IR 05000334/2007006
| ML071350412 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 05/15/2007 |
| From: | Ronald Bellamy NRC/RGN-I/DRP/PB6 |
| To: | Lash J FirstEnergy Nuclear Operating Co |
| BELLAMY, RR | |
| References | |
| IR-07-006 | |
| Download: ML071350412 (20) | |
Text
May 15, 2007
SUBJECT:
BEAVER VALLEY POWER STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000334/2007006 AND 05000412/2007006
Dear Mr. Lash:
On April 5, 2007, the U. S. Nuclear Regulatory Commission (NRC) completed a team inspection at the Beaver Valley Power Station. The enclosed report documents the inspection findings, which were discussed on April 5, 2007 with yourself and other members of your staff during an exit meeting.
This inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.
On the basis of the samples selected for review, there were no findings of significance identified during this inspection. The Team concluded that problems were properly identified, evaluated, and resolved within the problem identification and resolution (PI&R) programs. Active use of the corrective action program (CAP) resulted in generally good equipment reliability. However, during the inspection, some examples of minor problems were identified, including conditions adverse to quality that were not being entered into the corrective action program. The Team also noted that corrective actions for procedure adherence issues identified in a number of licensee self assessments were not fully effective, and acknowledged FENOCs plans to make this issue a station focus area for 2007.
2 In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web-site at http://www.nrc.gov/NRC/ADAMS/index. html (the Public Electronic Reading Room).
Sincerely,
/RA/
Ronald R. Bellamy, Ph.D., Chief Reactor Projects Branch 6 Division of Reactor Projects Docket Nos.: 50-334, 50-412 License Nos: DPR-66, NPF-73
Enclosures:
Inspection Report 05000334/2007006; 05000412/2007006 w/Attachment: Supplemental Information
REGION I==
Docket Nos:
50-334, 412 License Nos:
05000334/2007006 & 05000412/2007006 Licensee:
FirstEnergy Nuclear Operating Company Facility:
Beaver Valley Power Station Location:
Shippingport, Pennsylvania 15077 Dates:
March 26 to April 5, 2007 Team Leader:
D. Kern, Senior Resident Inspector - Three Mile Island, Division of Reactor Projects Inspectors:
S. McCarver, Project Engineer, Division of Reactor Projects T. Setzer, Project Engineer, Division of Reactor Projects D. Werkheiser, Resident Inspector - Beaver Valley, Division of Reactor Projects Approved by:
Dr. Ronald R. Bellamy, Chief Projects Branch 7 Division of Reactor Projects ii Enclosure
SUMMARY
OF ISSUES
IR 05000334/2007006, IR 05000412/2007006; 03/26/2007-04/05/2007; Beaver Valley Power Station, Units 1 & 2; baseline inspection of the identification and resolution of problems.
The report covered a two week team inspection conducted by two regional inspectors and two resident inspectors. No findings or violations were identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC)0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3 dated July 2000.
Identification and Resolution of Problems The Team concluded that First Energy Nuclear Operating Company (FENOC) was effective in identifying problems and entering them into the corrective action program (CAP). FENOCs effectiveness at problem identification was evidenced by the relatively few significant deficiencies identified by external organizations (including the NRC) that had not been previously identified by the licensee during the review period. Although overall plant material condition had improved, the Team noted that some plant housekeeping deficiencies and minor long-term equipment deficiencies were commonly accepted by station personnel. If left uncorrected, these deficiencies could potentially mask equipment problems which may become worse. Station management initiated actions to address this concern. Once entered into the CAP, issues were promptly and consistently screened, prioritized, and evaluated commensurate with their significance. Active use of the CAP to identify and resolve equipment issues has resulted in good overall equipment reliability. Corrective actions were generally effective and were typically completed in a timely manner.
Use of industry operating experience improved since 2005 and was effective. Self-assessments were critical, identified meaningful performance trends, and issues were entered, as appropriate, into the CAP. Self-assessments repeatedly identified deficient procedure adherence across the station; however, corrective actions taken since 2005 have been only partially effective in addressing the issue. The Team noted that station management has identified procedure adherence as a 2007 station focus area. The Team determined the licensee supported a safety conscious work environment in which workers actively participate in the CAP and freely raise issues of concern to station management. Workers and managers alike consistently demonstrated a positive perspective toward improving station safety and working conditions.
NRC-Identified and Self-Revealing Findings
None.
B.
Licensee Identified Findings None.
J. Lash
REPORT DETAILS
OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution
a.
