IR 05000266/2015010

IR 05000266/2015010, 05000301/2015010; on 08/10/2015 - 08/28/2015; Point Beach Nuclear Plant, Units 1 and 2; Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications. (Jjc)

ML15261A631
Person / Time
Site:	Point Beach
Issue date:	09/16/2015
From:	Robert Daley Engineering Branch 3
To:	Mccartney E Point Beach
References
IR 2015010
Download: ML15261A631 (16)

Text

UNITED STATES ber 16, 2015

SUBJECT:

POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 - EVALUATIONS OF CHANGES, TESTS, AND EXPERIMENTS AND PERMANENT PLANT MODIFICATIONS BASELINE INSPECTION REPORT 05000266/2015010; 05000301/2015010

Dear Mr. McCartney:

On August 28, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications inspection at your Point Beach Nuclear Plant. The enclosed inspection report documents the inspection results which were discussed on August 28, 2015, with you, and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

The NRC inspectors documented one finding of very-low safety significance (Green) in this report. This finding was determined to involve a violation of NRC requirements. However, because of its very-low safety significance, and because the issue was entered into your Corrective Action Program, the NRC is treating the issue as a Non-Cited Violation (NCV) in accordance with Section 2.3.2 of the NRC Enforcement Policy.

If you contest the subject or severity of the Non-Cited-Violation, 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, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Point Beach Nuclear Plant. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS)

component of the NRC's Agencywide Documents Access and Management System (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Docket Nos. 50-266; 50-301 License Nos. DPR-24; DPR-27

Enclosure:

IR 05000266/2015010; 05000301/2015010 w/Attachment: Supplemental Information

REGION III==

Docket No: 50-266; 50-301 License No: DPR-24; DPR-27 Report No: 05000266/2015010; 05000301/2015010 Licensee: NextEra Energy Point Beach, LLC Facility: Point Beach Nuclear Plant, Units 1 and 2 Location: Two Rivers, WI Dates: August 10 - 28, 2015 Inspectors: Jorge J. Corujo-Sandín, Reactor Inspector (Lead)

Mark T. Jeffers, Reactor Inspector Michael A. Jones, Reactor Inspector Approved by: Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Enclosure

SUMMARY

Inspection Report 05000266/2015010, 05000301/2015010; 08/10/2015 - 08/28/2015; Point

Beach Nuclear Plant, Units 1 and 2; Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications.

This report covers a 2-week announced baseline inspection on evaluations of changes, tests, and experiments and permanent plant modifications. The inspection was conducted by Region III based engineering inspectors. One finding was identified by the inspectors. The finding was considered a Non-Cited Violation (NCV) of U.S. Nuclear Regulatory Commission (NRC) regulations. The significance of most findings is indicated by their color (i.e., Greater than Green, or Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609,

Significance Determination Process. Cross-cutting aspects were determined using IMC 0310,

Aspects Within the Cross Cutting Areas. Findings for which the Significance Determination Process does not apply may be Green or be assigned a severity level after NRC management review. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated July 9, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5, dated February 2014.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a finding of very-low safety significance, and an associated NCV of Title 10, Code of Federal Regulations, Part 50, Appendix B,

Criterion III, Design Control, for the licensees failure to evaluate for potential gas intrusion from the spray additive tank into the containment spray (CS) system during the injection phase of a design-basis accident. As part of immediate corrective actions, the licensee entered the concern in the Corrective Action Process as AR 2068569, and performed an evaluation which determined no air entrainment is expected to occur during the injection phase.

The performance deficiency was determined to be more than minor because it was associated with the Mitigating Systems cornerstone attribute of equipment performance, and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, air intrusion into the CS system could affect the operability of the CS pumps by causing degraded performance and/or air binding of the pumps.

