IR 05000334/2017001

Integrated Inspection Report 05000334/2017001 and 05000412/2017001 and Exercise of Enforcement Discretion

ML17135A162
Person / Time
Site:	Beaver Valley
Issue date:	05/15/2017
From:	Michael Scott Division Reactor Projects I
To:	Richey M FirstEnergy Nuclear Operating Co
Kennedy S
References
EA-17-045 IR 2017001
Download: ML17135A162 (35)

Text

May 15, 2017

SUBJECT:

BEAVER VALLEY POWER STATION - INTEGRATED INSPECTION REPORT 05000334/2017001 AND 05000412/2017001 AND EXERCISE OF ENFORCEMENT DISCRETION

Dear Mr. Richey:

On March 31, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Beaver Valley Power Station, Units 1 and 2. On April 6, 2017, the NRC inspectors discussed the results of this inspection with Mr. Richard Bologna, General Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.

NRC inspectors documented one Severity Level IV violation with no associated finding. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy. Additionally, a violation of FirstEnergy Nuclear Operating Company (FENOCs) site-specific licensing basis for tornado-generated missile protection was identified.

Because this violation was identified during the discretion period covered by Enforcement Guidance Memorandum 15-002 Revision 1, Enforcement Discretion for Tornado Missile Protection Non-compliance (ML16355A286)1 and because FENOC is implementing compensatory measures, the NRC is exercising enforcement discretion by not issuing an enforcement action and is allowing continued reactor operation.

If you contest the violations or significance of the NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U. S.

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Beaver Valley Power Station.

1 Designation in parentheses refers to the Agencywide Documents Access and Management System (ADAMS) Accession Number. Documents referenced in this letter are publicly-available using the Accession Number in ADAMS. This letter, its enclosure, and your response, (if any), will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and the NRCs Public Document Room in accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Michael L. Scott, Director Division of Reactor Projects

Docket Nos.

50-334 and 50-412 License Nos. DPR-66 and NPF-73

Enclosure:

Inspection Report 05000334/2017001 and 05000412/2017001 w/Attachment:

Supplementary Information

REGION I==

Docket Nos.:

50-334 and 50-412

License Nos.:

DPR-66 and NPF-73

Report No.:

05000334/2017001 and 05000412/2017001

Licensee:

FirstEnergy Nuclear Operating Company (FENOC)

Facility:

Beaver Valley Power Station, Units 1 and 2

Location:

Shippingport, PA 15077

Dates:

January 1, 2017 to March 31, 2017

Inspectors:

J. Krafty, Senior Resident Inspector

S. Horvitz, Resident Inspector

R. Rolph, Health Physicist

Approved By:

Silas R. Kennedy, Chief

Reactor Projects Branch 6

Division of Reactor Projects

SUMMARY

IR 05000334/2017001 and 05000412/2017001; 1/1/2017 - 3/31/2017; Beaver Valley

Power Station Units 1 and 2; Other Activities.

This report covered a three-month period of inspection by resident inspectors and announced baseline inspections performed by regional inspectors. The inspectors identified one non-cited violation (NCV) which was a Severity Level IV. The significance of most findings and violations 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. However, as explained below, certain violations are assessed using a different process referred to as traditional enforcement. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated November 1, 2016. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,

Revision 6.

Cornerstone: Mitigating Systems

• Severity Level IV. The inspectors identified a Severity Level IV NCV of Title 10 of the Code of Federal Regulations (CFR) 50.55a(z), Alternatives to codes and standards requirements, for FENOCs failure to obtain prior authorization for implementing an alternative to the American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code). Specifically, until prompted by the inspectors, FENOC did not submit to the NRC and receive an alternative to the ASME OM Code requirement to not test the residual heat removal (RHR) relief valve, RV-1RH-721, during a recent refueling outage for Unit 1 when the charging system letdown relief valve,

RV-1CH-203, failed to lift within three percent of set-pressure. FENOCs immediate corrective actions included performing a prompt operability determination, submitting a relief request, and entering the issue into the corrective action program (CAP) as condition report (CR) 2017-03937.

