IR 05000334/2016001
| ML16125A037 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 05/04/2016 |
| From: | Silas Kennedy NRC/RGN-I/DRP/PB6 |
| To: | Richey M FirstEnergy Nuclear Operating Co |
| KENNEDY, SR | |
| References | |
| IR 2016001 | |
| Download: ML16125A037 (34) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION May 4, 2016
SUBJECT:
BEAVER VALLEY POWER STATION - INTEGRATED INSPECTION REPORT 05000334/2016001 AND 05000412/2016001
Dear Mr. Richey:
On March 31, 2016, 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 April 27, 2016, with you 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 violation of NRC requirements, which was of very low safety significance (Green). However, because of the very low safety significance, and because the violation is 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. 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 05000334/2016001 and 05000412/2016001 w/Attachment: Supplementary Information
REGION I==
Docket Nos.: 50-334 and 50-412 License Nos.: DPR-66 and NPF-73 Report No.: 05000334/2016001 and 05000412/2016001 Licensee: FirstEnergy Nuclear Operating Company (FENOC)
Facility: Beaver Valley Power Station, Units 1 and 2 Location: Shippingport, PA 15077 Dates: January 1, 2016 to March 31, 2016 Inspectors: J. Krafty, Senior Resident Inspector B. Reyes, Resident Inspector R. Rolph, Health Physicist Approved By: Silas R. Kennedy, Chief Reactor Projects Branch 6 Division of Reactor Projects Enclosure
SUMMARY
IR 05000334/2016001, 05000412/2016001; 01/01/2016 - 03/31/2016; Beaver Valley Power
Station, Units 1 and 2; Operability Determinations and Functionality Assessments.
This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified one 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: Barrier Integrity
- Green.
The inspectors identified an NCV of Title 10 of the Code of Federal Regulations (CFR), Part 50, Appendix B, Criterion XI, Test Control, for FENOCs failure to properly evaluate the test results of the Control Room Envelope (CRE) unfiltered air in-leakage test performed in December 2015. Specifically, the test results exceeded the acceptance criteria specified in the test procedure and required further engineering evaluation to determine if the control room emergency ventilation system (CREVS) could meet its specified safety function. The inspectors identified that the engineering evaluation of the test results did not account for all of the in-leakage and resulted in a reasonable doubt of operability of CREVS.
FENOCs immediate corrective action was to re-evaluate the December 2015 calculation and verify that CREVS remained operable with the increased in-leakage. FENOC entered the issue into their corrective action program, condition report (CR) 2016-03836.
The performance deficiency is more-than-minor because it is associated with the human performance attribute of the Barrier Integrity cornerstone, and adversely affected the cornerstone objective of providing reasonable assurance that physical design barriers protect from radionuclide releases caused by accidents or events. Specifically, FENOCs evaluation did not account for in-leakage from the non-tested portions of the control room radiological barrier, and therefore, did not provide reasonable assurance that the control room dose would not exceed five rem during an uncontrolled release of radioactivity.
Additionally, this issue is similar to example 3j and 3k of IMC 0612 Appendix E, Examples of Minor Issues, in that FENOCs December 2015 engineering evaluation failed to adequately account for CRE in-leakage and resulted in a reasonable doubt of the operability of CREVS. The inspectors determined that this finding was of very low safety significance (Green) because it only represented a degradation of the radiological barrier function provided for the control room. This finding has a cross-cutting aspect in the area of Human Performance, Conservative Bias, because FENOC did not take a conservative approach to decision making, particularly when the in-leakage information was incomplete [H.14].
(Section 1R15)
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 at 100 percent power and operated at full power until February 3, 2016, when the unit entered a planned outage to make repair to the main generator.
Operators returned the unit to 100 percent power on February 13, 2016, and operated 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
.1 External Flooding
a. Inspection Scope
During the week of February 22, 2016, the inspectors performed an inspection of the external flood protection measures for Beaver Valley Power Station. The inspectors reviewed technical specifications, procedures, design documents, and Chapters 2.7.3 of the Unit 1 updated final safety analysis report (UFSAR) and 3.4.1 of the Unit 2 UFSAR, which depicted the design flood levels and protection areas containing safety-related equipment to identify areas that may be affected by external flooding. The inspectors conducted a general site walkdown of the main intake structure, Unit 1 turbine building, Unit 2 service building, and Unit 1 main control room air conditioning and relay rooms to ensure that FENOC erected flood protection measures in accordance with design specifications. The inspectors also reviewed operating procedures for mitigating external flooding during severe weather to determine if FENOC planned or established adequate measures to protect against external flooding events. Documents reviewed for each section of this inspection report are listed in the Attachment.
b. Findings
No findings were identified.
