 4OA7 of this report.

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REPORT DETAILS

Summary of Plant Status Unit 1 The unit operated at or near full power for the inspection period, except for brief power reductions to conduct planned maintenance and surveillance activities.

Unit 2 The unit operated at or near full power until March 4, 2017, when the unit began coastdown in preparation for the planned refueling outage (RFO) U2R35. The unit was shut down on March 18, 2017, and remained shut down for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness

1R01 Adverse Weather Protection

.1 External Flooding

a. Inspection Scope

The inspectors evaluated the design, material condition, and procedures for coping with the design basis probable maximum flood. The evaluation included a review to check for deviations from the descriptions provided in the Final Safety Analysis Report (FSAR) for features intended to mitigate the potential for flooding from external factors. As part of this evaluation, the inspectors checked for obstructions that could prevent draining, checked that the roofs did not contain obvious loose items that could clog drains in the event of heavy precipitation, and determined that barriers required to mitigate the flood were in place and operable. Additionally, the inspectors performed a walkdown of the protected area to identify any modification to the site, which would inhibit site drainage during a probable maximum precipitation event or allow water ingress past a barrier. The inspectors also walked down underground bunkers/manholes subject to flooding that contained multiple train or multiple function risk-significant cables. The inspectors also reviewed the abnormal operating procedure (AOP) for mitigating the design basis flood to ensure it could be implemented as written. Documents reviewed are listed in the Attachment to this report. This inspection constituted one external flooding sample as defined in inspection procedure (IP) 71111.01-05.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk-significant systems:

• G-03 emergency diesel generator (EDG) with G-01 EDG out of service (OOS);

• diesel-driven fire pump with the motor-driven fire pump OOS; and

• Unit 1 motor driven auxiliary feedwater pump after testing. The inspectors selected these systems based on their risk significance relative to the Reactor Safety Cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could impact the function of the system and, therefore, potentially increase risk. The inspectors reviewed applicable procedures, system diagrams, the FSAR, and the Fire Protection Evaluation Report to determine the correct system alignment. The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and

resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program (CAP) with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report. These activities constituted three partial system walkdown samples as defined in IP 71111.04-05.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Routine Resident Inspector Tours

a. Inspection Scope

The inspectors conducted fire protection walkdowns, which were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:

• Fire Zone 309: G-02 EDG room;

• Fire Zone 552: service water pump room & Fire Zone 553; circulating water pump room;

• Fire Zone 237: component cooling water heat exchanger and boric acid tank room;

• Fire Zone 305: 4160 volt vital switchgear room; and

• Fire Zone 310: air compressor room.

5 The inspectors reviewed areas to assess whether the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and implemented adequate compensatory measures for OOS, degraded or inoperable fire protection equipment, systems, or features in accordance with the licensee's fire plan. The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plant's Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plant's ability to respond to a security event. Using the documents listed in the Attachment to this report, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensee's CAP. Documents reviewed are listed in the Attachment to this report. These activities constituted five quarterly fire protection inspection samples as defined in IP 71111.05-05.

b. Findings

No findings were identified.

1R07 Annual Heat Sink Performance

.1 Heat Sink Performance

a. Inspection Scope

The inspectors reviewed the licensee's testing of the G-02 EDG coolant heat exchanger and the primary auxiliary building battery room vent cooler heat exchanger to verify that potential deficiencies did not mask the licensee's ability to detect degraded performance, to identify any common cause issues that had the potential to increase risk, and to ensure that the licensee was adequately addressing problems that, in the event of an initiating event, would cause an increase in risk. The inspectors reviewed the licensee's observations as compared against acceptance criteria, the correlation of scheduled testing and the frequency of testing, and the impact of instrument inaccuracies on test results. Inspectors also verified that test acceptance criteria considered differences between test conditions, design conditions, and testing conditions. Documents reviewed for this inspection are listed in the Attachment to this document. This annual heat sink performance inspection constituted two samples as defined in IP 71111.07-05.

b. Findings

No findings were identified.

1R08 Inservice Inspection Activities

From March 22, 2017, through March 31, 2017, the inspectors conducted a review of the implementation of the licensee's Inservice Inspection (ISI) Program for monitoring degradation of the Unit 2 reactor coolant system (RCS), emergency feedwater systems, risk-significant piping and components, and containment systems. The reviews described in Sections 1R08.1, 1R08.2, R08.3, IR08.4, and 1R08.5 below, count as one inspection sample as described by Inspection Procedure 71111.08.

.1 Piping Systems Inservice Inspection

a. Inspection Scope

The inspectors reviewed records of the following Non-Destructive Examinations (NDE) required by the American Society of Mechanical Engineers (ASME)Section XI Code, and/or Title 10 of the Code of Federal Regulations (10 CFR) 50.55a to evaluate compliance with the ASME Code,Section XI, and Section V requirements, and if any indications and defects were detected, to determine whether these were dispositioned in accordance with the ASME Code or an NRC-approved alternative requirement:

• ultrasonic examination of feedwater system pipe weld FW-16-FW-2001-28D; and

• visual VT-3 examination of residual heat removal system pipe supports AC-601R-6-2H20A and 601R-6-R2376. The licensee had not identified any recordable indications during surface and volumetric examinations performed since the beginning of the previous refueling outage. Therefore, no NRC review was completed for this inspection procedure attribute. The inspectors reviewed records of the following risk-significant pressure boundary ASME Code Section XI Class 2 welds fabricated since the beginning of the last refueling outage to determine whether the licensee applied the pre-service NDE and acceptance criteria required by the construction Code and the ASME Code Section XI. Additionally, the inspectors reviewed the welding procedure specification and supporting weld procedure qualification records to determine whether the weld procedure was qualified in accordance with the requirements of the Construction Code and the ASME Code Section IX:

• welds 1, 2, and 3 in the component cooling water system - Work Order (WO) 040312562-01 (2CC-755B Cutout and Replace Valve).

b. Findings

No findings were identified.

.2 Reactor Pressure Vessel Upper Head Penetration Inspection Activities

a. Inspection Scope

For the Unit 2 vessel head, no examination was required pursuant to 10 CFR 50.55a(g)(6)(ii)(D) for the current refueling outage. Therefore, no NRC review was completed for this inspection procedure attribute.

b. Findings

No findings were identified.

.3 Boric Acid Corrosion Control

a. Inspection Scope

The inspectors performed an independent walkdown of portions of the RCS and connected systems within containment that had received a recent licensee boric acid walkdown to determine whether the licensee's visual examinations had effectively identified boric acid leakage that potentially degraded safety-related components. The inspectors reviewed the following licensee evaluations of RCS components with boric acid deposits to determine whether degraded components were documented in the corrective action system and for degraded components that the planned or completed corrective actions met the Construction Code, ASME Section XI Code, and/or NRC-approved alternative.

