IR 05000266/2009007
| ML100210779 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 01/21/2010 |
| From: | Robert Daley NRC/RGN-II/DRS/EB3 |
| To: | Meyer L Point Beach |
| References | |
| IR-09-007 | |
| Download: ML100210779 (19) | |
Text
anuary 21, 2010
SUBJECT:
POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 EVALUATION OF CHANGES, TESTS, OR EXPERIMENTS AND PERMANENT PLANT MODIFICATIONS BASELINE INSPECTION REPORT 05000266/2009007(DRS); 05000301/2009007(DRS)
Dear Mr. Meyer:
On December 18, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications Inspection at your Point Beach Nuclear Plant, Units 1 and 2. The enclosed report documents the inspection results, which were discussed on December 18, 2009, with you and other members of your staff.
This inspection examined activities conducted under your license as they relate to safety and to 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.
Based on the results of this inspection, one NRC-identified finding of very low safety-significance was identified. The finding involved 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 VI.A.1 of the NRC Enforcement Policy.
If you contest the subject or severity of a 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 a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission -
Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Point Beach Nuclear Plant. In addition, if you disagree with the characterization of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at the Point Beach Nuclear Plant.
The information that you provide will be considered in accordance with Inspection Manual Chapter 0305. In accordance with 10 CFR 2.390 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 NRC Public Document Room or from the Publicly Available Records System (PARS)
component of NRC's Agencywide Documents Access and Management System (ADAMS),
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Robert Daley, Chief Engineering Branch 3 Division of Reactor Safety Docket Nos. 50-266; 50-301 License Nos. DPR-24; DPR-27
Enclosure:
Inspection Report No. 05000266/2009007(DRS); 05000301/2009007 (DRS)
w/Attachment: Supplemental Information
REGION III==
Docket No: 05000266; 05000301 License No: DPR-24; DPR-27 Report No: 05000266/2009007(DRS); 05000301/2009007(DRS)
Licensee: NextEra Energy Point Beach, LLC Facility: Point Beach Nuclear Plant, Units 1 and 2 Location: Two Rivers, WI Dates: November 30, 2009 through December 18, 2009 Inspectors: A. Dahbur, Senior Reactor Inspector (Lead)
J. Neurauter, Senior Reactor Inspector N. Feliz-Adorno, Reactor Inspector Observers: S. Edmonds, NSPDP M. Benson, General Engineer, NSPDP Approved by: R. Daley, Chief Engineering Branch 3 Division of Reactor Safety (DRS)
Enclosure
SUMMARY OF FINDINGS
IR 05000266/2009007 (DRS); 05000301/2009007 (DRS); 11/30/2009 - 12/18/2009; Point
Beach Nuclear Plant, Units 1 and 2; Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications.
This report covers a two-week announced baseline inspection on Evaluations of Changes,
Tests, or Experiments and Permanent Plant Modifications. The inspection was conducted by Region III based engineering inspectors. Based on the results of this inspection, one finding of very low safety-significance (Green) was identified. The finding was considered a Non-Cited Violation (NCV) of NRC regulations. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.
NRC-Identified
and Self-Revealed Findings
Cornerstone: Mitigating Systems
- Green.
A finding of very low safety-significance (Green) and associated Non-Cited Violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control was identified by the inspectors for the licensees failure to adequately calculate the maximum room temperature for G-01 and G-02. Specifically, the licensees calculation 2005-0054 failed to incorporate the design basis described in Technical Specification (TS) bases 3.8.1 related to the numbers of fire dampers associated with G-01 and G-02 exhaust fans that must be opened to maintain room temperature. The calculation also failed to demonstrate that the temperature stratification close to the combustion air intake filter was acceptable. Instead, the calculation only considered the bulk air temperature in the room. The licensee subsequently entered these concerns into their corrective action program as AR 01162599 and AR 01162759.
