IR 05000334/2015004
| ML16088A388 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 03/29/2016 |
| From: | Silas Kennedy NRC/RGN-I/DRP/PB6 |
| To: | Richey M FirstEnergy Nuclear Operating Co |
| KENNEDY, SR | |
| References | |
| IR 2015004 | |
| Download: ML16088A388 (35) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION rch 29, 2016
SUBJECT:
BEAVER VALLEY POWER STATION - INTEGRATED INSPECTION REPORT 05000334/2015004 AND 05000412/2015004
Dear Mr. Richey:
On December 31, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Beaver Valley Power Station, Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on January 27, 2016, with Mr. M. Richey, site vice president, and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
This report documents one finding of very low safety significance (Green). The finding involved a violation of NRC requirements. However, because of the very low safety significance, and because it has been entered into your corrective action program, the NRC is treating the finding as a non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy.
If you contest the non-cited violation in this report, 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 I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Beaver Valley Power Station. In addition, if you disagree with the cross-cutting aspect assigned to any finding, or a finding not associated with a regulatory requirement 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 I, and the NRC Resident Inspector at Beaver Valley Power Station.
M. Rickey -2-In accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records component of the NRCs Agencywide Documents Access Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Silas R. Kennedy, Chief Reactor Projects Branch 6 Division of Reactor Projects Docket Nos.: 50-334 and 50-412 License Nos.: DPR-66 and NPF-73
Enclosure:
Inspection Report 05000334/2015004 and 05000412/2015004 w/Attachment: Supplementary Information
REGION I==
Docket Nos.: 50-334 and 50-412 License Nos.: DPR-66 and NPF-73 Report No.: 05000334/2015004 and 05000412/2015004 Licensee: FirstEnergy Nuclear Operating Company (FENOC)
Facility: Beaver Valley Power Station, Units 1 and 2 Location: Shippingport, PA 15077 Dates: October 1, 2015 to December 31, 2015 Inspectors: J. Krafty, Senior Resident Inspector B. Reyes, Resident Inspector T. Lamb, Acting Resident Inspector P. Kaufman, Senior Reactor Inspector R. Rolph, Health Physicist J. DeBoer, Emergency Preparedness Inspector H. Gray, Senior Reactor Inspector Approved By: Silas R. Kennedy, Chief Reactor Projects Branch 6 Division of Reactor Projects Enclosure
SUMMARY
IR 05000334/2015004, 05000412/2015004; 10/01/215 - 12/31/2015; Beaver Valley Power
Station, Units 1 and 2; Maintenance Effectiveness.
This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified a finding of very low safety significance (Green) which was a non-cited violation (NCV). The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process, dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310, Aspects Within Cross-Cutting Areas, dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated February 4, 2015. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.
Cornerstone: Mitigating Systems
- Green.
The inspectors identified an NCV of Title 10 of the Code of Federal Regulations (CFR) 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants, for FENOCs failure to monitor the performance of the Unit 1 auxiliary feedwater (AFW) system against licensee-established goals. Specifically, FENOC did not identify and properly account for a maintenance preventable functional failure (MPFF) of the turbine driven auxiliary feedwater (TDAFW) pump, which demonstrated that performance of the Unit 1 AFW system was not being effectively controlled through appropriate preventive maintenance. FENOCs immediate corrective actions included entering this issue into their corrective action program, re-evaluating and classifying the TDAFW pump failure as a MPFF, performing a 10 CFR 50.65 (a)(1) evaluation of the Unit 1 AFW system, and placing the system in (a)(1) status.
The performance deficiency was determined to be more-than-minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone, and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.
Additionally, example 7.d from IMC 0612 Appendix E details that a performance deficiency is more than minor if equipment performance problems were such that effective control of performance through appropriate preventive maintenance under (a)(2) could not be demonstrated. This finding was determined to be of very low safety significance (Green)since it was not a deficiency affecting the design or qualification of a mitigating structure, system, or component (SSC), it did not represent the loss of a system and/or function, it did not represent an actual loss of function of at least a single train or two separate safety systems out-of-service for greater than its technical specifications allowed outage time, and it did not represent an actual loss of a non-technical specification equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This finding has a cross-cutting aspect in Human Performance,
Avoid Complacency, because FENOC failed to consider the extent of condition and their causes following the failure of the Unit 1 TDAFW pump on January 6, 2014 [H.12]. (Section 1R12)
REPORT DETAILS
Summary of Plant Status
Unit 1 operated at or near 100 percent power for the entire inspection period.
