IR 05000266/2021010
| ML21182A131 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 07/01/2021 |
| From: | Richard Skokowski Division of Reactor Safety III |
| To: | Strope M Point Beach |
| References | |
| IR 2021010 | |
| Download: ML21182A131 (11) | |
Text
July 1, 2021
SUBJECT:
POINT BEACH NUCLEAR PLANT - TRIENNIAL INSPECTION OF EVALUATION OF CHANGES, TESTS AND EXPERIMENTS BASELINE INSPECTION REPORT 05000266/2021010 AND 05000301/2021010
Dear Mr. Strope:
On May 21, 2021, 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.
No findings or violations of more than minor significance were identified during this inspection.
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,
/RA/
Richard A. Skokowski, Chief Engineering Branch 3 Division of Reactor Safety Docket Nos. 05000266 and 05000301 License Nos. DPR-24 and DPR-27
Enclosure:
As stated
Inspection Report
Docket Numbers: 05000266 and 05000301 License Numbers: DPR-24 and DPR-27 Report Numbers: 05000266/2021010 and 05000301/2021010 Enterprise Identifier: I-2021-010-0049 Licensee: NextEra Energy Point Beach, LLC Facility: Point Beach Nuclear Plant Location: Two Rivers, WI Inspection Dates: May 17, 2021 to May 21, 2021 Inspectors: K. Barclay, Reactor Inspector J. Bozga, Senior Reactor Inspector J. Neurauter, Senior Reactor Inspector Approved By: Richard A. Skokowski, Chief Engineering Branch 3 Division of Reactor Safety Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a triennial inspection of evaluation of changes, tests and experiments baseline 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
No findings or violations of more than minor significance were identified.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000266, Containment Air 71111.17T Open 05000301/2021010-01 Recirculation System Design Function Change
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.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), inspectors were directed to begin telework. In addition, regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
71111.17T - Evaluations of Changes, Tests, and Experiments Sample Selection (IP Section 02.01)
The inspectors reviewed the following evaluations, screenings, and/or applicability determinations for 10 CFR 50.59 from September 2018.
- (1) 50.59 Evaluation 2020-002, Extend Surveillance Intervals for Independent Overspeed Protection System (IOPS), Cross-Over Steam Dumps, Turbine Over-Speed Trip Device, and Turbine Trip and Stop Valves
- (2) 50.59 Screening 2018-0159, Revise AOP-9A Step 16.b to Secure Containment Cooling Fans
- (3) 50.59 Screening 2019-0006, 1P-2C Charging Pump Suction Pressure Indicator Throttled
- (4) 50.59 Screening 2019-0067, Raise Flooding High Lake Level Trigger Points
- (5) 50.59 Screening 2019-0094, Install Duplex Strainers in Service Water Supply Lines to the Three Service Water Cooled Air Compressors (K-2A, K-2B, K-3B)
- (6) 50.59 Screening 2019-0120, HV-487, VNDRM-4512 Temperature Control Valve Outlet Isolation Abnormally Aligned Shut
- (7) 50.59 Screening 2019-0121, HV-606, HX-83A, EL 8, PAB Fan Room Unit Heater Steam Inlet Abnormally Aligned Shut
- (9) 50.59 Screening 2020-0033, 2MS-5501A Packing Leak Sealant Injection
- (10) 50.59 Screening 2020-0035, Isolation of Unit 1 Accident Fan(s) Dependent on Service Water Leakage Detection
- (11) 50.59 Applicability Determination, EC 294090: Final Safety Analysis Report (FSAR)
Update to Sections 7.2.3.5 and 9.8.1 to Clarify Temperature
- (12) 50.59 Applicability Determination, EC 295543: FSAR Table A.5-3
- (13) 50.59 Applicability Determination, EC 295893; Revise Updated Final Safety Analysis Report (UFSAR) Section 5.6 and Appendix A.5 to Incorporate License Amendment 263 (Unit 1) and 266 (Unit 2) Containment Dome Truss
- (14) 50.59 Screening 2018-0173, Post-Outage Containment Closeout Inspection Unit 1 & 2 (CL-20, CL-20A)
- (15) 50.59 Screening 2018-0181, EC 292393: Generic Seismic II/I Ladder Storage Bracket (Drawing C-375)
- (16) 50.59 Screening 2018-0201, LR-AMP-021-OCCW, Open Cycle Cooling (Service)
Water - Revision 9
- (17) 50.59 Screening 2019-0093, EC 293591 (Service Water) SW Leak Pipe Patch TCC Downstream of SW-371
