IR 05000266/2021003

Integrated Inspection Report 05000266/2021003 and 05000301/2021003

ML21292A276
Person / Time
Site:	Point Beach
Issue date:	10/20/2021
From:	Nestor Feliz-Adorno Reactor Projects Region 3 Branch 4
To:	Strope M Point Beach
References
IR 2021003
Download: ML21292A276 (24)

Text

SUBJECT:

POINT BEACH NUCLEAR PLANT - INTEGRATED INSPECTION REPORT 05000266/2021003 AND 05000301/2021003

Dear Mr. Strope:

On September 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Point Beach Nuclear Plant. On October 5, 2021, the NRC inspectors 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.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

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.

If you disagree with a cross-cutting aspect assignment 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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Point Beach Nuclear Plant.

October 20, 2021 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, Néstor J. Féliz Adorno, Chief Branch 4 Division of Reactor Projects 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:

05000266/2021003 and 05000301/2021003

Enterprise Identifier:

I-2021-003-0099

Licensee:

Nextera Energy Point Beach, LLC

Facility:

Point Beach Nuclear Plant

Location:

Two Rivers, WI

Inspection Dates:

July 01, 2021 to September 30, 2021

Inspectors:

R. Baker, Senior Operations Engineer

J. Cassidy, Senior Health Physicist

T. Hartman, Senior Resident Inspector

V. Petrella, Resident Inspector

T. Wingfield, Operations Engineer

Approved By:

Néstor J. Féliz Adorno, Chief

Branch 4

Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated 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

Inadequate Description of the Amount of Radioactive Material in Shipping Papers Cornerstone Significance Cross-Cutting Aspect Report Section Public Radiation Safety Green NCV 05000266,05000301/2021003-01 Open/Closed

[P.3] -

Resolution 71152 A Self-Revealed Green finding and associated Non-cited Violation (NCV) of 10 CFR 71.5(a)for the failure to provide the correct quantity of radioactive material identified on shipping papers, in accordance with NRC and Department of Transportation requirements.

Additional Tracking Items

None.

PLANT STATUS

Unit 1 began the inspection period at rated thermal power. On July 31, 2021, Unit 1 was shut down due to the trip of a main feedwater pump. The unit was restarted on August 1, 2021, and reactor power was raised to approximately 55 percent until the main feedwater pump was repaired. On August 7, 2021, the unit was returned to rated thermal power, and remained at or near full power throughout the remainder of the inspection period.

Unit 2 began the inspection period at rated thermal power. On September 8, 2021, the unit began coastdown for the upcoming refueling outage. The unit was at 86 percent of rated thermal power at the end of the inspection period.

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 Disease 2019 (COVID-19), resident and regional inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week, increasing the amount of time on site as local COVID-19 conditions permitted. As part of their onsite activities, resident inspectors conducted plant status activities, as described in IMC 2515, Appendix D, observed risk significant activities, and completed on site portions of IPs. In addition, resident and 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.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Unit 1 motor-driven auxiliary feedwater pump on August 1, 2021

(2) Unit 2 train A emergency diesel generator (G-02) on August 17, 2021

(3) Unit 1 train B containment spray on August 26, 2021

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the Unit 2 safety injection system on July 22, 2021.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1)fire zones 152, 153, 154, and 155 on August 11, 2021 (2)fire zones 306 and 307 on September 29, 2021 (3)fire zone 308 on September 30, 2021 (4)fire zone 309 on September 30, 2021

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the:

(1) circulating water pump and service water pump building

Cable Degradation (IP Section 03.02) (1 Sample)

The inspectors evaluated cable submergence protection in:

(1) manholes #1 and #2 (Z-65A/B)

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 August 16, 2021 through September 24, 2021.

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 February 17, 2021.

Annual Requalification Operating Tests The inspectors evaluated the adequacy of the facility licensees annual requalification operating test.

Administration of an Annual Requalification Operating Test The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by 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.

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.

Problem Identification and Resolution The inspectors evaluated the licensees ability to identify and resolve problems associated with licensed operator performance.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the Control Room during Unit 1 reactor startup on August 1, 2021.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated annual operator requalification in the simulator on August 24, 2021.

