IR 05000334/2011009
| ML113000366 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 10/27/2011 |
| From: | Eugene Dipaolo NRC/RGN-I/DRP/PB6 |
| To: | Harden P FirstEnergy Nuclear Operating Co |
| DIPAOLO, EM | |
| References | |
| IR-11-009 | |
| Download: ML113000366 (21) | |
Text
SUBJECT:
BEAVER VALLEY POWER STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT O5OOO334/201 1OO9 AND 050004121201 1009
Dear Mr. Harden:
On September 16, 2011, the United States Nuclear Regulatory Commission (NRC) completed an inspection at your Beaver Valley Power Station Units 1 and 2. The enclosed report documents the inspection results discussed with you, and other members of your staff.
This inspection examined activities conducted under your license as they relate to identification and resolution of problems and compliance with the Commission's rules and regulations and conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.
Based on the samples selected for review, the inspectors concluded that FirstEnergy Nuclear Operating Company (FENOC) was generally effective in identifying, evaluating, and resolving problems. FENOC personnel identified problems and entered them into the corrective action program at a low threshold. FENOC prioritized and evaluated issues commensurate with the safety significance of the problems and corrective actions were generally implemented in a timely manner.
This report documents two self-revealing findings of very low safety significance (Green). The inspectors determined that each of these findings also involved a violation of NRC requirements. However, because of the very low safety significance and because they were entered into your corrective action program, the NRC is treating these findings as non-cited violations, consistent with Section 2.3.2 of the NRC Enforcement Policy. lf you contest these non-cited violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to the Regional Administrator, Region l; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Beaver Valley Power Station. ln addition, if you disagree with the cross-cutting aspect assigned to 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 l, and the NRC Resident lnspector at Beaver Valley Power Station.
ln accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC website at http:i/www.nrc.qov/readino-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/r*n. tf.r'4*/'--
Docket Nos.:
License Nos.:
Enclosure:
REGION I==
50-334, 50-412 DPR.66, NPF-73 05000334/201 1 009 and 050004121201 1009 FirstEnergy Nuclear Operating Company (FENOC)
Beaver Valley Power Station, Units 1 and 2 Shippingport, PA 15077 August 29,2011 - September 16, 2011 Carey Bickett, Senior Prolect Engineer Scott Barber, Senior Project Engineer Paul Kaufman, Senior Reactor Inspector Erin Bonney, Beaver Valley Resident Inspector Eugene M. DiPaolo, Acting Chief Reactor Projects Branch 6 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
f R 0500033412011009 and 05000412/201 1009; 0812912011 - 091161201 1; Beaver Valley Power
Station; Biennial Baseline Inspection of Problem ldentification and Resolution. The inspectors identified one finding in the area of problem evaluation and one finding in the area of implementation of corrective actions.
This NRC team inspection was performed by three regional inspectors and one resident inspector. The inspectors identified two self-revealing findings of very low safety significance (Green) during this inspection and classified these findings as non-cited violations. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using NRG Inspection Manual Chapter (lMC) 0609, "Significance Determination Process." Findings for which the SDP does not apply may be Green or assigned a severity level after NRC management review. Cross-cutting aspects associated with findings are determined using IMC 0310, "Components Within the Cross-Cutting Areas." The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
Problem ldentification and Resolution The inspectors concluded that FENOC was generally effective in identifying, evaluating, and resolving problems. FENOC personnel identified problems, entered them into the corrective action program at a low threshold, and prioritized issues commensurate with their safety significance. In most cases, FENOC appropriately screened issues for operability and reportability, and performed causal analyses that appropriately considered extent of condition, generic issues, and previous occurrences. The inspectors also determined that FENOC typically implemented corrective actions to address the problems identified in the corrective action program in a timely manner. However, the inspectors identified two violations of NRC requirements, one in the area of problem evaluation, and one in the area of implementation of corrective actions.
The inspectors concluded that, in general, FENOC adequately identified, reviewed, and applied relevant industry operating experience to Beaver Valley Power Station (Beaver Valley)operations. ln addition, based on those items selected for review, the inspectors determined that FENOC's self-assessments and audits were thorough.