The inspectors determined that this violation impacted the ability of the NRC to perform its regulatory oversight function, and was therefore subject to traditional enforcement. Section 2.2.1.c of the Enforcement Policy states that failure to receive prior NRC approval for changes in licensed activities when required is an example of impacting the ability of the NRC to perform its regulatory oversight function. After considering the factors in Section 2.2.1.c of the Enforcement Policy, the inspectors determined that the performance deficiency was a Severity Level IV violation because the change implemented by FENOC would likely be approved by the NRC. Because this violation involves the traditional enforcement process and does not have an associated finding that is more than minor, the inspectors did not assign a cross-cutting aspect to this violation in accordance with IMC 0612, Appendix B.

(Section 4OA5)

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 or near full power until March 17, 2017, when the unit entered end-of-cycle coastdown operations. Unit 2 ended the inspection period at 95 percent power.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

.1 External Flooding

a. Inspection Scope

During the week of January 16, 2017, the inspectors performed an inspection of the external flood protection measures for Beaver Valley Power Station. The inspectors reviewed technical specifications, procedures, Unit 1 updated final safety analysis report (UFSAR), Chapter 2.7.3 and Unit 2 UFSAR Chapter 3.4.1, 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 walkdown of susceptible areas of the plant, including the lower elevations of the Unit 1 auxiliary building and the Unit 2 auxiliary building, cable tunnel, safeguards room, and control building to ensure that FENOC flood protection measures were in accordance with design specifications. The inspectors verified that adequate procedures existed for inspecting flood seals. The inspectors also reviewed operating procedures for mitigating external flooding during severe weather to confirm that FENOC had established adequate measures to protect against external flooding events and, more specifically, that credited operator actions were adequate. 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 extreme cold weather on February 9, 2017. 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 tanks 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

Partial System Walkdowns (71111.04 - 4 samples)

a. Inspection Scope

==

The inspectors performed partial walkdowns of the following systems:

• Unit 1 C charging pump aligned to A train during A charging pump maintenance on January 23, 2017;

• Unit 1 A motor driven auxiliary feedwater (MDAFW) pump and turbine driven auxiliary feedwater (TDAFW) pump while the B MDAFW pump was out of service for maintenance on February 16, 2017;

• Unit 2 TDAFW pump following surveillance testing on February 22, 2017;

• Unit 2 emergency diesel generator (EDG) 2-2 following recent testing on March 21, 2017

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 the systems performance of its 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 FENOC staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.

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 Auxiliary Building 768 Level, Fire Area PA-1A, on January 19, 2017;

• Unit 1 Turbine Building, Fire Areas TB-1, TB-2, TB-3, and TG-1, on January 19, 2017;

• Unit 1 EDG 1-2 room, Fire Area DG-2, on February 8, 2017;

• Unit 2 Battery Rooms 2-2 and 2-4, Fire Areas SB-8 and SB-9 on February 15, 2017;

• Unit 2 Computer Room, Fire Area CB-4 on February 17, 2017

• Unit 2 Battery Rooms 2-1 and 2-3, Fire Areas SB-6 and SB-7 on February 21, 2017;

• Unit 1 and Unit 2 Alternate Intake Structure, Fire Area AIS-1 on March 13, 2017

b. Findings

No findings were identified.

.2 Fire Protection - Drill Observation

a. Inspection Scope

The inspectors observed a fire brigade drill scenario conducted on February 4, 2017, that involved a fire in the unit 2 EDG 2-1 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 the following specific attributes of the drill:

• 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

Internal Flooding Review

a. Inspection Scope

The inspectors reviewed the UFSAR, the site flooding analysis, and plant procedures to identify internal flooding susceptibilities for the site. The inspectors review focused on the Unit 2 safeguards building. It verified the adequacy of equipment seals located below the flood line, floor and water penetration seals, common drain lines and sumps, sump pumps, level alarms, and control circuits. It assessed the adequacy of operator actions that FENOC had identified as necessary to cope with flooding in this area and also reviewed the CAP to determine if FENOC was identifying and correcting problems associated with both flood mitigation features and site procedures for responding to flooding.

b. Findings

No Findings were identified.