71111.12 - Maintenance Effectiveness

Quality Control (IP Section 03.02) (1 Sample)

The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:

(1) The inspectors reviewed six work packages covering a variety of maintenance activities to evaluate whether licensee quality control verifications are properly specified, in accordance with the Quality Assurance Program, and are implemented, as specified.

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1)emergent work due to Unit 1 plant trip on August 1, 2021 (2)elevated plant risk due to G-01 emergency diesel generator and G-05 gas turbine out of service with severe weather forecasted on August 10, 2021 (3)elevated plant risk due to the Unit 1 turbine trip testing on July 21, 2021 (4)elevated plant risk due to DY-0A, Red 125V DC / 120V AC Alternate Inverter, maintenance on July 20, 2021 (5)elevated plant risk due to the D-305/D-09 swing station battery and charger maintenance and testing on August 31, 2021

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) G-02 emergency diesel generator elevated vibrations

(2) Unit 1 B steam generator feedwater regulator controller failed to operate in auto

(3) G-02 emergency diesel generator fuel oil transfer pump did not stop as expected

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:

(1) RMP 9036-1, DY-0A Red Channel Instrument Bus Static Inverter Maintenance Procedure, on July 20, 2021 (2)testing of Unit 1 B main feed water pump after the trip on timed overcurrent on August 7, 2021 (3)testing of the G-01 emergency diesel generator after maintenance on August 19, 2021 (4)testing of G-03 lube oil recirculation pump after replacement on August 31, 2021 (5)testing of Unit 2 B residual heat removal pump after maintenance on September 9, 2021

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1)1ICP 02.003A, Reactor Protection System Logic Train A 31 Day Surveillance, on July 15, 2021

(2) TS 83, Emergency Diesel Generator G-03 Monthly, on July 25,

71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage,

& Transportation

Radioactive Material Storage (IP Section 03.01)

(1) Inspectors evaluated the licensees performance in controlling, labeling, and securing radioactive materials.

Radioactive Waste System Walkdown (IP Section 03.02) (1 Sample)

(1) Inspectors walked down accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality.

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

MS06: Emergency AC Power Systems (IP Section 02.05)===

(1) Unit 1 July 1, 2020 - June 30, 2021

(2) Unit 2 July 1, 2020 - June 30, 2021

MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)

(1) Unit 1 July 1, 2020 - June 30, 2021

(2) Unit 2 July 1, 2020 - June 30, 2021

MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)

(1) Unit 1 July 1, 2020 - June 30, 2021

(2) Unit 2 July 1, 2020 - June 30, 2021 BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (2 Samples)

(1) Unit 1 October 1, 2020 - June 30, 2021

(2) Unit 2 October 1, 2020 - June 30, 2021

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) October 1, 2020 - June 30, 2021 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)

(1) October 1, 2020 - June 30, 2021

71152 - Problem Identification and Resolution

Semiannual Trend Review (IP Section 02.02) (1 Sample)

(1) The inspectors reviewed the licensees corrective action program from December 2020 to May 2021 for potential adverse trends that might be indicative of a more significant safety issue.

Annual Follow-Up of Selected Issues (IP Section 02.03) (2 Samples)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1)gap identified on Unit 1 electrical equipment room fire barrier (2)transportation of radioactive materials

71153 - Follow-Up of Events and Notices of Enforcement Discretion Event Follow-Up (IP Section 03.01)

(1) The inspectors evaluated a plant trip as a result of a loss of main feedwater pump and the licensees response on July 31,

INSPECTION RESULTS

Inadequate Description of the Amount of Radioactive Material in Shipping Papers Cornerstone Significance Cross-Cutting Aspect Report Section Public Radiation Safety Green NCV 05000266,05000301/2021003-01 Open/Closed

[P.3] -

Resolution 71152 A self-revealed Green finding and associated Non-cited Violation (NCV) of 10 CFR 71.5(a) for the failure to provide the correct quantity of radioactive material identified on shipping papers, in accordance with NRC and Department of Transportation requirements.