Unit 2 began the inspection period shutdown in refueling outage 2R18. Following the completion of refueling and maintenance activities, operators commenced a reactor startup on October 29, 2015, and reached 100 percent power on November 2, 2015, and remained at or near 100 percent power for the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
Readiness for Seasonal Extreme Weather Conditions
a. Inspection Scope
The inspectors performed a review of FENOCs readiness for the onset of seasonal cold temperatures. The review focused on the Unit 1 and Unit 2 intake structures and the equipment in the Unit 2 safeguards building. The inspectors reviewed the technical specifications, and the corrective action program to determine what temperatures or other seasonal weather could challenge these systems, and to ensure FENOC personnel had adequately prepared for these challenges. The inspectors reviewed station procedures, including FENOCs seasonal weather preparation procedure and applicable operating procedures. The inspectors performed walkdowns of the selected systems to ensure station personnel identified issues that could challenge the operability of the systems during cold weather conditions. Documents reviewed for each section of this inspection report are listed in the Attachment.
b. Findings
No findings were identified.
1R04 Equipment Alignment
.1 Partial System Walkdowns
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems:
Unit 2 No. 1 emergency diesel generator while the No. 2 emergency diesel generator was out of service for scheduled maintenance on October 9, 2015 Unit 2 recirculation spray system following the performance of a full-flow surveillance test on October 20, 2015 Unit 2 charging system following maintenance on the C charging pump on December 2, 2015 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the Updated Final Safety Analysis Report (UFSAR), technical specifications, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether FENOCs staff had properly identified equipment issues and entered them into the corrective action program for resolution with the appropriate significance characterization.
b. Findings
No findings were identified.
.2 Full System Walkdown
a. Inspection Scope
On October 19 through 23, 2015, the inspectors performed a complete system walkdown of accessible portions of the Unit 2 low head safety injection system to verify the existing equipment lineup was correct. The inspectors reviewed drawings and equipment line-up check-off lists to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability and hanger and support functionality. The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed system health reports and a sample of related condition reports and work orders to ensure FENOC appropriately evaluated and resolved any deficiencies.
b. Findings
No findings were identified.
1R05 Fire Protection
Resident Inspector Quarterly Walkdowns (71111.05Q - 2 samples)
a. Inspection Scope
The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that FENOC controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.
Unit 2 East Cable Vault, Fire Area CV-2, on October 26, 2015 Unit 2 Cable Tunnel Fan Room, Fire Area CT-1, on December 2, 2015
b. Findings
No findings were identified.
1R07 Heat Sink Performance (711111.07A - 1 sample)
a. Inspection Scope
The inspectors reviewed the Unit 2 A component cooling heat exchanger to determine its readiness and availability to perform its safety functions. The inspectors reviewed the design basis for the component and verified FENOCs commitments to NRC Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment.
The inspectors reviewed the results of the recent inspection of the heat exchanger and compared it to a previous inspection in order to determine if there was a degrading trend. The inspectors discussed the results of the inspection with engineering staff and reviewed pictures of the as-found conditions. The inspectors verified that FENOC initiated appropriate corrective actions for identified deficiencies. The inspectors also verified that the number of tubes plugged within the heat exchanger did not exceed the maximum amount allowed.
b. Findings
No findings were identified.
1R08 In-service Inspection - Beaver Valley Unit 2
a. Inspection Scope
The inspectors conducted a review of FENOCs implementation of in-service inspection (ISI) program activities for monitoring degradation of the reactor coolant system (RCS)boundary, risk significant piping and components, and containment systems during the Beaver Valley Power Station (BVPS), Unit 2 refueling outage 2R18) The sample selection was based on the inspection procedure objectives and risk priority of those pressure retaining components in these systems where degradation would result in a significant increase in risk. The inspectors observed in-process non-destructive examinations (NDE), reviewed documentation, and interviewed FENOC personnel to verify that the NDE activities performed as part of the BVPS Unit 2 ISI program were being conducted, in accordance with the requirements of American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI, 2001 Edition, 2003 Addenda.
NDE and Welding Activities (IMC Section 02.01)
The inspectors performed observations of NDE and reviewed records of the NDE activities listed below:
Ultrasonic test (UT) - pressurizer nozzle-to-vessel welds 2RCS*PRE21-N-10 and 2RCS*PRE21-N-12, RCS 2RCS-007-F03 valve to pipe weld, RCS safe-end to elbow weld 2RCS-007-F04 Visual inspection of Unit 2 containment liner coating; The inspectors reviewed a sample of NDE technician certifications and verified the inspections were performed in accordance with approved procedures and the results were reviewed and evaluated by a certified Level III NDE individual.