• boric acid corrosion control evaluation 15-190B-E (2SC-00966C-reactor coolant sample line hot leg containment isolation valve); and

• boric acid corrosion control evaluation 15-373A (2-RC-500-reactor vessel head vent valve). The inspectors reviewed the following corrective actions related to evidence of boric acid leakage to determine whether the corrective actions completed were consistent with the requirements of the ASME Code Section XI and 10 CFR Part 50, Appendix B, Criterion XVI.

• Action Request (AR) 02160467 (2SI-0866B boric acid leak); and

• AR 02153935 (2SI-0897B boric acid leak).

b. Findings

No findings were identified.

.4 Stream Generator Tube Inspection Activities

a. Inspection Scope

The NRC inspectors observed acquisition of ed dy current (ET) data, observed ET data analysis and reviewed procedures implementi ng the steam generator (SG) ISI program to determine whether:

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• the numbers and sizes of SG tube flaws/degradation identified was bounded by the licensee's previous outage Operational Assessment predictions;

• the SG tube ET examination scope and expansion criteria were sufficient to meet the Technical Specifications (TS), and the Electric Power Research Institute 1003138, "Pressurized Water Reactor SG Examination Guidelines";

• the SG tube ET examination scope included potential areas of tube degradation identified in prior outage SG tube inspections and/or as identified in NRC generic industry operating experience applicable to these SG tubes;

• the licensee identified new tube degradation mechanisms and implemented adequate extent of condition inspection scope and repairs for the new tube degradation mechanism;

• the licensee implemented repair methods which were consistent with the repair processes allowed in the plant TS requirements and implemented at appropriate tube locations;

• qualified depth sizing methods were applied to degraded tubes accepted for continued service;

• the licensee implemented an inappropriate "plug on detection" tube repair threshold (e.g., no attempt at sizing of flaws to confirm tube integrity);

• the licensee primary-to-secondary leakage (e.g., SG tube leakage) was below 3 gallons-per-day, or the detection threshold, during the previous operating cycle;

• the ET probes and equipment configurations, as documented on the Examination Technique Specification Sheets, used to acquire/analyze data from the SG tubes were qualified to detect and/or size the known/expected types of SG tube degradation in accordance with Appendix H and I, Performance Demonstration for ET Examination, of Electric Power Research Institute 1003138, "Pressurized Water Reactor Steam Generator Examination Guidelines"; and

• the licensee performed secondary side SG inspections for location and removal of foreign materials; The licensee did not perform in situ pressure testing of SG tubes. Therefore, no NRC review was completed for this inspection attribute.

b. Findings

No findings were identified.

.5 Identification and Resolution of Problems

a. Inspection Scope

The inspectors performed a review of ISI/SG related problems entered into the licensee's corrective action program and conducted interviews with licensee staff to determine whether the licensee had:

• established an appropriate threshold for identifying ISI/SG related problems;

• identified issues related to excessive deposit buildup on the SG tube bundle and/or excessive SG tube wear indicative of fluid-elastic instability within the SG tube bundle;

• performed a root cause (if applicable) and taken appropriate corrective actions; and 9

• evaluated operating experience and industry generic issues related to ISI and pressure boundary integrity. The inspectors performed these reviews to evaluate compliance with 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," requirements. The corrective action documents reviewed by the inspectors are listed in the Attachment to this report.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

.1 Resident Inspector Quarterly Review of Licensed Operator Requalification

a. Inspection Scope

On January 31, 2017, the inspectors observed a crew of licensed operators in the plant's simulator during licensed operator requalification training. The inspectors verified that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and that training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:

• licensed operator performance;

• crew's clarity and formality of communications;

• ability to take timely actions in the conservative direction;

• prioritization, interpretation, and verification of annunciator alarms;

• correct use and implementation of abnormal and emergency procedures;

• control board manipulations;

• oversight and direction from supervisors; and

• ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications. The crew's performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements. Documents reviewed are listed in the Attachment to this report. This inspection constituted one quarterly licensed operator requalification program simulator sample as defined in IP 71111.11-05.

b. Findings

No findings were identified.

.2 Resident Inspector Quarterly Observation During Periods of Heightened Activity or Risk

(71111.11Q)

a. Inspection Scope

On March 17-18, 2017, the inspectors observed the Unit 2 shut down for RFO U2R35. This was an activity that required heightened awareness or was related to increased risk. The inspectors evaluated the following areas:

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• licensed operator performance;

• crew's clarity and formality of communications;

• ability to take timely actions in the conservative direction;

• prioritization, interpretation, and verification of annunciator alarms;

• correct use and implementation of procedures;

• control board (or equipment) manipulations;

• oversight and direction from supervisors; and

• ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications. The performance in these areas was compared to pre-established operator action expectations, procedural compliance and task completion requirements. Documents reviewed are listed in the Attachment to this report. This inspection constituted one quarterly licensed operator heightened activity/risk sample as defined in IP 71111.11-05.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

.1 Routine Quarterly Evaluations

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following risk-significant systems:

• multiple vital 120 volt inverter failures; and

• D-109 battery charger failure. The inspectors reviewed events such as where ineffective equipment maintenance had or could have resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:

• implementing appropriate work practices;

• identifying and addressing common cause failures;

• scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule;

• characterizing system reliability issues for performance;

• charging unavailability for performance;

• trending key parameters for condition monitoring;

• ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and

• verifying appropriate performance criteria for structures, systems, and components (SSCs)/functions classified as (a)(2), or appropriate and adequate goals and corrective actions for systems classified as (a)(1). The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance 11 effectiveness issues were entered into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report. This inspection constituted two quarterly maintenance effectiveness samples as defined in IP 71111.12-05.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

.1 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the licensee's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:

• January 26: B-81 switchgear and PP-54 alternate shutdown power panel OOS with repairs to the electric fire pump;

• week of February 6: maintenance activities on the yellow channel instrument bus static inverter, "D" component cooling water heat exchanger, primary auxiliary building vent fan cooler, and emergent work on control room emergency filtration system (CREFS);

• week of February 20: maintenance activities on G-01 EDG with D-05 and D-07 DC station battery chargers OOS;

• week of February 26: maintenance activities on the component cooling water heat exchanger B with G-01 EDG OOS; and

• March 7: maintenance activities on the Unit 2 train B residual heat removal pump with switchyard work and high winds in-progress. These activities were selected based on their potential risk significance relative to the Reactor Safety Cornerstones. As applicable for each activity, the inspectors verified that risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate and complete. When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met. Documents reviewed during this inspection are listed in the Attachment to this report. These maintenance risk assessments and emergent work control activities constituted five samples as defined in IP 71111.13-05.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functional Assessments

.1 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following issues:

• platforms in all reactor coolant pump and steam generator cubicles lack documentation;

• issue concerning CREFS on January 18, 2017; and

• Unit 2 reactor coolant hot leg sample isolation valve shut stroke time near upper limit. The inspectors selected these potential operability issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS and FSAR to the licensee's evaluations to determine

whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Documents reviewed are listed in the to this report. This operability inspection constituted three samples as defined in IP 71111.15-05.

b. Findings

One licensee-identified non-cited violation (NCV) of very low safety significance was identified and is documented in Section

==4OA7 of this report.