The finding was determined to be more than minor because the finding was similar to IMC 0612, Appendix E, Example (3.J). The calculation errors were significant in that there was reasonable doubt that the maximum room temperature would not exceed the value of the Vendor Technical manual. The finding impacted the Mitigating System cornerstone of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee did not ensure that the maximum room temperature of EDG-1 and EDG-2 would not exceed 115 degrees (o) Fahrenheit (F), which is required to be maintained to ensure that the EDGs will perform their safety function during a design basis accident when the outside air temperature was 95o F. The finding was of very low safety-significance based on a Phase 1 screening in accordance with IMC 0609, Appendix A, ASignificance Determination of Reactor Inspection Findings for At-Power Situations.@ This finding was not associated with a cross-cutting aspect because the finding was not indicative of the licensees current performance. (Section 1R17.1.b(1))
Licensee-Identified Violations
No findings of significance were identified.
REPORT DETAILS
REACTOR SAFETY
Cornerstone: Initiating Events, Mitigating Systems, and Barrier Integrity
1R17 Evaluation of Changes, Tests, or Experiments and Permanent Plant Modifications
.1 Evaluation of Changes, Tests, or Experiments
a. Inspection Scope
From November 30, 2009 through December 18, 2009, the inspectors reviewed 13 safety evaluations (SEs) performed pursuant to 10 CFR 50.59 to determine if the evaluations were adequate and that prior NRC approval was obtained as appropriate. The inspectors also reviewed 13 screenings and one calculation 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, or 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, or 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 13 samples of evaluations and 13 samples of changes as defined in IP 71111.17-04.
b. Findings
- (1) Errors Found in the Room Ventilation Calculation for G-01 and G-02
Introduction:
A finding of very low safety-significance and associated NCV of 10 CFR Part 50, Appendix B, Criterion III, ADesign Control was identified by the inspectors for the licensees failure to adequately calculate the maximum room temperature for the Emergency Diesel Generators (EDGs) G-01 and G-02 during post-accident scenarios and assuming an outside temperature of 95o F. Specifically, the licensees calculation for the EDG rooms ventilation did not incorporate the design basis described in TS Bases 3.8.1, which indicated that three out of four dampers were required to be open to maintain room temperature for the emergency diesel generators G-01 and G-02. In addition, the calculation also failed to demonstrate that the temperature stratification close to the combustion air intake filter was adequate, instead, the calculation only considered the bulk air temperature in the room.
Description:
Emergency Diesel Generators G-01 and G-02 draw combustion intake air from their respective rooms; therefore, the room temperature directly affected temperature limitations on the diesel. Design basis calculation for EDG ventilation, 2005-0054 Control Building GOTHIC Temperature Calculation was prepared to demonstrate the adequacy of the ventilation systems for the rooms housing the G-01 and G-02 in order to maintain an environment of 115o F for post-accident scenarios assuming a maximum outside air temperature of 95o F. The temperature limitation of 115o F was based on the diesel Vendor Technical Manual (VTM 00367) which stated that when the combustion air temperature exceeded 115o F, the diesel must be derated from its design load. Per calculation 2005-0054, the calculated maximum room temperature value inside the EDG rooms during an accident was 113.3o F. Based on this result, the licensee determined that the ventilation system for the EDG rooms were adequate to support the design basis loads of the diesels.
The licensee completed a 10 CFR 50.59 Screening 2009-010 Technical Specification 3.8.1 Bases Changes, to revise the stated allowable room temperature in the G01 and G02 room from 120o F to 115o F. The change was made to be consistent with the design basis calculation and the diesel Vendor Technical Manual.
The inspectors reviewed the Technical Specification Bases 3.8.1 and noted that a specific statement was not considered in the above calculation. Specifically, TS Basis 3.8.1 stated that for G-01 and G-02, three of four fire dampers associated with the diesel room exhaust fans must be open to maintain room temperature. The inspectors were concerned that calculation 2005-0054 was not conservative, in that the air flow measured values used by the calculation were obtained with all dampers open. These measurements were taken per PBTP 157 Diesel Room Exhaust Flow Measurement.