Description:

On December 8, 2020, Radiation Protection personnel performed radiological surveys of spent resin liner number 678141-2 using Work Plan 160A Resin Liner Survey and Liner to Shipping Cask, Revision 3, dated December 5, 2020. The results from this survey were used to calculate the quantity of radioactivity contained in the liner. The licensee transferred the calculated quantity of radioactivity in the liner to the NRC Form 540 Uniform Low-Level Radioactive Waste Manifest, which becomes a key attribute of the shipping papers when the liner was shipped to a vendor for waste processing on January 14, 2021. The inspectors observed that Radiation Protection Work Plan 160A Resin Liner Survey and Liner to Shipping Cask, Revision 3, dated December 5, 2020, had been developed in response to lessons learned from radioactive waste shipment 19-037 and to include corrective actions from CR 02360869, Preliminary White Finding Related to Radwaste Shipment.

On January 15, 2021, the vendor received the shipment and moved the liner to a shielded location for short term storage before processing. In April 2021, the waste processing vendor removed the liner from storage, performed a radiological survey, and identified significantly higher dose rates on the liner (and consequently higher activity of radioactive material within the liner) than had been reported by the licensee.

After an evaluation to reconcile the differences, the licensee determined that its staff had under-reported the activity in the liner. On April 21, 2021, the licensee revised the shipping papers, including the total package activity, and transmitted updated documents to the waste processor. In this case, the licensee determined the liner contained a revised total package activity of 1.07E+07 MBq (or 2.90E+05 mCi). This was 2.5 times the radioactive material reported at the time of the shipment (4.21E+06 MBq (or 1.14E+05 mCi)).

The licensee determined the direct cause of this error was RP Workplan 160A, Resin Liner Survey and Liner to Shipping Cask, did not require an adequate amount of survey points.

Corrective Actions: The corrected shipping papers, with the increased total package activity, were sent to waste processor. Additionally, the licensee revised RP workplan 160A, Resin Liner Survey and Liner to Shipping Cask, to require additional survey points.

Corrective Action References: AR 02389967

Performance Assessment:

Performance Deficiency: The licensee did not adequately describe hazardous material in shipping papers as required by regulatory requirements.

On January 14, 2021, the licensee shipped radioactive waste (Shipment 21-001) to a radioactive waste processing facility. The shipment documentation listed a radioactive content of 4.21E+06 MBq. After arriving at the facility, the waste processor identified that the radioactive content was incorrect. Subsequently, the licensee performed an evaluation and revised the shipment documentation to state a radioactive content of 1.07E+07 MBq, which was 254 percent of the radioactive material that was reported at the time of the shipment.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Program & Process attribute of the Public Radiation Safety cornerstone, and adversely affected the cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain, as a result of routine civilian nuclear reactor operation. Specifically, the licensee provided shipping papers for radioactive material that contained an error that exceeded 20 percent of the activity of the material (Example 6.l of Inspection Manual 0612, Appendix E).

Significance: The inspectors assessed the significance of the finding using Appendix D, Public Radiation Safety SDP. The inspectors evaluated the finding by applying the radioactive material control branch of the SDP (i.e., transportation or Part 61) and determined that the finding was of very low safety significance (i.e., Green) because:

(1) package radiation limits were not exceeded,

(2) there was not a breach of package during transit, (3)there was not a certificate of compliance concern,

(4) there was not a low level burial ground nonconformance, and

(5) there was no failure to make notifications or provide emergency response information.

Cross-Cutting Aspect: P.3 - Resolution: The organization takes effective corrective actions to address issues in a timely manner commensurate with their safety significance.

Specifically, the licensee determined the direct cause of this error was RP Workplan 160A, Resin Liner Survey and Liner to Shipping Cask, did not require an adequate amount of survey points. The number and location of survey points described in Workplan 160A had been revised to incorporate lessons learned from radioactive waste shipment 19-037, and to institutionalize some of the corrective actions from CR 02360869, Preliminary White Finding Related to Radwaste Shipment. The revision standardized the survey process for shipments to a reduced number of survey points. Consequently, the corrective action(s) to address potentially unreliable data for use in package characterization and shipment preparation was not effective.

