IR 05000266/2022010

Design Basis Assurance Inspection (Programs) Inspection Report 05000266/2022010 and 05000301/2022010

ML22040A062
Person / Time
Site:	Point Beach
Issue date:	02/09/2022
From:	Karla Stoedter NRC/RGN-III/DRS/EB2
To:	Strope M Point Beach
References
IR 2022010
Download: ML22040A062 (13)

Text

SUBJECT:

POINT BEACH NUCLEAR PLANT - DESIGN BASIS ASSURANCE INSPECTION (PROGRAMS) INSPECTION REPORT 05000266/2022010 AND 05000301/2022010

Dear Mr. Strope:

On February 3, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Point Beach Nuclear Plant and discussed the results of this inspection with Mr. M. Holzmann, Site Operations Director 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, Karla K. Stoedter, Chief Engineering Branch 2 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:

05000266/2022010 and 05000301/2022010

Enterprise Identifier:

I-2022-010-0017

Licensee:

Nextera Energy Point Beach, LLC

Facility:

Point Beach Nuclear Plant

Location:

Two Rivers, WI

Inspection Dates:

January 10, 2022 to February 03, 2022

Inspectors:

K. Barclay, Reactor Inspector

J. Benjamin, Senior Reactor Inspector

B. Jose, Senior Reactor Inspector

Approved By:

Karla K. Stoedter, Chief

Engineering Branch 2

Division of Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a design basis assurance inspection (programs) 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 05000266,05000301/

2022010-01 Potential Inadequate Basis/Justification for Motor-Operated Valve Rate-of-Loading Assumptions 71111.21N.02 Open

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

71111.21N.02 - Design-Basis Capability of Power-Operated Valves Under 10 CFR 50.55a Requirements POV Review (IP Section 03)

The inspectors:

a.

Determined whether the sampled power operated valves (POVs) are being tested and maintained in accordance with NRC regulations along with the licensees commitments and/or licensing bases.

b.

Determined whether the sampled POVs are capable of performing their design-basis functions.

c.

Determined whether testing of the sampled POVs is adequate to demonstrate the capability of the POVs to perform their safety functions under design-basis conditions.

d.

Evaluated maintenance activities including a walkdown of the sampled POVs (if accessible).

(1)1SI-00866B; Safety Injection (SI) Pump 1P-15 Discharge to Reactor Coolant System (RCS) Cold Leg Motor Operated Valve (MOV)

(2)1SI-00851A; Residual Heat Removal (RHR) Pump P-10A Suction from Containment Sump B MOV (3)2SI-00850A; Unit 2 RHR Pump 10A Suction from Containment Sump B Hydraulically Operated Valve (HOV)

(4)2AF-04002; Turbine Driven Auxiliary Feedwater (TDAFW) Pump 2P-29 Recirculation Flow Control Air Operated Valve (AOV)

(5)1AF-04000; AFW Pump 1P-29 Discharge to Steam Generator 1B, Heat Exchanger Inlet Isolation MOV (6)2RC-00430; T-1 Pressurizer Power Operated Relief AOV (7)2SI-00860A; Unit 2 Containment Spray Pump P-14A Discharge MOV (8)2SI-00852B; Unit 2 Low Head SI Core Deluge Isolation MOV

INSPECTION RESULTS

Unresolved Item (Open)

Potential Inadequate Basis/Justification for Motor-Operated Valve Rate-of-Loading Assumptions URI 05000266,05000301/2022010-01 71111.21 N.02

Description:

During the inspection of MOV 1AF-4000, a discharge valve associated with the 1P-29 turbine-driven auxiliary feedwater pump, an Unresolved Item was identified.

During the review of calculation 2003-0014, MOV Operating Parameters, the inspectors found the rate of loading (ROL) value assigned to valve 1AF-4000 was zero. The inspectors questioned the low ROL value and reviewed the supporting reference, licensee internal correspondence PBM 92-1200, "Rate of Loading/Stem-To-Stem Nut Coefficient of Friction, dated October 7, 1992. The inspectors and NRC MOV subject matter experts from the Office of Nuclear Reactor Regulation found the licensees methodology for incorporating the ROL effects into their MOV program was not consistent with existing industry methods.

A review of correspondence between the NRC and the licensee found that the Agencys concern with ensuring proper validation of the ROL methodology dated back to the inspection and closeout of NRC Generic Letter (GL) 89-10, Safety-Related Motor-Operated Valve Testing and Surveillance, and GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves.