The inspectors reviewed UT examination data records of RCS hot and cold leg safety injection system piping welds 2SIS-006-24-1 and 2SIS-006-15-1 conducted to implement an industry initiative in accordance with the MRP-146, Management of Thermal Fatigue in Normally Stagnant Non-Isolable Reactor Coolant System Branch Lines, to verify the examinations were conducted in conformance with FENOC procedures.
Repair/Replacement Consisting of Welding Activities The inspectors reviewed the welding activity and weld data sheets associated with replacement of 2-inch Kerotest globe valve BV-RCS-5 to verify that the welding and applicable NDE activities were performed in accordance with ASME Code requirements.
Pressurized Water Reactor Reactor Pressure Vessel Upper Head Penetration Inspection Activities The inspectors observed portions of the remote bare metal visual examination (VT-2)of the exterior surface of the Unit 2 reactor pressure vessel upper head penetration to confirm appropriate inspection coverage was achieved and to verify that no boric acid leakage or wastage had been observed. The inspectors directly observed remotely portions of the Unit 2 reactor pressure vessel upper head penetration control rod drive mechanism (CRDM) nozzle J-groove weld UT examinations to verify that they were being performed in accordance with requirements of 10 CFR Part 50.55a(g)(6)(ii)(D)and ASME Boiler and Pressure Vessel Code Case N-729-1, Alternative Examination Requirements for PWR Reactor Vessel Upper Heads, to ensure the structural integrity of the reactor vessel head pressure boundary.
The inspectors reviewed the recordable indications identified by UT of CRDM nozzle penetrations No. 37 and No. 53 J-groove welds on the Unit 2 reactor pressure vessel upper closure head during refueling outage 2R18 that had been accepted by evaluation for continued service. The inspectors verified that the dye-penetrant examinations confirmed that the indications were not surface connected.
Boric Acid Corrosion Control (BACC) Inspection Activities The inspectors reviewed the BACC program and implementing BVPS procedures, discussed the program with the boric acid program owner and sampled photographic and visual inspection records of boric acid observed on safety significant piping and components inside the containment structure during walk downs conducted by FENOC personnel to verify that boric acid leakage was being appropriately identified and non-conforming conditions of boric acid leaks were documented in the corrective action program with a focus on areas that could cause degradation of safety significant components. The inspectors reviewed a sample of boric acid evaluations to verify that they were properly dispositioned consistent with the requirements of the ASME Code and 10 CFR 50, Appendix B, Criterion XVI, Corrective Action.
Steam Generator (S/G) Tube Inspection Activities The inspectors observed a sample of the BVPS S/G eddy current tube examinations to verify that they were performed in accordance with Unit 2 Technical Specification 5.5.5.2 and the Steam Generator Program and reviewed a sample of the indications identified in the S/G tubes to verify that they were consistent with the potential degradation mechanisms documented in the Beaver Valley Unit 2 2R18 Steam Generator Degradation Assessment Report SG-SGMP-15-14, dated August 17, 2015.
The inspectors reviewed the S/G tube eddy current test results to verify that no primary-to-secondary leakage occurred over the operating cycle, in-situ pressure testing was properly performed, and tubes which exhibited degradation and did not meet the acceptance criteria were properly plugged using the alternate repair criteria per Generic Letter 95-05, Voltage-Based Repair Criteria for Westinghouse Steam Generator Tubes Affected by Outside Diameter Stress Corrosion Cracking. The inspectors verified that the S/G tube examination screening criteria was in accordance with the Electric Power Research Institute (EPRI) Steam Generator Guidelines and flaw sizing was in accordance with the EPRI examination technique specification sheet.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Quarterly Review of Licensed Operator Requalification Testing and Training
a. Inspection Scope
The inspectors observed licensed operator simulator training on November 19, 2015, which included a loss of an offsite source of electrical power, a letdown leak, spurious turbine trip causing a reactor trip, failure of select components to automatically start or open as required, and loss of heat sink. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager and the technical specification action statements entered by the shift manager. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.
b. Findings
No findings were identified.
.2 Quarterly Review of Licensed Operator Performance in the Main Control Room
a. Inspection Scope
The inspectors observed the draining of the Unit 2 RCS to six inches below the reactor vessel flange on October 1, 2015. The inspectors observed infrequently performed test or evolution briefing to verify that the briefing met the criteria specified in FENOCs procedure NOBP-OP-0007, Conduct of Infrequently Performed Tests or Evolutions, Revision 5. Additionally, the inspectors observed test performance to verify that procedure use and crew communications met established expectations and standards.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on SSC performance and reliability. The inspectors reviewed system health reports, corrective action program documents, maintenance work orders, and maintenance rule basis documents to ensure that FENOC was identifying and properly evaluating performance problems within the scope of the maintenance rule.