.2 Readiness for Impending Adverse Weather Conditions
a. Inspection Scope
The inspectors reviewed FENOCs preparations for the onset of cold weather on January 19, 2016. The inspectors reviewed the implementation of adverse weather preparation procedures before the onset of and during this adverse weather condition.
The inspectors walked down the refueling water storage tanks and demineralized water storage tank to ensure availability. The inspectors verified that operator actions defined in FENOCs adverse weather procedure maintained the readiness of essential systems.
The inspectors discussed readiness and staff availability for adverse weather response with operations and work control personnel.
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 A train of recirculation spray system (RSS) while the D train of RSS was out of service for scheduled maintenance on January 22, 2016 Unit 2 service water system when the standby service water system was connected to the A train of service water on February 1, 2016 Unit 1 low head safety injection system following surveillance testing on the A train on February 29, 2016 Unit 1 quench spray system (QSS) following surveillance testing on the B QSS on March 7, 2016 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, technical specifications, CRs, 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 February 29, 2016, the inspectors performed a complete system walkdown of accessible portions of the Unit 2 QSS to verify the existing equipment lineup was correct.
The inspectors reviewed operating procedures, surveillance tests, drawings, equipment line-up check-off lists, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, pipe hanger and support functionality, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the system 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 a sample of related CRs to ensure FENOC appropriately evaluated and resolved any deficiencies.
b. Findings
No findings were identified.
1R05 Fire Protection
.1 Resident Inspector Quarterly Walkdowns
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 1 Normal Switchgear, Fire Area NS-1, on January 22, 2016 Unit 1 DF Switchgear, Fire Area ES-2, on January 22, 2016 Unit 2 Cable Spreading Room, Fire Area SB-3, on February 8, 2016 Unit 2 Auxiliary Boiler, Fire Area SOB-1, on February 16, 2016 Unit 2 Relay Room, Fire Area CV-6, on February 16, 2016 Unit 2 Rod Control Area, Fire Area CV-3, on February 16, 2016 Unit 1 Auxiliary Building 722 ft., Fire Area PA-1G on February 24, 2016
b. Findings
No findings were identified.
.2 Fire Protection - Drill Observation
a. Inspection Scope
The inspectors observed a fire brigade drill scenario conducted on March 8, 2016, that involved a fire in the Unit 2 condensate polishing control room. The inspectors evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that FENOC personnel identified deficiencies, openly discussed them in a self-critical manner at the debrief, and took appropriate corrective actions as required. The inspectors evaluated specific attributes as follows:
Proper wearing of turnout gear and self-contained breathing apparatus Proper use and layout of fire hoses Employment of appropriate fire-fighting techniques Sufficient fire-fighting equipment brought to the scene Effectiveness of command and control Search for victims and propagation of the fire into other plant areas Smoke removal operations Utilization of pre-planned strategies Adherence to the pre-planned drill scenario Drill objectives met The inspectors also evaluated the fire brigades actions to determine whether these actions were in accordance with FENOCs fire-fighting strategies.
b. Findings
No findings were identified.
1R06 Flood Protection Measures
.1 Internal Flooding Review
a. Inspection Scope
The inspectors reviewed the UFSAR, the site internal flooding analysis, and plant procedures to assess susceptibilities involving internal flooding. The inspectors also reviewed the corrective action program to determine if FENOC identified and corrected flooding problems and whether operator actions for coping with flooding were adequate.
The inspectors focused on the Unit 1 auxiliary building to verify the adequacy of equipment seals located below the flood line, common drain lines and sumps, sump pumps, level alarms, and control circuits.
b. Findings
No findings were identified.
