IR 05000334/2011003
| ML112140011 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley  |
| Issue date: | 08/02/2011 |
| From: | Darrell Roberts Division Reactor Projects I |
| To: | Harden P FirstEnergy Nuclear Operating Co |
| BELLAMY RR | |
| References | |
| EA-11-160 IR-11-003 | |
| Download: ML112140011 (42) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION I
475 ALLENDALE ROAD KING OF PRUSSIA. PA,I9406.1415
SUBJECT:
BEAVER VALLEY POWER STATION . NRC INTEGMTED INSPECTION REPORT 05000334/2011003 AND 0500041212011003, AND EXERCISE OF ENFORCEMENT DISCRETION
Dear Mr. Harden:
On June 30, 2011, the United States Nuclear Regulatory Commission (NRC) completed an inspection at your Beaver Valley Power Station Units 1 and2. The enclosed integrated inspection report documents the inspection results, which were discussed on July 21, 2011, with members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and iecords, observed activities, and interviewed personnel.
Based on the results of this inspection, this report documents one (1) NRC-identified finding (Green) and one (1) self-revealing finding of very low safety significance (Green). One finding was determined to involve a violation of NRC requirements. However, because of the very low safety significance and because it was entered into your corrective action program (CAP), the NRC is tieating this as a non-cited violation (NCV), consistent with Section 2.3.2 of the NRC's Enforcement Policy.
lf you contest any of the findings in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for lour denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the RegionalAdministrator Region l; the Director, Officp of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Beaver Valley. In addition, if you disagree with the characterization of the cross-cutting aspect of any finding 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 Regional Administrator, Region 1 and the NRC Senior Resident Inspector at the Beaver Valley Power Station. The information you provide will be considered in accordance with lnspection Manual Chapter 0305.
Additionally, the inspectors reviewed Licensee Event Report 50-41212011-001, which described the details associated with defective diesel generalor fuel injection pump supply lines resulting in the Train 'A' Emergency Diesel Generator (EDG) being declared inoperable. This issue constituted a violation of NRC requirements, in that FENOC operated with both EDGs inoperable without immediately taking actions to restore an EDG to operable status in accordance with Technical Specifications (TS). However, the NRC concluded that the cause of the inoperability, incorrectly assembled compression fittings on replacement fuel injection pump supply lines, was due to an inadequate vendor design change and therefore, did not represent a perfoimance deficiency on the licensee's part. The NRC noted that FENOC took immediate action to ensure availability of at least one EDG, deolared the EDG inoperable in a timely manner, and effectively implemented the TS required action statement to immediately initiate action to restore operability. The NRC's risk evaluation determined the issue to be of very low safety significance. Based on these facts, I have been authorized, after consultation with the Direcior,-Office of Enforcement, and the Regional Administrator, to exercise enforcement discretion in accordance with the NRC Enforcement Policy and refrain from issuing enforcement for the violation.
ln accordance with 10 CFR 2.390 of the NRC's "Rulps of Practice," a copy of this letter, and its enclosures, and your response (if any) will be availaple 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 Website at http://www.nrc.qovlreadino-rmiadams.html (the Public Electronic Reading Room). We appreciate your cooperatton Please contact me at 610-337-5200 if you have any questions regarding this letter.
SincerelY,
,^M%"
Division of Reactor Projects Docket Nos.: 50-334, 50-412 License Nos: DPR-66, NPF-73
Enclosures:
Inspection Report 05000334/201 1003; 050004121201 1003 w/ Attachment: Supplemental Information
REGION I Docket Nos. 50-334, 50-412 License Nos. DPR-66, NPF-73 Report Nos. 05000334/201 1 003 and 050004121201 1003 Licensee: FirstEnergy Nuclear Operatin$ Company (FENOC)
Facility: Beaver Valley Power Station, Units 1 and 2 Location: Shippingport, PA 15077 Dates: April 1 ,2011through June 30, 2011 Inspectors: D. Werkheiser, Senior Residqnt Inspector E. Bonney, Resident Inspectdr C. Crisden, Emergency Preparedness Specialist T. Moslak, Health Physicist T. Ziev, Reactor Engineer Approved by: R. Bellamy, Ph.D., Chief Reactor Projects Branch 6 Division of Reactor Projects Enclosure
TABLE Of REPORT DETAILS Summarv of Plant Status:
Unit 1 began the inspection period at 100 percent R{wer. On April 7, the unit was down-powered Io 82 percent for planned waterbox cleaninp, then commenced a planned shutdown for ieplacement of a power range nuclear instrument (\l-+21 The unit commenced a startup on April 16, and retuined to full power on April 21. The unit remained at 100 percent power for the remainder of the inspection period.
Unit 2 began the inspection period shut down in a rd[ueling outage. On April 8, the unit commenCed a start-up. On April 10, the unit reachep leVo reactor power and performed a required shutdown in response to an AFW system l{ak, prior to synchronization. The unit restarted on April 10, and returned to full power on ,$Rril 14. The unit was down-powered to 94 percent on npiit 26for a reheater drain control vaMl repair and returned to full power on April 27. The unit remaine.d at 100 percent power for the remainder of the inspection period'
1. REACTOR SAFETY Cornerstone: Initiating Events, Mitigatirig Systems, Barrier Integrity [R]
1R01 Adverse Weather Protection (71111.01)
a. Inspection Scope (2 samples: hot weather power system readiness)
Seasonal Susceotibilitv The inspectors reviewed the Beaver Valley Station (BVPS) design features and FENOC's implementation of procedures to risk significant mitigating systems from adverse weather effects due to su weather. The inspectors reviewed the corrective action program database, experience, and the Updated Final Safety Analysis Report (UFSAR), to determine the of adverse weather conditions to which the site is susceptible, and to verify tl the licensee was appropriately identifying and resolving weather-related equipment blems.
The inspectors evaluated BVPS design featg res and FENOC's imPlementation of procedures to address issues that could imp ct offsite alternating current (AC) power systems. The inspectors reviewed FENOC': procedures and programs which discussed the operation and availability/reliability of offi ite and alternate AC power systems during adverse weather. The inspectors verified th t communication protocols between the transmission system operator and FENOC e isted, and the appropriate information would be conveyed when potential grid stre s and disturbances existed. The inspectors also verified that FENOC's procedures cont ined actions to monitor and maintain the availability/reliability of offsite and onsite po er systems prior to and during adverse weather conditions.
b. Findinqs No findings were identified.
Enclosure
1 R04 Equipment Alionment (71111.04)
.1 Partial Svstem Walkdowns (71111.04O)
a. Inspection Scope (3 samPles)
The inspectors performed three partial alignment inspections during conditions of increased safety significance, uding when redundant equipment was unavailable during maintenance or adverse itions. The partial alignment inspections were also completed after equi was recently returned to service after significant maintenance. The inspectors partial walkdowns of the following systems, including associated electrical d bution components and control room panels, to verify the equipment was aligned perform its intended safety functions:
. Unit 2, April 25,'A' train component water (CCW) during 'B' CCW heat exchanger cleaning;
. Unit 2, June 22, temporary air system line-up during'B' station air compressor maintenance; and
. Unit 1, June 24, 1-2 emergency diesel g$nerator (EDG) fuel oil transfer pump (FOTP) system during 1-1 EDG fuel oil tr]ansfer pump (FOTP) testing.
b. Findinos No findings were identified.
.2 Complete Svstem Walkdown (7 1 I 11 .04S)
a. Inspection Scope (1 samPle)
The inspectors completed a detailed review the alignment and condition of the Unit 2
'A'train low head safety injection (LHSI) . The inspectors conducted a walkdown of the system to verify that the critical porti such as valve positions, switches, and breakers, were correctly aligned in accorda with procedures, and to identify any discrepancies that may have had an effect operability.
The inspectors also reviewed outstanding tenance work orders to verify that the deficiencies did not significantly affect the I system function. ln addition, the inspectors discussed system health with the engineer and reviewed the condition report database to verify that equipment nt problems were being identified and appropriately resolved. Documents revi during the inspection are listed in the Attachment.
b. Findinqs No findings were identified.
Enclosure
1R05 Fire Protection (71111.05)
.1 Quarterlv Sample Review (71111.05O)
a. lnspection Scope (5 samPles)
The inspectors reviewed the conditions of fire areas listed below, to verify compliance with criteria delineated in Admin Procedure 1 l2-ADM-1900, "Fire Protection," Rev. 23. This review included 's control of transient combustibles and ignition sources, material condition of protection equipment including fire detection systems, water-based fire systems, gaseous fire suppression systems, manual firefighting equipment and ty, passive fire protection features, and the adequacy of compensatory s for any fire protection impairments.
Documents reviewed are listed in the ent:
. Unit 1, Auxiliary Building General Area ({ire Area PA-1A);
. Unit 2, Cooling Tower Pump House (Fire Area CTP-1);
o Unit 2, Auxiliary Boiler Area (Fire Area SpB-1);
. Unit 2, South Office Shops Building Railviray Bay (Fire Area SOB-2); and
. Unit 2, South Office Shops Building (Fire Area SOB-3).
b. Findinos No findings were identified.