Assessment of the Corrective Action Program
- (1) Inspection Scope The Team reviewed the procedures describing the corrective action program (CAP) at the Beaver Valley Power Station (BVPS). Station personnel identified and documented problems by initiating either notifications in the SAP multi-management work tracking system (SAP) for non-adverse conditions, or condition reports (CRs) in the Condition Report Evaluation and Status Tracking system (CREST) for adverse conditions. Actions taken to address notifications were considered enhancement actions to address minor problems and were not intended to remediate or prevent adverse conditions or their causes. Condition reports were written for conditions adverse to quality such as failures, malfunctions, and deficiencies, or human performance, programmatic, organizational, or management weaknesses that adversely affect Quality, Augmented Quality, or nuclear safety related equipment, programs, or processes. The CRs were subsequently screened for operability, categorized by significance and evaluation method, and assigned for evaluation and resolution. The significance categories were significant condition adverse to quality (SCAQ) and condition adverse to quality (CAQ). The evaluation methods were root cause analysis, apparent cause evaluation, limited apparent cause evaluation, fix, and close. The Team attended daily initial screening and management review meetings to assess whether issues were appropriately evaluated and categorized in accordance with BVPS procedures.
The Team reviewed CRs selected across the seven cornerstones of safety in the NRCs Reactor Oversight Program, to determine if problems were being properly identified, characterized, and entered into the CAP for evaluation and resolution. Due dates for each corrective action were checked to verify they were assigned commensurate with the safety significance of the issue. The Team selected items from the maintenance, operations, engineering, emergency planning, security, radiological control, quality assurance, and employee concerns programs to ensure that BVPS was appropriately considering problems identified in each functional area. Based on risk insights, the Team also performed a focused assessment of PI&R for the Unit 1 auxiliary feedwater (AFW)system. The Team selected a risk-informed sample of CRs that had been issued since the last NRC PI&R inspection (August 2005), and for some samples such as the Unit 1 AFW system, reviewed related CRs for the past 5 years.
In addition to CRs, the Team selected items from other processes at Beaver Valley to verify that they appropriately considered problems identified in these areas for entry into the CAP. Specifically, the Team reviewed a sample of SAP notifications, maintenance work orders, control room deficiency and work-around lists, operability determinations, NRC & industry operating experience issues, engineering system health reports, the current temporary modification list, and completed surveillance tests. The documents and activities were reviewed to ensure that underlying problems associated with each issue were appropriately considered for resolution via the CAP. 10 CFR 50.65 a(1) evaluations were inspected to ensure decisions made to place systems in Maintenance Rule a(2)
J. Lash status were appropriate. In addition, the Team interviewed plant staff and management to determine their understanding of and involvement with the CAP. The Team also conducted walkdowns of selected systems and plant areas to assess whether degraded conditions were being properly identified and corrected. The CRs and other documents reviewed, and a list of key personnel contacted, are listed in the Attachment to this report.
- (2) Assessment Identification of Issues No findings of significance were identified in the area of identification of issues.
Overall, the Team considered the identification of problems at Beaver Valley to be appropriate, at a reasonably low threshold, with problems identified during plant activities being entered into the corrective action program (CAP). Approximately 8500 condition reports (CRs) were written per year, not including minor problems entered into SAP. No instances were identified where conditions adverse to quality were being handled outside the CAP. The inspectors did not identify any significant conditions adverse to quality which did not have an associated CR.
However, The Team noted examples where station personnel did not identify conditions adverse to quality:
- An inspection conducted in the Unit 1 river water valve pit flood seals associated with NCV 05000334/2006002-01 in February 2006 did not identify a missing pipe penetration flood seal and consequently did not correct the missing seal in a timely manner. This condition was discovered by the licensee in February 2007. This issue resulted in Green NCV 05000334/2007002-01. Further details are documented in NRC Inspection Report Nos. 05000334(412)/2007002.
- The Team identified an instance where maintenance personnel did not identify that the stuffing box clearance for the Unit 2 auxiliary feedwater pump [2FWE-P23A]
exceeded the limits specified in the repair work order. FENOC engineers consulted with the vendor and determined that, due to the size of the packing installed, the safety function of the pump would not be affected. This is considered a violation of minor significance and is not subject to enforcement action, in accordance with NRCs Enforcement Policy.
Station personnel established appropriate system health goals and performance monitoring criteria to help maintain low thresholds for identifying and resolving problems, resulting in good equipment reliability. Relatively few deficiencies were identified by external organizations, including the NRC, that had not been previously identified by the licensee.