==1R07 Heat Sink Performance (711111.07A - 1 sample)

a. Inspection Scope

==

The inspectors reviewed the Unit 2 C charging pump oil cooler heat exchanger, 2CHS-E25C, 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 Requirements Affecting Safety-Related Equipment. The inspectors reviewed the results of the inspection of the heat exchanger. The inspectors discussed the results of the most recent inspection with engineering staff and reviewed pictures of the as-found condition. 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 and Licensed Operator Performance

.1 Quarterly Review of Licensed Operator Requalification Testing and Training

a. Inspection Scope

The inspectors observed a Unit 1 licensed operator annual requalification simulator examination on January 31, 2017, which included two scenarios:

(1) a neutron shield tank leak with a loss of all alternating current (AC) power and failed open power operated relief valves and a failure of select components to automatically operate as required, and

(2) a loss of the 4160 volts alternating current (VAC) DF safety bus with a faulted steam generator and a failure of selected components to automatically operate as required. 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. 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 Unit 2 B train service water full flow test on March 16, 2017, and the Unit 1 EDG 1-1 surveillance test on March 22, 2017. The inspectors observed the briefings for the surveillance tests to determine if the review and coordination of the surveillances were given the appropriate level of attention for the first time performance of the significant revision to the procedure. The inspectors observed shift turnover briefings, and reactivity control briefings to verify that the briefings met the criteria specified in FENOCs Procedure NOP-OP-1002, Conduct of Operations, Revision 12.

Additionally, the inspectors observed test 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 performance and reliability.

The inspectors reviewed system health reports, CAP 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 structure, system, or component 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 structures, systems, and components classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these structures, systems, and components 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 EDGs on January 9, 2017

• Unit 1 fire protection system on March 7, 2017

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 1 EDG 1-1 and A charging pump out of service for planned maintenance on January 24, 2017;

• Unit 2 C charging pump, B plant safety monitoring system, and reactor coolant temperature loop 2RCS-T430 out of service for planned maintenance on February 7, 2017;

• Unit 2 B train of low head safety injection (LHSI) out of service for planned maintenance on the B LHSI mini flow recirculation valve and the D recirculation spray system discharge crossover valve to B LHSI train on February 17, 2017;

• Unit 2 A Safeguards Protection System relays unavailable during testing on February 28, 2017;

• Unit 2 yellow probabilistic risk assessment (PRA) risk for alternate intake bay cleaning on March 13, 2017;

• Unit 1 yellow PRA risk for A system station service transformer deluge testing on March 31, 2017

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 based on the risk significance of the associated components and systems:

• Unit 2 EDG 2-1 lube oil leak on February 1, 2017;

• Unit 1 battery 1-3 cracked cell covers on February 3, 2017;

• Unit 2 TDAFW pump steam line isolation valve, 2MSS*SOV105D, close stroke exceeded ASME OM Code limiting time on February 21, 2017;

• Unit 1 and Unit 2 main steam safety and atmospheric dump valve exhausts not protected from tornado-generated missiles on March 7, 2017,

• Unit 2 tornado doors not shut leaving safety-related equipment vulnerable to tornado-generated missiles on March 7, 2017

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. The inspectors confirmed, where appropriate, compliance with bounding limitations associated with the evaluations. 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.

b. Findings

10 CFR 50, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established to assure that the applicable regulatory requirements and the design basis for structures, systems, and components are correctly translated into specifications, drawing, procedures, and instructions. Contrary to the above, FENOC failed to correctly translate the design basis for protection against tornado-generated missiles into their specifications and procedures. Specifically, FENOC did not adequately protect Unit 1 and Unit 2s main steam safety and atmospheric dump valve exhausts from tornado-generated missiles. Additionally, FENOC did not adequately protect Unit 2s component cooling pumps and spent fuel from tornado-generated missiles by failing to include in their procedures actions for closing the tornado doors in the event of a tornado.

The inspectors evaluated FENOCs immediate compensatory measures, which included verifying that procedures are in place and training is current for performing actions in response to a tornado.

Because this violation was identified during the discretion period covered by Enforcement Guidance Memorandum 15-002, Revision 1, Enforcement Discretion for Tornado Missile Protection non-compliance (ML16355A286) and because FENOC has implemented compensatory measures, the NRC is exercising enforcement discretion, is not issuing enforcement action, and is allowing continued reactor operation.