.2 Annual Fire Drill Observation (71111.05A)
a. Inspection Scope (1 samPle)
The inspectors observed personnel ce during a fire drill involving a simulated fire at the Unit 1 'B' System Station Service (SSST) on April 19, to evaluate the readiness of station personnel to and fight fires. The inspectors observed the fire brigade members using protective ing, turnout gear, and self-contained breathing apparatus and entering the fire in a controlled manner. The inspectors also observed the fire fighting equipment to the fire scene to evaluate whether sufficient equipment was available to control and extinguish the simulated fire.
The inspectors evaluated whether the plant fire hose lines were capable of reaching the fire area and whether hose u was adequately simulated. The inspectors observed the fire fighting and communications between fire brigade members. The inspectors verified that the drill scenario was followed and observed the post drill critique to evaluate if drill objectives were satisfied and that any drill weaknesses were discussed.
Findinqs No findings were identified.
Enclosure
1R06 Flood Protection Measures (71111.06)
a. Inspection ScoPg (1 samPle)
The inspectors reviewed a sample of i flood protection measures for equipment in the common intake structure'D' cubicle ining safety-related service water equipment for Unit 2.
This review was conducted to evaluate F protection of the enclosed safety-related systems from internal flooding The inspectors performed a walkdown of the area, reviewed the UFSAR, related I flooding evaluations, and other related documents. The inspectors examined the nd equipment and conditions to ensure that they remained consistent with those ted in the design basis documentation, flooding mitigation documents, and risk assumptions. Documents reviewed during the inspection are listed in the A ent.
b. Findinos No findings were identified.
1R07 Heat Sink Performance (71111.07)
.1 Annual Sample Review (71111.07A)
a. Inspection Scgoe (1 samPle)
The inspectors reviewed the maintenance with the Unit 2'B'train RSS HX conducted in March and April 2011, in with 2CMP-1 3RSS-E-21 A-B-C-D-1 M,
"Recirculation Spray Heat Exchanger ," Rev. 7. The review included an assessment of the testing methodology and consistency with Electric Power Research lnstitute document NP-7552, Exchanger Performance Monitoring Guidelines," December 1991, and Generic tter 89-13, "Service Water SYstem Problems Affecting Safety-Related Equ " The inspectors reviewed maintenance results, related condition reports and 'B' Service Water System fullflow test results against applicable acceptance criteria.
b. Findinqs lntroduction: A Green, self-revealing non-ci violation (NCV) of TS 5.4.1,
"Procedures", was identified in that the Unit RSS Heat Exchangers HXs were not maintained in chemicalwet layup, contrary station procedures. Specifically, FENOC failed to maintain corrosion inhibitors in the HXs, resulting in significant HX corrosion, which led to degraded flow the 'B' RSS HX during a service water full flow test.
Descriotion: On February 24, during a 'B' service water (SW) fullflow test, Unit 2 discovered degraded flow through the 'B' HX. The as-found SW flow through the
'B' RSS HX during the full flow test was )gpm, which resulted in a failed surveillance test. The required SW flow rate through 'B' RSS HX was 5731 gPm Per 2OST-30.13.138, "Train 'B' Seryice Water System Full Flow Test". On March 4th, the'B' RSS HX was removed from service for i and cleaning. The inspection identified a Enclosure
I significant amount of corrosion products blo(king ftow in the fower end bell of the vertically-mounted heat exchanger. The corfosion products were removed from the end bell andhydrolazing was performed on the $W piping during the 2R15 outage in Aprilto restore system function.
The RSS HXs were originally placed in wet in November of 2008. Procedure 2OM-30.4.T, "Placing Recirc Spray HXs into Chemical Wet Layup", established that corrosion inhibitors are required to maintain HXs in wet layup. A maintenance review of the four RSS HXs determined that inhibitors were last added to the
'B'and 'D' RSS HXs in November 2008, the'A'and 'C' RSS HXs were last placed in wet layup in October 2009, per 2OM-30.4.T.
EPRI NP-7552, "Heat Exchanger Performa Monitoring Guidelines," allows use of the periodic maintenance method to comply heat exchanger testing methodology.
Water treatment is one of three periodic m methods used by FENOC to ensure adequate RSS HX performance. E NP-7552 states that "improper water treatment can result in accelerated , resulting in component reliability concerns." The work management process not utilized to establish a periodic chemical test and addition to maintain the wet layup chemical profile. Sampling of the RSS HXs was not Performed to the correct chemical concentration existed to ensure the selected maintenance method was effective. FENOC subsequently generated recurring work orders 200450991 and 200450994 to correct the issue and ensure allfour RSS HXs are maintained in proper chemical wet layup condition.
Analvsis: The failure to maintain the RSS in chemicalwet layup is considered a performance deficiency. Traditional t does not apply because the issue did not have an actual safety consequence or potential for impacting NRC's regulatory function, and was not the result of any wil violation of NRC requirements. The inspectors determined that the finding was similar to the examples for minor deficiencies contained in IMC A612, E, "Examples of Minor lssues". The finding is more than minor because it the Mitigating Systems and Barrier Integrity cornerstones. The finding is associated wi the equipment performance attribute of the Mitigating Systems cornerstone to ensure availability, reliability, and capability of systems that respond to initiating events to undesirable consequences and is also associated with the SSC and barrier aftribute of the Barrier IntegritY cornerstone to provide reasonable that physical design barriers (fuel cladding, reactor coolant system and conta ment) protect the public from radionuclide releases caused by accidents or events'
ln accordance with IMC 0609.04 (Table 4a Phase 1 - Initial Screening and Characterization of Findings," the finding determined to be of very low safetY significance (Green) because the finding d not result in a loss of operability nor was it a degradation of a radiological barrier, control barrier, hydrogen igniter, or an open pathway.
The cause of this NCV relates to the tting aspect of Human Performance, Work Control, in that FENOC personneldid not te work activities consistent with nuclear safety. Specifically, FENOC did coordinate work activities to complete the chemicalwet layup condition to support equipment reliability of the Unit 2 RSS HXs. H.3(b)
Enclosure
Enforcemen!: TS 5.4. 1, "Procedures", that procedures be established, implemented, and maintained as recom in Appendix A of Regulatory Guide 1.33.
Regulatory Guide 1.33, Section 10 requires, part, chemical and radiological control procedures to maintain water quality within bed limits and the limitations on concentrations of agents that may cause ive attack or fouling of heat-transfer surfaces. Contrary to the above, FENOC fa to maintain the RSS HXs in chemical wet layup in accordance with station res and EPRI NP-7552, which resulted in significant fouling of the B RSS HX. Beca this deficiency is considered to be of very low safety significance (Green), and was into the corrective action program (CR 11-90430), this violation is being treated as n NCV, consistentwith Section2.3.2 of the NRC Enforcement Policy. (NCV 0500041 1003-1, Failure to Maintain Recirculation Spray Heat Exchangers in hemicalWet LayuP)
1R1 1 Licensed Operator Requalification Prooram 71111.11)
.1 Resident Inspector Quarterlv Review (71111 .11O)
a. Inspection Scope (1 samPle)
The inspectors observed one sample of 1 licensed operator simulator training and drill on June 29. The inspectors evaluated operator performance regarding command and control, implementation of annunciator response, abnormal, and emergency operating Procedures, technical specification review and compliance, and emergencY Plan i . The inspectors evaluated the licensee staff training personnel to verify deficiencies in operator performance were identified, and that conditions adverse to lity were entered into the licensee's corrective action program for resolution. inspectors reviewed simulator physical fidelity to assure the simulator appropriately led the plant control room. The inspectors verified that the training eva adequately addressed that the applicable training objectives had been achieved.
b. Findinqs No findings were identified.
1R12 Maintenance Rule lmplementation (71111 -1 a. Inspection Scope (3 samPles)
The inspectors evaluated Maintenance (MR) implementation. The inspectors evaluated specific attributes, such as MR ino. characterization of failed structures, systems, and components (SSCs), MR risk of SSCs, SSC performance criteria and goals, and appropriateness of actions. The inspectors verified that the issues were addressed as required 10 CFR 50.65 and the licensee's program for MR implementation. For the selected the inspectors evaluated whether performance was properly dispositioned for category (aX1) and (a)(2) performance monitoring. MR System Basis Documents also reviewed. Documents reviewed are listed in the Attachment.
. On April 2, Unit 2, 'A'train solid state system 48 volt power supply failure, documented in CR 11-92245; Enclosure
On April 25, Unit 1 and 2, maintenance le program health "EquiPment Performance" yellow cornerstone, in CR 11-92375: and On April 27, Unit 2, emergencY diesel maintenance rule (aXl ) evaluation due to goalfailure, documented in CR 1 3.
b. Findinos No findings were identified.