For each sample selected, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with 10 CFR 50.65 and verified that the (a)(2)performance criteria established by FENOC staff was reasonable. As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2). Additionally, the inspectors ensured that FENOC staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.
Unit 1 AFW system on November 22, 2015 Unit 1 and 2 periodic assessment of maintenance rule program on December 14, 2015
b. Findings
Introduction.
The inspectors identified a Green NCV of 10 CFR 50.65 for FENOCs failure to monitor the performance of the Unit 1 AFW system against licensee-established goals. Specifically, FENOC did not identify and properly account for an MPFF of TDAFW pump, which demonstrated that performance of the Unit 1 AFW system was not being effectively controlled through appropriate preventive maintenance.
Description.
On March 23, 2015, the inspectors were performing a routine review of FENOCs maintenance rule program for the Unit 1 AFW system. The inspectors noted a potential discrepancy when a failure of the TDAFW pump was classified as a condition monitoring failure (CMF) rather than a MPFF.
The TDAFW pump was started during the performance of a surveillance test on November 1, 2013, following a Unit 1 refueling outage. After approximately two minutes, the TDAFW pump was shutdown from the main control room due to excessive condensate leakage reported by the field operators. Condensate was drained from the steam lines and the TDAFW surveillance test was re-performed on November 2, 2013.
The TDAFW pump was shutdown from the main control room, this time after one hour and 22 minutes due to excessive hunting of the governor observed in the field.
Operations removed a clearance that they believed was the source of water intrusion into the steam lines. Again, on November 2, 2013, the surveillance test for the TDAFW pump was performed and the pump was declared operable after 18 minutes of operation. FENOC classified the failure of the TDAFW pump on November 2, 2013, as a CMF.
Following a Unit 1 reactor trip on January 6, 2014, the TDAFW pump automatically tripped after one hour and 49 minutes of operation due to governor oscillations. FENOC launched an investigation to determine the cause of the TDAFW pump failure. The licensee determined that the cause of the TDAFW pump oscillations and subsequent failure was due to an improperly set governor needle valve. The needle valve was incorrectly adjusted during installation of a new TDAFW pump governor in the refueling outage just prior to the pump being declared operable on November 2, 2013. The TDAFW pump failure on January 6, 2014, was classified as a MPFF.
The inspectors concluded that the TDAFW pump failure on November 2, 2013, should have been re-evaluated and classified as a MPFF rather than a CMF because the cause of the TDAFW pump failures, the improperly set governor needle valve, was present during the failures on November 2, 2013, and on January 6, 2014. The inspectors discussed this observation with FENOC engineering personnel on March 23, 2015.
On August 26, 2015, as a result of the inspectors observation, FENOC re-evaluated the TDAFW pump failure that occurred on November 2, 2013, and determined that the failure was a MPFF. The two failures exceeded FENOCs performance criteria and on September 21, 2015, FENOC concluded that the AFW system would be placed in (a)(1)status for a combination of TDAFW pump MPFFs, motor-driven AFW pump MPFFs, and CMFs. The inspectors concluded that FENOC should have evaluated the AFW system for (a)(1) status upon the second TDAFW pump failure occurring on January 6, 2014.
Analysis.
The inspectors determined that failure to identify that the performance of the Unit 1 AFW system was not being effectively controlled through appropriate preventive maintenance and failure to monitor the equipment against licensee-established goals in accordance with 10 CFR 50.65 was a performance deficiency that was within the capability of FENOC to foresee and correct and should have been prevented. The performance deficiency was determined to be more-than-minor in accordance with IMC 0612 Appendix B, Issue Screening, because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone, and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, FENOC did not properly classify the November 2, 2013, failure of the TDAFW pump, which when properly classified, caused the maintenance rule performance criteria for the AFW system to be exceeded. As a result, the AFW system was evaluated and placed in 10 CFR 50.65 (a)(1) status for a combination of TDAFW pump MPFFs and motor-driven AFW pump MPFFs and CMFs. Additionally, example 7.d from IMC 0612 Appendix E, Examples of Minor Issues, details that a performance deficiency is more than minor if equipment performance problems were such that effective control of performance through appropriate preventive maintenance under (a)(2) could not be demonstrated.