.2 Annual Review of Cables Located in Underground Bunkers/Manholes
a. Inspection Scope
The inspectors conducted an inspection of underground bunkers/manholes subject to flooding that contain cables whose failure could affect risk-significant equipment. The inspectors performed walkdowns of risk-significant areas, including manhole EMH-8A and EMH-8B containing safety-related river water and service water cables, to verify that the cables were not submerged in water, that cables and/or splices appeared intact, and to observe the condition of cable support structures. When applicable, the inspectors verified proper sump pump operation and verified level alarm circuits were set in accordance with station procedures and calculations to ensure that the cables will not be submerged.
b. Findings
No findings were identified.
1R07 Heat Sink Performance (711111.07A - 1 sample)
a. Inspection Scope
The inspectors reviewed the Unit 1 C component cooling reactor (CCR) 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. The inspectors observed actual performance tests for the heat exchanger and reviewed the results of previous inspections of the Unit 1 CCR heat exchangers. The inspectors discussed the results of the most recent inspection with engineering staff and reviewed pictures of the as-found and as-left 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.
1R11 Licensed Operator Requalification Program
.1 Quarterly Review of Licensed Operator Requalification Testing and Training
a. Inspection Scope
The inspectors observed Unit 1 licensed operator simulator training on January 25, 2016, which included a load rejection, pressurizer level transmitter failure, instrument air compressor trip, medical emergency, and a reactor coolant pump locked rotor coincident with a steam generator tube rupture. 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 and reviewed Unit 2 reactor shutdown February 3, 2016. The inspectors observed infrequently performed test or evolution briefings and reactivity control briefings to verify that the briefings met the criteria specified in NOP-OP-1002, Conduct of Operations Revision 11. Additionally, the inspectors observed operator performance to verify that procedure use, crew communications, and coordination of activities between work groups similarly 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 structure, system, and component (SSC) performance and reliability. The inspectors reviewed system health reports, corrective action program documents, 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 2 service water on February 8, 2016 Unit 1 4 kilovolt (kV) station service system on February 16, 2016 Unit 1 fire protection system on March 4, 2016
b. Findings
No findings were identified.
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 2B transformer out of service for testing and the B charging pump out of service for planned maintenance on January 15, 2016 Unit 2 No. 2 emergency diesel generator (EDG) and B component cooling pump out of service on February 17, 2016 Unit 1 A train of reactor plant river water out of service for 9A auxiliary river water pump testing on March 2, 2016 Unit 1 No. 2 EDG and DF 4kV emergency bus undervoltage relays out of service for testing on March 8, 2016 Unit 1 yellow probabilistic risk assessment (PRA) risk during racking of the C river water pump breaker to the DF 4 kV emergency bus on March 18, 2016 Unit 1 yellow PRA risk during Unit 1 138 kV bus 1 power circuit breaker (PCB-92)relay trip checks
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 pressurizer vapor space sample outside containment isolation valve dual indication on January 7, 2016 Unit 1 B steam generator main feedwater regulating valve air leakage on January 25, 2016 Unit 1 and 2 CREVS in-leakage exceeded acceptance criteria on February 9, 2016 Unit 2 turbine driven auxiliary feedwater (TDAFW) pump oil reservoir water intrusion on February 10, 2016 Reanalysis of Unit 1 and Unit 2 CREVS December 2015 in-leakage that exceeded procedural limits on March 15, 2016 Unit 2 TDAFW pump slow start time on March 22, 2016 Unit 2 B service water pump head ratio in action range on March 28, 2016 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
Introduction.
The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XI, Test Control, for FENOCs failure to properly evaluate the test results of the CRE unfiltered air in-leakage test performed in December 2015.
Description.
In December 2015, FENOC performed surveillance procedure 3BVT 1.44.05, Control Room Envelope Air In-Leakage Test. This is a required surveillance that is used to verify that the Unit 1 and Unit 2 CREVS can perform its safety function to provide a protected environment for the control room operators following an uncontrolled release of radioactivity. The surveillance consists of four separate tests: normal mode, recirculation mode, Unit 1 pressurization mode, and Unit 2 pressurization mode. On December 22, 2015, all four tests exceeded their acceptance criteria specified in 3BVT 1.44.05,Section VIII, Acceptance Criteria. For tests results that exceed the acceptance criteria, the surveillance procedure required further engineering evaluation.
The engineering evaluation of all the test results, documented on December 31, 2015, concluded that the increased in-leakage would not cause the control room dose to exceed the limit of 5 rem stated in 10 CFR 50.67, Accident Source Term. Based on the engineering evaluation of the test results, FENOC concluded that CREVS was operable but degraded.