Based on the interviews the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual corrective action program and employee concerns program issues, the inspectors did not identify any indications that site personnel were unwilling to raise safety issues nor did they identify any conditions that could have had a negative impact on the site's safety conscious work environment.
Cornerstone: lnitiating Events
.
- Green.
The inspectors identified a Green, self-revealing, non-cited violation of 10 CFR 50,
Appendix B, Criterion XVl, "Corrective Action," in that FENOC did not take corrective actions to prevent recurrence of a significant condition adverse to quality. Specifically, FENOC failed to implement corrective actions following the 2A service water pump motor failure in 2005, which resulted in another failure of the same pump motor in 2011. FENOC implemented the corrective actions to prevent recurrence identified following the 2005 failure for the rewind of 2SWS-P21A motor in July 2011. FENOC documented this issue in their corrective action program as condition report 11-96293.
The inspectors determined that FENOC's failure to prevent recurrence of a significant condition adverse to quality was a performance deficiency. Specifically, FENOC failed to implement corrective actions to prevent recurrence of a turn-to-turn winding failure of the 2A service water pump due to excessive voiding in the epoxy of the stator end windings. This self-revealing finding is more than minor because it was associated with the equipment performance attribute of the Initiating Events cornerstone and adversely impacted the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors evaluated the significance of this finding using IMC 0609.04, "Phase 1 - Initial Screening and Characterization of Findings," for the initiating events cornerstone. The inspectors determined that the finding was of very low safety significance (Green) because it did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or function would be unavailable. The inspectors determined that this finding had no cross cutting aspect because it is not reflective of current plant performance.
Specifically, the actual performance deficiency occurred in 2005 and FENOC implemented corrective actions from the 2005 root cause evaluation for the 2011 rewind of the 24 service water pump motor. [Section 4OA2.1.c.(2)l
Cornerstone: Mitigating Systems
o
- Green.
The inspectors identified a Green, self-revealing, non-cited violation of 10 CFR 50,
Appendix B, Criterion XVl, "Corrective Action," in that FENOC failed to take adequate corrective actions to prevent recurrence of a significant condition adverse to quality.
Specifically, FENOC's extent of condition review and long-term corrective actions following a residual heat removal socket weld failure, caused by vibration-induced high-cycle fatigue, were inadequate to preclude the recurrence of a similar failure on the auxiliary feedwater system. FENOC entered this issue into their corrective action program as condition report 11-01453 for further review.
The inspectors determined that FENOC's failure to plan or implement adequate corrective actions to prevent recurrence of socket weld failures on safety-related piping was a performance deficiency. This issue was reasonably within FENOC's ability to foresee and correct due to previous opportunities to identify and correct socket weld failures on safety-related systems at Beaver Valley. The inspectors determined that this self-revealing finding was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). The inspectors evaluated the significance of this finding using IMC 0609.04, "Phase 1 - Initial Screening and Characterization of Findings," and determined that this finding was of very low safety significance (Green) because the finding was not a design or qualification deficiency, did not represent a loss of safety system function, and did not screen as potentially risk-significant due to external initiating events. This finding had a cross-cutting aspect in the area of problem identification and resolution because FENOC did not thoroughly evaluate a significant condition adverse to quality such that the resolutions address the extent-of-condition. Specifically, FENOC failed to perform an adequate extent of condition review following the failure of the 1RH-200 socket weld which resulted in not developing adequate corrective actions to address socket welds on the auxiliary feedwater system. P.1(c) [Section 4OA2.1.c.(1 )]
REPORT DETAILS
4. OTHER ACTTVTTTES (OA)
4OA2 Problem ldentification and Resolution (711528)
This inspection constitutes one biennial sample of problem identification and resolution as defined by Inspection Procedure71152. Alldocuments reviewed during this inspection are listed in the Attachment to this report.