In accordance with IMC 0609, Attachment 4, Initial Characterization of Findings, issued June 19, 2012, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) since it was not a deficiency affecting the design or qualification of a mitigating SSC, it did not represent the loss of a system and/or function, it did not represent an actual loss of function of at least a single train or two separate safety systems out-of-service for greater than its technical specifications allowed outage time, and it did not represent an actual loss of a non-technical specification equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
This finding has a cross-cutting aspect in Human Performance, Avoid Complacency, because FENOC failed to consider the extent of the condition and their causes following the failure of the Unit 1 TDAFW pump on January 6, 2014 [H.12].
Enforcement.
10 CFR 50.65 (a)(1), requires, in part, that the holders of an operating license shall monitor the performance of SSCs within the scope of the rule as defined by 10 CFR 50.65 (b), against licensee-established goals, in a manner sufficient to provide reasonable assurance that such SSCs are capable of fulfilling their intended functions.
10 CFR 50.65 (a)(2) states, in part, that monitoring as specified in 10 CFR 50.65 (a)(1)is not required where it has been demonstrated that the performance of an SSC is being effectively controlled through appropriate preventive maintenance, such that the SSC remains capable of performing its intended function. Contrary to the above, from January 6, 2014 until September 21, 2015, FENOC failed to monitor the equipment against licensee-established goals when the performance of the Unit 1 AFW system had not been effectively controlled through appropriate preventive maintenance. Specifically, FENOC did not identify and properly account for a MPFF of the TDAFW pump occurring on November 2, 2013. FENOCs immediate corrective actions included entering this issue into their corrective action program, re-evaluating and classifying the TDAFW pump failure as a MPFF, performing a 10 CFR 50.65 (a)(1) evaluation of the Unit 1 AFW system, and placing the system in (a)(1) status. Because this finding was of very low safety significance (Green) and was entered into FENOCs corrective action program as condition report (CR) 2016-00884, this violation is being treated as a NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000334/2015004-01, Inadequate Maintenance Rule Monitoring of the Auxiliary Feedwater System)
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that FENOC performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that FENOC personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When FENOC performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the stations probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.
Unit 2 yellow shutdown risk (decay heat removal) due to natural circulation not available on October 1, 2015 Unit 2 yellow shutdown risk (containment closure controls) due to supplemental leak collection and release system not available on October 12, 2015 Unit 1 yellow online risk due to alternate intake structure bay cleaning on November 23, 2015
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:
Unit 2 power operated relief valve (2RCS-PCV456) heat tracing non-functional on October 28, 2015 Unit 2 gas voids in emergency core cooling system piping on November 10, 2015 Unit 1 and 2 control room air in-leakage exceeded acceptance criteria on December 4, 2015 Unit 2 pressurizer power-operated relief valves (2RCS-PCV456 and 2RCS-PCV455D) lifting during surveillance testing on December 17, 2015 The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether technical specification operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and UFSAR to FENOCs evaluations to determine whether the components or systems were operable.
Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by FENOC. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.
b. Findings
No findings were identified.
1R18 Plant Modifications
a. Inspection Scope
The inspectors reviewed the temporary modifications for cooling to the Unit 2 battery rooms 2-1, 2-2, 2-3, and 2-4 to determine whether the modifications affected the safety functions of systems that are important to safety. The inspectors reviewed 10 CFR 50.59 documentation and post-modification testing results, and conducted field walkdowns of the modifications to verify that the temporary modifications did not degrade the design bases, licensing bases, and performance capability of the affected systems.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure was consistent with the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.
Unit 2 No. 2 emergency diesel generator following planned maintenance on October 12, 2015 Unit 2 diverse and flexible coping strategies piping modifications to the service water system and primary plant demineralized water storage tank on October 14, 2015 Unit 2 A service water pump discharge valve, 2SWS*MOV102A, following valve and actuator replacement on October 26, 2015 Unit 2 B power operated relief valve, 2RCS*PCV456, following valve overhaul on October 30, 2015 Unit 1 1A river water pump following overhaul of pump on December 22, 2015
b. Findings
No findings were identified.