1R19 Post-Maintenance Testing

==

.1 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the following post-maintenance (PM) activities to verify that procedures and test activities were adequate to ensure system operability and functional

capability:

• maintenance operation of G-02 EDG after mechanical inspection;

• Unit 1 turbine-driven auxiliary feedwater pump run after oil change and packing adjustment;

• testing after Unit 2 pressurizer high level bistable replacement;

• testing after maintenance associated with the yellow channel instrument bus static inverter; 13

• Unit 2 train B residual heat removal pump run after coupling replacement; and

• G-04 EDG testing after governor tuning maintenance (partial). These activities were selected based upon the structure, system, or component's ability to impact risk. The inspectors evaluated these activities for the following (as applicable): the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as

written in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing (temporary modifications or jumpers required for test performance were properly removed after test completion); and test documentation was properly evaluated. The inspectors evaluated the activities against technical specification (TS), the FSAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with PM tests to determine whether the licensee was identifying problems and entering them in the CAP and that the problems were being corrected

commensurate with their importance to safety. Documents reviewed are listed in the Attachment to this report. This inspection constituted five complete post-maintenance testing samples and one partial post-maintenance testing sample as defined in IP 71111.19-05.

b. Findings

No findings were identified.

1R20 Outage Activities

.1 Refueling Outage Activities

a. Inspection Scope

The inspectors reviewed the Outage Safety Plan (OSP) and contingency plans for the Unit 2 RFO, which started March 18, 2017, and continued through to the end of the inspection period, to confirm that the licensee had appropriately considered risk, industry experience, and previous site-specific pr oblems in developing and implementing a plan that assured maintenance of defense-in-depth. During the RFO, the inspectors observed portions of the shutdown and cooldown processes and monitored licensee controls over the outage activities listed below:

• licensee configuration management, including maintenance of defense-in-depth commensurate with the OSP for key safety functions and compliance with the applicable TS when taking equipment out of service;

• implementation of clearance activities and confirmation that tags were properly hung and equipment appropriately configured to safely support the work or testing;

• installation and configuration of reactor coolant pressure, level, and temperature instruments to provide accurate indication; 14

• controls over the status and configuration of electrical systems to ensure that TS and OSP requirements were met, and controls over switchyard activities;

• monitoring of decay heat removal processes, systems, and components;

• controls to ensure that outage work was not impacting the ability of the operators to operate the spent fuel pool cooling system;

• reactor water inventory controls including flow paths, configurations, and alternative means for inventory addition, and controls to prevent inventory loss;

• controls over activities that could affect reactivity;

• maintenance of containment integrity as required by TS;

• licensee fatigue management, as required by 10 CFR 26, Subpart I;

• refueling activities, including fuel handling and sipping to detect fuel assembly leakage; and

• licensee identification and resolution of problems related to RFO activities.

Documents reviewed are listed in the Attachment to this report. This inspection constituted a partial RFO sample as defined in IP 71111.20-05.

b. Findings

No findings were identified.

1R22 Surveillance Testing

.1 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the test results for the following activities to determine whether risk-significant systems and equipment were capable of performing their intended safety function and to verify testing was conducted in accordance with applicable procedural and TS requirements:

• Unit 1 motor driven auxiliary feedwater suction header pressure trip channel operability test (routine);

• Unit 2 reactor makeup water to containment local leak rate test (CIV);

• Unit 1 train "A" containment spray pump and valves (IST);

• G-04 endurance run (routine);

• Unit 2 train "B" low head safety injection pumps and valves (routine); and

• Unit 2 train "B" safety injection actuation with loss of engineering safeguards AC (partial). The inspectors observed in-plant activities and reviewed procedures and associated records to determine the following:

• did preconditioning occur;

• the effects of the testing were adequately addressed by control room personnel or engineers prior to the commencement of the testing;

• acceptance criteria were clearly stated, demonstrated operational readiness, and were consistent with the system design basis;

• plant equipment calibration was correct, accurate, and properly documented; 15

• as-left setpoints were within required ranges; and the calibration frequency was in accordance with TS, the FSAR, procedures, and applicable commitments;

• measuring and test equipment calibration was current;

• test equipment was used within the required range and accuracy; applicable prerequisites described in the test procedures were satisfied;

• test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; jumpers and lifted leads were controlled and restored

where used;

• test data and results were accurate, complete, within limits, and valid;

• test equipment was removed after testing;

• where applicable for inservice testing activities, testing was performed in accordance with the applicable version of Section XI, American Society of Mechanical Engineers code, and reference values were consistent with the system design basis;

• where applicable, test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable;

• where applicable for safety-related instrument control surveillance tests, reference setting data were accurately incorporated in the test procedure;

• where applicable, actual conditions encountering high resistance electrical contacts were such that the intended safety function could still be accomplished;

• prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test;

• equipment was returned to a position or status required to support the performance of its safety functions; and

• all problems identified during the testing were appropriately documented and dispositioned in the CAP. Documents reviewed are listed in the Attachment to this report. This inspection constituted three complete routine surveillance testing samples, one partial routine surveillance testing sample, one in-service test sample, and one containment isolation valve sample as defined in IP 71111.22, Sections-02 and-05.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine licensee emergency drill on February 14, 2017, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the Technical Support Center to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also 16 attended the licensee drill critique to compare any inspector-observed weakness with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensee staff was properly identifying weaknesses and entering them into the CAP. As part of the inspection, the inspectors reviewed the drill package and other documents listed in the Attachment to this report.

This emergency preparedness drill inspection constituted one sample as defined in IP 71114.06-05.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstones: Public Radiation Safety and Occupational Radiation Safety

2RS1 Radiological Hazard Assessment and Exposure Controls

.1 Radiological Hazard Assessment (02.02)

a. Inspection Scope

The inspectors assessed the licensee's current and historic isotopic mix, including alpha emitters and other hard-to-detect radionuclides. The inspectors evaluated whether survey protocols were reasonable to identify the magnitude and extent of the radiological hazards. The inspectors determined whether there have been changes to plant operations since the last inspection that may have resulted in a significant new radiological hazard for onsite individuals. The inspectors evaluated whether the licensee assessed the potential impact of these changes and implemented periodic monitoring, as appropriate, to detect and quantify the radiological hazard. The inspectors reviewed the last two radiological surveys from selected plant areas and evaluated whether the thoroughness and frequency of the surveys were appropriate for the given radiological hazard. The inspectors conducted walk-downs of the facility, including radioactive waste processing, storage, and handling areas to evaluate material conditions and performed independent radiation measurements as needed to verify conditions were consistent

with documented radiation surveys. The inspectors assessed the adequacy of pre-work surveys for select radiologically risk-significant work activities. The inspectors evaluated the radiological survey program to determine whether hazards were properly identified. The inspectors discussed procedures, equipment, and performance of surveys with radiation protection staff and assessed whether technicians were knowledgeable about when and how to survey areas for various types of radiological hazards. The inspectors observed work in potential airborne areas to assess whether air samples were being taken appropriately for their intended purpose and reviewed various survey records to assess whether the samples were collected and analyzed appropriately. The 17 inspectors also reviewed the licensee's program for monitoring contamination that had the potential to become airborne. These inspection activities constituted one complete sample as defined in IP 71124.01-05.

b. Findings

No findings were identified.