.1 Assessment of Corrective Action Proqram Effectiveness
a. lnspection Scope The inspectors reviewed the procedures that described FENOC's corrective action program at Beaver Valley. To assess the effectiveness of the corrective action program, the inspectors reviewed performance in three primary areas: problem identification, prioritization and evaluation of issues, and corrective action implementation. The inspectors compared performance in these areas to the requirements and standards contained in 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," and FENOC procedure NOP-LP-2001, "Corrective Action Program." For each of these areas, the inspectors considered risk insights from the station's risk analysis and reviewed condition reports selected across the seven cornerstones of safety in the NRCs Reactor Oversight Process. Additionally, the inspectors attended multiple Plan-ofthe-Day and Management Review Board meetings. The inspectors selected items from the following functional areas for review: engineering, operations, maintenance, emergency preparedness, radiation protection, chemistry, and physical security.
- (1) Effectiveness of Problem ldentification In addition to the items described above, the inspectors reviewed a sample of completed corrective and preventative maintenance work orders, completed surveillance test procedures, operator logs, and maintenance backlog lists. The inspectors also completed field walkdowns of various systems on site, such as the auxiliary feedwater system, safety related battery and switchgear rooms, component cooling water pumps, and the service water intake structure. Additionally, the inspectors reviewed a sample of condition reports written to document issues identified through internal self-assessments, audits, emergency preparedness drills, and the operating experience program. The inspectors completed this review to verify that FENOC entered conditions adverse to quality into their corrective action program as appropriate.
- (2) Effectiveness of Prioritization and Evaluation of lssues The inspectors reviewed the evaluation and prioritization of a sample of condition reports issued since the last NRC biennial Problem ldentification and Resolution inspection completed in September 20Q9. The inspectors also reviewed condition reports that were assigned lower levels of significance that did not include formal cause evaluations to ensure that they were properly classified. The inspectors' review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate corrective actions to address the identified causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of the issues.
- (3) Effectiveness of Corrective Actions The inspectors reviewed FENOC's completed corrective actions through documentation review and, in some cases, field walkdowns to determine whether the actions addressed the identified causes of the problems. The inspectors also reviewed condition reports for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed FENOC's timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of condition reports associated with selected non-cited violations and findings to verify that FENOC personnel properly evaluated and resolved these issues. In addition, the inspectors expanded the corrective action review to five years to evaluate FENOC's actions related to Unit 2 service air system deficiencies and failures of the 24 service water pump.
b. Assessment
- (1) Effectiveness of Problem ldentification Based on the selected samples, plant walkdowns, and interviews of site personnel in multiple functional areas, the inspectors determined that FENOC identified problems and entered them into the corrective action program at a low threshold. FENOC staff at Beaver Valley initiated approximately 15,500 condition reports between January 2009 and July 2011. The inspectors observed supervisors at the Plan-of{he-Day and Management Review Board meetings appropriately questioning and challenging condition reports to ensure clarification of the issues. Based on the samples reviewed, the inspectors determined that Beaver Valley trended equipment and programmatic issues, and appropriately identified problems in condition reports. The inspectors verified that FENOC entered conditions adverse to quality identified through this review into the corrective action program as appropriate. ln general, inspectors did not identify any issues or concerns that had not been appropriately entered into the corrective action program for evaluation and resolution. However, the inspectors did identify one observation related to effectiveness of problem identification.
During a review of equipment deficiencies and condition reports in the security functional area, the inspectors identified that the preventive maintenance work orders for some site security systems lacked detailed work instructions required to complete the maintenance. Further, the inspectors noted that although the work-in-progress log (used to describe specific work performed) did document some of the work activities that had been completed, it failed to provide a reference to any specific work instructions, and did not document implementation of any of the specific maintenance activities listed in the vendor manual. The inspectors also identified that there was a wide variance in the degree of documentation in the work-in-progress log. Some had technical detail, while others just stated that the quarterly preventive maintenance was completed. The inspectors determined that none of these work-in-progress log entries referenced a specific procedure or work instruction. Despite the lack of detailed documentation or work instructions, the inspectors did not identify any equipment failures that were directly attributable to this observation. As such, this issue is considered to be minor and therefore not subject to enforcement action in accordance with the Enforcement Policy.
FENOC entered this issue into their corrective action program as condition report 11-94255.
- (2) Effectiveness of Prioritization and Evaluation of lssues The inspectors determined that, in general, FENOC appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem.
FENOC screened condition reports for operability and reportability, categorized the condition reports by significance, and assigned actions to the appropriate department for evaluation and resolution. The condition report screening process considered human performance issues, radiological safety concerns, repetitiveness, adverse trends, and potential impact on the safety conscious work environment.