- (19) 50.59 Screening 2020-019, Leaving Rigging Links in Containment During Power Operations
- (20) 50.59 Screening 2020-0056, NP 7.7.14 Rev 13, Reactor Vessel Integrity Program
- (21) 50.59 Screening 2019-0089, Radiologic Shielding Improvements U1 and U2 Containment
- (22) 50.59 Applicability Determination, EC 294464 Revise FSAR 7.5 for Simplification of (Leading Edge Flow Meter) LEFM
- (23) 50.59 Screening 2020-0052, 0-SOP-DC-001, 0-SOP-DC-002, 0-SOP-DC-003, 0-SOP-DC-004 and 0-SOP-DC-005 125 VDC System and Components
- (24) 50.59 Screening 2018-0157, Provide Additional Containment Cooling Using 1/2SW-2907 or 1/2SW-2908, Hx-15A - D Cont Recirc (Heat Exchanger) HX Emergency (Flow Control Valve) FCV
- (25) 50.59 Screening 2019-0047, 1(2)P-53 (Motor-Driven Auxiliary Feed Water) MDAFW Pump Seal Leakage Temporary Alternate Drains Through HV-540 Condensate Return
- (26) 50.59 Screening 2020-0003, Revise Safety Classification for 1(2)A-01 and 1(2)A-02 Undervoltage and Underfrequency Circuits
- (27) 50.59 Screening 2019-0023, U1R38 - Temp Power to H-08 & H-09
- (28) 50.59 Screening 2019-0064, PBTP 268 - Unit 1 Online Verification of Real and Reactive Power Capability for (North American Electric Reliability Corporation) NERC Standard Mod-025-2
- (29) 50.59 Screening 2020-0057, Abnormal Alignment - 1WL-1728 Aligned Open
INSPECTION RESULTS
Unresolved Item Containment Air Recirculation System Design Function 71111.17T (Open) Change URI 05000266,05000301/2021010-01
Description:
The inspectors reviewed 10 CFR 50.59 Screening 2018-0157, Provide Additional Containment Cooling Using 1/2SW-2907 or 1/2SW-2908, HX-15A-D Cont Recirc HX Emergency FCV, dated August 27, 2018, which evaluated a change to an operating procedure for the containment air recirculation system associated with the alignment of the containment air recirculation system to provide additional containment cooling during normal operations.
The design basis of the Service Water (SW) system is to provide sufficient flow to support the heat removal requirements of components required to mitigate the consequences of a Loss of Coolant Accident (LOCA) in one unit, while supporting the normal flow of the unaffected unit.
Under the conditions of a LOCA and concurrent Loss-of-Offsite Power (LOOP), any three SW pumps are capable of providing the necessary cooling capacity for the essential loads for the affected unit and supply SW for the normal operation of the unaffected unit. When a Safety Injection (SI) signal is present, the containment cooler outlet valves (1/2SW-2907 and 1/2SW-2908) open, non-essential SW load valves close, and all six SW pumps receive start signals on a timed sequence.
The containment air coolers are aligned for emergency cooling by opening one of the containment cooler outlet valves (1/2SW-2907 or 1/2SW-2908) that bypasses the normal flow restricting orifice in the system. The increased SW flow causes an increase in the air cooler capacity to approximately 19 times the normal cooling rate. However, because of SW capacity limitations, opening the containment cooler outlet valves for the containment coolers places the opposite unit in a SW Technical Specification (TS) Action Condition. The SW system flow capacity is not adequate to support emergency containment cooling on one unit, during normal operations, and the SW requirements for a design basis accident with an assumed single failure on the opposite unit.
10 CFR 50.59 Screening 2018-0157 concluded that the change did not adversely affect the SW system design function. However, the inspectors identified that the 10 CFR 50.59 Screening SCR 2018-0157, stated, in part, In this condition, the overall reliability is reduced because a single failure could result in a system configuration which could not assure adequate flow to required equipment.
Licensee procedure, EN-AA-203-1201, 10 CFR Applicability and 10 CFR 50.59 Screening Reviews, Revision 21, Section 4.5 10 CFR 50.59 Screening, Step 11 stated, in part, It is necessary and expected that NEI 96-07, Revision 1, including Appendix E, and NEI 01-01, Revision 1 be consulted when performing the regulatory reviews governed by this procedure.