1R13 (71111.13)
a. Inspection Scope (4 samPles)
The inspectors reviewed the scheduling and of four activities, and evaluated their effect on overall plant risk. This review conducted to ensure compliance with applicable criteria contained in 10 CFR 50 a)(4). Documents reviewed during the inspection are listed in the Attachment.
o On April 14, Unit 1, planned entry into risk for transformer breaker work;
. On April 15, Unit 2, risk evaluation for addition to'A'and'C'RSS HXs Per wo 200451815;
. On May 24, Unit 1, planned maintenat during 'A' intake structure bay outage; and
. On May 26-27, Unit 2, PRA review for ne-driven auxiliary feedwater pinhole steam leak repairs.
b. Findinqs No findings were identified.
1R15 Operabilitv Evaluations (7 1 1 1 1 .15)
a. lnspection ScoPe (6 samPles)
The inspectors evaluated the technical of selected immediate operability determinations (lOD), prompt operability nations (POD), or functionalitY assessments (FA), to verifY that of operability were justified. In addition, the inspectors verified that technical (TS) limiting conditions for operation (LCO) requirements and UFSAR design requirements were properly addressed'
In addition, the inspectors reviewed com measures implemented to ensure the measures worked and were adequately con Documents reviewed are listed in the Attachment.
On March 31, Unit 2, pressurizer safety ve [2RCS-RV551C] gasket evaluation and acceptability as documented in CR 1-92159:
On April 4, Unit 1 evaluation of river piping below nominal thickness as documented in CR 11-92133; On May 3, Unit 2, stroke time for'B'a dump valve outside accePtance range as documented in CR 11-94053; On May 9, Unit 1, 'B'quench sPraY [1 QS-P-1 B] comPrehensive test acceptance criteria not meet evaluation documented in CR 11'94414; Enclosure
On June 8, Unit 1, IOD regarding net suction for fuel oil transfer for emergency diesel generators as in CR 11-96157; and
. On June 22, Units 1 and 2,licensee 1 1 evaluation regarding the MOV/AOV Kalsi Engineering Valve and Actuator software.
b. Findinos No findings were identified.
1 R18 Plant Modifications (71111.18)
a. lnspection ScoPe (2 samPles)
The inspectors reviewed the following nent and temporary modifications based on risk significance. The permanent and associated 10 CFR 50.59 screenings were reviewed against the design basis documentation, including the UFSAR and the TS. The inspectors verified that attributes and parameters within the design documentation were consistent with licensing and design bases, as well as credited codes and standards, and down the systems to verify that changes described in the package were a implemented. The inspectors verified the temporary modifications were implemented accordance with Administrative (ADM)
Procedure, 1 l2-ADM-2028, "Temporary tions," Rev. 6. The inspectors also verified the post-modification testing was sfactorily accomplished to ensure the system and components oPerated with their intended safety function.
Documents reviewed are listed in the Atta
. On March 26, Unit 2ECP 09'0771 to maintain a packing follower retainer on 2SWS-184; and
. On April 4, Unit 2 ECP-11-0179, d of BV-DC-SWBD 2-1 alarm.
b. Findinqs No findings were identified.
1R19 Post-Maintenance Testinq (71111'19)
a. lnspection ScoPe (7 samPles)
The inspectors reviewed the following to determine whether the Post-maintenance tests (PMT) adequately that the safety-related function of the equipment was satisfied given the scope of work, and that operability of the system was restored. In addition, the inspectors ted the applicable acceptance criteria to verify consistency with the design and bases, as well as TS requirements. The inspectors witnessed the test or reviewed tt data to verify results adequatelY demonstrated restoration of affected safety nctions. The inspectors also verified that conditions adverse to quality were entered i the corrective action Program for resolution. Documents reviewed during the spection are listed in the Attachment.
. On March 25, Unit 2,WO 2Q0450628 a rebuild of loop fill header relief valve
[2CHS-160];
Enclosure
,B'
o On April 3, Unit \WO 200451094 HX retesting after lower-end cleaning; o On April 6, Unit 2, WO 200452432 -MOV-1 55-2 testing after maintenance; a On April 10, Unit 2, non-destructive exa ination and pressure test after weld repairs to 2FWE-940 connection Per WO 2011 On April 15, Unit 1, WO 200451486 Range Nuclear Instrument (PRNI) N42 testing and performance after detector during outage 1POAC4; On April 17, Unit 1 adjustment of PRNI 42trip set points post-detector replacement; and o On May 5, Unit 1 'C'charging pump replacement and vent valve installation, b. Findinqs No findings were identified.
1R20 Refuelino and Outaoe Activities (71111'20) samples total)
.1 Unit 2 Refuelinq Outaoe (2R15)
a. Inspection Scope (1 samPle)
The inspectors observed selected outage to determine whether shutdown safety functions (e.9. reactor decay heat , spent fool pool cooling, and containment integrity) were properly ma tained as required bY TS and Plant procedures. The inspectors evaluated performance attributes including operator performance, communications, and instrum accuracy. The inspectors reviewed procedures and/or observed selected activi associated with the Unit 2 refueling outage. The inspectors verified activities performed in accordance with procedures and verified required acceptance criteria met. The inspectors also verified that conditions adverse to quality identified performance of selected outage activities were identified as required by the licensee's corrective action program. Documents reviewed are listed in the Attachment. The pectors also evaluated the:
o Final containment walkdown and close< inspection;
. Reactor start-ups (April 8 and April 10) heat-up; o Balance of plant walkdown during powe ascension.
The inspectors also observed selected review activities associated with restart readiness of Unit 2, following of the 2R15 refueling activities. The restart readiness review meeting was as required by NOBP-OM-4O10,
"Restart Readiness for Plant Outages,' Rev. 4, on March 30. The purpose of the review, in part, was to assure that the plant's condition, programs/processes, and personnel were ready for startup and safe, operation after completion of outage activities.
The inspectors observed the reactor trip shutdown on April 10 (return to Mode 3) in response to an AFW header leak as in NRC Event Notification 46744 (see Section 4OA3.1). lnspectors also observed subsequent reactor start up and power ascension following the repair to the AFW later in the evening on APril 10.
Enclosure
b. Findinqs No findings were identified.
.2 Unit 1 Maintenance Outaoe (1POAC4)
a. Insoection Scope (1 samPle)
The inspectors reviewed licensee during a planned maintenance outage following a Unit 1 shutdown on April 10, to the failed Power Range Nuclear lnstrument (PRNI-42) detector and to other plant related issues. The inspectors reviewed compliance to TS requirements approved procedures, conduct of outage risk evaluations, configuration control, and of key safety functions.
Documents reviewed during the inspection listed in the Attachment. During this maintenance outage, the inspectors FENOC's control of the outage activities listed below:
. Reactor Shutdown and Shutdown risk e
. Startup Readiness Review (April 15) anr Scheduling r Reactor Startup (April 15) and Criticality April 16)
o Plant Startup
. Power Ascension b. Findinos No findings were identified.
1R22 Surveillance Testinq (7 1111.22)
a. Inspection Scooe (6 samples: 1 isolation 1 leak rate, 1 in-service testing and 3 routine)
The inspectors witnessed the performance or reviewed test data for the eight following Operation Surveillance Test (OST) and nce Surveillance (MSP) packages. The reviews verified that the equipment or were being tested as required by TS, the UFSAR, and procedural requirements. The inspectors also verified that the licensee established proper test conditions, that no uipment pre-conditioning activities occurred, and that acceptance criteria were
. On April 2, Unit 2, 2BW-1'47 '11, Sl Charging System Containment Penetration Valve Integrity Test;
. On April 6, Unit 2, 2OST-30.138, Train Service Water System Full Flow Test; On April 10, Unit 1, l05T-6.24, Generated Reactor Cooling SYstem Water Balance lnventory; o On April 11, Unit 2, 2OST-24.9, Trip Test of Turbine Driven AFW; a On April 12, Unit 1, lRST-3.4, Incore ysis of Quadrant Power Tilt Ratio; and a On May 26, Unit 2,2OST-24.4, Steam Auxiliary Feed PumP l2Fal\,lE-P221 Quarterly Test.
Enclosure
Findinqs No findings were identified.
Gornerstone: Emergency Preparedness 1EP2 (71114.02)
a. lnspection Scooe (1 samPle)
An onsite review was conducted to assess maintenance and testing practices of the Beaver Valley ANS. During the inspection, inspectors reviewed the ANS maintenance and testing procedure, and test records, and the Federal Emergency Management Agency (FEMA) design report to ensure FENOC compliance with design report commitments system maintenance and testing. A sample of condition reports (CRs) to the ANS was reviewed for causes, trends, and corrective actions. The i interviewed FENOC corporate staff to discuss system performance and upgrades. The inspection was conducted in accordance with NRC Inspection Procedure 1114, Attachment 2. Planning Standard, 10 CFR 50.47(bX5) and the related of 10 CFR 50, Appendix E, were used as reference criteria.
b. Findinqs No findings were identified.