Based on the sample of condition reports reviewed, the inspectors noted that the guidance provided by FENOC's corrective action.program implementing procedures appeared sufficient to ensure consistency in categorization of issues. In general, the station performed operability and reportability determinations when conditions warranted, and, the evaluations supported the conclusion. In most cases, causal analyses appropriately considered the extent of condition or problem, generic issues, and previous occurrences of the issue.
The inspectors did identify one example of more-than-minor significance where FENOC personnel did not adequately evaluate a significant condition adverse to quality which resulted in corrective actions that did not prevent recurrence of the condition. This finding is documented in Section 4OA2.1.c.
- (3) Effectiveness of Corrective Actions The inspectors concluded that corrective actions for identified deficiencies were generally timely and adequately implemented. ln most cases, for significant conditions adverse to quality, FENOC identified actions to prevent recurrence. The inspectors concluded that in general, corrective actions to address the sample of NRC non-cited violations and findings since the last problem identification and resolution inspection were timely and effective.
However, the inspectors determined that FENOC did not take corrective actions for a condition adverse to quality related to implementation of a six-month frequency for inspection of safety-related cables with the potential for submergence. Fleet oversight audit report MS-C-10-07 identified a need for a preventive maintenance change request to change the frequency of inspection of manholes l EMH-8A and l EMH-88 from one year to six months. FENOC developed this change in response to a previously identified NRC non-cited violation related to submerged safety-related cables in these manholes (see NRC inspection report 05000334/2009003 and 0500041212009003). Following review of this audit report, the inspectors requested the last three completed work orders for this inspection. FENOC subsequently identified that the revised work order had not been implemented due to an issue with the work management software program. The last time FENOC had performed this inspection on these manholes was in July 2010.
Upon identification of this condition, FENOC promptly performed the required inspections on manholes lEMH-8A and lEMH-88 and found no significant deficiencies.
Inspectors performed a walkdown of manhole l EMH-88 upon initial opening and did not observe an excess water level in the manhole. In addition, FENOC has completed other maintenance activities in the manholes since July 2010, including inspection of the sump pumps that were installed in response to the 2009 NRC non-cited violation. The inspectors evaluated this issue for significance in accordance with IMC 0612, Appendix B, "lssue Screening," and IMC 0612, Appendix E, "Examples of Minor lssues," and determined that this issue was minor based on the satisfactory results of the manhole inspections and no evidence of flooding of the manholes. As such, this issue was not subject to enforcement action in accordance with the Enforcement Policy. FENOC documented this issue in condition report 11-01913.
The inspectors also identified one example of more than minor significance where FENOC personnelwere not effective in implementing corrective actions, This finding is documented in Section 4OA2.1.c.
c. Findinos
- (1) Failure to lmplement Effective Corrective Actions to Prevent Recurrence of Socket-Weld Failures
Introduction.
Inspectors identified a Green, self-revealing, non-cited violation of 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," in that FENOC failed to take adequate corrective actions to prevent recurrence of a significant condition adverse to quality. Specifically, FENOC's extent of condition review and long-term corrective actions following a residual heat removal socket weld failure, caused by vibration-induced high-cycle fatigue, were inadequate to preclude the recurrence of a similar failure on the auxiliary feedwater system.
Description.
On October 2,2010, Unit 1 experienced a socket weld failure on residual heat removal drain line valve 1RH-200. This failure resulted in FENOC declaring both trains of the residual heat removal system inoperable. FENOC subsequently repaired 1RH-200 and returned the residual heat removal system to service. Additionally, FENOC classified this event as a significant condition adverse to quality and initiated a root cause evaluation to determine the cause and any corrective actions. On April 9, 2011, a similar socket weld failure occurred on Unit 2 auxiliary feedwater vent valve 2FWE-940, resulting in FENOC declaring the 'A' steam generator feedwater injection header inoperable, and conducting a technical specification required shutdown to repair the weld. FENOC repaired 2FWE-940 and returned the injection header to service.
FENOC also classified this event as a significant condition adverse to quality and initiated a root cause evaluation to determine the cause and any corrective actions.