NRC Inspection Report 50-266/95007 (DRS); 50-301/95007 (DRS), dated July 13, 1995, which inspected the licensees response to GL 89-10, stated, The licensee developed a method to predict the effects of rate of loading for valves without a dynamic test; however, in-plant test data was inconclusive to fully support the method. Based on dp [differential pressure] test results, the method used plots taken during static testing which correlated torque from the stem thrust versus spring pack deflection. The inspectors encouraged the licensee to continue their research but were concerned with the inconclusive data from the valves that had been tested and the lack of data used to verify the method. The licensee committed to continue to compile data from periodic verification tests, both static and dynamic, to validate the rate of loading assumptions and prediction methodology.

On March 17, 1997, the licensee submitted a letter titled, "Response to NRC Generic Letter 96-05 Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves," to the NRC. This letter stated, in part, NRC Inspection Reports 50-266/95007 (DRS) and 50-301/95007 (DRS), dated July 13,1995, document our commitments in response to the GL 89-10 closeout inspection items. As documented in this report, the following commitments were made and will be completed within five years of that inspection report:, 3. We will collect and trend further static and dynamic periodic results to validate the valve factor study and rate of loading assumptions and prediction methodology.

NRC Inspection Reports 50-266/99012 (DRS) and 50-301/99012 (DRS), dated July 14, 1999, which inspected the licensees response to GL 96-05, stated, The inspectors reviewed the status of the long-term MOV actions planned following completion of GL 89-10 close-out inspection. In particular, the licensee had not completed the overall review of the assumptions for valve factor and load sensitive behavior because of the limited progress made in performing dynamic testing as part of the long-term MOV program. The report stated further, With respect to the long-term GL 89-10 issues, the licensee had not adhered to its efforts to implement planned dynamic tests, to perform an overall evaluation of program assumptions for valve factor or load sensitive behavior, or to perform qualitative and quantitative trending of MOV performance.

The inspectors requested the information and data used to validate the ROL assumptions and prediction methodology. The licensee found historical MOV program trend reports that stated there were no valves identified that exhibited rate-of-loading effects; however, the licensee was unable to locate formal documentation detailing the methods used to make these determinations or details of the test data evaluations that validated the rate-of-loading assumptions and predication methodology.

Planned Closure Actions: The inspectors need to review the data, methodology and results of the licensee's rate-of-loading study to determine if assigning a ROL value of zero is appropriate and whether a performance deficiency exists.

Licensee Actions: The licensee entered the issue into their Corrective Action Program (CAP)and created an initial corrective action to perform a Rate-of-Loading (ROL) study to document the basis for the ROL assumptions in calculation 2003-0014. Additionally, the licensee applied an MOV margin penalty to support a reasonable assurance of operability while the ROL study is being performed.

Corrective Action References: AR 2417688; 2022 POV Inspection - Calc 2003-0014 RE.

MOV Rate of Loading

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On February 3, 2022, the inspectors presented the design basis assurance inspection (programs) inspection results to Mr. M. Holzmann, Site Operations Director and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

01109-C-005

Auxiliary Feedwater (AFW) Air Operated Valve (AOV)

Functional and Maximum Expected Differential Pressure

(MEDP) Calculation

01109-C-018

AOV Component Level Calculation; 0AF-04007,

0AF-04014, 1AF-04002, and 2AF-04002

2001-0056

Turbine Driven Auxiliary Feedwater Pump (TDAFP)

Mini-Recirculation Valve (1/2AF-4002) Instrument Air

Accumulator Sizing

2003-0014

Motor Operated Valve (MOV) Operating Parameters,

Group 15

2004-0002

Alternating Current (AC) Electrical System Analysis

97-0041

Functional Times for Emergency Safeguards Equipment to

Be Used in Point Beach Accident Analysis

N-93-086

(2) AF-4000, AF-4001 (Group 30) MOV Differential

Pressure Calculation

& 0A

N-94-019

Determination of Conditions for MOV Pressure Locking

and Thermal Binding

04/13/1994

P-89-031

Voltage Drop Across MOV Power Lines

P-90-017

MOV Undervoltage Stem Thrust and Torque

P-94-004

MOV Thermal Overload Evaluation

P-94-004; EC 294777 Pending

Change A

MOV Overload Heater Evaluation

P-94-005

Motor Stem Thrust Calculation

Calculations

Powell 01-12-

1988

Maximum Thrust Calculations - Point Beach Nuclear Plant

(Wisconsin Electric)