These industry guidance documents elaborate on the specific screening questions and provides a description of the intent of each question and expected level of response. Refer to Section 4.2 of NEI 96-07, Revision 1 for the guidance applicable to performing a 10 CFR 50.59 screen.
NEI 96-07, Guidelines for 10 CFR 50.59 Evaluations, Revision 1, are acceptable to the NRC staff for complying with the provisions of 10 CFR 50.59. Title 10 CFR 50.59(a)(1) defines, in part, a change as a modification or addition to, or removal from, the facility that affects a design function or an evaluation that demonstrates that the intended function will be accomplished. Section 3.3 of NEI 96-07, in part, defines a change as a modification or addition to, or removal from, the facility or procedures that affects an evaluation that demonstrates that intended functions will be accomplished.
In addition, Section 4.2.1, Is the Activity a Change to the Facility or Procedures as Described in the UFSAR?, of NEI 96-07 provides the following guidance: Changes are screened in (i.e., require a 10 CFR 50.59 evaluation) if they adversely affect an SSC design function. A change that decreases the reliability of an SSC design function, including either functions whose failure would initiate a transient/ accident or functions that are relied upon for mitigation would be considered to adversely affect a design function and would screen in.
Hence, the decrease in the reliability of the SW system design function would require a 10 CFR 50.59 evaluation.
This unresolved item is being opened to determine if a violation of NRC requirements exists.
Planned Closure Actions: The inspectors need to review the licensees completed 50.59 evaluation to determine if a finding or a violation of NRC requirements exists, including the requirements found in 10 CFR 50.59 paragraphs (c)(1) or (d)(1).
Licensee Actions: Reassess screening SCR 2018-0157 to address the change activity, and if adverse, address the change as a 50.59 evaluation.
Corrective Action References: AR 2393904: 2021 NRC 50.59 INSP. SCR 2018-0157 AR 2393903: 2021 Potential Containment Temperature Discrepancy
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On May 21, 2021, the inspectors presented the triennial inspection of evaluation of changes, tests and experiments baseline inspection results to Mr. M. Strope, Site Vice President and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.17T Calculations 129187-M-0022 Verification of Adequacy of Containment Fan Cooler Units 1
during Normal Operations under Extended Power Uprate
(EPU) Conditions
Corrective Action 2295255 EC 292506 Repair of 1CW-3502 Needs a Screening or 12/19/2018
Documents Evaluation
2302879 P-53 Packing Leakage System Installed without a TCC 02/21/2019
2305891 Missed Required Procedure Reviews 03/15/2019
23666 50.59 Screening on Scaffolds Up Over 90 Days 08/07/2019
29686 Revise 20 CFR 50.59 Screening 2019-001 09/30/2019
2337234 Safety Classification Discrepancy 12/03/2019
2337968 Incomplete Bases Documentation for EOP Changes 12/11/2019
2338267 EOPs Revised without Sufficient Applicability and Screening 12/13/2019
2340361 50.59 Screening on Scaffolds Up Over 90 Days 01/08/2020
2341458 LIA Assessment: PCRs Inadvertently Missed Reviews 01/16/2020
2351425 2MS-5501A Packing Leak 04/05/2020
2361666 Abnormal Alignment: 1WL-1728 07/02/2020
2387160 Scaffold 1942 Documented as Removed by Remains in 03/17/2021
Place
Corrective Action 2393718 2021 NRC 50.59 INSP. SCR 2018-0157 05/19/2021
Documents 2393817 2021 50.59 Inspection - Unable to Locate Design Documents 05/20/2021
Resulting from 2393832 2021 NRC 50.59 INSP., EC 295629, Acoustic Emission 05/20/2021