To address the CREVS degraded condition, FENOC made repairs and adjustments to two CREVS inlet dampers, a fire door, and the differential pressure between the CRE and the adjoining spaces. In February 2016, FENOC re-performed in-leakage testing following the repairs. The normal mode test in-leakage increased from 907 standard cubic feet per minute (scfm) in December 2015 to 1306 scfm. FENOC performed repairs on a discharge damper, and reduced normal mode in-leakage to 1077 scfm.
The engineering evaluation of the results was documented on February 9, 2016, and concluded that the in-leakage would not result in exceeding the control room dose limit stated in 10 CFR 50.67. Based on the February 2016 engineering evaluation, FENOC concluded that CREVS remained operable but degraded.
The inspectors questioned why the normal mode in-leakage in February 2016 increased when repairs were made that should have actually decreased the in-leakage. FENOC informed the inspectors that the December 2015 normal mode test was a partial test since it only tested the CREVS inlet dampers rather than the entire normal mode lineup.
The inspectors determined that FENOC did not adequately evaluate the CRE test results in December 2015 since FENOCs evaluation did not make allowances for in-leakage in the untested portions of CREVS. As a result, the inspectors concluded that there was a reasonable doubt of operability of CREVS from December 31, 2015, to February 9, 2016, given that the actual December normal mode in-leakage was unknown.
FENOC provided evidence that the 1306 scfm in-leakage measured in the February 2016 normal mode test bounded the actual normal mode in-leakage in December 2015.
FENOC re-evaluated the December 2015 test results using the in-leakage numbers from the recirculation mode, Unit 1 pressurization mode, and Unit 2 pressurization mode tests and calculated that the control room dose limit stated in 10 CFR 50.67 would not be exceeded as long as the normal mode in-leakage did not exceed 1697 scfm. As a result, FENOC concluded that there was a reasonable expectation of operability during the period in question. In addition to re-evaluating the December 2015 calculation, immediate FENOC corrective action included entering this issue into their corrective action program as CR 2016-03836.
Analysis.
The inspectors determined FENOCs failure properly evaluate the December 2015 CRE in-leakage test results in accordance with 10 CFR 50 Appendix B, Criterion XI, Test Control, was a performance deficiency that was within the capability of FENOC to foresee and correct, and therefore should have been prevented. The performance deficiency was more-than-minor because it was associated with the human performance attribute of the Barrier Integrity cornerstone, and adversely affected the cornerstone objective of providing reasonable assurance that physical design barriers protect from radionuclide releases caused by accidents or events. Specifically FENOCs evaluation did not account for in-leakage from the non-tested portions of the control room radiological barrier, and therefore, did not provide reasonable assurance that the control room dose would not exceed five rem during an uncontrolled release of radioactivity.
Additionally, this issue is similar to example 3j and 3k of IMC 0612 Appendix E, Examples of Minor Issues, in that FENOCs December 2015 engineering evaluation failed to adequately account for CRE in-leakage and resulted in a reasonable doubt of the operability of CREVS.
In accordance with IMC 0609, Attachment 4, Initial Characterization of Findings, issued June 19, 2012, and Exhibit 3 of IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012, the inspectors determined that this finding was of very low safety significance (Green) because it only represented a degradation of the radiological barrier function provided for the control room.
This finding has a cross-cutting aspect in the area of Human Performance, Conservative Bias, because FENOC did not take a conservative approach to decision making, particularly when the in-leakage information was incomplete [H.14].
Enforcement.
10 CFR 50 Appendix B, Criterion XI, Test Control, requires, in part, that test results shall be documented and evaluated to assure that test requirements have been satisfied. Contrary to the above, from December 31, 2015 until February 9, 2016, FENOC failed to adequately evaluate the December 2015 CRE air in-leakage test results and could not assure that the five rem dose limit to the control room would not be exceeded. FENOCs immediate corrective action was to re-evaluate the December calculation and verify that CREVS remained operable with the increased in-leakage.
Because this finding is of very low safety significance (Green) and the issue was entered into the corrective action program as CR 2016-03836, this violation is being treated as a NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV
===5000334/2016001-01 and 05000412/2016001-01, Failure to Properly Evaluate Control Room Envelope Test Results).
