ML24331A106
| ML24331A106 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 12/10/2024 |
| From: | Paul Zurawski NRC/RGN-III/DORS/OB |
| To: | Durbin M Point Beach |
| References | |
| EA-24-101 IR 2024012 | |
| Download: ML24331A106 (1) | |
Text
EA-24-101 Michael Durbin Site Vice President NextEra Energy Point Beach, LLC 6610 Nuclear Road Two Rivers, WI 54241-9516
SUBJECT:
POINT BEACH NUCLEAR PLANT - NRC INSPECTION REPORT 05000266/2024012 AND 05000301/2024012 AND NOTICE OF VIOLATION
Dear Michael Durbin:
On November 14, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Point Beach Nuclear Plant and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
Based on the results of this inspection, the NRC has determined that a violation of NRC requirements occurred. Specifically, the violation involved a senior operator failing to maintain their license in an active status by actively performing the functions of a Senior Operator on a minimum of seven 8-hour shifts during a calendar quarter. 10 CFR 55.53(e) requires, in part, that if a licensee has not been actively performing the functions of an operator or senior operator, the licensee may not resume activities authorized by a license issued under this part except as permitted by paragraph (f) of this section. Additionally, 10 CFR 55.53(f), requires in part, if paragraph (e) of this section is not met, before resumption of functions authorized by a license issued under this part, an authorized representative of the facility licensee shall certify the following: (1) that the qualifications and status of the licensee are current and valid; and (2) that the licensee has completed a minimum of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of shift functions under the direction of an operator or senior operator as appropriate and in the position to which the individual will be assigned. The 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> must have included a complete tour of the plant and all shift turnover procedures.
This violation is normally categorized in accordance with the NRC Enforcement Policy at Severity Level III (see section 6.4.c of the NRC Enforcement Policy). However, the staff determined that the significance of this violation was Severity Level IV because the operator
- 1) did not cause consequential errors while standing watch, and 2) complied with all other requirements (e.g., full participation in the bi-annual requalification program and medical requirements were met).
The enclosed report discusses a cited Severity Level IV violation. The NRC evaluated this violation in accordance Section 2.3.2 of the NRC Enforcement Policy, which can be found at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. We determined that this December 10, 2024
M. Durbin 2
violation did not meet the criteria to be treated as a non-cited violation because this is consistent with the requirements contained in Section 2.2.4 of the Enforcement Policy. The NRC has determined that the reason, corrective actions taken and planned to address recurrence, and the date when full compliance was achieved for this violation is adequately addressed and captured on the docket in corrective actions from AR 02461507 dated July 21, 2023. Therefore, you are not required to respond to this letter unless the record does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice.
If you contest the violation or the significance or severity of the violation documented in this inspection report, 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 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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Paul J. Zurawski, Chief Operations Branch Division of Operating Reactor Safety Docket Nos. 05000266 and 05000301 License Nos. DPR-24 and DPR-27
Enclosure:
As stated cc w/ encl: Distribution via LISTSERV Signed by Zurawski, Paul on 12/10/24
SUNSI Review
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available OFFICE RIII OE/EB RIII RIII NAME THenning:gmp GGulla DBetancourt-Roldan PZurawski DATE 12/02/2024 12/05/2024 12/10/2024 12/10/2024 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Numbers:
05000266 and 05000301 License Numbers:
DPR-24 and DPR-27 Report Numbers:
05000266/2024012 and 05000301/2024012 Enterprise Identifier:
I-2024-012-0018 Licensee:
NextEra Energy Point Beach, LLC Facility:
Point Beach Nuclear Plant Location:
Two Rivers, WI Inspection Dates:
September 08, 2024 to November 14, 2024 Inspectors:
P. Gresh, Operations Engineer T. Henning, Senior Operations Engineer G. Roach, Senior Operations Engineer Approved By:
Paul J. Zurawski, Chief Operations Branch Division of Operating Reactor Safety
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SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a NRC inspection at Point Beach Nuclear Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations Senior Operator stood watch as Shift Manager while license not active Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NOV 05000266,05000301/2024012-01 Open EA-24-101 Not Applicable 71111.11B On July 3, 2023, the facility licensee identified a senior Operator that did not maintain watchstanding proficiency during the 2nd quarter of 2023 that assumed the Shift Manager (SM) watch station.
Additional Tracking Items None.
3 INSPECTION SCOPES Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY 71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance Requalification Examination Results (IP Section 03.03) (1 Sample)
(1)
The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam administered from September 2, 2024 to October 4, 2024, and the biennial written examinations completed from September 2, 2024 to October 4, 2024.
71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)
(1)
Biennial Requalification Written Examinations The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered on September 12, 2024.