1R18 Plant Modifications

Temporary Modifications

a. Inspection Scope

The inspectors reviewed the temporary modification to install and remove a temporary jumper on the Unit 2 C component cooling pump because the pump could not be secured from the control room to determine whether the modifications affected the safety functions of systems that are important to safety. The inspectors reviewed the Urgent Maintenance Log and appropriate drawings and interviewed maintenance personnel to verify that the temporary modification 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 adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedures were consistent with the information in the applicable licensing basis and/or design basis documents, and that the test results were properly reviewed and accepted and problems were appropriately documented. The inspectors also walked down the affected job site, confirmed work site cleanliness was maintained, and witnessed the test or reviewed test data to verify quality control hold points were performed and checked, and that results adequately demonstrated restoration of the affected safety functions.

• Unit 1 4160 VAC DF bus undervoltage (UV) relay replacement on January 10, 2017;

• Unit 2 B primary component cooling water pump, motor, and breaker maintenance on January 19, 2017;

• Unit 1 A centrifugal charging pump, motor, and relay maintenance on January 30, 2017;

• Unit 2 C centrifugal charging pump oil cooler cleaning on February 10, 2017;

• Unit 2 A fuel pool cooling pump and heat exchanger maintenance on March 22, 2017

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 structures, systems, and components 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:

• 2MSP-24.01-I, Loop 1 Narrow Range Steam Generator Water Level Channel I Test on January 24, 2017;

• 2OST-24.2, Motor Driven Auxiliary Feed Pump Test on January 25, 2017;

• 1OST-36.2, Diesel Generator No. 2 Monthly Test on February 8, 2017;

• 1MSP-21.19-I, P-1MS474, Loop1 Steamline Pressure Protection Channel II Calibration on February 8, 2017;

• 2OST-24.4, Steam Driven Auxiliary Feed Pump Quarterly Test on February 21, 2017;

• 2MSP-24.30-I, 2FWS-F497, Loop 3 Feedwater Flow Channel III Calibration on March 3, 2017;

• 2OST-30.13B, Train B Service Water System Full Flow Test on March 17, 2017

b. Findings

No findings were identified.

1EP6 Drill Evaluation

Training Observations

a. Inspection Scope

The inspectors observed a simulator annual requalification examination for Unit 1 licensed operators on January 31, 2017, 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 CAP.

b. Findings

No findings were identified.

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 (1 sample)

The inspectors conducted independent radiation measurements during walkdowns 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 of any new radiological hazards for onsite workers or members of the public.

b. 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 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 Valleys collective dose history and trends; ongoing and planned radiological work activities; previous post-outage ALARA reviews; radiological source term history and trends; and ALARA dose estimating and tracking procedures.

Verification of Dose Estimates and Exposure Tracking Systems (1 sample)

The inspectors reviewed the current annual collective dose estimate; basis methodology; and measures to track, trend, and reduce occupational doses for ongoing work activities.

The inspectors evaluated the adjustment of exposure estimates, or re-planning of work.

The inspector reviewed post-job ALARA evaluations of excessive exposure.

Problem Identification and Resolution (1 sample)

The inspectors evaluated whether problems associated with ALARA planning and controls were identified at an appropriate threshold and properly addressed in the CAP.

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 specification 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.

Self-Contained Breathing Apparatus (SCBA) for Emergency Use (1 sample)

The inspectors reviewed the following: the status and surveillance records for three SCBAs staged in-plant for use during emergencies, FENOCs SCBA procedures and maintenance and test records, the 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.

4OA1 Performance Indicator Verification

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, 2016, through December 31, 2016.

• 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, CRs, 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 FENOC entered issues into the CAP 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 CAP and periodically attended condition report 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 to identify trends that might indicate the existence of more significant safety concerns. The inspectors reviewed FENOCs CAP database for the third and fourth quarters of 2016 to assess CRs written in various subject areas (equipment problems, human performance issues, etc.), as well as individual issues identified during the inspectors daily CR review (Section 4OA2.1). The inspectors reviewed FENOCs Fleet Oversight Performance Gap Report for October through November 2016 and Performance Assessments of

1R24 outage management, operations, and maintenance, conducted under

NOBP-LP-2013, Performance Assessment, to verify that FENOC personnel were appropriately evaluating and trending adverse conditions in accordance with applicable procedures. The inspectors also reviewed Effectiveness Reviews completed in the third and fourth quarters of 2016 in order to determine if corrective actions were successful in addressing the issues identified in the respective condition reports.

b. Findings and Observations

No findings were identified.