Though improvements in material condition of the plant and control room were noted, the inspectors also observed stray material left within the radiological controlled area and numerous old equipment deficiency tags (some 7 years old). While none of the material issues had safety significance, they indicated deficient ownership of general plant housekeeping and acceptance of long term minor equipment deficiencies. Left uncorrected, minor equipment deficiencies and poor plant housekeeping tend to mask equipment problems which may lead to further degradation of plant equipment. In J. Lash response to this concern, station management initiated several CRs and a new self assessment to evaluate open plant equipment deficiency tags.
Prioritization and Evaluation of Issues No findings of significance were identified in the area of prioritization and evaluation of issues.
The Team determined that FENOCs prioritization and evaluation of issues was generally good. FENOC demonstrated a low threshold for assigning apparent cause and root cause evaluations for specific issues. Clear ownership was demonstrated by each department at the daily CR screening meetings.
System Health reports were of good quality. The inspectors found no inaccuracies with the determinations of maintenance preventable functional failures and maintenance rule functional failures. 10 CFR 50.65 a(1) evaluations were thorough and contained a well explained basis.
Operability determinations were found to be accurate and contained good detail. Where applicable, the basis for continued operation was well articulated. The inspectors found no instances where the basis for operability was inaccurate.
Work orders (WOs) were properly prioritized and had thorough documentation describing the actual work performed. The inspectors verified that FENOC was diligent in ensuring items in the CR process were entered into the SAP database for work order creation. No instances were found where a CR requiring a work order was closed out with no work performed. CRs and WOs had traceability to each other.
Effectiveness of Corrective Action No findings of significance were identified in the area of effectiveness of corrective actions.
The Team concluded that corrective actions were generally appropriate to resolve identified issues, and were typically completed in a timely manner. The majority of the corrective actions reviewed were effective. Examples included CR 05-02510, which resulted in improved maintenance procedure quality and reduced maintenance backlogs and CR 05-06537, which improved plant safety by increasing heat sink availability during online calibration of the main condenser vacuum pressure switches. Corrective actions to address NRC non-cited violations were generally timely and effective.
Notwithstanding the overall effectiveness of corrective actions, the Team identified some instances of ineffective or untimely corrective actions. Examples included:
- The Team identified a minor violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for a failure to take effective corrective actions to address elevated vibrations associated with the Unit 2 main feedwater regulating valve FW-HCV-488 actuator. The resulting air leak degraded the reliability of FW-HCV-488 design function to close.
J. Lash
- Untimely corrective actions led to the unplanned shutdown of Unit 2 A auxiliary feedwater pump 2FWE-P23A due to elevated stuffing box temperatures during surveillance testing (CR 06-4133). Engineers subsequently provided a bounding analysis which proved the pump remained operable, despite the elevated stuffing box temperatures.
- Corrective actions to address an unsuccessful emergency event declaration during licensed operator requalification training was too narrowly focused in that it did not address performance deficiencies by the peer check senior reactor operator (CR 06-04917).
The Team evaluated the CAP deficiencies noted above for potential significance. The Team determined that none of the individual issues was a finding of more than minor significance based upon the guidance in NRC Manual Chapter 0612, Power Reactor Inspection Reports, and therefore, these issues were not subject to enforcement action.
b.
Assessment of the Use of Operating Experience
- (1) Inspection Scope The Team reviewed station and fleet documents pertaining to operating experience (OE)information. The Team also selected a sample of operating experience issues to confirm that station personnel had evaluated the OE information for applicability to Units 1 and 2 and had taken appropriate actions, when warranted. The Team conducted interviews, plant walkdowns, and document reviews to ensure that underlying problems associated with the issues were appropriately considered for resolution via the corrective action process. A list of the specific documents reviewed is included in the Attachment.
- (2) Assessment No findings of significance were identified in the area of operating experience.
The use of OE at Beaver Valley was typically timely and effective. The inspectors found that OE information was appropriately considered for applicability, and corrective and preventive actions were taken, as needed. Operating experience information was integrated into routine activities, such as daily-shift and pre-job briefs, procedures, and training material. The inspectors noted several positive examples in which plant personnel considered alternate sources of OE information, in addition to material provided by the OE Program.
The inspectors noted that the OE process changed in September 2005 and is now facilitated by a FENOC fleet coordinator interfacing with the site OE coordinator. The fleet coordinator performs an initial screening of OE issues from various sources for applicability to the fleet and enters the issue into SAP as a notification for fleet evaluation.