The inspectors reviewed both root cause evaluations associated with these socket weld failures. The evaluations determined that both failures were the result of vibration-induced high-cycle fatigue. During review of these evaluations, the inspectors concluded that FENOC had prior opportunity to identify and implemenVplan corrective actions prior to the 2FWE-940 failure. The inspectors noted that the root cause evaluation for the residual heat removal issue did not include an adequate extent-of-condition review and planned corrective actions to prevent recurrence of socket weld failures on safety-related piping. Specifically, FENOC's extent of condition review for the residual heat removal failure eliminated the need to consider auxiliary feedwater socket welds based on infrequent operation of the auxiliary feedwater system. FENOC also did not establish corrective actions to review socket welds on safety-related systems that were eliminated from the initial scope of review. During review of the root cause evaluation for the auxiliary feedwater failure, the inspectors noted that FENOC's actions for long{erm review of socket welds was not sufficiently comprehensive in identifying the socket welds most susceptible to vibration-induced high-cycle fatigue. Specifically, FENOC credited their Risk-lnformed In-Service lnspection Program, which relies on VT-2 inspections, as a method to prioritize their scope of review. After review of this information, the inspectors noted that this program would have again eliminated the need to review auxiliary feedwater system socket welds. FENOC entered this issue into their corrective action program as condition report 11-01453 for further review.
Analvsis. The inspectors determined that FENOC's failure to plan or implement adequate corrective actions to prevent recurrence of socket weld failures on safety-related piping was a performance deficiency. This issue was reasonably within FENOC's ability to foresee and correct due to previous opportunities to identify and correct socket weld failures on safety-related systems at Beaver Valley. The inspectors determined that this self-revealing finding was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). The inspectors evaluated the significance of this finding using IMC 0609.04, "Phase 1 - Initial Screening and Characterization of Findings," and determined that this finding was of very low safety significance (Green) because the finding was not a design or qualification deficiency, did not represent a loss of safety system function for the auxiliary feedwater system, and did not screen as potentially risk-significant due to external initiating events. Inspectors dispositioned the socket weld failure associated with the Unit 1 residual heat removal system in Section 4OA3 of NRC inspection report 05000334/201 0005 and 0500041212010005.
This finding had a cross-cutting aspect in the area of problem identification and resolution because FENOC did not thoroughly evaluate a significant condition adverse to quality such that the resolutions address the extent-of-condition. Specifically, FENOC failed to perform an adequate extent of condition review following the failure of the 1RH-200 socket weld which resulted in not developing adequate corrective actions to address socket welds on the auxiliary feedwater system. P.1(c)
Enforcement.
10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," requires, in part, that in the case of significant conditions adverse to quality, measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. Contrary to the above, FENOC failed to assure that adequate corrective actions were sufficiently comprehensive to preclude recurrence of socket weld failures on safety-related systems caused by vibration-induced high-cycle fatigue. As a result, Beaver Valley experienced a failure of a socket weld on the auxiliary feedwater system in April 2011 which resulted in a technical specification required shutdown for repair.
Because this violation was of very low safety significance (Green), and FENOC entered this issue into the corrective action program (condition report 11-01453), this violation is being treated as a non-cited violation, consistent with the Enforcement Policy. (NCV 05000334, 41212011009-01: Failure to lmplement Effective Corrective Actions to Prevent Recurrence of Socket Weld Failures)
I
- (2) Failure to lmplement Corrective Actions for 2A Service Water Pump Motor Epoxv Voidinq
Introduction.
Inspectors identified a Green, self-revealing, non-cited violation of 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," in that FENOC did not take corrective actions to prevent recurrence of a significant condition adverse to quality. Specifically, FENOC failed to implement corrective actions following the 2A service water pump motor failure in 2005, which resulted in another failure of the same pump motor in 2011.
Description.