1 EP3 (71114.03)
a. Inspection tttgvvvlrvrr Scope vvvyv (1 t I samPle)
The inspectors conducted a review of Beav{r Valley's ERO augmentation staffing requirements and the process for notifying aird augmenting the ERO. The review was performed to ensure the readiness of key licpnsee staff to respond to an emergency event and to ensure FENOC's ability to actir/ate their emergency response facilities in a timely manner. The inspectors reviewed thg Beaver Valley Emergency Plan, duty roster, and iugmentation data. The inspectors als{ reviewed a sampling of ERO responder's traininfrecords to ensure training and qualilications were up to date. The inspection was conducted in accordance with NRC Insfiection Procedure71114, Attachment 3.
Planning Standard, 10 CFR 50.47(bX2) and]related requirements of 10 CFR 50, Appendix E, were used as reference criterial b. Findinqs No findings were identified.
Enclosure
1EP4 (71114.04)
a. Inspection Scooe (1 samPle)
Since the last NRC inspection of this area in April2010, FENOC implemented various revisions to the Beaver Valley Plan. FENOC had determined that, in accordance with 10 CFR 50.54(q), these made to the Plan, and its lowertier implementing procedures, had not resulted i any decrease in effectiveness of the Plan, and that the revised Plan continued to meet requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR 50. Although no action level (EAL)changes were reviewed during this inspection, a sample of plan changes, including the changes to lowertier emergency plan ting procedures, was evaluated for any potential decreases in effectiveness of the Vafley Emergency Plan. However, this review by the inspectors was not in an NRC Safety Evaluation RePort and does not constitute formal NRC of the changes. Therefore, these changes remain subject to future NRC inspection in ir entirety. The requirements in 10 CFR 50.sa(q) were used as reference criteria.
Findinos No findings were identified.
a. Inspection Scope (1 samPle)
The inspectors reviewed a sampling of self procedures and reports to assess FENOC's ability to evaluate their preparedness (EP) Performance and program. The inspectors reviewed a pling of CRs from SePtember 2009 through May 2011 initiated by FENOC from self-assessments, and audits. The inspectors also reviewed 10 CFR 50.54(t) it reports and nuclear oversight audits.
This inspection was conducted in with NRC Inspection Procedure 71114, Attachment 5, Planning Standard, 10 CFR .47(b)(14) and the related requirements of 10 CFR 50, Appendix E, were used as criteria.
b. Findings No findings were identified.
lEPO Drifl Evaluation (71114,00)
a. Inspection ScoPe (1 samPle)
The inspectors observed an emergency Red Team mini-drill and Unit 1 licensed-operator simulator evaluation a drillon June 29. Senior licensed-operator performance regarding event cl and notifications was specifically evaluated. The inspectors evaluated the .based scenario that involved multiple, safety-related component failures plant conditions that would have warranted emergency plan activation, facility activation, and escalation to the event classification of Site Area Emergency FENOC planned to credit this evolution toward Emergency PreParedness Performance ( DEP) l nd icators, Enclosure
therefore, the inspectors reviewed the ble event notifications and classifications to determine whether theY were credited, and properly evaluated consistent with Nuclear Energy Institute ( ) 99-02, Rev. 6, "Regulatory Assessment Performance Indicator Guideline." The reviewed licensee evaluator worksheets regarding the performance acceptability, and reviewed other crew and operator evaluations to ensure adverse itions were appropriately entered into the Corrective Action Program. Other utilized in this inspection include the following:
. 112-ADM-1111, Rev.4, "NRC EPP Indicator Instructions;"
I 12-ADM-11 1 1.F01, Rev. 3, "Emergency Performance Indicators Classifications/Notifications/PARS " ;
o EPP-I-1a/b, Rev. 14, "Recognition and of Emergency Conditions;"
o 1l2-EPP-l-2, Rev. 35, "Unusual Event;"
. 112-EPP-l-3, Rev.33, "Alert;"
. 112-EPP-!-4, Rev. 33, "Site Area
. 112-EPP-l-5, Rev.34, "General b. Findinqs No findings were identified.
2. RADIATION SAFEW Cornerstone: Public Radiation Safety [PSI 2RS05 Radiation Monitorinq lnstrumentation (7 112 05)
lnspection Scope (1 samPle)
Reactor Building Supplemental Leak and Release System (SCLRS)
Monitor, RM-1VS-110
. Auxiliary Building Exhaust Monitor, RM-1 111
. Reactor Building SCLRS Noble Gas Mor RM-1-VS-1 12 Liquid Effluent Monitors:
. Liquid Waste Effluent Monitor, RM-1LW-
. Contaminated Drains Effluent Monitor, R 1LW-116 o Component Cooling Water Monitor, RM- RW-101 In Unit 2, the walkdown included portions of following monitors:
Gaseous Effluent Monitors:
. Ventilation Vent Monitor, 2HVS-RQ101
. Supplemental Leak Collection and Relt System (SCLRS) Monitor, 2HVS-RQl 09 Liquid Effluent Monitors:
. Liquid Waste Effluent Monitor, Calibration and Testinq Proqram Through record reviews, the inspector that the effluent monitoring instruments were properly calibrated, and that the source checks and functionaltests had been routinely performed. The inspector that the effluent monitor alarm set points are established in accordance with Offsite Dose Calculation Manual (ODCM).
The inspector reviewed contamination sa results (per 10 CFR Part 61) used to cha racterize difficu lt-to-measure to determine if the calibration sources were representative of the radioisotopes fou in the plant's source term.
Problem ldentification and Resolution The inspector reviewed selected Condition (CRs), system health rePorts, and various Nuclear Oversight reports to eva the licensee's threshold for identifying, evaluating, and resolving problems for the monitoring instrumentation.
lncluded in this review were CRs related to worker and radiation Protection technician errors to determine if an pattern traceable in the maintenance or use of radiation instruments was evident.
b. Findinqs See finding in section 4OM.3 Enclosure
2RSO6 (71124.06)
a. Inspection Scope (1 samPle)
During the period June 20 - 23, the conducted activities to verify FENOC was properly maintaining the gaseous and liquid processing systems to ensure that radiological releases were properly monitored, and evaluated with respect to public exposure. lmplementation of these was reviewed against the criteria contained in the 10 CFR Parts 20 and 50, licensee's ODCM, and the licensee's procedures.
Effluent Report Reviews The inspector reviewed the 2009 and 2010 Radiological Effluent Release Reports to verify that the effluents program implemented as required by the ODCM.
lncluded in this review were the results of ground water protection program, the inclusion of Carbon-14 dose contributions, current land use census, and verification that no significant changes were made to Unit 1 and Unit 2 gaseous and liquid release system configurations, as specified i the Final Safety Analysis Report (FSAR)
and ODCM descriptions.
Walkdowns and Observations The inspector walked down the major comp{nents of the Unit 1 and Unit 2 gaseous and liquid release systems to verify the system cfnfigurations.complied with the FSAR description, to evaluate equipment material $ondition, and determine the status of system upgrades.
The inspector reviewed the most current Uni 1 and Unit 2 liquid and gaseous effluent monitor monthly source checks, quarterly fu ctional test results and 18-month calibration records to verify that instrumentation and as ociated pumps/isolation valves or fans/isolation dampers, respectively, were o erable.
The inspector reviewed the air cleaning systfms surveillance test results for the High Efficiency particulate Absolute (HEPA) anO {harcoal filtration systems installed in Unit 1 and Unit 2. The inspector confirmed that th$ air flow rates were consistent with the FSAR values and the filtration system test r{sults met the acceptance criteria.
Samplino and Analvsis The inspector reviewed the relevant samplinp/analytical procedures and observed a technician collect a weekly air sample from tfre Unit 2 Decontamination Building ventilation system (2RMO-RQ301B) and an lyze the sample on a gamma spectrophotometer. The inspector confirme{ tnat the technician.complied with the procedural requirements in taking the gas s{mple and the sample was appropriately analyzed.
Enclosure
programs to verify that the accuracy of other used for counting effluent samples were operating reliablY.
The inspector confirmed that procedures been established and alternative sampling equipment is readily available for , if normal effluent monitors become unavailable.
Dose Calculations The inspector reviewed monthly, quarterly, a annual dose projections for liquid and gaseous effluents performed during the past 2 months to verify that effluent was processed and released in accordance with requirements and to ensure that FENOC licensee properly calculated the dose from effluent releases. The inspector confirmed that no performance (criteria contained in Appendix I to 10 CFR Part 50) was exceeded for these re The inspector observed a technician a liquid discharge permit (No. 5823) for releasing the steam generator condensates nk (2SGC-TK23B). The insPector reviewed other liquid discharge permits for it 1 and Unit 2 to evaluate the adequacy of dilution flow, radioactive content, set point ustment on liquid waste monitor 2SGC-RQ100, and overall accuracy of the data.