1R18 Plant Modifications
a. Inspection Scope
The inspectors reviewed the temporary modification, Engineering Change Package 14-0099 - Reduction of Unit 1 Spray Line Low Temperature Setpoint, Revision 0, 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 source range detector N-31 troubleshooting unexpected neutron count at power due to a noise source and ground strap installation on February 10, 2016 Unit 1 power range nuclear instrument, N-43, replacement of isolation amplifiers on February 17, 2016 Unit 1 inadequate core cooling monitor data logger train A, digital contact input card replacement, on February 17, 2016 Unit 1 A charging pump motor and pump preventive maintenance on February 23, 2016 Unit 1 No. 2 EDG fuel oil transfer pump preventive maintenance on March 9, 2016 Unit 1 control room emergency ventilation following inlet and outlet damper maintenance on March 15, 2016 Unit 2 B component cooling water pump following mechanical seal replacement and breaker inspection on March 17, 2016
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:
2OST-30.13B, Train B Service Water System Full Flow Test, Revision 37, on January 13, 2016 (in-service test)1MSP-6.12-I, P-455, Pressurizer Pressure Channel I Test, Revision 15 on January 29, 2016 1OST-24.4, Steam Turbine Driven Auxiliary Feed Pump Test (1FW-P-2), Revision 54 on February 4, 2016 (in-service test)2BVT 1.16.7, Supplemental Leak Collection and Release System Train B Filter Efficiency and Flow Test, Revision 13, on February 22, 2016 2MSP-2.06-I, Power Range Neutron Flux Channel N44 Refueling Calibration, Revision 35 on February 26, 2016 2OST-1.11C, Safeguards Protection System Train A CIB/Spray Actuation Test, Revision 27 on March 29, 2016
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation
.1 Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors evaluated the conduct of a routine FENOC emergency drill on March 10, 2016, to identify any weaknesses and deficiencies in the classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator, technical support center, and emergency operations facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures.
The inspectors also compared their observations with those identified by FENOC staff in order to evaluate FENOCs critique and to verify whether the FENOC staff was properly identifying weaknesses and entering them into the corrective action program.
b. Findings
No findings were identified.
.2 Training Observations
a. Inspection Scope
The inspectors observed a simulator training evolution for Unit 1 licensed operators on January 25, 2016, which required emergency plan implementation by an operations crew. FENOC planned for this evolution to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the post-evolution critique for the scenario. The focus of the inspectors activities was to note any weaknesses and deficiencies in the crews performance and ensure that FENOC evaluators noted the same issues and entered them into the corrective action program.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstone: Occupational and Public Radiation Safety
2RS1 Radiological Hazard Assessment and Exposure Controls
a. Inspection Scope
The inspectors reviewed FENOCs performance in assessing and controlling radiological hazards in the workplace. The inspectors used the requirements contained in 10 CFR 20, technical specifications, applicable Regulatory Guides (RGs), and the procedures required by technical specifications as criteria for determining compliance.
Inspection Planning
The inspectors reviewed the performance indicators for the occupational exposure cornerstone, radiation protection program audits, and reports of operational occurrences in occupational radiation safety since the last inspection.
Radiological Hazard Assessment ===
The inspectors conducted independent radiation measurements during walk-downs of the facility and reviewed the radiological survey program; air sampling and analysis; continuous air monitor use, recent plant radiation surveys for radiological work activities, and any changes to plant operations since the last inspection to verify survey adequacy any new radiological hazards for onsite workers or members of the public.
Radiological Hazards Control and Work Coverage (1 sample)
The inspectors evaluated in-plant radiological conditions and performed independent radiation measurements during facility walk-downs and observation of radiological work activities. The inspectors assessed whether posted surveys, radiation work permits (RWPs), worker radiological briefings, the use of continuous air monitoring and dosimetry monitoring were consistent with the present conditions. The inspectors examined the control of highly activated or contaminated materials stored within the spent fuel pools and the posting and physical controls for selected high radiation areas (HRAs), locked high radiation areas and very high radiation areas (VHRA) to verify conformance with the occupational performance indicator.
Risk-Significant HRA and VHRA Controls (1 sample)
The inspectors reviewed the controls and procedures for HRAs, VHRAs, and radiological transient areas in the plant.
Problem Identification and Resolution (1 sample)
The inspectors evaluated whether problems associated with radiation monitoring and exposure control (including operating experience) were identified at an appropriate threshold and properly addressed in the corrective action program.