1R20 Refueling and Other Outage Activities
a. Inspection Scope
The inspectors reviewed the stations work schedule and outage risk plan for the Unit 2 maintenance and refueling outage 2R18, which was conducted September 26 through October 30, 2015. The inspectors reviewed FENOCs development and implementation of outage plans and schedules to verify that risk, industry experience, previous site-specific problems, and defense-in-depth were considered. During the outage, the inspectors observed portions of the shutdown and cooldown processes and monitored controls associated with the following outage activities:
Configuration management, including maintenance of defense-in-depth, commensurate with the outage plan for the key safety functions and compliance with the applicable technical specifications when taking equipment out of service Implementation of clearance activities and confirmation that tags were properly hung and that equipment was appropriately configured to safely support the associated work or testing Installation and configuration of reactor coolant pressure, level, and temperature instruments to provide accurate indication and instrument error accounting Status and configuration of electrical systems and switchyard activities to ensure that technical specifications were met Monitoring of decay heat removal operations Impact of outage work on the ability of the operators to operate the spent fuel pool cooling system Reactor water inventory controls, including flow paths, configurations, alternative means for inventory additions, and controls to prevent inventory loss Activities that could affect reactivity Maintenance of secondary containment as required by technical specifications Refueling activities, including fuel handling and fuel receipt inspections Fatigue management Tracking of startup prerequisites, walkdown of the primary containment to verify that debris had not been left which could block the emergency core cooling system suction strainers, and startup and ascension to full power operation Identification and resolution of problems related to refueling outage activities
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied technical specifications, the UFSAR, and FENOC procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:
2BVT 1.21.2, Trevitest Method for Main Steam Safety Valve Setpoint Check, Revision 12 on October 8, 2015 2BVT 1.47.5, Type C Leak Test (2SIS*MOV842), Revision 20 on December 16, 2015 (containment isolation valve)
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP4 Emergency Action Level and Emergency Plan Changes (IP
==71114.04 - 1 Sample)
a. Inspection Scope
==
The inspectors performed an in-office review of all Emergency Action Level and Emergency Plan changes submitted by FENOC as required by 10 CFR 50.54(q)(5),including the changes to lower-tier emergency plan implementing procedures, to evaluate for any potential reductions in effectiveness of the Emergency Plan. This review by the inspectors was not documented in an NRC Safety Evaluation Report and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety. The requirements in 10 CFR 50.54(q) were used as reference criteria.
b. Findings
No findings were identified
RADIATION SAFETY
Cornerstone: Occupational and Public Radiation Safety
2RS3 In-Plant Airborne Radioactivity Control and Mitigation
a. Inspection Scope
The inspectors reviewed the control of in-plant airborne radioactivity through the use of engineering controls, respiratory protection devices, and self-contained breathing apparatus (SCBA) to verify airborne concentrations are being controlled consistent with as low as is reasonably achievable (ALARA) and that the use of respiratory protection does not pose an undue risk to the wearer. The inspectors reviewed operability and use of both permanent and temporary ventilation systems; and the adequacy of airborne radioactivity radiation monitoring in the plant based on location, sensitivity, and alarm setpoints. The inspectors reviewed the adequacy of FENOCs use of respiratory protection devices in the plant to include applicable ALARA evaluations, respiratory protection device certification, respiratory equipment storage, air quality testing records, and individual qualification records. The inspectors reviewed the following: status and surveillance records for three SCBAs staged for use during emergencies, SCBA procedures and maintenance test records, procedures for refilling and transporting of SCBA air bottles, SCBA mask size availability, and the qualifications of personnel performing service and repair of this equipment.
b. Findings
No findings were identified.
2RS4 Occupational Dose Assessment
a. Inspection Scope
The inspectors reviewed the monitoring, assessment, and reporting of occupational dose. The inspectors used the requirements in 10 CFR 20, Regulatory Guides, technical specifications, and procedures required by technical specifications as criteria for determining compliance.
Internal Dosimetry The inspectors reviewed: internal dosimetry procedures; whole body counter measurement sensitivity and use, adequacy of the program for whole body count monitoring of plant radionuclides, adequacy of the program for dose assessments based on air sample monitoring and the use of respiratory protection, and internal dose assessments for any actual internal exposures.
Special Dosimetric Situations The inspectors reviewed: FENOCs worker notification of the risks of radiation exposure to the embryo/fetus; the dosimetry monitoring program for declared pregnant workers; external dose monitoring of workers in large dose rate gradient environments; and dose assessments performed since the last inspection that used multi-badging, skin dose or neutron dose assessments.
b. Findings
No findings were identified.
2RS7 Radiological Environmental Monitoring Program (REMP)
a. Inspection Scope
The inspectors reviewed the REMP to validate the effectiveness of the radioactive gaseous and liquid effluent release program. The inspectors reviewed or observed the following items in order to determine compliance.