Annual Requalification Operating Tests The inspectors evaluated the adequacy of the facility licensees annual requalification operating tests administered from August 26, 2024 - September 27, 2024.
Administration of an Annual Requalification Operating Test The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by Title 10 of the Code of Federal Regulations (10 CFR) 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.
Requalification Examination Security The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.
4 Remedial Training and Re-examinations The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.
Operator License Conditions The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.
Control Room Simulator The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.
INSPECTION RESULTS Senior Operator stood watch as Shift Manager while license not active Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NOV 05000266,05000301/2024012-01 Open EA-24-101 Not Applicable 71111.11B On July 3, 2023, the facility licensee identified a senior operator that did not maintain watchstanding proficiency during the 2nd quarter of 2023 that assumed the Shift Manager (SM) watch station.
==
Description:==
At 0605 on July 3, 2023, the individual assumed the SM watch. The individual reviewed their SM qualifications using the Learning Management System (LMS) and verified all items were satisfied. The individual began reviewing Corrective Action products and other administrative duties at that time. At 0720, the individual attempted to enter their name into the official logs using the Electronic Shift Operations Management System (eSOMS), the system denied the log entry. Subsequent investigation by the individual revealed that they did not stand the requisite number of watches in the previous quarter to maintain proficiency (seven 8-hour shifts in 2nd quarter 2023) and that the individuals license was no longer active as of July 1, 2023. The facility licensee did not certify the individual completed the minimum hours on shift prior to resumption of senior operator functions in accordance with 10 CFR 55.53(f).
Once the individual recognized they were not qualified, the Shift Technical Advisor (STA) was called to the Main Control Room (MCR) to temporarily relieve the SM (the STA was verified eligible to stand the SM watch). A replacement SM was called in and assumed the SM watch at 0818.
Corrective Actions: The individual immediately notified the facility, and a relief was found and implemented shortly thereafter. Condition Report 02461507 was generated. The facility now runs eSOMS reports prior to the end of each quarter and notifies any and all licensees if the
5 required watchstanding time has not been completed. The individual successfully completed re-activation on July 13, 2023.
Corrective Action References: Condition Report 02461507 Performance Assessment:
None Enforcement:
The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance.
Severity: This is a Severity Level IV violation. (Enforcement Policy Section 6.4). This violation is normally categorized in accordance with the NRC Enforcement Policy at Severity Level III (see Section 6.4.c of the NRC Enforcement Policy). However, the staff determined that the significance of this violation was Severity Level IV because: (1) the short duration while as SM; (2) no consequential errors while during that time period, and (3) all other requirements were met (e.g., full participation in the bi-annual requalification program).
Violation: 10 CFR Section 55.53(e) requires, in part, if a licensee has not been actively performing the functions of an operator or senior operator, the licensee may not resume activities authorized by a license issued under this part except as permitted by paragraph (f) of this section. To maintain active status, the licensee shall actively perform the functions of an operator or senior operator on a minimum of seven 8-hour or five 12-hour shifts per calendar quarter.
10 CFR Section 55.53(f), states, in part, if paragraph (e) of this section is not met, before resumption of functions authorized by a license issued under this part, an authorized representative of the facility licensee shall certify the following: (1) that the qualifications and status of the licensee are current and valid; and (2) that the licensee has completed a minimum of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of shift functions under the direction of an operator or senior operator as appropriate and in the position to which the individual will be assigned. The 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> must have included a complete tour of the plant and all required shift turnover procedures.
Contrary to the above, on July 3, 2023, the facility licensee failed to certify the senior operator completed a minimum of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of shift functions under the direction of an operator or senior operator as appropriate and in the position to which the individual will be assigned prior to the resumption of functions authorized by the senior operators license and scheduled the senior operator to stand watch as SM when not in an active status. Specifically, the individual licensee failed to maintain an active status by actively performing the functions of a senior operator on a minimum of seven 8-hour shifts during the calendar quarter.
Subsequently, the individual licensee inappropriately assumed the duties of the SM on July 3, 2023, while not maintaining an active license.
Enforcement Action: This violation is being cited because the licensee failed to restore compliance within a reasonable period of time after the violation was identified consistent with Section 2.2.4 of the Enforcement Policy.
6 EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
On September 9, 2024, the inspectors presented the Entrance Meeting inspection results to Sky Bryant - Point Beach Operations Site Director and other members of the licensee staff.
On November 14, 2024, the inspectors presented the Exit Meeting inspection results to Michael Durbin - Site Vice President and other members of the licensee staff.