.2 Instructions to Workers (02.03)

a. Inspection Scope

The inspectors reviewed select radiation work permits used to access high radiation areas and evaluated the specified work control instructions or control barriers. The inspectors also assessed whether workers where made aware of the work instructions and area dose rates. The inspectors reviewed electronic alarming dosimeter dose and dose rate alarm set-point methodology. For selected electronic alarming dosimeter occurrences, the inspectors assessed the worker's response to the alarm, the licensee's evaluation of the alarm, and any follow-up investigations. The inspectors reviewed the licensee's methods for informing workers of changes in plant operations or radiological conditions that could significantly impact their occupational dose. The inspectors reviewed the labeling of select containers of licensed radioactive material that could cause unplanned or inadvertent exposure to workers. These inspection activities constituted one complete sample as defined in IP 71124.01-05.

b. Findings

No findings were identified.

.3 Contamination and Radioactive Material Control (02.04)

a. Inspection Scope

The inspectors observed locations where the licensee monitors material leaving the radiologically controlled area and assessed the methods used for control, survey, and release of material from these areas. As available, the inspectors observed health

physics personnel surveying and releasing material for unrestricted use. The inspectors observed workers leaving the radiologically controlled area, assessed their use of tool and personal contamination monitors, and reviewed the licensee's criteria for use of the monitors.

18 The inspectors assessed whether instrumentation was used at its typical sensitivity levels based on appropriate counting parameters or whether the licensee had established a de facto release limit. The inspectors selected several sealed sources from the licensee's inventory records and assessed whether the sources were accounted for and verified to be intact. The inspectors also evaluated whether any transactions made since the last inspection that involved nationally tracked sources were reported in accordance with 10 CFR 20.2207. These inspection activities constituted one complete sample as defined in IP 71124.01-05.

b. Findings

No findings were identified.

.4 Radiological Hazards Control and Work Coverage (02.05)

a. Inspection Scope

The inspectors evaluated ambient radiological conditions during tours of the facility. The inspectors assessed whether the conditions were consistent with applicable posted surveys, radiation work permits, and worker briefings. The inspectors evaluated the adequacy of radiological controls, such as required surveys, radiation protection job coverage, and contamination controls. The inspectors evaluated the licensee's use of electronic alarming dosimeters in high noise areas as high radiation area monitoring devices. The inspectors assessed whether radiation monitoring devices were placed on the individual's body consistent with licensee procedures. The inspectors assessed whether the dosimeter was placed in the location of highest expected dose or that the licensee properly employed a NRC-approved method of determining effective dose equivalent. The inspectors reviewed the application of dosimetry to effectively monitor exposure to personnel in work areas with significant dose rate gradients. For select airborne area radiation work permits, the inspectors reviewed airborne radioactivity controls and monitoring, the potential for significant airborne levels, containment barrier integrity, and temporary filtered ventilation system operation. The inspectors examined the licensee's physical and programmatic controls for highly activated or contaminated materials stored within pools and assessed whether appropriate controls were in place to preclude inadvertent removal of these materials from the pool. These inspection activities constituted one complete sample as defined in IP 71124.01-05.

b. Findings

No findings were identified.

.5 High Radiation Area and Very High Radiation Area Controls (02.06)

a. Inspection Scope

The inspectors observed posting and physical controls for high radiation areas and very high radiation areas to assess adequacy. The inspectors conducted a selective inspection of posting and physical controls for high radiation areas and very high radiation areas to assess conformance with performance indicators. The inspectors reviewed procedural changes to assess the adequacy of access controls for high and very high radiation areas to determine whether procedural changes substantially reduced the effectiveness and level of worker protection. The inspectors assessed the controls for high radiation areas that were greater than 1 rem/hour and areas with the potential to become high radiation areas greater than 1 rem/hour for compliance with TS and procedures. The inspectors assessed the controls for very high radiation areas and areas with the potential to become very high radiation areas. The inspectors also assessed whether individuals were unable to gain unauthorized access to these areas. These inspection activities constituted one complete sample as defined in IP 71124.01-05.

b. Findings

No findings were identified.

.6 Radiation Worker Performance and Radiation Protection Technician Proficiency (02.07)

a. Inspection Scope

The inspectors observed radiation worker performance and assessed their performance with respect to radiation protection work requirements, the level of radiological hazards present, and radiation work permit controls. The inspectors assessed worker awareness of electronic alarming dosimeter set-points, stay times, or permissible dose for radiologically significant work as well as expected response to alarms. The inspectors observed radiation protection technician performance and assessed whether the technicians were aware of the radiological conditions and radiation work permit controls and whether their performance was consistent with training and qualifications for the given radiological hazards. The inspectors observed radiation protection technician performance of radiation surveys and assessed the appropriateness of the instruments being used, including calibration and source checks. These inspection activities constituted one complete sample as defined in IP 71124.01-05.

b. Findings

No findings were identified.

.7 Problem Identification and Resolution (02.08)

a. Inspection Scope

The inspectors assessed whether problems associated with radiological hazard assessment and exposure controls were being identified at an appropriate threshold and were properly addressed for resolution. For select problems, the inspectors assessed the appropriateness of the corrective actions. The inspectors also assessed the licensee's program for reviewing and incorporating operating experience. The inspectors reviewed select problems related to human performance errors and assessed whether there was a similar cause and whether corrective actions taken resolved the problems. The inspectors reviewed select problems related to radiation protection technician error and assessed whether there was a similar cause and whether corrective actions taken resolved the problems. These inspection activities constituted one complete sample as defined in IP 71124.01-05.

b. Findings

No findings were identified.

2RS3 In-Plant Airborne Radioactivity Control and Mitigation

.1 Use of Respiratory Protection Devices (02.03)

a. Inspection Scope

The inspectors assessed whether the licensee provided respiratory protection devices for those situations where it was impractical to employ engineering controls such that occupational doses were as-low-as-reasonably-achievable. For select instances when respiratory protection devices were used, the inspectors assessed whether the licensee concluded that further engineering controls were not practical. The inspectors also assessed whether the licensee had established means to verify that the level of protection provided by the respiratory protection devices was at least as good as that assumed in the work controls and dose assessment. The inspectors assessed whether the respiratory protection devices used to limit the intake of radioactive materials were certified by the National Institute for Occupational

Safety and Health/Mine Safety and Health Administration or have been approved by the NRC. The inspectors evaluated whether the devices were used consistent with their National Institute for Occupational Safety and Health/Mine Safety and Health Administration certification or any conditions of their NRC approval. The inspectors evaluated whether selected individuals qualified to use respiratory protection devices had been deemed fit to use the devices by a physician.