Enforcement:

Violation: 10 CFR 71.5(a) states that each licensee who transports licensed material outside the site of usage, as specified in the NRC license, or where transport is on public highways, or who delivers licensed material to a carrier for transport, shall comply with the applicable requirements of the DOT regulations in 49 CFR parts 107, 171 through 180, and 390 through 397, appropriate to the mode of transport.

49 CFR 172.200(a) states, with exceptions not applicable here, that each person who offers a hazardous material for transportation shall describe the hazardous material on the shipping paper, in the manner required by subpart C of 49 CFR Part 172.

Pursuant to 49 CFR 172.101, radioactive material is classified as hazardous material.

49 CFR 172.203(d)(3) states, in part, the description for a shipment of a Class 7 (radioactive)material must include the following additional entries as appropriate: the maximum activity of the radioactive contents contained in each package during transport in terms of the appropriate SI units (e.g., Becquerels (Bq), Terabecquerels (TBq)).

Contrary to the above, on January 14, 2021, the licensee delivered licensed material to a carrier for transport, and the description on the shipping paper that accompanied the shipment did not include the correct maximum activity of the radioactive contents.

Specifically, the shipment paper stated a maximum activity of 4.21E+06 MBq. Upon subsequent evaluation, the licensee determined the activity to be 1.07E+07 MBq.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Observation: Review of Selected Transportation of Radioactive Materials Issues 71152 In 2019, the licensee offered for transport a radioactive material package, containing spent resin, as Low Specific Activity - II (LSA-II) that did not meet the radiation level limits specified in 49 CFR 173.427 for shipping as LSA. Specifically, licensee staff did not recognize that measured radiation levels were in excess of 10 mSv/ hour (1 Rem/hour) at 3 meters from the unshielded package, exceeding the conditions of transport for LSA material. This shipment is also known as Radwaste Shipment 19-037. (In NRC Inspection Report Nos.

05000266/2020090 and 05000301/2020090, the NRC documented a Green finding and the associated non-cited violations for the noncompliances for the shipment.)

The inspectors reviewed Root Cause Evaluation - AR 02360869, Radwaste Shipping Error Results in Preliminary White Finding, to ensure that the licensee implemented corrective actions, commensurate with the significance of the identified issues. Additionally, the inspectors reviewed AR 02389967, Radiological Survey Differences Identified, that was evaluated for another shipment of spent resin performed in January 2021.

In response to the 2019 shipping issue, the licensee determined that, Radwaste Shipment 19-037 was assigned the incorrect shipping name and therefore did not have the proper Emergency Response Guide included in the shipping documents which resulted in non-compliance with site and regulatory shipping requirements. As corrective actions, the licensee:

Revised radwaste shipping checklist RP-AA-108-1002-F06, and applicable similar checklists, to include documented validation of critical parameters when determining proper shipping names and emergency response guide;

Incorporated a management oversight risk matrix within its procedure to drive observation and oversight of key risk-sensitive elements of the shipping process;

Revised radwaste shipping program documents to require development of an annual projected high or elevated risk radwaste shipment schedule and include a method for periodic review and oversight of the schedule; and

Revised applicable shipping and survey procedures to include the option for use of RADMAN calculated 3-meter dose rates vs. measured 3-meter dose rates, and to include cautions/warnings for use of measured 3-meter values, use of the RADMAN override feature, and the potential impact on Proper Shipping Name/Emergency Response Guide.

The inspectors found that the licensee had completed its implementation of the corrective actions identified.

The inspectors observed that the licensees revisions to its survey procedure (RP Workplan 160A) provided additional uniformity (i.e., distances and locations) to the radiation measurements performed on a package prepared for transport. The inspectors observed that the procedure also reduced the number of measurements routinely taken on a package, which appeared to be based on a package having a reasonably homogeneous mixture of radioactivity throughout the package and having consistent radiation levels from the package.

Reviewing the 2019 shipment survey, the inspectors observed that there were notable gradients of radioactivity within the package, as indicated by the range of radiation levels measured by the licensee. At the time of the shipment, the licensee did not appear to recognize the gradients, and calculated the shipment contents with a computer model that relied on a reasonably homogeneous mixture. In addition, the inspectors noted that the licensees revised survey process did not accurately characterize the radioactivity in the 2021 shipment, providing additional indication that the licensees bases (homogeneous distribution of radioactivity) may not be technically sound.