BVPS 2013 and 2014 annual radiological environmental operating reports REMP program audits Sample collection, monitoring, and dose measurement stations (e.g.,
thermoluminescent dosimeter, air monitoring, vegetation, milk)
Calibration and maintenance records for air sample and dosimetry measurement equipment Environmental sampling of the effluent release pathways specified in the Offsite Dose Calculation Manual (ODCM)
Meteorological tower instrument local and control room data readouts Meteorological instrument operability status and calibration results Missed and anomalous environmental samples reported in the annual radioactive environmental monitoring report Positive environmental sample results Groundwater monitoring program of selected potential leaking SSCs 10 CFR 50.75(g) records of leaks, spills, and remediation since the previous inspection Changes to the ODCM due to changes to the land use census, long-term meteorological conditions, and modifications to the environmental sample stations Environmental sample laboratory analysis results, and measurement detection sensitivities Results of the laboratory quality control program audit, and the inter-and intra-laboratory comparison program results
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
.1 Mitigating Systems Performance Index (4 samples)
a. Inspection Scope
The inspectors reviewed FENOCs submittal of the Mitigating Systems Performance Index for the following systems for the period of October 1, 2014, through September 30, 2015:
Unit 1 emergency alternating current (AC) power system Unit 2 emergency AC power system Unit 1 high pressure injection system Unit 2 high pressure injection System To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in nuclear energy institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7. The inspectors also reviewed FENOCs condition reports, mitigating systems performance index derivation reports, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.
b. Findings
No findings were identified.
.2 Radiological Effluent Technical Specifications/ODCM Radiological Effluent Occurrences
(1 sample)
a. Inspection Scope
The inspectors reviewed FENOCs submittals for the radiological effluent technical specifications/ODCM radiological effluent occurrences performance indicator for the 1st quarter 2014 through the 4th quarter 2014. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7. The inspectors also reviewed FENOCs condition reports, public dose assessments, gaseous and liquid effluent summary data and the results of associated offsite dose calculations to validate the accuracy of the submittals.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review of Problem Identification and Resolution Activities
a. Inspection Scope
As required by Inspection Procedure 71152, Problem Identification and Resolution, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that FENOC entered issues into the corrective action program at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the corrective action program and periodically attended condition report screening meetings.
b. Findings
No findings were identified.
.2 Annual Sample: Maintenance Rule Program Implementation Corrective Actions
a. Inspection Scope
The inspectors performed an in-depth review of FENOCs apparent cause analysis and corrective actions associated with CR 2015-00267 for FENOCs failure to adequately implement risk management actions (RMAs). Specifically, FENOCs failure to implement a contingency plan resulted in an increase in the duration of an elevated risk condition.
The inspectors assessed FENOCs problem identification threshold, cause analyses, extent of condition reviews, compensatory actions, and the prioritization and timeliness of corrective actions to determine whether FENOC was appropriately identifying, characterizing, and correcting problems associated with this issue and whether the planned or completed corrective actions were appropriate. The inspectors compared the actions taken to the requirements of FENOCs corrective action program and 10 CFR 50, Appendix B. In addition, the inspectors performed field walkdowns and interviewed engineering personnel to assess the effectiveness of the implemented corrective actions.
b. Findings and Observations
FENOC determined the apparent cause to be a failure of NOP-OP-1007, Risk Management, to assign clear ownership and responsibility for completion of the RMAs.
FENOCs corrective action plan consisted of eight corrective actions. The first four corrective actions included the preparation of a communication package addressing the RMAs and controls requirements of NOP-OP-1007 and discussion of the package with maintenance and construction, operations, and work management departments.
Corrective action five included a revision of NOP-OP-1007 to define the process and ownership for identifying RMAs that need to be implemented and corrective actions six through eight included a discussion of the changes to the departments previously listed.
Corrective actions five through eight were not performed and closed in June and July of 2015, when FENOC determined that station procedure 1/2-ADM-0804, On-Line Risk Assessment and Management, sufficiently identifies the process and ownership for identifying RMAs and concluded that changes to fleet procedure NOP-OP-1007 were not necessary. 1/2-ADM-0804 states in part, The following are examples that should be performed by the work groups (work centers) to reduce the duration of the work activity, and lists several RMAs. The inspectors determined that the guidance in 1/2-ADM-0804 does not sufficiently address the implementation of RMAs. Specifically, 1/2-ADM-0804 does not identify who in the work group is responsible nor does the procedure establish a process for the implementation of RMAs.
The inspectors concluded that the corrective actions for CR 2015-00267 did not adequately address the apparent cause; however, a revision to NOP-OP-1007, effective December 15, 2015, was made outside of the corrective actions for the condition report.
Changes included a requirement for the lead work group to develop a risk management plan, for yellow and orange risk activities, that has to be reviewed by the work week senior reactor operator and approved by the manager of site operations prior to the commencement of work. The inspectors concluded that the revision to NOP-OP-1007 adequately assigns ownership and responsibility for the completion of RMAs.