21 The inspectors reviewed training curricula for use of respiratory protection devices to assess whether individuals are adequately trained on donning, doffing, function checks, and how to respond to a malfunction. These inspection activities supplemented those documented in IR 05000266/2016001; 05000301/2016001 and constituted a partial sample as defined in IP 71124.03-05.

b. Findings

No findings were identified.

.2 Self-Contained Breathing Apparatus for Emergency Use (02.04)

a. Inspection Scope

The inspectors reviewed the status and surveillance records for select self-contained breathing apparatuses (SCBAs). The inspectors evaluated the licensee's capability for refilling and transporting SCBA air bottles to and from the control room and operations support center during emergency conditions. The inspectors assessed whether control room operators and other emergency response and radiation protection personnel were trained and qualified in the use of SCBAs and evaluated whether personnel assigned to refill bottles were trained and qualified for that task. The inspectors assessed whether appropriate mask sizes and types were available for use. The inspectors evaluated whether on-shift operators had no facial hair that would interfere with the sealing of the mask and that appropriate vision correction was available. The inspectors reviewed the past 2 years of maintenance records for selected in-service SCBA units used to support operator activities during accident conditions. The inspectors assessed whether maintenance or repairs on a SCBA unit's vital components were performed by an individual certified by the manufacturer of the device to perform the work. The inspectors evaluated the onsite maintenance procedures governing vital component work to determine whether there were any inconsistencies with the SCBA manufacturer's recommended practices. The inspectors evaluated whether SCBA cylinders satisfied the hydrostatic testing required by the U.S. Department of Transportation. These inspection activities supplemented those documented in IR 05000266/2016001; 05000301/2016001 and constituted one complete sample as defined in IP 71124.03-05.

b. Findings

No findings were identified.

.3 Problem Identification and Resolution (02.05)

a. Inspection Scope

The inspectors assessed whether problems associated with the control and mitigation of in-plant airborne radioactivity were being identified by the licensee at an appropriate threshold and were properly addressed for resolution. Additionally, the inspectors 22 evaluated the appropriateness of the corrective actions for selected problems involving airborne radioactivity documented by the licensee. These inspection activities supplemented those documented in IR 05000266/2016001; 05000301/2016001 and constituted one complete sample as defined in IP 71124.03-05.

b. Findings

No findings were identified.

2RS4 Occupational Dose Assessment

.1 External Dosimetry (02.03)

a. Inspection Scope

The inspectors evaluated whether the licensee's dosimetry vendor was National Voluntary Laboratory Accreditation Program accredited and whether the approved irradiation test categories for each type of personnel dosimeter used were consistent with the types and energies of the radiation present and the way the dosimeter was being used. The inspectors evaluated the onsite storage of dosimeters before their issuance, during use, and before processing/reading. For personnel dosimeters stored on-site during the monitoring period, the inspectors evaluated whether they were stored in low dose areas with control dosimeters. For personnel dosimeters that are taken off-site during the monitoring period, the inspectors evaluated the guidance provided to individuals with respect to care and storage of the dosimeter. The inspectors evaluated the calibration of active dosimeters. The inspectors assessed the bias of the active dosimeters compared to passive dosimeters and the correction factor used. The inspectors also assessed the licensee's program for comparing active and passive dosimeter results, investigations for substantial differences, and recording of dose. The inspectors assessed whether there were adverse trends for active

dosimeters. These inspection activities supplemented those documented in IR 05000266/2016001; 05000301/2016001 and constituted one complete sample as defined in IP 71124.04-05.

b. Findings

No findings were identified.

.2 Internal Dosimetry (02.04)

a. Inspection Scope

The inspectors reviewed procedures used to assess internal dose using whole body counting equipment to evaluate whether the procedures addressed methods for differentiating between internal and external contamination, the release of contaminated individuals, the route of intake and the assignment of dose. The inspectors assessed whether the frequency of measurements was consistent with the biological half-life of the nuclides available for intake. The inspectors reviewed the licensee's evaluation for use 23 of portal radiation monitors as a passive monitoring system to determine whether instrument minimum detectable activities were adequate to detect internally deposited radionuclides sufficient to prompt additional investigation. The inspectors reviewed whole body counts and evaluated the equipment sensitivity, nuclide library, review of results, and incorporation of hard-to-detect radionuclides. The inspectors reviewed procedures used to determine internal dose using in vitro analysis to assess the adequacy of sample collection, determination of entry route and assignment of dose. The inspectors reviewed the licensee's program for dose assessment based on air sampling, as applicable, and calculations of derived air concentration. The inspectors determined whether flow rates and collection times for air sampling equipment were adequate to allow lower limits of detection to be obtained. The inspectors also reviewed the adequacy of procedural guidance to assess internal dose if respiratory protection was used. The inspectors assessed select dose assessments based on air sampling for adequacy. The inspectors reviewed select internal dose assessments and evaluated the monitoring protocols, equipment, and data analysis. These inspection activities supplemented those documented in IR 05000266/2016001; 05000301/2016001 and constituted one complete sample as defined in IP 71124.04-05.

b. Findings

No findings were identified.

.3 Special Dosimetric Situations (02.05)

a. Inspection Scope

The inspectors assessed whether the licensee informs workers of the risks of radiation exposure to the embryo/fetus, the regulatory aspects of declaring a pregnancy, and the specific process to be used for declaring a pregnancy. The inspectors evaluated whether the monitoring program for declared pregnant workers was technically adequate to assess the dose to the embryo/fetus. The inspectors assessed results and/or monitoring controls for compliance with regulatory requirements. The inspectors reviewed the licensee's methodology for monitoring external dose in non-uniform radiation fields or where large dose gradients exist. The inspectors evaluated the licensee's criteria for determining when alternate monitoring was to be implemented. The inspectors reviewed dose assessments performed using multi-badging to evaluate whether the assess ment was performed consistently with licensee procedures and dosimetric standards. The inspectors evaluated the licensee's methods for calculating shallow dose equivalent from distributed skin contamination or discrete radioactive particles. The inspectors reviewed select shallow dose equivalent dose assessments for adequacy. The inspectors evaluated the licensee's program for neutron dosimetry, including dosimeter types and/or survey instrumentation. The inspectors reviewed select 24 neutron exposure situations and assessed whether dosimetry and/or instrumentation was appropriate for the expected neutron spectra, there was sufficient sensitivity, and neutron dosimetry was properly calibrated. The inspectors also assessed whether interference by gamma radiation had been accounted for in the calibration and whether time and motion evaluations were representative of actual neutron exposure events. For the special dosimetric situations reviewed in this section, the inspectors assessed how the licensee assigned the dose of record. This included an assessment of external and internal monitoring results, supplementary information on individual exposures, and radiation surveys and/or air monitoring results when dosimetry was based on these techniques. These inspection activities supplemented those documented in IR 05000266/2016001; 05000301/2016001 and constituted one complete sample as defined in IP 71124.04-05.

b. Findings

No findings were identified.