The inspectors observed that the licensees problem statement may have limited the licensees evaluation and corrective actions, resulting in missing some of the underlying causes. As discussed above, the licensees evaluation did not appear to fully recognize some issues with its survey methods and waste characterizations, which were discussed in NRC Inspection Report Nos. 05000266/2020090 and 05000301/2020090. In the report, the NRC documented that, The NRC staff observed that the material appeared to have some gradients in the radionuclide distribution (radiation levels were not fully uniform across the container), which may have impacted the licensees calculations. The inspectors determined that these shortcomings contributed to the non-cited violation documented above. The licensee was evaluating additional corrective actions to address the radiological survey issues.

Observation: Semi Annual Trend Review 71152 The inspectors reviewed action requests entered into the corrective action program for the following:

complete, accurate, and timely documentation of the issue identified in the corrective action program

evaluation and timely disposition of operability and reportability issues

consideration of extent of condition and cause, generic implications, common cause, and previous occurrences

classification and prioritization of the problems resolution, commensurate with the safety significance

identification of corrective actions that are appropriately focused to correct the problem

completion of corrective actions in a timely manner, commensurate with the safety significance of the issue

identification of negative trends associated with human or equipment performance that can potentially impact nuclear safety

operating experience is adequately evaluated for applicability, and applicable lessons learned are communicated to appropriate organizations, and implemented The inspectors completed the review and did not note any significant trends that weren't already identified and addressed by the licensee.

EXIT MEETINGS AND DEBRIEFS

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

On October 5, 2021, the inspectors presented the integrated inspection results to Mr. M. Holzmann, Site Operations Director, and other members of the licensee staff.

On August 19, 2021, the inspectors presented the radiation protection inspection results to Mr. M. Strope, Site Vice President, and other members of the licensee staff.

On September 2, 2021, the inspectors presented the Biennial Licensed Operator Requalification Program inspection results to Mr. M. Strope, Site Vice President, and other members of the licensee staff.

On September 29, 2021, the inspectors presented the Biennial Licensed Operator Requalification Program Annual Operating Test Results inspection results to Mr. A. Moore, Operations Training Supervisor, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Corrective Action

Documents

Resulting from

Inspection

AR 02400605

Update ISO DWG to Depict Gravity Supports as Restraints

08/09/2021

110E017 Sheet 2

Safety Injection System

110E017 Sheet 3

Safety Injection System

110E035 Sheet 1

P&ID Safety Injection System

110E035 Sheet 2

P&ID Safety Injection System

M-202 Sh. 2

P&ID Feedwater System

M-202 Sh. 3

P&ID Feedwater System

M-209 Sh. 12

P&ID Em. Diesel Air Starting Sys.

M-219 Sh. 1

P&ID Fuel Oil System

M-219 Sh. 2

P&ID Fuel Oil System - Diesel Generator Building

P-202

Suction from RWST to SI, CS, RHR Pumps

P-219

Safety Injection Pump Discharge to Injection

SI-1501R-1 and SI-1501R-3

Drawings

P-220

Safety Injection Pump Discharge to Injection Line

SI-1501R-1 and SI-1501R-2

CL 10D

Fuel Oil Systems

71111.04

Miscellaneous

CL 11A G-02

G-02 Diesel Generator Checklist

Corrective Action

Documents

Resulting from

Inspection

AR 2400835

Plant Housekeeping Issues Identified by NRC

08/11/2021

PFP-0-CB

Pre-Fire Plan Control Building - Elev 8 ft, 26 ft, 44 ft and 66

ft

71111.05

Fire Plans

PFP-0-PAB-8

Pre-Fire Plan Primary Auxiliary Building Elevations 8' and

Below

2009-0008

Circulating Water Pump House Internal/External Flooding

Calculations

2014-0007

Allowable Flood Levels

& 4

Procedures

NP 8.4.17

PBNP Flooding Program

34, 35, & 36

71111.06

Work Orders

WO 40753341-01

P-290A, Annual Service / Maintenance

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

WO 40753342-01

P-290B, Annual Service / Maintenance

WO 40756075-01

Manhole: Electrical Inspections (Yearly - Fall)