01/12/1988

Corrective Action

Documents

AR 2231511

1SI866B Overthrust Event

11/17/2017

AR 2416029

Alarm Response Book (ARB) for 2RC-0430, Low

Temperature Over Pressure (LTOP) Defined Incorrectly

01/13/2022

71111.21N.02

Corrective Action

Documents

Resulting from

Inspection

AR 2416280

Calculation P-94-005, Use of Torque Reaction Factor

Inversed

01/17/2022

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

AR 2416353

1SI-866B 2017 as Left Test Review, as Left Close Thrust

Below Minimum Required and No Evaluation Performed

01/18/2022

AR 2416888

The Work Plan for Work Order 4072625-03 Step 5 Directs

Performer to Circle the PMT Done of Two Listed and None

Circled

01/24/2022

AR 2416904

Work Order Documentation for 1AF-04000; RMP9376-2

for 03/09/2010 Recorded 180 Foot Pounds for Mounting

Bolts Instead of 88 Foot Pounds

01/24/2022

AR 2416916

MOV Design Basis Review of Valve Family 30 Shows

Medium Risk Vs. Actual Low Risk

01/24/2022

AR 2416967

Drawing Discrepancy; Stem Speed for 1/2AF-04000

Shown as 4.21 Inches/Minute Vs 7.375 Inches/Minute

01/252022

AR 2416984

Training Work Request Written Against Operations

Procedure OM 3.20 to Remind Operators that 24 Demand

Valves Have No Seal-In Contacts, Therefore Hold the

Control Switch until Full Open/Close

01/25/2022

AR 2416997

Model Number for New Solenoid 2AF-4002-S Not

Updated in Component Database

01/25/2022

AR 2417022

Criterion Error in MOV Test Software

01/25/2022

AR 2417028

Air Operated Valve (AOV) Trending Spread Sheet Error,

Close Thrust for AOV 2AF-04002 Listed as 4180 Pounds

Vs 4039 Pounds

01/25/2022

AR 2417137

Validate 2AF-04002 Spring Parameters

01/26/2022

AR 2417139

No Evaluation for 2011 and 2017 AOV Test Spring Rate

Found Below Acceptance Criteria

01/26/2022

AR 2417419

Documentation Provided to NRC in Request for

Information 1.17 for 1AF-4000 Was Medium Risk Vs

Actual Low Risk

01/28/2022

AR 2417688

22 Power Operated Valve (POV) Inspection, Calculation

2003-0014 MOV Rate of Loading

2/01/2022

499B466 Sheet

1801

Elementary Wiring Diagram Turbine Driven Auxiliary

Feedwater Pump Discharge 1AF-4000

Drawings

499B466 Sheet

868

Elementary Wiring Diagram Steam to TDAFP 2MS2020

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

499B466 Sheet

869

Elementary Wiring Diagram Turbine Driven Auxiliary

Feedwater Pump Mini Recirculation Control Valve

2AF-4002

M-217 Sheet 1

Piping & Instrumentation Diagram (P&ID) Auxiliary

Feedwater System

107

WM Powell

Sheet 035115

FIG 19051WE 3" - 900 Pound "Y" Globe Valve

2/26/1968

EC 11683

Modification for Flow Control to Prevent Residual Heat

Removal (RHR) Pump Excessive Flow with Containment

Spray Aligned during Recirculation Phase

Engineering

Changes

EC 292094

Replace 1(2) DPIS-4002, DPIS-4007, DPIS-4014

Differential Pressure Indicator Switches

EQCK-LIMIT-001

Environmental Qualification (EQ) Assessment of

Limitorque SMB Valve Actuators with H/RH Motor

Insulation

Engineering

Evaluations

PE 433789

Item Equivalency Evaluation; ASCO Valve Part Number

NPEF8300141EF

AOV Margin Review Worksheet; 2AF-04002; Last Valve

Test Data: March 31, 2017

& 1

NRC Request for Information 1.17: Point Beach Power

Operated Valve (POV) Data Submittal

01108-TR-003

Nuclear Management Company Air Operated Valve

Program Calculation Guideline

AR 1901191

Operating Experience Evaluation Form; NRC Information Notice 2013-14: Potential Design Deficiency in

Motor-Operated Valve Control Circuitry

10/11/2013

Group 30

AF-4000

Individual MOV Periodic Verification Report

06/06/2007

IST Appendix B

Inservice Testing Program Valve Relief Requests

IST Appendix F

Inservice Testing Program Technical Positions

IST Program

Document

Point Beach Nuclear Plant (PBNP) Inservice Testing

Program 5th Interval

Miscellaneous

IST Program

Table - AF

Inservice Testing Program Table - AF

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

NRC-92-085

Letter from Wisconsin Electric Power Company to U.S.