In May 2001, FENOC sent the 24 service water pump motor (2SWS-P21A)to a vendor for motor rewind due to a bearing failure that damaged the motor. Following the rewind, the station returned the motor to service in November 2001. On August 2, 2005, 2SWS-P21A tripped on overcurrent due to inadequate insulation of the stator coils. FENOC determined that this issue was a significant condition adverse to quality and performed a root cause evaluation for this failure. The station determined that the inadequate insulation of the stator coils was the result of voids in the epoxy of the motor coils, and developed corrective actions to prevent recurrence of this issue. However, FENOC sent 2SWS-P21A to the vendor to be rewound before the corrective actions to prevent recurrence were implemented. Updated procedures requiring FENOC inspection at process hold points were not in place at the time of the 2005 mot6r rewind, and FENOC had no plans to return the motor to the vendor to ensure the motor was rewound in accordance with the new specifications.
Two sample stator coils were created during the 2005 motor rewind for void determination testing. The inspection of the vendor sample revealed no voids and the station placed the motor back in service in August 2005. In September 2005, FENOC sent the second sample coil to an independent laboratory for testing and significant voiding was discovered. Based on these results, FENOC scheduled a third party to perform a partial discharge test to detect voids on 2SWS-P21A in October 2005. The test can detect voids in the linear portion of the coil; however the test does not detect voids in the end turns of the stator coils. The 2005 and 2011 motor failures occurred due to voids in the end turns of the stator coils. The 2SWS-P21A motor was left in service after the satisfactory partial discharge test until the June 2011 motor failure.
On June 10,2011, 2SWS-P21A again tripped due to an overcurrent condition caused by a turn-to-turn failure in the end windings of the motor stator which resulted from voids in the epoxy of the stator end windings. The voids in the stator end windings allowed movement of the motor coils causing insulation degradation. Insulation degradation resulted in a short across several coilwindings, which caused an overcurrent condition, tripping 2SWS-P21A. This was the third failure of the motor in ten years, with both the August 2005 and June 2011 failures being due to the same cause. FENOC implemented the corrective actions to prevent recurrence identified following the 2005 failure for the rewind of 2SWS-P21A motor in July 2011. FENOC documented this issue in their corrective action program as condition report 11-96293.
Analvsis. The inspectors determined that FENOC's failure to prevent recurrence of a significant condition adverse to quality was a performance deficiency. Specifically, FENOC failed to implement corrective actions to prevent recurrence of a turn-toturn winding failure of the 2A service water pump due to excessive voiding in the epoxy of the stator end windings. This self-revealing finding is more than minor because it was associated with the equipment performance attribute of the lnitiating Events cornerstone
.2 and adversely impacted the cornerstone objective of limiting the likelihood of those
events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors evaluated the significance of this finding using IMC 0609.04, "Phase 1 - Initial Screening and Characterization of Findings," for the initiating events cornerstone. The inspectors determined that the finding was of very low safety significance (Green) because it did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or function would be unavailable.
The inspectors determined that this finding had no cross cutting aspect because it is not reflective of current plant performance. Specifically, the actual performance deficiency occurred in 2005 and FENOC implemented corrective actions from the 2005 root cause evaluation for the 2011 rewind of the 2A service water pump motor.
Enforcement.
10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," requires, in part, that in the case of significant conditions adverse to quality, measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. Contrary to the above, in 2005, FENOC failed to take adequate corrective action to prevent recurrence of a turnto-turn failure in the stator end coils of the 2A service water pump motor. As a result, in June 2011, FENOC experienced an additional failure of the 2A service water pump motor. Because this violation was of very low safety significance (Green), and FENOC entered this issue into their corrective action program (condition report 11-96293), this violation is being treated as a non-cited violation, consistent with Enforcement Policy. (NCV 0500041212011009-02, Failure to f mplement Corrective Actions tor 2A Service Water Pump Motor Epoxy Voiding)
Assessment of the Use of Operatinq Experience lnspection Scope The inspectors reviewed a sample of condition reports associated with review of industry operating experience to determine whether FENOC appropriately evaluated the operating experience information for applicability to Beaver Valley and had taken appropriate actions, when warranted. The inspectors also reviewed evaluations of operating experience documents associated with a sample of NRC generic communications to ensure that FENOC adequately considered the underlying problems associated with the issues for resolution via their corrective action program. In addition, the inspectors observed various plant activities to determine if the station considered industry operating experience during the performance of routine and infrequently performed activities.
Assessment The inspectors determined that FENOC appropriately considered industry operating experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The inspectors determined that operating experience was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable.
a.
b.