During a walkdown in the G-01 and G-02 rooms, the inspectors also noted that the combustion air intake was close to the un-insulated portion of the exhaust manifold which could have a temperature of 800o F during diesel operation. The inspectors were also concerned that calculation 2005-0054 was again not conservative in that the calculation only addressed the bulk temperature in the rooms and did not account for temperature stratification close to the combustion air intake filter. This may result in an increase of the combustion air temperature for the diesel that may require a decrease of the diesel loading.
On December 4, 2009, the licensee entered this issue into their corrective action program as AR 01162599 TS Bases 3.8.1 not supported by calculation, and AR 01162759 DG Room Temperature Calculation has Low Margin. Following the inspectors identification of these concerns, the licensee revised calculation 2005-0054 using the actual diesel design basis loading, 2820 KW for G-01 and 2818 KW for G-02, which was less than the 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> rating of the diesels (2850 KW). By calculating the temperature using actual loading, the licensee was able to produce more margin when addressing the inspectors concerns. The licensee demonstrated that using the actual design basis loading resulted in an increase of the maximum allowable G-01 and G-02 room temperatures, 118.8o F for G-01 and 119o F for G-02, and thus an increase in the available margin. However, the results of the revised calculation also showed that when assuming both fans running and one of the four fire dampers closed for each diesel as indicated in the TS bases, the maximum predicted temperature of the diesel rooms would increase from the previous calculation. However, even though the results of the new calculation reduced margin due to higher calculated temperatures relative to the previous calculation, margin was still available such that the increased temperature was not enough to affect the operability of the diesels.
The licensee also performed a walkdown in the G-01 room to determine a temperature distribution throughout the room when the EDG and fans were operating. The specific purpose was to determine whether there was a difference between the bulk heatup temperature of the room and the combustion air inlet. Based on several readings that were taken, the licensee determined that although there were variations in the air temperature in the room, there was no evidence of a temperature differential between the bulk air temperature of the ventilation flow and the temperature at the combustion air inlet.
Analysis:
The inspectors determined that the licensees failure to adequately calculate the maximum room temperature for emergency diesel rooms for pos-accident was contrary to the requirements of 10 CFR Part 50, Appendix B, Criterion III and was a performance deficiency. Specifically, the licensee did not ensure that the TS basis and the variation of the air temperature were accounted for when calculating the maximum room temperature for G-01 and G-02. The licensee failed to ensure that the maximum room temperature would not exceed 115o F, which is required to be maintained to ensure that the EDGs will perform their safety function during a design basis accident when the outside air temperature was 95o F.
The finding was determined to be more than minor because the finding was similar to IMC 0612, Appendix E, Example (3.J). Specifically, the errors in the calculation were significant in that although, at the end of the inspection, the licensee was able to demonstrate operability and adequate margin existed; at the time of discovery there was reasonable doubt that the maximum room temperature for G-01 and G-02 would not exceed the value specified in the Vendor Technical Manual which ensure the availability and reliability of the diesel during post design basis accident. The performance deficiency also impacted the Mitigating System cornerstone of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.
The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase 1 -
Initial Screening and Characterization of Findings, Tables 3b and 4a for the Mitigating Systems Cornerstone. The inspectors determined that the finding was of very low safety-significance (Green) because the finding did not involve a design or qualification deficiency there was no actual loss of safety function, no single train loss of safety function for greater than the TS allowed outage time, and no risk due to external events.
The inspectors did not identify a cross-cutting aspect associated with this finding because the finding was not indicative of the licensees current performance. The licensee change to the Technical Specification bases did not require revision to the existed calculation 2005-0054.
Enforcement:
Title 10 CFR Part 50, Appendix B, Criterion III, ADesign Control,@ requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions.