Ground Water Protection Program The inspector verified that FENOC is continqing to implement the voluntary NEI/Industry Ground Water Protection Initiative. The insppctor reviewed monitoring well sample results, trending data, and decommissioning records, maintained per 10 CFR S0.7S [g), to evaluate procedural corfnpliance and to identify off normal results.
b. Findinos No findings were identified.
4. oTHER ACTIVITIES [OAl 4OA1 Performance lndicator Verification (7 1151)
a. Inspection Scope (9 samples total)
The inspectors sampled licensee submittals Performance Indicators (Pl) listed below for both Unit 1 and Unit 2 to verify accuracy the data recorded from July 2010 through June 201 1. The inspectors reviewed Licen Event Reports, condition rePorts, portions of various plant operating logs and and Pl data develoPed from monthlY operating reports. Methods for compiling reporting the Pls were discussed with cognizant engineering and licensing pers L To verify the accuracy of the Pl data reported during this period, Pl definitions guidance contained in Nuclear Energy Institute (NEl) 99-02, "Regulatory lndicator Guideline," Revision 6, were used for each data element.
Enclosure
Cornerstone: Mitiqatinq Svstems (2
. Unit 1 and Unit 2 Safety System lFailure [MS05];
Cornerstone: Barrier lnteqritv (4 samples)
. Unit 1 and Unit 2 Reactor Coolant Activity [B101]
. Unit 1 and Unit 2 Reactor Coolant Leak Rate [8102]
Cornerstone: Emeroencv Preparedness (3 mples)
The inspectors reviewed data for EP Pls, o Drilland Exercise Performance;
. ERO Drill Participation; and
. ANS Reliability.
The inspectors reviewed the Pl data and its documentation from the second quarter of 2010 through the first quarter of 11 to verify the accuracy of the reported data.
b. Findinos No findings were identified.
4c.42 Problem ldentification and Resolution (711 - 2 samples total)
.1 a Inspection Scope As required by Inspection Procedure71152, "ldentification and Resolution of Problems,"
and in order to help identify repetitive equi failures or specific human performance issues for follow-up, the inspectors a daily screening of items entered into FENOC's corrective action program. This was accomplished bY reviewing summary lists of each CR, attending meetings, and accessing FENOC's computerized CR database.
b. Findinos No findings were identified.
.2 Inspection Scope (1 samPle)
The inspectors reviewed a selected number CRs related to the implementation of work management at the station and on issues related to the completion of surveillance tests documented CR 11-895 and 11-91287 as a problem identification and resolution (Pl&R) sample for a detailed revlew.
Enclosure
The inspectors reviewed FENOC's fullappa cause and monitored the corrective action review board assessment for CR 11 76. The inspectors reviewed cause determination and assessed FENOC's of condition, operability determination, and prioritization and timeliness of corrective to prevent recurrence. Documents reviewed for this inspection are located in Attachment.
Findinqs and Observations No findings were identified.
In general, FENOC has identified trends in management and has aPProPriatelY addressed the trends within their CAP and taken by the work management group to communicate and provide guidance to station. FENOC continues to focus on improvements to and effectiveness of the management implementation. The inspectors have recently observed challeng in completing work activities due to insufficient staff resources, particularly tion and controls staff, during outages at other fleet stations. FENOC plans to their resource-sharing plans to minimize this impact. The inspectors will continue to this area and assess the effectiveness of planned and in-progress actions.
Inspection Scope (1 samPle)
The inspectors reviewed a selected number CRs related to issues and deficiencies regarding various radiation monitors that important to safe operation and used in emergency response assessments. , the inspectors focused on corrective actions for the Unit 1 and 2 RSS HX r [RM-1RW-100A, B, C, D and 2SWS-RQ100A, B, C, Dl, however other actions other monitors related to FENOC's prompt function assessment (CR 10-86918 and 196) were reviewed as a Problem identification and resolution (Pl&R) sample a detailed follow-uP review.
The inspectors reviewed FENOC's prompt assessment, control room radiation monitor logs, action plans, and completed actions for the selected monitors'
The inspectors reviewed cause determ and assessed FENOC's extent of condition, prioritization, and timeliness of actions. Documents reviewed for this inspection are located in the b. Findinqs and Observations One finding was identified. The inspectors observed a significant number of out-of-service radiation monitors documented in radiation monitor track logs in the control room for both Unit 1 and Unit 2. These were accounted for by FENOC in their prompt function assessments (CR 10-8691 and 09-68196), however a number of corrective actions are stilloutstanding and been extended. Also, a number of these out-of-service monitors were not for safe operation.
lntroduction: A Green, NRC-identified (FlN) was identified in that plans and actions to correct long-standing radiation ritor system instrument deficiencies where not accomplished in a timely manner, in nce with FENOC CAP Procedure NOP-LP-2001. Specifically, FENOC failed to and return to service radiation monitor Enclosure
instruments for Unit 1 and 2 RSS HX [RM-1 100A,8,C,D and 2SWS-RQ100A,B,C,D], in a timely manner, requi maintenance of alternate monitoring and challenges to assessing radiation detection nd assessment during accident situations.
This issue was entered into the licensee's action program under CR(s) 11-91673 and 1 1-89700.
Discussion: A review of FENOC's prompt fu assessments revealed that Unit 1 and Unit 2 RSS HX radiation monitors have out of service since September 2007 and 2006, respectively, due to failing to meet UFSAR river and service water flow requirements during surveillance testing. low flow is due to the susceptibility of the sample lines to clog with debris and mud. issues were originally documented in CRs 06-00509,07-05648, and 09-68196. F inspector review identified this condition has been observed on Unit 1 2003.
Alternate methods for detection (alternate ) and methods for estimating releases (i.e. 1 l2-EPP-lP-2.7, Liquid Release Estima ) were identified and implemented.
Engineering changes were developed and i plemented in an attempt to correct the low flow issue and return the monitors to service The recovery of these monitors require multiple groups to coordinate and complete actions.
These issues have been long-standing with corrective actions that have been extended and delayed due to design, parts, urce, and scheduling issues. The monitors have not yet been returned to FENOC has reevaluated and modified their recovery plans and has made progress towards completing the ECPs affecting the recovery of the RSS HX mon Analvsis: Traditional enforcement does not because the issue did not have an actual safety consequence or the potential impacting NRC's regulatory function, and was not the result of any willful violation of requirements. The insPectors determined that the finding was not similar the examples for minor deficiencies contained in IMC 0612, Appendix E, "Exa of Minor lssues". The finding is more than minor because it affects the Public Rad ion Safety cornerstone. The finding is associated with the attribute of plant eq and instrumentation (process radiation monitors) attribute of the Public Radiation cornerstone to ensure adequate protection of public health and safety from re to radioactive materials released into the public domain as a result of routine lian nuclear reactor oPeration.
In accordance with IMC 0609'04 (Table 3a)' Phase 1 - Initial Screening and Characterization of Findings," the finding evaluated using IMC 0609 Appendix D,
"Public Radiation Safety Significance ination Process" and determined to be of very low safety significance (Green) becr the finding was not a failure to implement the effluent program or cause any public to be exceeded.
The cause of this NCV relates to the cross aspect of Problem, ldentification, and resolution, Corrective Action Program, in FENOC personnel did not take timely corrective actions to develop and implement ions for long-standing radiation monitor deficiencies. [P.1 (d)]
Enforcement: Enforcement action does not because the performance deficiency did not involve a violation of a regulatory . FENOC has revised and refocused their radiation monitor action plan nd continues to take action to return the Enclosure
40A3 (7 1 153 - 2 samples total)
The inspectors performed one event inspection activity. Documents reviewed for this inspection activity are listed in the I lnformation attached to this report.
.1 Plant Event Review Inspection Scope (1 samPle)
For the plant event below, the inspectors and/or observed plant parameters, reviewed personnel performance, and eva performance of mitigating systems.
The inspectors communicated the plant eve to regional personnel and compared the event details with criteria contained in IMC , "Reactive Inspection Decision Basis for Reactors," for consideration of additional inspection activities. The inspectors reviewed FENOC's follow-up actions to the events to assure that appropriate corrective actions were im plemented with their safety significance.
Documents reviewed during the inspection listed in the Attachment.
. Unit 2: On April 10, control room initiated a manual reactor trip while performing TS required shutdown due reaching the pre-established trip criteria for low water level (25%) on the'A'steam water level. The TS required shutdown was in resPonse to an weld leak at 2FWE-940, an auxiliary feedwater header line. This weld leak not affect steam generator water levels.
After the manual reactor trip, water level to lower due to shrink and reached 20.5o/o level, and caused an atic actuation of the steam driven auxiliary feedwater pump. Operators q y recovered and stabilized steam generator water levels. This event was to the NRC via Event Notification M67744 and was directly observed by resident inspectors. Operators responded appropriately and mitigating systems as designed. The licensee documented this issue in CR 11-92597 11-92603 and is conducting a root cause evaluation. This issue was also under NRC OpESS FY2009-02, "Negative Trend and Recurring Events lnvolving Systems."
b. Findinqs No findings were identified.