.3 Findinqs
No findings were identified.
Assessment of Self-Assessments and Audits Insoection Scope The inspectors reviewed a sample of audits, including the most recent audit of the corrective action program, departmental self-assessments, and assessments performed by independent organizations. lnspectors performed these reviews to determine if FENOC entered problems identified through these assessments into the corrective action program, when appropriate, and whether FENOC initiated corrective actions to address identified deficiencies. The inspectors evaluated the effectiveness of the audits and assessments by comparing audit and assessment results against self-revealing and NRC-identified observations made during the inspection.
Assessment The inspectors concluded that self-assessments, audits, and other internal assessments were generally critical, thorough, and effective in identifying issues. The inspectors observed that FENOC personnel knowledgeable in the subject completed these audits and self-assessments in a methodical manner. FENOC completed these audits and self-assessments to a sufficient depth to identify issues which were then entered into the corrective action program for evaluation. ln general, the station implemented corrective actions associated with the identified issues commensurate with their safety significance.
Findinqs No findings were identified.
Assessment of Safetv Conscious Work Environment Inspection Scope During interviews with station personnel, the inspectors assessed the safety conscious work environment at Beaver Valley. Specifically, the inspectors interviewed personnel to determine whether they were hesitant to raise safety concerns to their management and/or the NRC. The inspectors also interviewed the station Employee Concerns Program coordinator to determine what actions are implemented to ensure employees were aware of the program and its availability with regards to raising safety concerns.
The inspectors reviewed the Employee Concerns Program files to ensure that FENOC entered issues into the corrective action program when appropriate.
Assessment In general, Beaver Valley staff expressed a willingness to use the corrective action program to identify plant issues and deficiencies, and stated that they were willing to raise safety issues. All of those interviewed stated that they would initially raise concerns to their supervisors and would also use the corrective action program to resolve their issues. These same individuals indicated that they would raise their b.
.4 b.
concerns up the management chain if they did not get satisfactory resolutions at the supervisory levels. All individuals were also aware that they could raise their concerns through the Employee Concerns Program and/or bring them to the NRC. The inspectors noted that no one interviewed stated that they personally experienced or were aware of a situation in which an individual had been retaliated against for raising a safety issue.
Based on these limited interviews, the inspectors concluded that there was no evidence of an unacceptable safety conscious work environment and no significant challenges to the free flow of information.
Findinos No findings were identified.
Meetinqs. lncludinq Exit On September 16, 2011, the inspectors presented the inspection results to Mr. Paul Harden, Site Vice President, and other members of Beaver Valley staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
P. Harden
Site Vice President
D. Batina
Employee Concerns Program Representative
D. Benyak
Manager, Regulatory Compliance
A. Berger
Nuclear Engineering Manager
S. Buffington Design Engineering
R. Dibler
Security Supervisor
K. Deberry
ChemicalVolume Control System Engineer
A. Dometrovich Regulatory Compliance
M. Johnson
Operating Experience Program
- G. Kammerdeiner Principal Consultant, Fleet Engineering
S. Kubis
Electrical System Engineer
J. Kunz
lnstrument & Control Supervisor
R. Lieb
Director, Site Operations
R. Lubert
Supervisor, Design Engineering
J. Marsh
Electrical Engineer
J. Matsko
Electrical Engineering Supervisor
D. Miller
Work Management Supervisor
K. Mitchell
ChemicalVolume Control System Engineer
M. Mitchell
Technical Services Supervisor
D. Murray
Director, Performance lmprovement
C. O'Neil
Nuclear Engineer
D. Reeves
Manager, Technical Services Engineering
D. Salera
Chemistry Manager
J. Saunders
Radiation Protection Supervisor
D. Schwer
Operations Supervisor
B. Sepelak
Regulatory Compliance
J. West
System Engineer
T. White
Maintenance Specialist
R. Winters
Chemistry Supervisor
K. Wolfson
Performance lmprovement Supervisor
Opened and Closed
05000334, 412t201 1 009-01
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Failure to lmplement Effective Corrective Actions to Prevent Recurrence of Socket Weld Failures Failure to lmplement Corrective Actions for 2A Service Water Pump Motor Epoxy Voiding