71111.11A

Miscellaneous

Requalification

Program Annual

Testing Summary

Results

Licensed Operator Annual Examination Performance

Records for 2021

09/27/2021

AR 1911813

Procedure Variance for AOP-9A (Service Water System

Malfunction)

10/13/2013

AR 2302377

EC 292423 Unit 1 Cycle 39 Core Reload Modification

2/18/2019

AR 2368376

EC 294656 Unit 1 Cycle 40 Core Reload Modification

09/15/2020

AR 2373582

Simulator - U1C40 Core Test Acceptance Criterion Not Met

10/28/2020

AR 2382181

Crew Failure During NRC Operational Exam

01/27/2021

AR 2385859

NRC Biennial Written Exam Security Issue

03/03/2021

AR 2388219

License Termination Letter Not Sent to NRC within 30 Day

Requirement

03/29/2021

Corrective Action

Documents

AR 2389305

21Biennial Written Exam Performance

04/08/2021

Post Event

Testing

Unit 1 Small RCS Leak in Containment Building - Validate

1Re-211 Simulator Response

05/21/2020

Scenario Based

Testing (SBT)

Checklist

SBT Package for PNB LOC 000 043E Simulator Exercise

Guide (SEG) Rev 5

06/19/2021

Scenario Based

Testing Checklist

SBT Package for PNB LOC 000 003E SEG Rev 6

06/19/2021

Simulator

Certification Test

6.2.1

100% Power Steady State Performance Test U1C40

05/23/2021

Simulator

Certification Test

6.2.2

75% Power Steady State Performance Test U1C40

05/23/2021

Simulator

Certification Test

6.2.3

28% Power Steady State Performance Test U1C40

05/23/2021

71111.11B

Engineering

Evaluations

Simulator

Certification Test

PORV Open without High Head Safety Injection U1C39/40

05/15/2021

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

6.5.10

Simulator

Certification Test

6.5.2

Simultaneous Trip of Both Main Feed-Water Pumps

U1C39/40

04/24/2021

Simulator

Certification Test

6.5.5

Trip of a Single Reactor Coolant Pump U1C39/40

05/15/2021

Simulator

Certification Test

6.5.8

Loss of Coolant Accident (LOCA) with Loss of Offsite Power

U1C39/40

05/15/2021

20 Give 2

EXAM RO

RO Written Examination

2/17/2021

20 Give 2

EXAM SRO

SRO Written Examination

2/17/2021

Attendance

Records

Licensed Operator Continuous Training Attendance Records

(Various)

2019-2020

License

Reactivation

Records

License Reactivation Records for 4 Individuals - 04/24/2020

- 07/21/2020

08/31/2021

Medical Records

Licensed Operator Medical Records for 11 Operators

09/01/2021

PBN JPM

P000.008a.COT

Job Performance Measure

PBN JPM

P000.020a.AOT

Job Performance Measure

PBN JPM

P000.033b.COT

Job Performance Measure

PBN JPM

P000.037.COT

Job Performance Measure

PBN JPM

P000.047b.AOT

Job Performance Measure

PBN JPM

P000.047c.AOT

Job Performance Measure

Miscellaneous

PBN JPM

P002.005c.COT

Job Performance Measure

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

PBN JPM

P004.013a.COT

Job Performance Measure

PBN JPM

P004.026.AOT

Job Performance Measure

PBN JPM

P078.006.AOT

Job Performance Measure

PBN SEG LOC

000 003E

Simulator Dynamic Scenario

PBN SEG LOC

000 026E

Simulator Dynamic Scenario

PBN SEG LOC

000 043E

Simulator Dynamic Scenario

PBN SEG LOC

000 068E

Simulator Dynamic Scenario

Remediation

Records

20 Annual Operating Test Failure Remediation Packages

for 3 Individuals

09/01/2021

Remediation

Records

20 Biennial Written Exam Failures Remediation Packages

for 7 Individuals

09/01/2021

Simulator Review

Committee (SRC)

Meeting Minutes

SRC Meeting Minutes from January 2021

01/24/2021

Simulator Review

Committee (SRC)