Contrary to the above, on December 2, 2009, the inspectors identified that the licensee failed to assure that the design basis for the emergency diesel generators were correctly translated into instructions. Specifically, the licensees calculation 2005-0054 failed to account for the Technical Specification 3.8.1 requirement related to the numbers of fire dampers associated with G-01 and G-02 exhaust fans that must be opened to maintain room temperature. The date of origination for the TS requirement that led to this violation could not be determined. The calculation also failed to demonstrate that the temperature stratification close to the combustion air intake filter was acceptable. Instead, the licensee only calculated the bulk air temperature in the room. Because this violation was of a very low safety-significance and because it was entered into the licensees corrective action program as AR 01162599 and AR 01162759, this violation is being treated as a Non-Cited Violation (NCV), consistent with Section VI.A.1 of the NRC enforcement policy.
(NCV 05000266/2009007-01; 05000301/2009007-01)
.2 Permanent Plant Modifications
a. Inspection Scope
From November 30, 2009 through December 18, 2009, the inspectors reviewed nine permanent plant modifications that had been installed in the plant during the last three years and two calculations that had been also revised during the last three years. This review included in-plant walkdowns for the Component Cooling Water (CCW) heat exchangers; PAB battery and inverter rooms; façade flood barriers; and EDG-1 and EDG-2 rooms and their associated damper areas. The modifications were selected based upon risk significance, safety-significance, and complexity. The modifications selected also included two modifications that were installed to facilitate the extended power uprate (EPU) project.
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 11 permanent plant modification samples as defined in IP 71111.17-04.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES (OA)
4OA2 Identification and Resolution of Problems
.1 Routine Review of Condition Reports
a. Inspection Scope
From November 30, 2009 through December 18, 2009, the inspectors reviewed 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 pant modifications and evaluations for changes, tests, or experiments issues. 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 of significance were identified.
4OA5 Other Activities
.1 Plant Modifications in Support of Extended Power Uprate (EPU)
a. Inspection Scope
From November 30, 2009 through December 18, 2009, the inspectors reviewed the following completed plant modifications that supported EPU:
- Unit 2 replacement motor driven auxiliary feedwater mechanical tie-ins to the service water and auxiliary feedwater systems. Specifically, the inspectors reviewed a sample of the associated engineering change documentation including the 10 CFR 50.59 screening, design calculations, work orders, engineering change requests, and corrective action requests to assure the installed plant change was consistent with the design and licensing bases. The inspectors also walked down the mechanical tie-ins to the service water and feedwater systems to verify the installed piping configurations were consistent with the design and installation documentation.
- Replacement of motor driven auxiliary feedwater electrical and instrumentations tie-ins modification installed during Unit 2 refueling per EC-13401. The inspectors also walked down changes, installed per EC-13401, to the Unit 2 control room panels with the Seismic Qualification Utility Group (SQUG) engineer.
b. Findings
No findings of significance were identified.
4OA6 Meetings
.1 Exit Meeting Summary
On December 18, 2009, the inspectors presented the inspection results to you, and other members of your staff. The licensee personnel acknowledged the inspection results presented and did not identify any proprietary content. The inspectors confirmed that all proprietary material reviewed during the inspection were returned to the licensee staff.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- L. Meyer, Site Vice President
- J. Costedio, Licensing Manager
- M. Durbin, Training Supervisor
- R. Harrsch, Operations Manager
- V. Kanal, Engineering Supervisor (Electrical)
- K. Locke, Licensing Engineering Analyst
- A. Mitchell, System Engineering Manager
- C. Trsziss, Engineering Director
- S. Ruesch, NOS Manager
- B. Woyak, Design Engineering Supervisor (Mechanical)
- P. Wild, Design Engineering Manager
Nuclear Regulatory Commission
- S. Burton, Senior Resident Inspector
- A. Sanchez, Reactor Inspector (Trainee)
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened and Closed
- 05000266/2009007-01; NCV Errors Found in the Room Ventilation Calculation for G-01
- 05000301/2009007-01 and G-02 (Section 1R17.1.b.(1))
Discussed
None Attachment