.2 Review of Licensee Event Reports (LERs) ( sample)
ll lnoDerable" On March 25, while Beaver ValleY, Unit 2 shut down in Mode 6 (refueling),
scheduled maintenance was performed on Train'A' EDG which included replacing Enclosure
the twelve fuel injection pump supply lines new fuel injection pump supply lines procured from the EDG vendor. During post maintenance testing of the Train 'A' EDG, the supply line to the number four injector replaced with its original supply line due to a smallfuel leak (approximately 6 drops minute). Several additional fuel supply line fittings were tightened to eliminate signs minor leakage and the required post maintenance testing and endurance run of Train'A' EDG was completed satisfactorily. After successful post mai testing, the Train'A'EDG was declared operable by the licensee and the T 'B' EDG was subsequentlY declared inoperable and removed from service for ne maintenance.
Approximately 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> later the vendor in the licensee of its recommendation to remove all of the new fuel injection pump lines previously installed on the Train
'A' EDG due to concerns over the adequacy the assembly method of the fuel line compression fittings. Based on this vendor mendation, the licensee immediately declared Train'A' EDG inoperable. Since EDG trains were inoPerable for approximately 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />, during which time action was immediately taken to restore one to operability as required by TS 3'8.2.8, licensee was inadvertentlY in a condition prohibited by TS. When the li determined that both EDG trains were inoperable, they entered TS 3.8.2.8, initi actions to restore one EDG to operable status, and evaluated the issue for and appropriately issued LER 50-41212011 -001, "Defective Fuel lnjection Supply Lines Provided by the Diesel Engine Manufacturer Results in an Diesel Generator Being lnoperable,"
dated May 19, 2011. This LER reported Beaver Valley, Unit 2 had been in a condition that was prohibited by TS 3.8.2.8, requires immediate action if both trains of EDG are inoperable while in Mode operations.
The issue was considered within the I enforcement process because there was no performance deficiency identified and ion Manual Chapter (lMC) 0612, Appendix B, "lssue Scrbening" directs of this issue in accordance with the Enforcement Policy. The inspectors used Enforcement Policy, Section 6.1 - Reactor Operations, to evaluate the significance of violation. The inspectors concluded that the violation is more than minor and best racterized as Severity Level lV (very low safety significance) because it is similar to Policy Section 6.1, examPle d.1.
Additionally, the inspectors assessed the associated with the issue by using IMC 0609, Appendix G, "Shutdown Operations nificance Determination Process." The inspectors screened the issue, and eva it using Checklist 4 of IMC 0609, Appendix G, Attachment 1. The inspectors also the licensee's risk evaluation of the event. Based on these reviews, this issue screen as very low safety significance (Green).
Because it was not reasonable for the to either have declared the Train 'A' EDG inoperable at an earlier time or to have fore the inadequate assembly of the fuel injection pump supply line fittings, the NRC ned no performance deficiencY existed. Thus, the NRC has decided to ise enforcement discretion in accordance with the Enforcement Policy and refrain issuing enforcement action for the violation.
(EA-1 1-160). Further, because licensee s did not contribute to this violation, it will not be considered in the assessment or the NRC's Action Matrix. This LER is closed.
Enclosure
40A5 Other
.1 The inspectors reviewed the final report ( April 19th, 2011) for the INPO plant assessment of Beaver Valley conducted in ruary 2011 on May 17'n,2011. The inspectors also reviewed the final report for lNPO accreditation team evaluation of the maintenance, chemistry, and radiolog protection technical training programs conducted February 2011. The inspectors these reports to ensure that anY issues identified were consistent with NRC ves of FENOC performance and to determine if INPO identified any significant issues that required further NRC follow-up.
Findinqs No findings were identified.
.2 Nuclear Station Fuel Damaqe Event" The inspectors assessed the activities and taken by the licensee to assess its readiness to respond to an event similar to Fukushima Daiichi nuclear plant fuel damage event. This included (1) an of the licensee's capability to mitigate conditions that may result from beyond des basis events, with a particular emphasis on strategies related to the spent fuel pool, required by NRC Security Order Section 8.5.b issued February 25,2002, as comm to in severe accident management guidelines, and as required by 10 CFR 50'5 ); (2) an assessment of the licensee's capability to mitigate station blackout (SBO) , as required by 10 CFR 50.63 and station design bases; (3) an of the licensee's capability to mitigate internal and externalflooding events, as req ired by station design bases; and (4) an assessment of the thoroughness of the wa and inspections of important equipment needed to mitigate fire and flood which were performed bY the licensee to identify any potential loss of of this equipment during seismic events possible for the site Inspection Report 05000334/4 12-2011008 ( I I I 31 0328) documented detailed results of this inspection activity.
.3 On May 18, 2011, the inspectors completed a review of the licensee's severe accident management guidelines (SAMGS), ted as a voluntary industry initiative in the 1990's, to determine (1) whether the were available and updated, (2) whether the licensee had procedures and processes r place to controland update its SAMGS, (3) the nature and extent of the licensee's ning of personnel on the use of SAMGS, and (4) licensee personnel's familiarity with The results of this review were provided to NRC task force chartered bY the Executive Director for Operations to cond a near-term evaluation of the need for Enclosure
agency actions following the Fukushima Daiiphifuel damage event in Japan. Plant-specific results for Beaver Valley Power Station were provided in an Attachment to a memorandum to the Chief, Reactor tnspectiQn Branch, Division of lnspection and Regional Support, dated May 27,2011 (ML111470361)'
4046 Manaqement Meetinqs
.1 2010 Annual Assessment Discussion On April 28, Ronald Bellamy, NRC Branch Qniet for Beaver Valley, discussed Beaver Valley performance for 2010 with Mr. P. Harden, Site Vice President, prior to the public annual assessment meeting.
.2 On May 10, Commissioner Magwood, ied by his staff and Mr. J. Clifford, NRC Region I Deputy Director of Reactor toured Beaver Valley Power Station and discussed station performance with Mr. P. rden, Site Vice President, and other senior members of FENOC.
.3 On May 20, an exit meeting was conducted th Mr. R. Brosi, Director of Performance lmprovement, and other members of the Valley staff to discuss the results and observations of the insPection.
.4 Emerqencv Preparedness On May 20, an exit meeting was conducted Mr. R. Brosi, Director of Performance lmprovement, and other members of the Valley staff to discuss the results and observations of the insPection.
.5 On June 3, an exit meeting was conducted Mr. R. Lieb, Director of Site Operations to discuss the results of the Tl.
.6 On June 23, an exit meeting was conducted with Mr. P. Harden, Site Vice President, and other members of the Beaver Valley staff to the results and observations of the Radioactive Effluent inspection.
.7 Quarterlv Inspection RePort Exit On July 21,the inspectors presented the baseline inspection results to Mr. D.
Murray, Director of Performance and other members of the licensee staff.
The inspectors confirmed that proprietary rmation was not retained at the conclusion of the inspection period.
ATTACHMENT: SUPPLEMENTAL INFORMATION Enclosure
A-1 SUPPLEMENTAL ORMATION KEY POINTS OF Licensee personnel M. Banko Chemistry Supervisor R. Brosi Director, lmprovement S. Buffington Design Engineer G. Cacciani Design Analysis Eng D. Canan Radiation Protection W. Cress Supervisor, Laboratory G. Cramer Emergency Manager D. Eckleberry Senior Radiation tion Technician R. Fedin Staff Nuclear Emergency Preparedness J. Gallagher Staff Nuclear D. Gibson Operations Site Vice President M. Helms Fleet Oversight Speci R. Lieb Director, Site J. Matsko Plant Engineering J. Mauck Compliance Engineer C. McFeaters Operations Manager D. Murray Director Performance provement A. Oduho System Radiation Engineer L. Renz Environmental Specia J. Saunders Radiation Protection pervrsor F. Schaffner Staff Nuclear Specia Emergency Preparedness B. Sepelak Supervisor, Regu Compliance H. Szklinski Staff Nuclear Speci Emergency Preparedness R. Thompson Senior Chemistry T B. Tuite Manager Regulatory pliance Other Personnel L. Ryan I nspector, Pennsylvania t of Radiation Protection Attachment
A-2 LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Ooen/Closed 050004122011003-01 NCV Failure to Maintain Recirculation Spray Heat Exchanlers in ChemicalWet Layup. (Section 1 R07)
05000334, 41212011003-02 FIN Failure [o timely correct Radiation Monitor deficiericies. (Section 40.42.3)
Closed 050004121201 1001-00 LER Defectirle Fuel lnjection Pump Supply Lines Provide[ by the Diesel Engine Manufacturer Results in an Emergency Diesel Generator Being lnoper{ble. (Section 4OA3.2)
05000334, 41212515/1 83 Tl Followlp to the Fukushima Daiichi Nuclear Station Fuel D{mage Event. (Section 4OA5.2)
05000334, 4121251 51 184 Tl Avaihbflity and Readiness lnspection of Severe Acciderft Management Guidelines (SAMGS).