7 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date AR 2446501 1RE-215 BKGD Value Incorrectly Entered During HPIP 7.51.8 01/22/2023 AR 2447890 Procedure Use Placekeeping 02/09/2023 AR 2454079 Operations Director Escalation on HU 04/11/2023 AR 2466585 Escalation OPS Trend - Incorrectly Recorded Data 09/10/2023 AR 2468845 Incorrect Revision Used 10/06/2023 AR 2478195 1Q24 EP Drill 02/02/2024 AR 2478619 Sections Reperformed During IT09A 02/08/2024 AR 2488956 Isolation Valve Tightened Outside of Process 06/19/2024 AR 2489438 Task Not Assigned to Clearance for Work That Was Performed 06/26/2024 Corrective Action Documents AR 2492378 SM Reactivation Form Missing 08/08/2024 LOR Attendance Report 2022 LOR Attendance Report 2023 LOR Attendance Report 2024 Watchstanding Logs (Third License) 4Q2023 Watchstanding Logs (RO U2) 1Q2024 Watchstanding Logs (RO U2) 2Q24 Watchstanding Logs (SM) 1Q2024 Watchstanding Logs (SRO U1) 2Q2024 Watchstanding Logs (SRO U2) 2Q2023 017E Simulator Evaluation Guide (SEG) 7 023E Simulator Evaluation Guide (SEG) 6 027E Simulator Evaluation Guide (SEG) 6 059e Simulator Evaluation Guide (SEG) 2 2024 AOE Outline Exam Cross Check 08/2024 2024 Exam Item Analysis Exam Cross Check 08/2024 71111.11B Miscellaneous BRE Master 2023-2024 Sample Plan Exam Cross Check 08/2024
8 Inspection Procedure Type Designation Description or Title Revision or Date LMS SM Shift Manager Qualification Curricula Report 09/11/2024 LOR JPM by year Exam Cross Check 08/2024 P000.002E.COT Job Performance Measure (JPM) 1 P000.008a.aot Job Performance Measure (JPM) 2 P000.017C.AOT Job Performance Measure (JPM) 2 P000.027.AOT Job Performance Measure (JPM) 9 P004.029.aot Job Performance Measure (JPM) 8 P006.002.COT Job Performance Measure (JPM) 11 P026.002A.COT Job Performance Measure (JPM) 6 P064.002B.AOT Job Performance Measure (JPM) 1 P064.007B.COT Job Performance Measure (JPM) 4 PBN DTG 94.0, Simulator Performance Test Procedure: Simultaneous Trip of Both Main Feed-water Pumps - Cycle 42 02/01/2024 PBN DTG 94.0, Simulator Performance Test Procedure: Trip of a Single Reactor Coolant Pump - Cycle 42 03/05/2024 PBN DTG 94.0, Simulator Performance Test Procedure: Turbine Trip Below P Cycle 42 02/13/2024 PBN DTG 94.0, Simulator Performance Test Procedure: Maximum Design Load Rejection - Cycle 42 02/19/2024 PBN DTG 94.0, Simulator Performance Test Procedure: 100% Power Steady Performance Test - Cycle 42 03/20/2024 PBN DTG 94.0, Simulator Performance Test Procedure: 75% Power Steady State Test - Cycle 42 03/25/2024 PBN DTG 94.0, Simulator Performance Test Procedure: 49% Power Steady State Performance Test - Cycle 42 03/27/2024 PBN DTG 94.0, Simulator Performance Test Procedure: Manual Reactor Trip
- Cycle 42 01/31/2024 PBN DTG 94.0, Simulator Performance Test Procedure: Simultaneous Trip of Both Reactor Coolant Pumps - Cycle 42 02/06/2024 PBN DTG 94.0, Simulator Performance Test Procedure: Maximum Rate Power Ramp 100% to 75% to 100% - Cycle 42 02/19/2024 PBN DTG 94.0, Simulator Performance Test Procedure: PORV Open Without High Head Safety Injection - Cycle 42 03/05/2024
9 PBN DTG 94.0, Simulator Work Request Test Procedure: Post Event Test -
Load Ramp Test 08/26/2024 PBN SIMGL C1.4 Unit 1 Cycle 42 Core Load Simulator Test 10/26/2023 SEG by Year Exam Cross Check 08/2024 TR-AA-230-1000-F07 Week 3 Comprehensive Biennial SRO Written Examination 09/12/2024 TR-AA-230-1000-F07 Week 3 Biennial Comprehensive RO Exam 09/12/2024 Miscellaneous Training Request 02478446 EP Drill - SM Stumbled Announcement for Alert 02/06/2024 LOR TPD Licensed Operator Continuing Training Program Description 9
OM-1.1 Conduct of Plant Operations (PBNP Specific) 55 OM-3.1 Operations Shift Staffing Requirements 21 OP-AA-100-1000 Conduct of Operations 42 OP-AA-100-1001 License Maintenance and Activation 10 TR-AA-201-1000 Conduct of Training 17 TR-AA-220-1002 NRC Licensed Operator Exam Security 6
TR-AA-220-1004 Licensed Operator Continuing Training Annual Operating and Biennial Written Exams 9
TR-AA-230-1000 Systematic Approach to Training Process 4
TR-AA-230-1007 Conduct of Simulator Training and Evaluation 18 TR-AA-230-1008 Simulator Scenario Based Testing and Validation 4
Procedures TR-AA-230-1009 Training Examination Security 7
Self-Assessments L2A 02492799 2024 Pre-NRC 71111.11 Pre-Inspection Self-Assessment 07/2024 SWR 02476668 Turbine First Out Alarm 02/26/2024 SWR 02476761 Simulator Set to Inactive During Scenario 02/28/2024 SWR 02476920 Power Supply for the 1(2)P-53 MDAFW Pump Low Suction Pressure Was Incorrect 02/26/2024 SWR 02478546 Charging Pump Speed Control Alarm Logic 02/28/2024 SWR 02480652 Turbine Lube Oil Modeling 04/01/2024 71111.11B Work Orders SWR 2460062 Simulator Modification: Replace Yokogawa Main Feed-water Regulating Valve Controllers 07/08/2024