.4 Problem Identification and Resolution (02.06)

a. Inspection Scope

The inspectors assessed whether problems associated with occupational dose assessment were being identified by the licensee at an appropriate threshold and were properly addressed for resolution. The inspectors assessed the appropriateness of the corrective actions for a selected sample of problems documented by the licensee involving occupational dose assessment. These inspection activities supplemented those documented in IR 05000266/2016001; 05000301/2016001 and constituted one complete sample as defined in IP 71124.04-05.

b. Findings

No findings were identified. 4. OTHER ACTIVITES Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security

4OA1 Performance Indicator Verification

.1 Unplanned Scrams per 7000 Critical Hours

a. Inspection Scope

The inspectors sampled licensee submittals for the Unplanned Scrams per 7000 Critical Hours performance indicator (PI) (IE01) Point Beach Nuclear Plant, Units 1 and 2, for the first quarter through the fourth quarter of 2016. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, "Regul atory Assessment Performance Indicator 25 Guideline," Revision 7, dated August 31, 2013, were used. The inspectors reviewed the licensee's operator narrative logs and event reports during this time period to validate the accuracy of the submittals. The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report. This inspection constituted two unplanned scrams per 7000 critical hour samples as defined in IP 71151-05.

b. Findings

No findings were identified.

.2 Unplanned Scrams with Complications

a. Inspection Scope

The inspectors sampled licensee submittals for the Unplanned Scrams with Complications performance (IE04) Point Beach Nuclear Plant, Units 1 and 2, for the first quarter through the fourth quarter of 2016. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI

Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, dated August 31, 2013, were used. The inspectors reviewed the licensee's operator narrative logs and event reports during this time period to validate the accuracy of the submittals. The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified

. Documents reviewed are listed in the Attachment to this report. This inspection constituted two unplanned scrams with complication samples as defined in IP 71151-05.

b. Findings

No findings were identified.

.3 Unplanned Power Changes per 7000 Critical Hours

a. Inspection Scope

The inspectors sampled licensee submittals for the Unplanned Transients per 7000 Critical Hours performance indicator (IE03) Point Beach Nuclear Plant, Units 1 and 2, for the first quarter through the fourth quarter of 2016.

To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI

Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, dated August 31, 2013, were used. The inspectors reviewed the licensee's operator narrative logs and station power history during this time period to validate the accuracy of the submittals. The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report.

26 This inspection constituted two unplanned transients per 7000 critical hour samples as defined in IP 71151-05.

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems

.1 Routine Review of Items Entered into the Corrective Action Program

a. Inspection Scope

As discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify they were being entered into the licensee's corrective action program at an appropriate threshold, adequate attention was being given to timely corrective actions, and adverse trends were identified and addressed. Some minor issues were entered into the licensee's corrective action program as a result of the inspectors' observations; however, they are not discussed in this report. These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure they were considered an integral part of the inspections performed during the quarter.

b. Findings

No findings were identified.

.2 Annual Follow-up of Selected Issues:

G-02 Emergency Diesel Generator Wrist Pin Bearing Degradation

a. Inspection Scope

The inspectors selected the following issue for an in-depth review:

• G-02 emergency diesel generator (EDG) oil analysis indicates increased silver content. This issue was identified on December 28, 2016, when a review of results from a lubricating oil sample of the G-02 EDG taken on November 17, 2016, indicated increased silver content. The licensee routinely analyzed the silver content of the G-02 EDG lubricating oil based on manufacturer and vendor recommendations as increased silver content may indicate abnormal wear on susceptible components, including the engine's wrist pin bearings. As a result of the increase in silver content, the licensee inspected the EDG engine on January 3, 2017, and identified silver debris in the oil sump and wear on the wrist pin bearings. The licensee replaced all power assemblies in the engine with an updated wrist pin bearing design that is less susceptible to this issue. The G-02 EDG was returned to service on January 8, 2017, after repairs were completed. The licensee completed an apparent cause evaluation (ACE) and a past operability review for this issue. Additionally, they performed an analysis of the wrist pin bearing degradation.

27 As appropriate, the inspectors verified the following attributes during their review of the licensee's corrective actions for condition reports (CR's) documenting the issue:

• complete and accurate identification of the problem in a timely manner commensurate with its safety significance and ease of discovery;

• consideration of the extent of condition, generic implications, common cause, and previous occurrences;

• evaluation and disposition of operability/functionality/reportability issues;

• classification and prioritization of the resolution of the problem commensurate with safety significance;

• identification of the apparent and contributing causes of the problem;

• identification of corrective actions, which were appropriately focused to correct the problem; and

• completion of corrective actions in a timely manner commensurate with the safety significance of the issue. The inspectors discussed the corrective actions and associated evaluations with licensee personnel. Documents reviewed are listed in the Attachment to this report. This review constituted one in-depth problem identification and resolution inspection sample as defined in IP 71152. b. Observations The licensee's past operability review discussed that increased silver content in the lubricating oil was first detected on November 29, 2016, when the licensee received analysis results from an oil sample taken on November 17, 2016. The inspectors questioned the sequence of events from November 17, 2016, until the condition report was written on December 28, 2016, for this issue. The licensee indicated that lubricating oil samples were taken monthly, however, they were analyzed on a quarterly basis, which was identified as a programmatic issue in their ACE. The initial analysis results for the November 17, 2016, oil sample were received on November 29, 2016. However, the vendor that completed the analysis did not use a high accuracy analysis method.

This resulted in the silver content being repor ted as 1 ppm silver and the exact level of silver was unknown by the licensee. At the request of the licensee, the sample was reanalyzed with a high accuracy analysis and the licensee received the resulting silver content of 1.1 ppm on December 27, 2016. When the high accuracy analysis results were received, the licensee submitted additional G-02 lubricating oil samples from October 18, 2016, and December 15, 2016, for analysis. The licensee's ACE identified that an elevated silver content was also discovered in these two samples. The inspectors questioned the licensee's sensitivity to this issue due to past operating experience. Specifically, on November 29, 2016, they received analysis results that, although not a high accuracy analysis, indicated a higher than expected silver content in the lubricating oil. At that time, the issue was discussed among the system engineers, however it was not placed in the CAP process. The inspectors discussed that, although the licensee took prompt action when the high accuracy analysis results were obtained, the opportunity to take more timely action was missed when the low accuracy results were initially received on November 29, 2016.

c. Findings

No findings were identified.