(Sectiofl 4OA5.3)
Attachment
REVIEWED Section 1R01: Adverse Weather Protection Procedures 1/2OM-35.4A.A, Voltage Schedule Guidance, Rev.
1 I2OM-53C.4A.35.1, Degraded Grid, Rev. 7 NOP-WM-2001, Work Management I Readiness Process, Rev.11 Conditions Reports 11-88241 10-81176 10-81 175 08-42553 08-35334 Section 1R04: Equipment Alisnment Procedures 2OM-15.3.B.1, Valve List-2CCP, Rev. 16 2OM-11.3.B.1, Valve List-2SlS, Rev. 12 Drawinqs voND 1 0800-RM-041 5-001 voND 10080-RM-0411-041 Condition Reports 11-92336 11-94045 Section 1R05: Fire Protection Procedures 1/2 ADM-1900 1t2 ADM-1902 Pre-Fire Plans l PFP-AXLB-768 2PFP-CTP1 Calculation
'10080-8-085, Rev. 14 Condition Reports 11-92600 11-95411 11-94375 11-91 07-31091 Section 1R06: Flood Protection Calculations 8700-DMC-3443, Rev. 2 Condition Reoorts 11-92449 Attachment
A-4 Other BVPS-2 UFSAR BVPS Unit 2 Probabilistic Risk Assessment 2DBD-30 Section 1R07: Heat Sink Performance Procedures 2OM-30.4.T, Placing Recirc Spray Hxs into Chemicfl Wet Layup, Rev.O 2OST-30.138, Train B Service Water System Full Flow Test, Rev. 28 Condition Reports 11-90096 11-90430 11-92189 11-91 1 1-90643 11-92570 11-90899 11-90901 1 1-90787 11 11-91018 11-91026 11-91513 11-92251 11-92644 11 02-00350 02-00277 Other NOTF 600464500 wo200451815 wo200450994 1R11:
Red Team Mini-Drill Scenario, Rev.0 Procedures NOP-ER-3004, FENOC Maintenance Rule P Rev. 1 NOP-ER-21 01, Engineering Program Management, Rev.3 NOBP-LP-4012, NRC Performance Indicators, Rev 3 Other Maintenance Rule Quarterly Program Health 2011-1 wo200452790 NOTF 600673949 Condition Reports 11-92375 11-92245 11-88460 07-31 Procedures 1t2 ADM-2033 Condition Reports 11-92841 11-91436 11-90721 Other BV Unit 1 Weekly Maintenance Risk Summary for tfie week of April 11,2011, Rev. 1 BV Unit 1 Weekly Maintenance Risk Summary for tfie week of May 23,2011, Revs.1,2,and3, Attachment
A-5 Section 1Rl5: Operabilitv Evaluations Procedures l OST-1 3.02,'B' Quench Spray pump surveillance tQst 2OST-47.3M, Quarter Valve Strokes 2OST-30.138, Train 'B'service Water System Full Flow Test, Rev' 28 Condition Reports 11-89270 11-94426 Drawinos 2006.51 0-001-025, Rev D, Calculations 8700-DMC-3395, Rev.0 Other 2SVS-PCV1 01 B stroke-time history BV1 Shift Operations Logs dated May 9,2011 Clearance 1W09-1 3-QS-003 Section 1Rl8: Plant Modifications Condition Reports 1 1-91800 ECP 11-0179-000 ECP 09-0771 EER 600672192 Other NOTF 600672192 ECP 11-0179-000 Section 1 R19: Post-Maintenance Testinq Procedures U2 CMp.1-2-002, PR Neutron Flux Detector ReplaQement and Post Installation Tests, Rev. 3 1-CMP-1-02-003 1 CMP-2N1-OVRPWR.SPI l RST-2.10, Alignment of Power Range lnstrumentation for Startup after Mid-cycle detector replacement, Rev.0 1 t2-Ml-75-Packing-1 M, Valve Packing Instruction, Rpv. 10
%-CMP -M-75-039, Repai r Rockwel l-Edwards U n ivalves, Rev. 4 2OST-30.138, Train B Service Water System Full Flow Test, Rev. 28 BVBP-SITE-0053, Post-Maintenance Test Requirenfents, Rev. 1 Work Orders 20045:z86 200432097 200451486 200452F32 '200452432 20A403244 200451094 200450356 200400196 200451765 Attachment
A-6 I Condition Reports 11-92952 11-92170 11-92224 11-917tr7 1 1-91905 11-92001 11-90096 11-92251 1 1-90760 Other BetaLab report M11110 for weld crack evaluation BV2 Shift operations logs dated April 3, 2011 ECP 11-005-003 Section {R20: Refuelinq and Outaqe Activities Procedures 2MSP-13RS-SUMP, Unit 2 Containment Sump Cloqe-out'
Condition Reoorts 11-92146 11-92219 [ 1-91659 11-91365 11-92177 11-92238 ft t-otssz 11-91115 11-92229 11-91910 11-91483 11-92442 11-91883 111-91392 11-92467 11-91746 [ 1-91390 Other 1POAC4 Work Project Schedule dated March 30, 2q11 BV1 Shift Operations logs dated March 16,20, & 26, 2011 BV1 PRNI detector current plots from plant computdr, dated March 16,2Q11 operational Decsion Making lnterface for unit 1 PR4'll-42' dated March 26' 201'l WO 200399672, QC inspection of Unit 2 containmeflt sump Section 1 R22: Surveillance Testinq Condition Reports 11-91918 11-92143 11-95443 11-911$0 Procedures 1l2ADM'1107, Alert Notification System (Sirens) Mfintenance and Testing, Rev. 11 Other Elaver Valley Nuclear Facility Design Report, Emerpency Warning Notification System, March 1, 1984 Supplement to the Beaver Valley Power Station Emprgency Warning Notification System Design Report Various Siren and Maintenance Tests, 4th quarter - 1't quarter 2011 Procedures 1 12-ADM-1101, Emergency Response Organization 112-ADM-1102, BVPS Emergency Notification T , Review and Trending, Rev. 2 Attachment
1 12-EPP -lP-1 . 7, Emergency Response (ERO) Teams, Rev. 20 112 OST-57.1, Emergency Beeper Notification , Rev. 15 Other Beaver Valley Power Station Emergency Plan ERO Roster Procedures NOP+P$O02, Evaluation of Changes to Plans and Supporting Documents 10 CFR 50.54(q), Rev. 2 NOP-LP-4003, Evaluation of Changes, Test and Rev.6 Chanoe Evaluations BV-2010-064-00 Bv-2010-069-00 BV-201 BV-2010-030-00 BV-2010-033-00 BV-2010-029-00 BV-201 BV-2010-067-00 BV-2010-044-00 BV-2010-044-00 BV-201 12-00 BV-2010-039-00 BV-2010-038-00 EPS: C Other BVRM-EP-5003, Equipment lmportant to Response, Rev.2 BV-PA-10-01, Beaver Valley Nuclear Fleet Oversigl'Jt Quarterly Report, 1 quarter zulv 1" quaner 2010 BV-pA-10-02, Beaver Valley Nuclear Fleet Oversigfit Quarterly Report, 2*
2nd quarter quarler 201(
2010 BV-pA-10-03, Beaver Valley Nuclear Fleet Oversigl.{t Quarterly Report, 3'quarter 2010 MS-C-1 O-11-24, Fleet Overiignt RuOit Report, ttovelnOer 12,2010 through Decemb_e_r 15, 2010 lp-SA-10-217, Integrated Pe*ormance Assessment and trending, 1't six months of 2010 lp-SA-1 i-041,Integrated Performance Assessment and trending, 2no six months of 2010 lp-SA-1 1-176,Integrated Performance Assessment and trending, 1'tquarter.2011 SN-SA-10-160, 2010 Beaver Valley Emergency Redponse Organization Red Team Mini Drill#1 MS-C-99-1 1-24,FleetOversightAudit Report, Noveinber 11,2009 through December 16,2009 SN-SA-10-284, Beaver Valley Power station Emerg$ncy Response Organization Blue Team during Mini-Drill #3, JulY 22,2010 SN-SA-10-285, Beaver Valley itower station Emerg$ncy Response Organization Green Team during Mini-Drill #4, August 12, 2010 Condition Reports 103020 11-94455 09-64018 10-87068 11-87868 10-86883 10-86905 11-94392 10-76036 11-937$6 09-69009 09-68905 no-A1n6n 1n-A2226 Procedures:
112-ODC-1.01, ODCM: Index, Matrix, and History of Changes 1 12-ODC-2.01, ODCM: Liquid Effluents 1 12-ODC-2.02, ODCM: Gaseous Effluents Attachment
A-8 Proc$d ure & Source Term lnPuts 112-ODC-3.03, ODCM: Controls for RETS and Program 1 -HPP-4.02.008, SA-9/SA-1 0 Noble Gas Monitors 1 l 2-HPP -4.02.002, Effluent Mon itors 1 -HPP -4.02. 0 1 0, SPI NG-4 Particulate, lodine, and Gas Monitor