The inspectors did not identify any trends that had not been identified by FENOC.

As part of the performance assessment inspection, the inspectors reviewed NOBP-LP-2023, Performance Assessment, which states that the purpose and scope of the observation should be included in the assessment area. The inspectors noted that purpose and scope was not included in any of the assessment areas reviewed. FENOC documented this issue in CR 2017-03915. Additionally, an oversight assessment of the schedule change requests for deleting work from 1R24, oversight concluded that some of the justifications did not describe why it was acceptable from a risk standpoint. There were no follow-up actions resulting from this issue that were documented in a CR or other process as required by FENOCs CAP. After engagement from the inspectors, notification 601069932 1R24 POLLs, item 44 was written to address the issue of the justifications for deleting work from 1R24.

FENOC initiated CR 2017-02303 to evaluate that no CR was written for an oversight assessment that was determined to be marginally effective. The inspectors determined that these two performance deficiencies are minor because they are administrative in nature and had no safety impact.

In the inspectors review of 11 effectiveness reviews, one was determined to be ineffective. In three of the reviews that were determined to be effective, the effectiveness review plan did not have specific and quantifiable criteria for the expected results (2016-02356, 2016-03558, 2016-03125) as required by NOBP-LP-2011, FENOC Cause

Analysis.

In five of the reviews that were determined to be effective, the closure criteria either did not appear to be met or was unclear if it was met (2015-13615; 2015-06355, plus the three above). For example, the effectiveness review for CR 2016-02356 was to perform a review of rigging and material handling human performance events in 1R24. No specific criteria was given to determine effectiveness.

Additionally, there were four rigging human performance events in 1R24, yet the corrective actions were determined to be effective. FENOC documented this issue in CR 2017-02227. The inspectors determined that this performance deficiency is minor because it is administrative in nature and there was no safety impact.

.3 Annual Sample:

Operator Workarounds

a. Inspection Scope

The inspectors performed a review of Unit 1 and Unit 2 operator workarounds, burdens and control room deficiencies to verify that FENOC is identifying these issues at the appropriate threshold and are entering them into their CAP. The inspectors review included verifying that FENOC was evaluating these issues under all plant conditions and was considering the cumulative effects of all the issues. Additionally, the purpose of the review was also to verify that FENOC was following NOBP-OP-0012, Operator Work-Arounds, Burdens, Control Room Deficiencies and Operations Aggregate Assessment.

b. Findings and Observations

No findings were identified.

The inspectors determined, in general, FENOC was identifying these issues at the appropriate threshold and was entering the issues into their CAP. FENOC also evaluated the issues under all plant conditions and their cumulative effect on plant operation appropriately. The inspectors compared the number of issues in the fourth quarter 2015 aggregate risk review to the fourth quarter 2016 review and noted that the overall number of issues decreased from 48 to 11 for Unit 1 and from 67 to 33 for Unit 2.

NOBP-OP-0012 requires that temporary modifications that require a compensatory operator action and locked in annunciators be considered in the aggregate assessment.

The inspectors determined that the operations individual performing the assessment did not have access to the temporary modification list that is maintained by engineering. As a result, the compensatory action required for the modification to valve 1CCT-25 was not considered. This is a minor performance deficiency since the omission did not change the conclusions of the assessment. The inspectors noted that the procedure does not specify how long an annunciator should be locked in to be considered, so only long-term locked in annunciators (several months) were considered in the assessment.

4OA3 Follow-Up of Events and Notices of Enforcement Discretion

Plant Events

a. Inspection Scope

For the Unit 1 notice of unusual event (NOUE) on January 27, 2017, caused by a smoke detector alarm in containment that FENOC could not verify that there was no fire within 15 minutes, 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 and headquarters 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. The inspectors also verified that FENOC properly exited the NOUE after entering containment and verifying that there was no fire. The inspectors reviewed FENOCs follow-up actions related to the event to assure that FENOC implemented appropriate corrective actions commensurate with its safety significance.

b. Findings

No findings were identified.