Meeting Minutes

SRC Meeting Minutes from June 2021

06/10/2021

Simulator Work

Request (SWR)

Listing

List of all Open SWR Items

08/30/2021

SWR Listing

List of all SWR Items Closed Since Previous Biennial

Requal Inspection

08/30/2021

Watch Proficiency

Records

eSOMS Credit for Standing Watch 04/01/2021 to

06/28/2021 Reports

08/31/2021

Desktop Guide

94.0

Simulator Health Management

Procedures

Desktop Guide

Simulator Work Requests

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

94.3

FL-LOCT-TPD

Licensed Operator Continuing Training Program Description

OP-AA-100-1001

License Maintenance and Activation

TR-AA-220-1002

NRC Licensed Operator Exam Security

TR-AA-220-1004

Licensed Operator Continuing Training Annual Operating

and Biennial Written Exams

TR-AA-221-1000

Simulator Change Control

TR-AA-230-1007

Conduct of Simulator Training and Evaluation

TR-AA-230-1007-

F01

Crew Simulator Evaluation Forms for 2021 Annual

Operating Test - Crew A

TR-AA-230-1007-

F02

Individual Simulator Evaluation Forms for 2021 Annual

Operating Test - Crew A-All Operators

TR-AA-230-1008

Simulator Scenario Based Testing and Validation

Simulator Work Request 2291459

EC 291769 Fire Detection Upgrade - Phase II

11/20/2018

Simulator Work Request 2329323

Xenon Response During Rapid Load Reduction

09/26/2019

Work Orders

Simulator Work Request 2398451

Add PPCS Failure Malfunctions

07/14/2021

Miscellaneous

PBN LOC 000

069E

NRC Annual Operating Exam

OP 1B

Reactor Startup

71111.11Q

Procedures

OP 1B Appendix

A

Estimated Critical Position Calculation

NP 11.1.14

Inspection Planning

Procedures

NP 11.1.15

Quality Control Inspections

WO 40178723 11

G-01-FTS-H/L//Numerous Fuel Oil XTFR Alarms G-01

08/21/2021

WO 40720934 10

U2 RPI/EC-294454 - RPI Replacement

09/09/2021

WO 40722095 01

F-222/G-02 SW Inlet Duplex Strainer Not to be Cleaned

09/14/2021

WO 40739986 02

2-62/YIC-926B-T, Bench Calibrate Replacement Relay

09/17/2021

WO 40760281 05

PI-3719, P-35A Disch. Press. Indicating Low

09/16/2021

71111.12

Work Orders

WO 40765372 01

2P-2A-Z/Cooling Fan Replacement

09/03/2021

71111.13

Miscellaneous

Point Beach Elevated Risk Focus Activities for the Turbine

07/21/2021

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Trip Test Unit 1 Quarterly

PBN Unit 1 and 2 Current Risk Summary Report

08/10/2021

T-0 Execution Schedule, by Early Start

08/09/2021

Point Beach Elevated Risk Focus Activities for the

DY-0A Red 125V DC / 120V AC Inverter Maintenance

07/20/2021

Point Beach Work Activity High Risk List for the D-305/D-09

Station Battery / Charger Maintenance and Service Test

08/31/2021

T-0 Execution Schedule, by Early Start

08/01/2021

Procedures

AOP-13C

Severe Weather Conditions

Work Orders

WO 40730660 01

TS-3A, Unit 1 Turbine Trip Test

07/21/2021

AR 02394000

1CS-476 Failed to Operate in Auto

05/22/2021

AR 2404583

G-02 Fuel Oil Transfer Pump Would Not Shut Off Manually

09/19/2021

Corrective Action

Documents

AR 3404006

Elevated Vibrations on G-02 EDG During TS 82

09/13/2021

883D195 Sheet

Logic Diagram Feedwater Control and Isolation

71111.15

Drawings

M-202 Sheet 2

Feedwater System

AR 02400516

1CS-2187 Suction Relief Valve was Noted to be Dripping

08/07/2021

Corrective Action

Documents

Resulting from

Inspection

AR 02402759

DGB Door 107 Not Self Latching

08/31/2021

Miscellaneous