4OA3 Follow-Up of Events and Notices of Enforcement Discretion

.1 (Closed) Licensee Event Report 05000266/2016-001-00:

Unit 1 Degraded Condition On March 15, 2016, during performance of boric acid inspection activities for the Unit 1 refueling outage the licensee identified a boric acid indication upstream of the valve seating surface on the inlet of the "B" letdown orifice outlet control valve body. The condition was assessed as a through-wall flaw located within the reactor coolant system pressure boundary. On May 12, 2016, the licensee submitted the licensee event report (LER) in accordance with requirements of 10 CFR 50.73(a)(2)(ii)(A) for any event or condition that resulted in the condition of the nuclear power plant, including its principal safety barriers, being seriously degraded. The licensee concluded that the material defect in the primary coolant system could not be found acceptable in accordance with ASME Section XI, IWB-3600, "Analytical Evaluation of Flaws," or ASME Section XI, Table IWB-3410-1, "Acceptance Standards." The licensee performed an ACE, which identified the most likely cause for the through-wall leak to be associated with a sand inclusion during valve fabrication revealed through destructive testing and records review. Review of valve fabrication radiographic examination results from 1968 further revealed that sand inclusions were noted and accepted as is using the Class 2 acceptance criteria of ASTM Specification E-71, "Reference Radiographs for Steel Castings up to 2 inches in Thickness," which was the inspection specification at the time of fabrication. Corrective actions included replacement of the leaking "B" letdown orifice outlet control valve and extent of condition visual examinations of the other valves fabricated using the same casting. The inspectors reviewed the LER, the licensee's ACE and corrective actions and determined

that no findings or violations of NRC requirements existed. Documents reviewed are listed in the Attachment to this report. This LER is closed. This event follow-up review constituted one sample as defined in IP 71153-05.

.2 (Closed) Licensee Event Report 05000266/2012-001-00:

Operability of G-01 and G-02 Emergency Diesel Generators

a. Inspection Scope

The inspectors reviewed the subject LER that was submitted on June 25, 2012. In Task Interface Agreement (TIA) 2011-011, "Evaluation of Point Beach Nuclear Plant Tornado Missile Protection Licensing Basis," dated August 16, 2011, the NRC concluded that the licensing basis for Point Beach Nuclear Plant (PBNP) required the EDG exhaust stacks to be protected from tornado missiles. Licensee personnel, in a prompt operability determination, determined that the EDGs were operable, but non-conforming. Subsequently, the NRC issued TIA 2012-07, "App licability of General Design Criteria Requirements in Operability Determinations and Assessment of the Point Beach Nuclear Plant Operability Determination for Emergency Diesel Generators with Respect to Tornado Missiles," dated April 24, 2012. Based on concerns in TIA 2012-07, PBNP declared EDGs G-01 and G-02 inoperable on April 26, 2012, and entered the 7-day Action Condition for TS 3.8.1, "AC Sources - Operating." A protective structure was 29 designed and built around the G-02 EDG exhaust stack within 7 days and the EDGs were returned to an operable status. Subsequently, in November 2012, the licensee revised the FSAR which changed the PBNP tornado missile licensing basis for safety related equipment to "separation and redundancy" as opposed to providing physical protection from tornado missiles. The inspectors noted that the FSAR change was performed under AR 01819360 dated November 2, 2012, and 10 CFR 50.59 Screening SCR 2012-0178 dated November 5, 2012. While reviewing the FSAR change, the inspectors noted that the licensee used a Westinghouse letter E-R-206, dated October 2, 1969, and the NRC Staff Evaluation Report, "Individual Plant Examination of External Events Submitted for PBNP, Units 1 and 2," dated September 15, 1999, as the basis for the FSAR change. The inspectors identified this action was contrary to the conclusions of TIA 2011-011, and was a minor violation of "Failure to obtain a License Amendment for a Licensing Basis Change in the UFSAR." The conclusions of the TIA 2011-011 stated, in part that, "the licensee's use of the Individual Plant Examination of External Events, other non-licensing basis documentation and judgements of low probability to demonstrate compliance with the licensing basis are not acceptable without submitting this material for NRC staff review and inclusion in the UFSAR." When the inspectors raised this concern the licensee captured it in their CAP as AR 02188846 with the recommendation to initiate a licensing change to remove "separation and redundancy" as the licensing basis for tornado missile protection from the FSAR. The inspectors reviewed the LER to ensure it was reported accurately in accordance with 10 CFR 50.73 reporting requirements. Documents reviewed are listed in the to this report. This LER is closed. This event follow-up review constituted one sample as defined in IP 71153-05.

b. Findings

No findings were identified.

.3 Notification of Unusual Event due to Fire Alarm in Unit 1 Containment

a. Inspection Scope

On Monday, March 20, 2017, at 4:20 p.m. CDT, Point Beach, Unit 1 declared a Notice of Unusual Event due to a smoke detector alarm in the Unit 1 containment. There were no indications of any other detector alarms, no abnormal equipment indications, and containment temperature and humidity parameters were normal. The declaration was made under the Initiating Condition of HU2, "Fire Within Protected Area Boundary Not Extinguished Within 15 Minutes of Detection," and the Emergency Action Level HU2.1, "Fire in Table H-1 areas not extinguished within 15 minutes of control room notification or verification of control room alarm." Unit 1 containment was one of the areas listed in Table H-1. Following the smoke detector alarm, the licensee entered AOP-40, "Response to Fire," Revision 0 and dispatched the fire brigade to the Unit 1 containment. The licensee entered the Unit 1 containment lower hatch at 4:36 p.m., and at 4:40 p.m., the individuals in containment reported that there was no smoke, no fire, and no hot spots identified. The licensee announced that the smoke alarm was not valid and directed the 30 fire brigade response to stand down. The malfunctioning smoke detector was declared non-functional and the licensee terminated the event at 8:22 p.m. The inspectors responded to the control room shortly after fire was announced and remained in the control room throughout the event until it was terminated. The inspectors confirmed that the licensee's event classification and notification were both timely and accurate. Documents reviewed are listed in the Attachment to this report. This event follow-up review constituted one sample as defined in IP 71153-05.

b. Findings

No findings were identified.

4OA5 Other Activities

.1 (Closed) NRC Temporary Instruction 2515/192, "Inspection of the Licensee's Interim Compensatory Measures Associated with the Open Phase Condition Design Vulnerabilities in Electric Power Systems"

a. Inspection Scope

The objective of this performance-based temporary instruction (TI) is to verify implementation of interim compensatory measures associated with an open phase condition (OPC) design vulnerability in the electric power system for operating reactors.

The inspectors conducted an inspection to determine whether the licensee had implemented the following interim com pensatory measures. These compensatory measures are to remain in place until permanent automatic detection and protection schemes are installed and declared operable for OPC design vulnerability. The inspectors verified the following:

• The licensee had identified and discussed with plant staff the lessons-learned from the OPC events at the U.S. operating plants including the Byron station OPC event and its consequences. This includes conducting operator training for promptly diagnosing, recognizing consequences, and responding to an OPC

event.