4OA5 Other Activities

.1 Temporary Instruction (TI) 2515/192:

Inspection of the Licensees Interim Compensatory Measures Associated with the Open Phase Condition Design Vulnerabilities in Electric Power Systems

a. Inspection Scope

The inspectors verified that FENOC implemented interim compensatory measures associated with an open phase condition (OPC) design vulnerability in electric power systems for operating reactors. The inspectors verified the following:

• FENOC had identified and discussed with plant staff the lessons-learned from the OPC events at the United States operating plants including the Byron station OPC event and its consequences. This includes conducting operator training for promptly diagnosing, recognizing consequences, and responding to an OPC event.

• FENOC had updated plant operating procedures to help operators promptly diagnose and respond to OPC events on off-site power sources credited for safe shutdown of the plant.

• FENOC had established and continues to implement periodic walkdown activities to inspect switchyard equipment such as insulators, disconnect switches, and transmission line and transformer connections associated with the offsite power circuits to detect a visible OPC.

• FENOC had ensured that routine maintenance and testing activities on switchyard components have been implemented and maintained. As part of the maintenance and testing activities, FENOC assessed and managed plant risk in accordance with 10 CFR 50.65(a)(4) requirements.

b. Findings

No findings were identified.

.2 World Association of Nuclear Operators (WANO) Report Review

a. Inspection Scope

The inspectors reviewed the final report for the WANO plant assessment of Beaver Valley Power Station conducted in February 2017. The inspectors evaluated this report to ensure that NRC perspectives of FENOC performance were consistent with any issues identified during the assessments. The inspectors also reviewed these reports to determine whether WANO identified any significant safety issues that required further NRC follow-up.

b. Findings

No findings were identified.

.3 Unit 1 Relief from the Requirements of the ASME OM Code

a. Inspection Scope

The inspectors reviewed the March 2, 2017, NRC letter granting relief from the ASME OM Code which authorized FENOCs proposed alternative to delay testing valve RV-1RH-721 until the refueling outage in the spring of 2018. The inspectors also reviewed the circumstances surrounding the relief valve testing in October 2016 that caused FENOC to request an alternative to testing RV-1RH-721 in order to determine if there were performance issues. The operability aspects of this issue were reviewed in IR 05000334/2016004, Section 1R15.

b. Findings

Introduction.

The inspectors identified a Severity Level IV NCV of 10 CFR 50.55a(z),

Alternatives to codes and standards requirements, for FENOCs failure to obtain prior authorization for implementing an alternative to the ASME OM Code. Specifically, until prompted by the inspectors, FENOC did not submit and receive an alternative to the ASME OM Code requirement to not test the RHR relief valve, RV-1RH-721, during a recent refueling outage when the charging system letdown relief valve, RV-1CH-203, failed to lift within three percent of set-pressure.

Description.

On October 4, 2016, letdown relief valve, RV-1CH-203, was tested and lifted more than three percent above its setpoint. CR 2016-11847 documented that this was a failure per ASME OM Code, Appendix I, which required that the remaining valve in the group, RV-1RH-721, the RHR relief valve, be tested. Engineering evaluation 601066674 approved on October 13, 2016, created a new owner specified limit of five percent above the reference value as an acceptance criteria.

Based on the as found lift pressure falling within the new acceptance range, FENOC, determined that no expansion of scope was necessary and that RV-1RH-721 would not be tested during the outage.

On October 14, 2016, the inspectors, in consultation with NRC headquarters staff, determined that establishing a new limit after the failed test did not eliminate the ASME OM Code requirement to test the other valve in the group. The inspectors discussed this conclusion with FENOC. FENOC indicated that it would be a hardship to test the other valve and that they would perform an operability determination and submit a relief request to test the RHR relief valve at the next refueling outage. A prompt operability determination was completed on October 15, 2016, which concluded that the RHR relief valve remained operable. The inspectors reviewed the prompt operability determination and determined that there was a reasonable expectation of operability of the RHR relief valve. FENOC submitted the relief request to delay the testing of the RHR relief valve on October 24, 2016 and it was approved by the NRC on March 2, 2017.

Analysis.