Findings No findings were identified.
2RS2 Occupational ALARA Planning and Controls
a. Inspection Scope
The inspectors assessed FENOCs performance with respect to maintaining occupational individual and collective radiation exposures as low as is reasonably achievable (ALARA). The inspectors used the requirements contained in 10 CFR 20, applicable RGs, technical specifications, and procedures required by technical specifications as criteria for determining compliance.
Inspection Planning
The inspectors conducted a review of Beaver Valley collective dose history and trends; ongoing and planned radiological work activities; radiological source term history and trends; and ALARA dose estimating and tracking procedures.
Radiological Work Planning (1 sample)
The inspectors selected the following radiological work activities based on exposure significance for review:
RWP No.
Description Dose Estimate Actual Dose (person-Rem) (person-Rem)115-4028 Scaffolding-Construction 11.459 9.459 215-5028 Scaffolding-Construction 12.625 14.456 115-4023 Construction Support for ISI 2.950 2.364 215-5017 Primary Side Steam 8.445 7.450 Generator For each of these activities the inspectors reviewed: ALARA work activity evaluations; exposure estimates; exposure reduction requirements; results achieved (dose rate reductions, actual dose); person-hour estimates and results achieved; and post-job reviews that were conducted to identify lessons learned.
b. Findings
No findings were identified.
2RS3 In-Plant Airborne Radioactivity Control and Mitigation
a. Inspection Scope
The inspectors reviewed the control of in-plant airborne radioactivity and the use of respiratory protection devices in these areas. The inspectors used the requirements in 10 CFR 20, RG 8.15, RG 8.25, NUREG/CR-0041, technical specifications, and procedures required by technical specifications as criteria for determining compliance.
Inspection Planning
The inspectors reviewed the UFSAR to identify ventilation and radiation monitoring systems associated with airborne radioactivity controls and respiratory protection equipment staged for emergency use. The inspectors also reviewed respiratory protection program procedures and current performance indicators for unintended internal exposure incidents.
Engineering Controls (1 sample)
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 set-points.
Problem Identification and Resolution (1 sample)
The inspectors evaluated whether problems associated with the control and mitigation of in-plant airborne radioactivity were identified at an appropriate threshold and addressed by FENOCs corrective action program.
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, RGs, technical specifications, and procedures required by technical specifications as criteria for determining compliance.
Inspection Planning
The inspectors reviewed: radiation protection program audits; National Voluntary Laboratory Accreditation Program (NVLAP) dosimetry testing reports; and procedures associated with dosimetry operations.
External Dosimetry (1 sample)
The inspectors reviewed: dosimetry NVLAP accreditation; onsite storage of dosimeters; the use of correction factors to align electronic personal dosimeter results with NVLAP dosimetry results; dosimetry occurrence reports; and corrective action program documents for adverse trends related to external dosimetry.
Special Dosimetric Situations (1 sample)
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.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
.1 Unplanned Scrams, Unplanned Power Changes, and Unplanned Scrams with
Complications (6 samples)
a. Inspection Scope
The inspectors reviewed FENOCs submittals for the following Initiating Events cornerstone performance indicators for the period of January 1, 2015, through December 31, 2015.
Unit 1 Unplanned Scrams Unit 2 Unplanned Scrams Unit 1 Unplanned Power Changes Unit 2 Unplanned Power Changes Unit 1 Unplanned Scrams with Complications Unit 2 Unplanned Scrams with Complications To determine the accuracy of the performance indicator data reported during those periods, inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7. The inspectors reviewed FENOCs operator narrative logs, event reports, and NRC integrated inspection reports 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 CR screening meetings.
b. Findings
No findings were identified.
.2 Semi-Annual Trend Review
a. Inspection Scope
The inspectors performed a semi-annual review of site issues, as required by Inspection Procedure 71152, Problem Identification and Resolution, to identify trends that might indicate the existence of more significant safety issues. The inspectors reviewed the FENOCs Beaver Valley Fleet Oversight report for February 1 through July 31 of 2015, conducted under NOBP-LP-2023, Performance Assessment, and selected elevation/escalation letters and associated CRs to verify that FENOC personnel were appropriately evaluating and trending adverse conditions in accordance with applicable procedures. The inspectors also reviewed FENOCs corrective action program database for the third and fourth quarters of 2015 to assess CRs written in various subject areas (equipment problems, human performance issues, etc.), as well as individual issues identified during the NRCs daily CR review (Section 4OA2.1).
b. Findings and Observations
No findings were identified.