1P-28B Steam Generator Feed Pump and Motor Monitoring

Plan

OI 169

Steam Generator Feed Pumps Isolation and Restoration

Mode 1, 2, or 3 Unit 1

Procedures

OP 1C

Startup to Power Operation Unit 1

WO 40738003 09

DY-0A, Maintain and Inspect Inverter

07/20/2021

WO 40779246 01

IT 04 Train B Low Head Safety Injection Pumps and Valves

Train B Unit 2

09/10/2021

WO 40787760 18

1P-28B (MFP) Trip on Timed Overcurrent

08/10/2021

WO 40788643

TS-81, G-01 Emergency Diesel Generator Operability Test

08/22/2021

71111.19

Work Orders

WO 40789102 01

P-215A G-03 Lube Oil Recirc Pump Noisy

08/31/2021

71111.22

Procedures

1ICP 02.003A

Reactor Protection System Logic Train A 31 Day

Surveillance

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Work Orders

WO 40744625 01

TS-83, G-03 Emergency Diesel Generator Operability

07/25/2021

Corrective Action

Documents

Resulting from

Inspection

AR 02401599

Source Leak Check Certificate Mismatch

08/19/2021

LMS ID NUCRPT

1030

Lesson Title - 10CFR37 Cat 1 & 2 Material

RP-AA-107-1004-

F02

Source Leak Test and Inventory

08/12/2021

Miscellaneous

TRM 3.7.4

Sealed Radioactive Sources

PCP

Process Control Program

71124.08

Procedures

RP-AA-107-1004

Procedure for Radioactive Source Controls and Leak

Testing

MSPI Derivation Reports; High Pressure Injection,

Emergency AC, Cooling Water; Unavailability Index;

Units 1 and 2

07/01/2020 -

06/30/2021

MSPI Derivation Reports; High Pressure Injection,

Emergency AC, Cooling Water; Unreliability Index;

Units 1 and 2

07/01/2020 -

06/30/2021

MSPI Margin Reports; Units 1 and 2

07/01/2020 -

06/30/2021

NP 5.2.16 -

Occupational

Exposure

Effectiveness

B; PI Data Calculation, Review and Approval

October

20 - June

21

NP 5.2.16 -

ODCM

Radioactive

Effluents

Effectiveness

B; PI Data Calculation, Review and Approval

October

20 - June

21

Miscellaneous

NP 5.2.16 - RCS

Activity Fuel

Performance

B; PI Data Calculation, Review and Approval

October

20 - June

21

71151

Procedures

CAMP 044

Fuel Integrity Monitoring

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

CAMP 410

Determination of Radioactive Iodine and Iodine 131

Equivalents in Reactor Coolant

PBN-BFJR-18-

054

MSPI Basis Document for PBNP

AR 02360869

Preliminary White Finding Related to Radwaste Shipment

01/13/2021

Corrective Action

Documents

AR 02389967

Radiological Survey Differences Identified

04/14/2021

AR 02401505

Procedure Change Request to Revise RP-AA-108-1003

"Radioactive Materials Surveys for Shipment" to add

LSA/SCO Dose Rate Limits for Unshielded Material at

3-meters.

08/18/2021

AR 02401602

Highest Contact Reading Discrepancy Identified

08/19/2021

AR 02401619

Weight Discrepancy on Shipment 18-058

08/19/2021

Corrective Action

Documents

Resulting from

Inspection

AR 2395628

Small Gap Identified Between FZs 245 and 322

06/10/2021

Miscellaneous

Trend ARs 12-01-2020 thru 05-31-2021

06/09/2021

RP-AA-108-1002

Shipment of Radioactive Material

Procedures

RP-AA-108-1003

Radioactive Materials Surveys for Shipment

E-RS 210406-08

Container No 678141-2 Incoming Survey

04/06/2021

Radiation

Surveys

E-RS 210407-06

Container No 678141-2 Incoming Liner

04/08/2021

Shipment 21-001

Primary Resin

01/14/2021

71152

Shipping Records

Shipment 21-001

(Revised)

Primary Resin

04/21/2021

71153

Corrective Action

Documents

AR 2399946

Unit 1 Reactor Trip due to 1P-28B MFP Trip

08/01/2021