}-HPP -4.02.020, DRMS, Process Monitoring 2-HPP -4.02.021, D RMS, Effl uent Mon itoring Su bs 1/2-ENV-05.04, Radioactive Waste Discharge tion-Liquid 112-HPP- 3.06.006, Batch Radioactive Waste Authorization-Gas 112- ADM-1730, Laboratory Quality Assurance and strument Quality Control Program NOP-OP-3202 , FENOC Radiochemistry Quality Program NOP-OP-4705, Response to Contaminated Spi Mon Unit-1:
t tytsp-+S.O1C-1, RM-VS1 12 Reactor Bldg / SLCRS ftadiation Monitor Calibration lMSp-43.18-1, RM-LW104 Liquid Waste Effluent Rqdiation Monitor Calibration 1 MSP-43.21 -1, RM-1 GW-1 08A Gaseous Waste Pa(iculate Calibration lMSP-43.231, RM-1LW-1 16 Channel Functional Te$t 1 MSP-43.61 C-1, RM-VS-1 12 Reactor Bldg/SLCRS [onitor calibration 1 OST-43.7, Noble Gas Monitors RM-1VS-109111 0, IGW-109 Functional Test 1 OST-43.9D, RM-1 GW-1 08 Channel Functional Te$t lOST-43.9F, RM-1LW-104 High Range Channel Functional Test lOST-43.9E, RM-1LW-104 Low Range Channel Fuitctional Test 1 OST-43.9H, RM-1 RW-1 00 Liquid Effluent Monitor Channel Functional Test 1 OST-43.91/J, RM-1 VS-1 01 A/B Gaseous Effluent tvfionitor Functional Test 1 OST-43.91(1, RM-1VS-1 07 Gaseous Effluent Monitor Functional Test Unit-2:
zusp-+e. g6A-1, 2HVS-RQl 1 01, Ventilation Vent R{diation Monitor Test 2MSp-43.33-t, 2HVS-RQ1109, BICID Elevated Relefse Gas Monitor Calibration 2MSP-43.39-1, 2SGC-RQl 1 00, Liquid Waste Effluent Monitor Calibration 2OST -43.2, 2RMF-RQt301 A/B, Fuel Building Exhaulst Monitor Functional Test 2OST-43. 3, 2SGC-RQl 1 00, Liquid Waste Effluent tt{onitor Functional Test 2OST-43.5, 2MSS-RQ101 NBIC Noble Gas Monitof channelTest 20sT-43.9A, 2HVS-RQ101 A/B Ventilation Vent Fuhctional Test 2OST-43.8, 2HVS-RQI109C Elevated Release wRqM Functional Test 2OST-43.98, 2RMQ-RQ301 A/B Decon Bldg Efflueipt Monitor FunctionalTest 2OST-43.9C, 2HVL-RQl112A/B Condensate Polishing Bldg Effluent RM Test 2OST-43.9D, 2RMQ-RQ303 A/B Waste Gas Ventilaftion Monitor FunctionalTest Air Cleaninq Svstem Testinq:
Unit 1:
W-f eW-01-16-06/07, Unit 1 A/B SLCRS HEPA an[ Charcoal Filter Efficiency and Flow Test BV-1BW-01-16-08, Unit 1 Main Filter Charcoal San'iple - A SLCRS BV-2BW-o1-16-11, Unit 1 Main Filter Charcoal Sanr'iple - B SLCRS Attachment
A-9 Unit 2:
BV-2BW-01-16-06/07, Unit 2 A/B SLCRS HEPA Charcoal Filter Efficiency and Flow Test BV-2BW-01-16-08, Unit 2 Main Filter Charcoal ple - A SLCRS BV-2BW-01-16-11, Unit 2 Main Filter Charcoal ple - B SLCRS Nuclear Oversiqht Reports:
Audit MS-C-10-08-02, First Energy Multi-Site and Environmental Audit Beaver Valley Fleet Oversight Fourth Quarter 2010 First Quarter 2011 Reports Field Observations:
8V3201 14154 8V220093821 8V320103932 Other Documents:
Monthly, Quarterly, and Annual Liquid & Gaseous E Dose Assessments for Unit 1 and Unit 2 from January 2011 through May 2011 2010 Radioactive Effluent Release Report System 43, Radiation Monitoring Systern Health 1" Quarter 2011 50.75 (g) Decommissioning Records RETS Dose Proiection for June 2011 Unit 1 Boron Recovery/Liquid Waste System I - 50.59 Evaluations Inter-laboratory Comparison Program Results 201 0 4th Quarter 2010 RETS Cross Check Program Resufts Condition Reports:
11-96782 11-95363 1 1-93037 11-szete 11-94121 1 1-94365 11-95716 11-95774 11-92949 1 1-e50I1 11-92214 1A-85877 1/2 ADM - 1111, NRC EPP Performance lndicator Rev.5 Other Performance Indicator data - 2nd quarter 2010 to 1't 2011 Condition Reports 07-05648 09-63257 0-82077 1 1-93608 07-26618 09-63273 1-89204 1 1-94038 10-71353 1-90598 1 1-94089 07-31 350 08-38146 11-71984 1-90801 11-94165 09-53803 1 0-79691 1-90958 11-94167 09-53854 10-80659 1-90962 11-94168 09-6021 8 10-81046 1-90966 11-95701 09-60782 10-81305 1-91287 09-60852 10-81680 1-92447 Attachment
A-10 Procedures
%-ADM-1900, Fire Protection Program lOST-30.12A & B, Service Water Full-Flow Test I lOST-33.10H, 1B Service Station Transformer anO lRfS Transformer 38 Deluge Valve Test l MSP-1.04, Solid State Protection System Testing, firain 'A'
NOP-LP-2001, Corrective Action Program NOP-WM-4300, Order Execute Process I Work Orders 2ooqsazaa 200456670 200385515 200449533 200400261 Other AVpS Maintenance Strategy, Update and Status ; 2Q07,2009, 2010, 201 1 BVPS Radiation Monitor lnstrument Action Plan, 20'f l CR1 1-89576, CARB Package for April 12,2011 l EPP l-1a, TAB 1.3.4 Containment Bypass Event Notification M5296 oDcM, %-oDc-3.03 NUREG-1022 Surveillance and Periodic Test Program Change for 2MSP-01-04-l & 2MSP-01*05-1 , dated Feb 10,2009 Engineering Change Packages 02-0186, 05-0385, q8-650, 09-0131, 09-01 32, and 11-0256.
Section 4OA3: Event ResPonse Condition Reports 11-95539 11-94109 11-92597 11 Other BV2 AFW PlD, 10080-RM-424.3, Rev. 9 BV2 steam generator water level plots from plant i computer, dated APril 10, 2011 BV2 shift operations logs, dated April 9 & 10,2011 Event notification #46744 dated April 10,2011 Event Review Team Package for April 10,2011 trip, dated April 10, 2011 Sequence of Events recorder output for BV2 dated 10,2011 Attachment
LIST OF AC ADM Administrative Procedure ANS Alert and Notification SYstem BCO Basis for Continued BVPS Beaver Valley Power Station I CAP Corrective Action Program ccw Component Cooling Water CFR Code of Federal Regulations CR Condition Report(s)
DEP Environmental Protection Department of Environmental EAL Emergency Action Level EDG Emergency Diesel Generator i EP Emergency Preparedness ERO Emergency Response Organilation FA Functionality Assessments FEMA Federal Emergency Manage$ent Agency FENOC First Energy Nuclear Operatirig Company FOTP Fuel OilTransfer PumP FSAR Final Safety Analysis RePort HEPA High-Efficiency Particulate Ail HX Heat Exchanger rMc Inspection Manual ChaPter roD tmmediate Operability Deterniination IP Inspection Procedure I tsr lnservice lnspection LCO Limiting Conditions for Operations LER Licensee Event Report LHSI Low Head Safety lnjection i MR Maintenance Rule MSP Maintenance Surveillance Pafkage NEI Nuclear Energy Institute NO Nuclear Oversight NRC Nuclear Regulatory Commission OD Operability Determinations ODCM Offsite Dose Calculation ManUal OST Operations Surveillance Test I PI Performance Indicator PI&R Problem ldentification and POD Prompt Operability Determi PMT Post Maintenance Testing PRNI Power Range Nuclear I RSS Recirculation Spray SYstem SAMG Severe Accident Guidelines SBO Station Blackout SLCRS Supplemental Leak and Release System ssc Structures, Systems, and ponents SSST System Station Service T Attachment
A-12 SW Service Water TS Technical Specification UFSAR Updated Final Safety Analysi$ Report Attachment