The finding screened as having very-low safety significance. Specifically, the finding was a deficiency affecting the design or qualification of a mitigating structure, system, or component (SSC), however, based on the evaluation performed by the licensee the SSC maintained its operability. Based on the timeframe of the violation the inspectors did not identify a cross-cutting aspect associated with this finding. (Section 1R17.1b)

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R17 Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications

.1 Evaluation of Changes, Tests, and Experiments

a. Inspection Scope

The inspectors reviewed 7 safety evaluations performed pursuant to Title 10, Code of Federal Regulations (CFR), Part 50, Section 59, to determine if the evaluations were adequate, and that prior U.S. Nuclear Regulatory Commission (NRC) approval was obtained as appropriate. The inspectors also reviewed 16 screenings where licensee personnel had determined that a 10 CFR 50.59 evaluation was not necessary. The inspectors reviewed these documents to determine if:

• the changes, tests, and experiments performed were evaluated in accordance with 10 CFR 50.59 and that sufficient documentation existed to confirm that a license amendment was not required;

• the safety issue requiring the change, tests or experiment was resolved;

• the licensee conclusions for evaluations of changes, tests, and experiments were correct and consistent with 10 CFR 50.59; and

• the design and licensing basis documentation was updated to reflect the change.

The inspectors used, in part, Nuclear Energy Institute (NEI) 96-07, Guidelines for 10 CFR 50.59 Implementation, Revision 1, to determine acceptability of the completed evaluations, and screenings. The NEI document was endorsed by the NRC in Regulatory Guide 1.187, Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments, dated November 2000. The inspectors also consulted Part 9900 of the NRC Inspection Manual, 10 CFR Guidance for 10 CFR 50.59, Changes, Tests, and Experiments.

This inspection constituted 7 samples of evaluations and 16 samples of screenings and/or applicability determinations as defined in Inspection Procedure (IP) 71111.17-04.

b. Findings

Failure to Evaluate Containment Spray System for Potential Gas Intrusion

Introduction:

The inspectors identified a finding of very-low safety significance (Green), and an associated Non-Cited Violation (NCV) of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to evaluate for potential gas intrusion from the spray additive tank into the containment spray (CS) system during the injection phase of a design-basis accident (DBA).

Description:

On January 11, 2008, the NRC requested each addressee of Generic Letter (GL) 2008-01 to evaluate its Emergency Core Cooling Systems, decay heat removal, and CS systems licensing basis, design, testing, and corrective actions to ensure that gas accumulation was maintained less than the amount that would challenge the operability of these systems, and take appropriate actions when conditions adverse to quality were identified. The licensees original actions to address these requests were, in part, to perform design reviews to identify and address gas intrusion mechanisms. Vortexing was among the gas intrusions mechanisms identified by GL 2008-01.

Per its design bases, the CS system would operate during both the injection phase and recirculation phase of certain DBA. However, the inspectors identified the licensee had failed to evaluate the CS system against potential gas intrusion during the injection phase, under design bases conditions. Specifically, during the injection phase one of CS design bases functions is to transfer sodium hydroxide (NaOH) from the spray additive tank (SAT) to the containment sump. This function is required to maintain adequate pH level in the sump in order to prevent chloride induced stress corrosion cracking and maintain iodine in the iodate form that will stay in solution. To accomplish this function the CS system is aligned to two separate suction sources, the SAT and the Refueling Water Storage Tank (RWST). The inspectors noted the licensee had evaluated for potential gas intrusion, including vortex prevention, from the RWST but had failed to evaluate for potential draining or vortex formation on the SAT during the injection phase.

The inspectors discussed their concerns with the licensee and preliminary results showed the SAT could be completely drained and air ingested into the CS system.

This concern was entered into the Corrective Action Program (CAP) as AR 2068569.

A follow-up evaluation was performed by the licensee and determined the SAT would not drain down and no air entraining vortex should form. As a result the licensee determined the CS system remained operable.

Analysis:

The inspectors determined the failure to evaluate for potential gas intrusion from the SAT into the CS system during the injection phase of a DBA was contrary to 10 CFR Part 50, Appendix B, Criterion III, Design Control, and was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the Mitigating Systems cornerstone attribute of equipment performance, and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, air intrusion into the CS system could affect the operability of the CS pumps by causing degraded performance and/or air binding of the pumps.

The inspectors determined the finding could be evaluated using the Significance Determination Process in accordance with Inspection Manual Chapter (IMC) 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings. Specifically, the inspectors used IMC 0609, Appendix A, Significance Determination Process for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, issued June 19, 2012, and answered yes to Question A.1. The finding was a deficiency affecting the design or qualification of a mitigating structure, system, or component (SSC), but the SSC maintained its operability. Specifically the licensee evaluated the CS system and determined the SSC remained operable. As a result, the finding screened as having a very-low safety significance, i.e., Green.