10 71111.11B Work Orders SWR 2474620 Model 1P-1A Reactor Coolant Pump Labyrinth Seal Differential Pressure 02/27/2024 NOTICE OF VIOLATION NextEra Energy Point Beach, LLC Docket Nos.: 05000266 and 05000301 Point Beach License Nos.: DPR-24 and DPR-27 EA-24-101 Consistent with the NRC Enforcement Policy and Title 10 of the Code of Federal Regulations (10 CFR) Part 2.201, the following violation identified in inspection report 2024012 is being cited:
10 CFR Section 55.53(e) requires, in part, if a licensee has not been actively performing the functions of an operator or senior operator, the licensee may not resume activities authorized by a license issued under this part except as permitted by paragraph (f) of this section. To maintain active status, the licensee shall actively perform the functions of an operator or senior operator on a minimum of seven 8-hour or five 12-hour shifts per calendar quarter.
10 CFR Section 55.53(f), states, in part, if paragraph (e) of this section is not met, before resumption of functions authorized by a license issued under this part, an authorized representative of the facility licensee shall certify the following: (1) that the qualifications and status of the licensee are current and valid; and (2) that the licensee has completed a minimum of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of shift functions under the direction of an operator or senior operator as appropriate and in the position to which the individual will be assigned. The 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> must have included a complete tour of the plant and all required shift turnover procedures.
Contrary to the above, on July 3, 2023, the facility licensee failed to certify the senior operator completed a minimum of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of shift functions under the direction of an operator or senior operator as appropriate and in the position to which the individual will be assigned prior to the resumption of functions authorized by the senior operators license and scheduled the senior operator to stand watch as Shift Manager when not in an active status. Specifically, the individual licensee failed to maintain an active status by actively performing the functions of a senior operator on a minimum of seven 8-hour shifts during the calendar quarter. Subsequently, the individual licensee inappropriately assumed the duties of the Shift Manager on July 3, 2023, while not maintaining an active license.
This is a Severity Level IV violation.
Consistent with 10 CFR 19.11, you are required to post this Notice of Violation within two working days of receipt.
Replying to Notice of Violation This violation is normally categorized in accordance with the NRC Enforcement Policy at Severity Level III (see section 6.4.c of the NRC Enforcement Policy). However, the staff determined that the significance of this violation was Severity Level IV because the operator
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- 1) did not cause consequential errors while standing watch, and 2) complied with all other requirements (e.g., full participation in the bi-annual requalification program and medical requirements were met).
The enclosed report discusses a cited Severity Level IV violation. The NRC evaluated this violation in accordance Section 2.3.2 of the NRC Enforcement Policy, which can be found at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. We determined that this violation did not meet the criteria to be treated as a non-cited violation because this is consistent with the requirements contained in Section 2.2.4 of the Enforcement Policy. The NRC has determined that the reason, corrective actions taken and planned to address recurrence, and the date when full compliance was achieved for this violation is adequately addressed and captured on the docket in corrective actions from AR 02461507 dated July 21, 2023. Therefore, you are not required to respond to this letter unless the record does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice If you contest this enforcement action, please provide an additional copy of your response, with your basis for denial, to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.
Dated this 10th day of December 2024.