NRC; Dockets 50-266 and 50-301 In-Service Testing

Pump and Valve Program Third 10-Year Program Safety

Evaluation Report Point Beach Nuclear Plant, Units 1 and

07/30/1992

PBM 92-1200

Rate of Loading / Stem-To-Stem Nut Coefficient of Friction

Evaluation

10/07/1992

Specification

6118-M-91

Motor Operated Valves

2-PT-AF-3

2P-29 Turbine-Driven AFW Pump Backup Air System

Pressure Decay Test (Refueling) Unit 2

ARB 2C042C4-

ARB, 2RC-0430 or 0431C Pressurizer Power Operated

Relief Valve (PORV) Not Shut

CMP 2.2

Motor Operated Valves

CMP 2.2.1

Determination of the Set-Up Parameters for Motor

Operators

CMP 2.2.16

Joint Owners Group (JOG) Periodic Verification (PV)

Classification

CMP 2.2.2

Design Basis Review of Valves Driven by Motor Operators

CMP 2.2.6

Analysis of Test Signatures Taken during Differential

Pressure (DP) Test

CMP 2.2.8.18

MOV Design Basis Review for Valve Family 18

CMP 2.2.8.30

MOV Design Basis Review for Valve Family 30

CMP 2.2.9

MOV Overthrust/Overtorque Review Guidance

CMP 2.5

Point Beach Nuclear Plant AOV Program Document

CMP 2.5.1

Point Beach AOV Scoping Methodology

CMP 2.5.2

Setup Parameters for Air Operated Valves

CMP 2.5.2.1

Setup Parameters for Category 1 Air Operated Valves

EC 13398

Repower Valves for TDAFW PUMP 1P-29

ER-AA-100

Air Operated Valve Program

ER-AA-100-1000

Air Operated Valve Program Implementation

ER-AA-100-1001

AOV Design Basis Review

ER-AA-103

In-Service Test (IST) Program

Procedures

IT 08A

Cold Start of Turbine-Driven Auxiliary Feedwater Pump

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

and Valve Test (Quarterly) Unit 1

IT 09A

Cold Start of Turbine-Driven Auxiliary Feedwater Pump

and Valve Test (Quarterly) Unit 2

MA-AA-100-1014

Limitorque MOV Testing and Actuator Inspections

MA-AA-100-1021

Motor Operated Valve Stem Lube and Actuator Gearbox

Grease Inspection

OI 128

Safety Injection (SI) System Fill and Vent Unit 1

OM 3.20

MOV/AOV/Manual Valve Operating Requirements

RMP 9141

Air-Operated Valve Testing and Adjustment

219460 03

SI-00850-0 Inspection/Rebuild

10/10/2006

366848

MOV Actuator Check-Out

03/28/2010

366848

RMP 9376-2 Limitorque MOV Static/DP Testing for Gate

and Globe Valves

03/09/2010

383027 01

MCTW-141 Calibration

08/24/2010

389729

2AF-04002-O / Replace Actuator Base Capscrews

06/17/2011

208015

2AF-4002-S - Replace Solenoid Valve

04/05/2014

253633

1AF-04000-O - Valve Stem Clean & Lubricate

10/19/2014

40418959

2AF-04002 / Minor Air Leak Around Diaphragm

05/10/2017

40453229

2AF-4002-O - Diagnostic Check

04/20/2017

40543620

Diagnostic Test Valve 2SI-00852B

10/15/2018

40543723

2SI-00852B; Stem Lube and Actuator Gear Box Grease

Replacement

01/24/2019

40573109

1AF-04000-O - MOV Actuator Check-Out

04/26/2019

40573109 02

1AF-04000-O / OPS RTS-PMT

04/11/2019

40573198

1AF-04000-O / Stem Lube & Actuator Gearbox Grease

04/11/2019

40644388

2RC-00430 - Rebuild Valve Actuator

04/30/2020

40693383 01

1AF-04000-O; Clean and Inspect Torque Switch Contacts

10/18/2020

40693383 02

1AF-04000-O: OPS RTS-PMT

10/19/2020

40706080

1AF-04002-O/Replace Air Supply Hose

05/26/2020

40726250

2AF-4002-S - Replace Solenoid Valve

10/13/2021

40726905

2SI-00860A MOV Actuator Diagnostics and Inspections

10/31/2021

Work Orders

40726906

2SI-00860A MOV Stem Lube and Gear Box Grease

Inspections

11/30/2021

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

25456-001

Perform Actuator Refurbishment Every 15 Years per

Environmental Qualification Maintenance Request

(EQMR)

11/09/2000

WO 00354830

1SI-0086B Repack Valve

09/15/2018

WO 0215178

SI-00851A MOV Actuator Checkout

04/01/2004

WO 0387601

1SI-00866B Valve Stem Clean and Lube

2/11/2013

WO 40472723 03

SI-00866B-O Actuator Checkout - Inspection and Test

10/07/2017

WO 9948609

MOV Actuator Checkout

10/01/2002