The inspectors determined that the failure to request and receive relief from the ASME OM Code following the decision to not test the RHR relief valve, in accordance with 10 CFR 50.55a(z), was a performance deficiency reasonably within FENOCs ability to foresee and correct, and should have been prevented. The inspectors determined that this violation impacted the ability of the NRC to perform its regulatory oversight function and was therefore subject to traditional enforcement.

Section 2.2.1.c of the Enforcement Policy states that failure to receive prior NRC approval for changes in licensed activities when required is an example of impacting the ability of the NRC to perform its regulatory oversight function. After considering the factors in Section 2.2.1.c of the Enforcement Policy, the inspectors determined that the performance deficiency was a Severity Level IV violation because the change implemented by FENOC would likely be approved by the NRC. Because this violation involves the traditional enforcement process and does not have an associated finding that is more than minor, the inspectors did not assign a cross-cutting aspect to this violation in accordance with IMC 0612, Appendix B.

Enforcement.

10 CFR 50.55a(z), Alternatives to codes and standards requirements, requires, in part, that alternatives to the requirements of 10 CFR 50.55a(f) may be used when authorized by the NRC and that the proposed alternative must be submitted and authorized prior to implementation. 10 CFR 50.55a(f), Inservice testing requirements, requires, in part, that systems and components of pressurized water-cooled nuclear power reactors must meet the requirements of the ASME OM Code. ASME OM Code-2001,Code for Operation and Maintenance of Nuclear Power Plants, Appendix I, requires that two additional valves from the same valve group shall be tested for each valve that exceeds the set-pressure acceptance criteria. Contrary to the above, FENOC implemented an alternative to the ASME OM Code without obtaining authorization from the NRC. Specifically, from October 4, 2016, when the letdown relief valve failed its set-pressure test, until March 2, 2017, FENOC implemented an alternative, which was to not test the RHR relief valve during the outage, without obtaining prior authorization from the NRC. FENOCs immediate corrective actions included performing a prompt operability determination and submitting a relief request to test the valve at the next refueling outage. Because this violation is Severity Level IV and the issue was entered into FENOCs CAP as CR 2017-03937, it is being treated as a NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 5000334/2017001-01, Failure to Follow the ASME OM Code for a Failed Relief Valve Set Pressure Test)

4OA6 Meetings, Including Exit

On April 6, 2017, the inspectors presented the inspection results to Richard Bologna, General Plant Manager, 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

R. Bologna, General Plant Manager

M. Adams, Unit 2 Shift Manager

C. Battistone, Acting Supervisor, Fleet Oversight

M. Berg, Nuclear Engineering Specialist, Electrical/I&C Engineering

J. Crocker, Superintendent, Nuclear Shift Operations Unit 2

E. Crosby, Radiation Protection Manager

E. Ebeck, Supervisor, Nuclear Structural/Mechanical Engineering

W. Etzel, Consulting Engineer, Analytical Methods

R. Ferrie, Electrical Supervisor

J. Fontaine, Radiation Protection Supervisor ALARA

J. Gallagher, Maintenance Rule Coordinator

D. Gibson, Training Manager

D. Gmys, System Engineer

L. Greeley, System Engineer

J. Halvorsen, Maintenance Manager

P. Hartig, Shift Manager

M. Jansto, System Engineer

D. Jones, IST Program Engineer

S. Keener, Operations Shift Manager

R. Kristophel, Superintendent, Nuclear Shift Operations Unit 1

F. Magnotta, Technical Training Specialist

C. Martin, Respiratory Protection Technician

J. Miller, Fire Marshall

A. Mueller, Manager, Fleet Maintenance and Work Management

J. Ostrowski, Heat Exchanger Program Owner

R. Patterson, Senior Radiation Protection Technician

J. Sheets, PRA Specialist

J. Snyder, Electrical Systems Engineer

E. Thomas, Regulatory Compliance Supervisor

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened/Closed

05000334/2017001-01 NCV Failure to Follow the ASME OM Code for a Failed Relief Valve Set Pressure Test (Section 4OA5)

Closed

05000334/2515/192

05000412/2515/192 TI Inspection of the Licensees Interim Compensatory Measures Associated with the Open Phase Condition Design Vulnerabilities in Electric Power Systems (Section 4OA5)