The issue is also forwarded to each FENOC site for further screening and, if needed, site evaluation. Beaver Valley has access to the fleet information in addition to the OE items screened as applicable to the site. A CR is entered into the CAP if it is determined an OE issue necessitates further evaluation, review, or corrective actions.
During a September 2006 fleet OE program assessment, FENOC identified a significant backlog of OE items to be screened by Beaver Valley. A fleet CR was entered into the J. Lash CAP and appropriate corrective actions were implemented. Backlog OE issues were appropriately prioritized and screened in a reasonable period of time. The Team reviewed a sample of prior backlog OE issues and did not identify circumstances which could result in significant degraded conditions based on a failure to timely disseminate OE information.
The existing backlog is managed and does not represent significant undetected or unaddressed issues at Beaver Valley. Despite this deficiency, the team concluded that the OE program at Beaver Valley has improved since 2005, based on consistent integration of OE into routine plant activities and effective resolution of the OE items reviewed.
c.
Assessment of Self-Assessments (SAs) and Audits
- (1) Inspection Scope The Team reviewed a sample of FENOCs Quality Assurance audits, Fleet Oversight Quarterly Performance Reports, Corporate Nuclear Safety Review Board reports, departmental integrated performance assessments (IPAs), and focused area SAs including the most recent self-assessment of the CAP. The sample included the December 2006 BVPS Safety Culture Assessment. The review was performed to determine whether self-assessments and audits were effective at identifying issues, whether identified issues were entered into the CAP, when appropriate, and whether corrective actions were appropriate, commensurate with the issues safety significance.
The effectiveness of the audits and SAs was evaluated by comparing audit and SA results against self-revealing and NRC-identified findings, and current observations during the inspection. A list of the specific documents reviewed is included in the Attachment.
- (2) Assessment No findings of significance were identified.
The Team determined that, in general, audits and assessments were critical, identified meaningful trends and areas for improvement, and the results were entered into the CAP for tracking and resolution. In 2006, in addition to performing SAs on selected focused topics or programs, the licensee began performing broad based IPAs of each section of the organization. The Team observed that several IPAs demonstrated improved quality and performance trend assessment over the previous SA format. Two specific examples of successful IPAs and effective follow-up corrective action were noted. BV-SA-06-096, IPA - Security - 2006 First 6 months, identified an emerging declining trend in equipment reliability. Corrective actions were appropriately implemented. BV-SA-06-023, IPA -
Chemistry - 2005 Second 6 months, identified adverse trends in procedure adherence and procedure level-of-use. Corrective actions included raising the level-of-use for analysis procedures from general skill reference to in-field reference. A second assessment in April 2006 noted that while procedure use was improved, a trend of minor procedure adherence issues continued. A supervisor field observation program and required reading reference binder were established as corrective actions. The Team determined the corrective actions were effectively implemented and Chemistry department procedure use has improved.
The Team noted that SAs and IPAs performed over the past 2 years indicated a continued underlying performance theme of deficient procedure adherence among several station departments. FENOC performed a common cause assessment to J. Lash determine the cause(s) of the continued procedure adherence issues. The principle causal factors as described in 2005 Common Cause Assessment of Human Performance (CR 06-03195) were procedure not followed, incomplete work, and inattention to detail.
Some corrective actions had been implemented with positive results (e.g., reduced vendor/contractor procedure errors, less frequent section clock resets, reduced significance of errors, reduced errors noted during management and peer-to-peer field observations, and improved work order quality). Others (e.g., procedure in-hand day, procedure focus daily - message, pre outage read & sign), were untimely or had not been implemented.
The Team identified several minor procedure violations during this inspection (CRs 07-16920, 07-17129, 07-17175, 07-17248, 07-17487, 07-17555, and 07-17565). These violations occurred broadly across station departments, represented current performance, and were typically associated with administrative or general skill reference category procedures. The Team determined that none of the individual issues was a finding of more than minor significance based upon the guidance in NRC Manual Chapter 0612, Power Reactor Inspection Reports, and therefore, these issues were not subject to enforcement action.
These observations, coupled with a review of CR causal factor trends from 2005 to present, indicated that corrective actions to improve procedure adherence had not been fully effective. Condition reports were appropriately initiated for each issue and station management acknowledged that procedure adherence was a continued problem and was a 2007 station focus area. The Performance Improvement staff informed the Team of several new performance assessment tools and associated corrective actions being generated as a result of these self-assessments. These actions were not yet implemented and therefore were not assessed during this inspection.
d.