No adverse trends were identified by the inspectors that had not already been identified by FENOC. The inspectors verified that identified trends were addressed within the scope of the corrective action program, or were considered as emerging or adverse trends through review and documentation in the fleet oversight report.
The inspectors noted that an adverse trend in configuration control has been identified annually by Fleet Oversight since 2012, and was discussed in the 2015 3rd quarter NRC inspection report (2015003). The inspectors evaluated a sampling of CRs associated with plant configuration control. The inspectors determined that FENOC appropriately identified a trend in the stations failure to maintain plant configuration control in CR 2015-14433, dated October 24, 2015, and implemented corrective actions.
CR 2015-14433 identifies a trend of 18 plant configuration control events that occurred during maintenance activities from May 4 through October 31, 2015. Three of the events involved the operations department and the other events involved predominantly electrical maintenance and the instrumentation and control departments. Each of the 18 events involved inadequate procedures, procedure use and adherence, or a failure to implement human performance error prevention techniques. Corrective actions included management reinforcement of human performance error prevention techniques to the maintenance department and further discussion of the techniques during focused shop briefs. The inspectors identified seven additional CRs for plant status control events not included in CR 2015-14433, all of which were operations-related.
The inspectors determined that on average, 22.5 plant configuration control events have occurred annually since 2012, with 14.25 of those events being attributed to the operations department. The inspectors identified that from May 4 through October 31, 2015, the number of operations department plant configuration control events was below the annual average with 10 events; however, the number of station events was above the annual average with 25 events. The inspectors concluded that while operations department plant configuration control improved in 2015, FENOCs corrective actions from a previous Fleet Oversight elevation and an escalation have not mitigated the trend in the stations failure to maintain plant configuration control.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion
Plant Events
a. Inspection Scope
For the plant events listed below, the inspectors reviewed and/or observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant events to appropriate regional personnel, and compared the event details with criteria contained in IMC 0309, Reactive Inspection Decision Basis for Reactors, for consideration of potential reactive inspection activities. As applicable, the inspectors verified that FENOC made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR Parts 50.72 and 50.73, if required. The inspectors reviewed FENOCs follow-up actions related to the events to assure that FENOC implemented appropriate corrective actions commensurate with their safety significance.
Unit 1 Notice of Unusual Event on January 1, 2016, due to FENOCs inability to verify that there was no fire within 15 minutes of receiving a smoke detector alarm in containment.
Unit 2 planned outage on February 3, 2016, to address high vibrations on main generator end turns.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
On April 27, 2016, the inspectors presented the inspection results to M. Richey, Site Vice President, and other members of the Beaver Valley Power Station 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
C. McFeaters Plant General Manager
D. Barth Radiation Protection Technician
A. Brunner Supplemental Leak Collection and Release System Engineer
G. Caccani 10 CFR 50.59 Program Manager
E. Crosby Radiation protection Manager
R. Egolf System Engineer
W. Etzel Senior Consulting Engineer
J. Fontaine Radiation Protection Supervisor ALARA
P. Hartig Shift Manager
J. Huling Mechanical Maintenance
D. Jones IST Engineer
M. Kienzle Unit 2 Auxiliary Feedwater System Engineer
T. King System Engineer
A. Lang Chemical Analyst
S. Mercer System Engineer
J. Miller Fire Marshall
T. OLeary Shift Manager
M. Ressler Nuclear Configuration Control Engineering Supervisor
C. Sacha Radiation Protection Services Supervisor
W. Scott Control Room Supervisor
- T. Steed Director, Performance Improvement
M. Stoner Instrumentation and Controls Supervisor
E. Thomas Regulatory Compliance Supervisor
K. Tiefenthal Shift Manager
S. Vicinie Fleet Oversight Supervisor
D. Wacker Compliance Engineer
Z. Warchol System Engineering Supervisor
D. Wilson Air Operated Valve Engineer
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened/Closed
- 05000334/2016001-01 NCV Failure to Properly Evaluate Control Room
- 05000412/2016001-01 Envelope Test Results (Section 1R15)