.3 Annual Sample: Units 1 and 2 Service Water and River Water Systems, Current Status,
Maintenance and Upgrade Plans
a. Inspection Scope
The inspectors performed an in-depth review of the FENOC staffs problem identification, evaluation and corrective actions related to the Unit 1 river water and Unit 2 service water systems. The inspectors assessed the problem identification threshold, extent of condition reviews, and the prioritization and timeliness of corrective actions to determine whether FENOC personnel were appropriately identifying, characterizing, and correcting problems associated with these heat removal systems and whether the planned or completed corrective actions were appropriate. The inspector reviewed procedure NOP-OP-1009, Rev 5, for control, evaluation and correction of pressure boundary degradation in these systems, and the related operability determination process, for comparison to Appendix C.12 and Appendix C.13 of NRC IMC 0326, Operability Determinations & Functionality Assessments for Conditions Adverse to Quality or Safety.
The inspectors observed the river intake structure and areas in both units where river or service water systems provide heat removal capability, including the Unit 1 component cooling and Unit 2 component cooling primary heat exchangers to exchange heat from closed cooling systems, the emergency diesel generators, and a chemical addition monitoring station. The recent and updated methods and effectiveness of the chemical addition program to the river and service water systems were reviewed.
The inspectors discussed the status of system components with cognizant technical personnel to assess the effectiveness of the planned, scheduled, and completed corrective actions to resolve identified deficiencies. The inspectors compared the actions taken to verify compliance with FENOCs corrective action program procedure and 10 CFR 50, Appendix B requirements.
b. Findings and Observations
No findings were identified.
The inspectors determined that the condition reports reviewed were written to document conditions that required evaluation and corrective actions of maintenance, repair or replacement. The inspectors determined that corrective actions taken were effective to repair or replace the deficient components.
The inspectors determined the extent-of-condition reviews, previous occurrence, generic implications, and common cause evaluations were adequately performed and technically accurate. The inspectors also found that FENOCs technical staff had procedures and processes in place to properly address component wall thinning and thru wall leakage of service water and river water systems pressure boundary components. The inspectors verified that if an inoperability decision was reached as a result of a degraded condition it was adequately addressed.
The inspectors determined FENOCs overall response to identify the causes of degradation of either system, evaluate the significance of the condition, and initiate corrective actions met the standards in FENOCs corrective action program. The scope and timing of the corrective actions was determined to be commensurate with the safety significance of the problems. No issues were identified with the timing for the scope of planned work.
4OA6 Meetings, Including Exit
On January 27, 2016, the inspectors presented the inspection results to Mr. M. Richey, site vice president, and other members of the BVPS 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
M. Richey Site Vice President
E. Larson Site Vice President
- C. McFeaters Director, Site Operations
N. Adams Plant Operator
G. Alberti Steam Generator Project
M. Banko Environmental Supervisor
- G. Buck ISI/NDE, Level III Contractor
G. Cacciani Safety Analysis Engineer
C. Casto Advance Nuclear Specialist
E. Crosby Radiation Protection Manager
- T. DiLeo Supervisor, Fuel Handling
R. Dinello Environmental Field Specialist
A. Dometrovich Regulatory Compliance
R. Egolf System Engineer
J. Fontaine ALARA Supervisor
J. Gallagher Maintenance Rule Coordinator
E. Grabski Radiation Protection Technician (Trainee)
D. Hardaway Radiation Protection Technician
R. Hayward Design Engineer
- D. Heck Staff Engineer, Technical services
- T. Heimel ISI/NDE, Level III Contractor
M. Jansto System Engineer
D. Jones IST Engineer
M. Kienzle System Engineer
- M. Manoleras Director, Engineering
J. Miller Fire Marshall
T. Miller Fleet Access Authorization Specialist
J. Ostrowski Heat Exchanger Program Engineer
M. Ressler Design Engineer
C. Sacha Supervisor Radiation Protection Services
J. Saska Radiation Protection Technician (Trainee)
S. Sawtschenko Emergency Preparedness Manager
C. Scarpone Radiation Protection Technician
P. Seidel Nuclear Specialist (Trainee)
H. Tremblay Auxiliary Feedwater System Engineer
- E. Thomas Supervisor, Regulatory Compliance
D. Wacker Regulatory Compliance
- Z. Warchol Supervisor, Plant Engineering
G. Woolsey Shift Manager
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened/Closed
- 05000334/2015004-01 NCV Inadequate Maintenance Rule Monitoring of the Auxiliary Feedwater System (Section 1R12)