• The licensee had updated plant operating procedures to help operators promptly diagnose and respond to OPC events on off-site power sources credited for safe shutdown of the plant.

• The licensee had established and continued to implement periodic walkdown activities to inspect switchyard equipment such as insulators, disconnect switches, and transmission line and transformer connections associated with the offsite power circuits to detect a visible OPC.

• The licensee had ensured that routine maintenance and testing activities on switchyard components have been implemented and maintained. As part of the maintenance and testing activities, the licensee assessed and managed plant risk in accordance with 10 CFR 50.65(a)

(4) requirements.

b. Findings and Observations

No findings of significance were identified. The inspectors identified that the licensee conducted training with personnel to understand the consequences and required actions 31 upon detection of an open phase event. The licensee had not provided operator training for promptly diagnosing an open phase event beyond the existing training for responding to annunciator alarms. The licensee has, in their current analyses for plant response to an open phase event, concluded that either the safety busses will switch to onsite power or, because of their transformers winding configuration and capability, will be adequately powered even with an open phase. Licensee procedures require a minimum of two daily inspections of the switchyard, weather permitting, with instructions to visually inspect conductors and switchyard equipment. The licensee also schedules semi-annual thermography inspection of switchyard components. TI 2515/192 is closed.

4OA6 Management Meetings

.1 Exit Meeting Summary On April 4, 2017, the inspectors presented the inspection results to Mr. R. 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.

.2 Interim Exit Meetings Interim exits were conducted for:

• On March 2, 2017, the inspectors conducted an interim exit and presented the inspection results for the LER 05000301/2012-001-00, "Operability of G-01 and G-02 Diesel Generators" closure to Mr. B. Woyak, Regulatory Assurance Manager. Licensee personnel acknowledged the inspection results.

• On March 31, 2017, the inspectors conducted an interim exit for the inservice inspection activities with Mr. R. Coffey, and other members of the licensee's staff. Licensee personnel acknowledged the inspection results.

• The inspection results for the Radiation Safety Program review with Mr. R. Coffey, on March 31, 2017. The inspectors confirmed that none of the potential report input discussed was considered proprietary. Proprietary materials received during the inspection were returned to the licensee.

4OA7 Licensee-Identified Violations The following violation of very low significance (Green) was identified by the licensee and is a violation of NRC requirements, which meets the criteria of the NRC Enforcement Policy for being dispositioned as a non-cited violation (NCV). The licensee identified a finding of very low safety significance (Green) and an NCV of TS 5.5.14, "Safety Function Determination Program (SFDP)," due to the failure to detect

a loss of safety function and ensure appropriate actions were taken during maintenance activities conducted during performance of WO 40513133 for troubleshooting the check source drive mechanism for RE-235, control room noble gas monitor, on January 18, 2017. In addition to the troubleshooting activities in WO 40513133, the licensee concurrently performed preventative maintenance on W-14A, F-16 control 32 room charcoal filter fan, and W-13B2, control room recirculation fan. Due to these activities, the licensee implemented procedure NP 10.3.8, "Safety Function Determination Program," to ensure that a loss of safety function was detected and the appropriate actions were taken for the equipment out of service associated with the CREFS. Specifically, NP 10.3.8, step 4.2.2 stated, "Perform Loss of Safety Function Evaluation." Contrary to NP 10.3.8, step 4.2.2, an adequate loss of safety function evaluation was not performed for the CREFS system based on the equipment that was out of service. As a result of the inadequate loss of safety function evaluation, the licensee did not perform the Required Actions of TS limiting condition for operation (LCO) 3.7.9, "Control Room Emergency Filtration System (CREFS)," Condition C. The inadequate loss of safety function evaluation was identified when an operator wrote an action request that questioned condition of the CREFS during maintenance activities on January 18, 2017. TS 5.5.14, "Safety Function Determination Program," required, in part, that if a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. Contrary to the above, on January 18, 2017, the licensee did not enter the appropriate Conditions and Required Actions of the LCO in which a loss of safety

function existed. Specifically, the licensee did not adequately implement procedure NP 10.3.8, step 4.2.2, which resulted in the licensee not performing the Required Actions of TS LCO 3.7.9, Condition C. The licensee entered this issue into the CAP as AR 02183341. The inspectors determined that this issue was of very low safety significance (Green) after reviewing IMC 0609, "Significance Determination Process,"

0609.04, "Initial Characterization of Findings," dated October 7, 2016 and IMC 0609, Appendix A, "The Significance Determination Process (SDP) For Findings At-Power," dated July 1, 2012. The inspectors answered "Yes" to Question 1 in

Exhibit 3, Section C, "Control Room Auxiliary, Reactor, or Spent Fuel Pool Building." This resulted in the finding screening as Green. ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

R. Coffey, Site Vice President

R. Craven, Plant General Manager

S. Aerts, Performance Improvement Manager

R. Barker, Senior Engineering Analyst

A. Bussiere, Information Technology Project Manager

R. Clark, Licensing Engineer

S. Forsha, Principal Engineer

J. Gerondale, Security Supervisor

B. Gierach, Information Technology Manager

J. Golding, Inspection Lean and System Engineering Supervisor

B. Griffin, Communications Specialist

A. Gustafson, Operations Training General Supervisor

D. Halverson, Information Technology Specialist

R. Harrsch, Engineering Director R. Hastings Operations Assistant Manager

R. Higgins, Operations Assistant Manager

K. Johansen, ODCM Specialist

E. Korkowski, Senior Engineering Analyst

T. Lesniak, Site Maintenance Director

K. Locke, Licensing Engineer

S. Manthei, Licensing Engineer

M. Millen, Senior Project Manager

C. Neuser, Site Engineering Manager

J. Ramski, Outage Manager

E. Schmidt, Site Engineering Manager

T. Schneider, Senior Engineer

R. Seizert, Emergency Preparedness Manager

R. Severson, Principal Engineer

B. Smith, ISFSI Project Manager

G. Strharsky, Site Quality Manager

R. Welty, Radiation Protection Manager

J. Wilson, Site Operations Director

P. Wild, Site Engineering Manager

B. Woyak, Licensing Manager

U.S. Nuclear Regulatory Commission J. Cameron, Chief, Reactor Projects Branch 4

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Closed

05000266/2016-001-00 LER Unit 1 Degraded Condition

05000266/2012-001-00 LER Operability of G-01 and G-02 Emergency Diesel

Generators TI 2515/192 TI NRC Temporary Instruction (TI) 2515/192, Inspection of the Licensee's Interim Compensatory Measures Associated with the Open Phase Condition Design Vulnerabilities in Electric Power Systems

LIST OF DOCUMENTS REVIEWED

The following is a partial list of documents reviewed during the inspection.

Inclusion on this list does not imply that the NRC inspector reviewed the documents in their entirety, but rather that