Assessment of Safety-Conscious Work Environment
- (1) Inspection Scope The Team observed morning management meetings, pre-evolution briefings, shift turnover briefings, and conducted interviews with station personnel to assess the safety conscious work environment (SCWE) at BVPS. Specifically, the inspectors assessed whether workers were hesitant to enter issues into the CAP or raise safety concerns to their management and/or the NRC due to a fear of retaliation or fear of creating an increased workload which may require excessive overtime to address. The Team reviewed the results of the December 2006 BVPS Safety Culture Assessment, 2005 BVPS SCWE survey, 2006 BVPS SCWE survey, and associated CRs, to assess challenges to the free flow of information. The Team also reviewed employee concerns program (ECP) effectiveness to determine whether employees were willing to use the program as an alternate path for raising concerns. The Team reviewed a selection of 2005 and 2006 ECP files to determine whether issues raised through the program were appropriately addressed. A list of the specific documents reviewed is included in the
.
J. Lash
- (2) Assessment No findings of significance were identified.
The Team determined BVPS supported a safety conscious work environment, in which workers actively participate in the CAP and freely raise issues of concern to station management. Workers and managers alike consistently demonstrated a positive perspective toward improving station safety and working conditions. Station personnel were aware of the importance of nuclear safety and demonstrated a willingness to raise safety issues. The Team noted a positive trend over the last two years in Safety Culture survey participation and positive responses in Security and Chemistry. Overall, the use of overtime was not excessive and periods of elevated overtime (e.g. refueling outages)were reasonably managed.
The Team concluded the ECP was actively used, resulted in reasonable and timely evaluations, and provided feedback to the originators. Based on the interviews and document reviews described above, the Team concluded there was no evidence of any SCWE issues at Beaver Valley.
4OA6 Meetings, including Exit
On April 5, 2007, the Team presented the inspection results to Mr. J. Lash and other FENOC personnel, who acknowledged the results of this inspection. The inspectors confirmed that proprietary information reviewed during the inspection has been returned or would be handled in accordance with 10 CFR 2.390, "Public Inspections, Exemptions, Request for Withholding."
ATTACHMENT: Supplemental Information In addition to the documentation that the inspectors reviewed (listed in the Attachment),copies of information requests given to the licensee and e-mail correspondence between the NRC and licensee personnel are in ADAMS, under accession number ML071350070.
J. Lash
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- S. Baker, Manager, Radiation Protection
Safety and Environmental Protection
- D. Batina, Employee Concerns Representative
- J. Belfiore, Design Engineering
- R. Bisbee, Supervisor, Performance Improvement
- J. Bosiljevac, Supervisor, Nuclear Information Technology Maintainence
- S. Buffington, Design Engineering
- G. Cacciani, Design Engineering
- T. Cosgrove, Director, Maintenance
- T. Cotter, Superintendent, Ops Services
- P. Dawson, Security Contractor
- P. Dearborn, Engineer
- B. Furbak, Supervisor, Chemistry
- J. Gallagher, Technical Services Engineer
- F. Gardner, Design Engineering
- J. Habuda, System Engineer, U1 Auxiliary Feedwater
- M. Johnston, Supervisor, Training Services
- C. Keller, Manager, Regulatory Compliance
- M. Kienzle, System Engineer, U2 Auxiliary Feedwater
- C. Mancuso, Manager, Design Engineering
- M. Manoleras, Director, Engineering
- C. Makowka, Packing Program and Oil Analysis
- J. Mauck, Regulatory Compliance
- D. Mickinac, Operating Experience Coordinator
- M. Mitchell, Supervisor, System Engineering
- N. Morrison, Superintendent, Work Planning
- M. Mitchell, Work Planning and Support
- D. Murray, Manager, Plant Engineering
- F. Oberlitner, Design Engineering
- P. Pauvlinch, Technical Services
- M. Pavlick, Operating Experience Coordinator, FENOC Fleet
- M. Pergar, Supervisor, Nuclear Oversight
- T. Porter, Nuclear Oversight
- R. Rossomme, Manager, Fleet Cap
- D. Salera, Manager, Chemistry
- F. Schweitzer, Advanced Nuclear Specialist, Chemistry
- P. Sena, Director, Site Operations
- B. Sepelak, Supervisor, Compliance
- G. Shildt, Plant Engineer
- J. West, Staff Nuclear Engineer, Plant Engineering
- B. Winters, Advanced Nuclear Specialist, Chemistry
J. Lash
Others
- R. Bellamy, Branch Chief, USNRC
- P. Cataldo, Senior Resident Inspector, USRNC
- L. Ryan, PA-BRP
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Open and
Closed
None