Inspection Testing
2393903 2021 NRC 50.59 INSPEC., Potential Ctmt. Temp. 05/20/2021
Discrepancy
2393904 2021 NRC 50.59 INSP. SCR 2018-0157 05/20/2021
Drawings 499B466 Sheet Elementary Wiring Diagram 4160V Switchgear 1A01 CUB-3 22
2 Incoming Line 1A03-PT/1A01
499B466 Sheet Elementary Wiring Diagram 4160V Switchgear, CUB.16 Bus 19
499B466 Sheet Elementary Wiring Diagram 4160V Switchgear 2A01, 20
207 CUB. 18 Bus Tie from 2A-03 At 2A52-44
499B466 Sheet Elementary Wiring Diagram 2A02 Bus Tie 2A52-48 to Bus 21
Inspection Type Designation Description or Title Revision or
Procedure Date
209 2A-04 2A00-34
E-11 Sheet 2 Schematic Meter & Relay Diagram 4160V Auxiliary System 12
E-2011 Sheet 1 Schematic Meter & Relay Diagram 4160V Auxiliary System 09
E-2011 Sheet 2 Schematic Diagram Meter & Relay Diagram 4160V Auxiliary 13
System
E-2011 Sheet 3 Schematic Meter & Relay Diagram 4160V Auxiliary System 13
E-2011 Sheet 4 Three Line Diagram EDG G-04 4160V Bus 2-A06 Relay & 12
Metering
Engineering 291748 Install Duplex Strainers in Service Water Supply Lines to the 5
Changes Three Service Water Cooled Air Compressors (K-2A, K-2B,
K-3B)
293515 Radiologic Shielding Improvements U1 and U2 Containment 5
294090 FSAR Update to Sections 7.2.3.5 and 9.8.1 to Clarify 1
Temperature
294316 2CV-290, 2P-2C Discharge Valve Stem Gag 0
294621 Installation of Leak Injection Sealant for Packing of 0
294916 Chapter 14.1.12 Update with New Turbine Overspeed 0
Calculation
295629 Use of Acoustic Emission Technology as an Alternate 01/20/2021
Method for NDE of Special Lifting Devices EE 2020-0020
Engineering EE 2020-0020 Use of Acoustic Emission Technology as an Alternate 0
Evaluations Method for NDE of Special Lifting Devices
Miscellaneous Unit 2 Circulating Water - Service Water Temperatures 08/18-
2/2018
Units 1 & 2; Containment Temperatures 08/18-
2/2018
Unit 2; Graph of Containment Air and Circulating Water 08/18-
Temperatures 22/2018
EC-UCR 294090 UFSAR Change Request: FSAR Update to Sections 7.2.3.5 0
AND 9.8.1 to Clarify Temperature
PCR 2269200 Procedure Change Request: Revise AOP-9A 06/20/2018
PCR 2319200 Procedure Change Request: PBF-2124a - Average 06/25/2019
Converted Lake Level
Inspection Type Designation Description or Title Revision or
Procedure Date
PCR 2319202 Procedure Change Request: AOP-13C - Severe Weather 06/25/2019
Conditions
PCR 2355135 Procedure Change Request: Change TRM, TSR 3.7.6.1, .2, 04/30/2020
.3, .4 Surveillance Intervals
Procedures 1-SOP-4KV-001 4KV System Operation Unit 1 10
AOP-0.0 Abnormal Operating Procedure: Vital DC Malfunction 37
AOP-40D Abnormal Operating Procedure: Response to Fire in PAB 26 4
FT North of Monitor Tanks
EN-AA-203-1100 Engineering Evaluations 13
EN-AA-203-1102 Safety Classification Determination 7
EN-AA-203-1201 10 CFR Applicability and 10 CFR 50.59 Screening Reviews 21
EN-AA-203-1202 10 CFR 50.59 Evaluation 3
EN-AA-205-1100 Design Change Packages 31
EN-AA-205-1102 Temporary Configuration Changes 17
LI-AA-101-1003 Updated Final Safety Analysis Report (UFSAR) Revision 11
NP 7.2.30 Quality-Basis Values and Quality Group Codes 2
OI 72 Containment Air Recirculation System 18
OP 2B 345 KV Transmission System Impacts Upon PBNP Station 19
Operations
PBTP 268 Unit 1 Online Verification of Real and Reactive Power 0
Capability for NERC Standard MOD-025-2
RMP 9359-5C D-305 Station Battery, D-09 Battery Charger Maintenance 23
and Surveillances
RMP 9359-6C D-305 Station Battery, D-109 Battery Charger Maintenance 20
and Surveillances
TS 33 Containment Accident Recirculation Fan-Cooler Units Unit 1 42
Work Orders WO 40713603 07 OPS WP 2020-016: 1HX-15C, Containment Accident 04/27/2020
Recirculation Heat Exchanger Isolation
9