The inspectors did not identify a cross-cutting aspect associated with this finding.

Specifically, the decision to not evaluate the injection phase was taken around the 2008 timeframe when the licensee was responding to the GL 2008-01. As a result the inspectors determined this finding was not representative of the licensees current performance.

Enforcement:

Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established to assure that design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculation methods, or by the performance of a suitable testing program.

Contrary to the above, as of August 28, 2015, the licensee had not verified the adequacy of the CS design. Specifically, the licensee failed to evaluate for potential gas intrusion into the CS system due to drain down and/or vortexing in the SAT during the injection phase of a DBA.

This violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. The violation was entered into the licensees CAP as AR 2068569.

As part of immediate corrective actions the licensee performed an evaluation which determined the SAT would not drain down and no air entraining vortex should form.

As a result the licensee determined the CS system remained operable.

(NCV 05000266/2015010-01; 05000301/2015010-01, Failure to Evaluate Containment Spray System for Potential Gas Intrusion).

.2 Permanent Plant Modifications

a. Inspection Scope

The inspectors reviewed seven permanent plant modifications that had been installed in the plant during the last 3 years. This review included in-plant walkdowns for; portions of the Spent Fuel Pool Instrumentation modification; reroute of transformer 1X04 low voltage side power cables modification; portions of the CS system associated with modified procedures; and the (G-05) gas turbine generator including control cabinets, supporting equipment, including batteries, support diesels, piping, supports, and the air inlet weather hood structure. The modifications were selected based upon risk significance, safety significance, and complexity. The inspectors reviewed the modifications selected to determine if:

• the supporting design and licensing basis documentation was updated;

• the changes were in accordance with the specified design requirements;

• the procedures and training plans affected by the modification have been adequately updated;

• the test documentation as required by the applicable test programs has been updated; and

• post-modification testing adequately verified system operability and/or functionality.

The inspectors also used applicable industry standards to evaluate acceptability of the modifications. The list of modifications and other documents reviewed by the inspectors is included as an Attachment to this report.

This inspection constituted seven permanent plant modification samples as defined in IP 71111.17-04.

4OA2 Problem Identification and Resolution

.1 Routine Review of Condition Reports

a. Inspection Scope

The inspectors reviewed several corrective action process documents that identified or were related to 10 CFR 50.59 evaluations and permanent plant modifications. The inspectors reviewed these documents to evaluate the effectiveness of corrective actions related to permanent plant modifications and evaluations of changes, tests, and experiments. In addition, corrective action documents written on issues identified during the inspection were reviewed to verify adequate problem identification and incorporation of the problems into the corrective action system. The specific corrective action documents that were sampled and reviewed by the inspectors are listed in the attachment to this report.

b. Findings

No findings were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

On August 28, 2015, the inspectors presented the inspection results to Mr. McCartney, and other members of the licensee staff. The licensee personnel acknowledged the inspection results presented and did not identify any proprietary content. The inspectors confirmed that all proprietary material provided to the inspection team was identified and will be dispositioned in accordance with applicable processes.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

S. Aerts, Performance Improvement Manager

D. DeBoer, Plant Manager

F. Eichhorst, Design Engineering Configuration Management Supervisor

D. Forter, Manager of Projects

R. Harrsch, Engineering Director

D. Jensen, Design Engineering

K. Kinjerski, Procedures Supervisor

T. Lohr, Reactor Operator

E. McCartney, Site Vice President

A. Nash Design Engineering Supervisor

R. Parker, Chemistry Manager

M. Rosseau, Electrical / I&C Design Supervisor

G. Strharsky, NOS Manager

R. Webber, Operations Director

P. Wild, Design Engineering Manager

J. Wilson, Maintenance Director

B. Woyak, Licensing Manager

U.S. Nuclear Regulatory Commission

D. Oliver, Senior Resident Inspector

LIST OF ITEMS

Opened and Closed

05000266/2015010-01; Failure to Evaluate Containment Spray System for NCV

05000301/2015010-01 Potential Gas Intrusion (Section 1R17.1b)

Discussed

None