IR 05000334/2017008

Problem Identification and Resolution Inspection Report 05000334/2017008 and 05000412/2017008

ML17194A930
Person / Time
Site:	Beaver Valley
Issue date:	07/10/2017
From:	Silas Kennedy NRC/RGN-I/DRP/PB6
To:	Richey M FirstEnergy Nuclear Operating Co
Shaffer S
References
IR 2017008
Download: ML17194A930 (15)

Text

UNITED STATES uly 10, 2017

SUBJECT:

BEAVER VALLEY POWER STATION - PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000334/2017008 AND 05000412/2017008

Dear Mr. Richey:

On June 22, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at Beaver Valley Power Station (BVPS), Units 1 and 2.

The NRC inspection team discussed the results of this inspection with you, and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews, the team found no evidence of challenges to your organizations safety-conscious work environment.

Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

In all of the areas reviewed, the NRC inspectors did not identify any findings or violations of more than minor significance. 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Silas R. Kennedy, Chief Reactor Projects Branch 6 Division of Reactor Projects Enclosure:

Inspection Report 05000334/2017008 and 05000412/2017008 w/Attachment: Supplementary Information

ML17194A930 SUNSI Review Non-Sensitive Publicly Available OFFICE RI/DRP RI/DRP RI/DRP NAME SShaffer/SS MFerdas/MF SRKennedy/SRK DATE 07/05/17 7/06/17 07/10/17

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket Nos.: 50-334 and 50-412 License Nos.: DPR-66 and NPF-73 Report Nos.: 05000334/2017008 and 05000412/2017008 Licensee: FirstEnergy Nuclear Operating Company (FENOC)

Facility: Beaver Valley Power Station, Units 1 and 2 Location: Shippingport, PA 15077 Dates: June 5, 2017 through June 22, 2017 Team Leader: S. Shaffer, Senior Project Engineer Inspectors: S. Horvitz, Resident Inspector Andrey Turilin, Project Engineer D. Merzke, Senior Reactor Operations Engineer Approved by: Silas R. Kennedy, Chief Reactor Projects Branch 6 Division of Reactor Projects Enclosure

SUMMARY

IR 05000334/2017008 and 05000412/2017008; 06/5/2017 - 06/22/2017; Beaver Valley

Power Station (BVPS) Units 1 and 2; Biennial Baseline Inspection of Problem Identification and Resolution.

This NRC team inspection was performed by two regional inspectors, one headquarters inspector and one resident inspector. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,

Revision 6.

Problem Identification and Resolution The inspectors concluded that FENOC was effective in identifying, evaluating, and resolving problems. FENOC personnel identified problems, entered them into the corrective action program at a low threshold, and prioritized and evaluated issues commensurate with their safety significance. FENOC appropriately screened issues for operability and reportability, and performed causal analyses that appropriately considered extent of condition, generic issues, and previous occurrences.

The inspectors concluded that FENOC appropriately identified, reviewed, and applied relevant industry operating experience to BVPSs operations. In addition, based on those items selected for review, the inspectors determined that FENOCs self-assessments and audits were critical, thorough, and effective in identifying issues.

Based on the interviews the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual corrective action program and employee concerns program issues, the inspectors did not identify any indications that site personnel were unwilling to raise safety issues nor did they identify any conditions that could have had a negative impact on the sites safety conscious work environment.

No findings were identified.

REPORT DETAILS

4OA2 Problem Identification and Resolution

This inspection constitutes one biennial sample of problem identification and resolution as defined by Inspection Procedure 71152. All documents reviewed during this inspection are listed in the Attachment to this report.

.1 Assessment of Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the procedures that described FENOCs corrective action program at BVPS. To assess the effectiveness of the corrective action program, the inspectors reviewed performance in three primary areas: problem identification, prioritization and evaluation of issues, and corrective action implementation. The inspectors compared performance in these areas to the requirements and standards contained in 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, and FENOCs procedure NOP-LP-2001, Corrective Action Program. For each of these areas, the inspectors considered risk insights from the stations risk analysis and reviewed condition reports selected across the seven cornerstones of safety in the NRCs Reactor Oversight Process. Additionally, the inspectors attended multiple Management Ownership and Alignment meetings; Management Review Committee meetings; and Corrective Action Review Board meetings. The inspectors selected items from the following functional areas for review: engineering, operations, maintenance, emergency preparedness, radiation protection, chemistry, physical security, and oversight programs.

(1) Effectiveness of Problem Identification In addition to the items described above, the inspectors reviewed system health reports, a sample of completed corrective and preventative maintenance work orders, completed surveillance test procedures, operator logs, and periodic trend reports. The inspectors also completed field walkdowns of various systems on site, such as emergency diesel generators, auxiliary feedwater pumps, and security structures. Additionally, the inspectors reviewed a sample of condition reports written to document issues identified through internal self-assessments, audits, emergency preparedness drills, and the operating experience program. The inspectors completed this review to verify that FENOC entered conditions adverse to quality into their corrective action program as appropriate.

(2) Effectiveness of Prioritization and Evaluation of Issues The inspectors reviewed the evaluation and prioritization of a sample of condition reports issued since the last NRC biennial Problem Identification and Resolution inspection completed in June 2015. The inspectors also reviewed condition reports that were assigned lower levels of significance that did not include formal cause evaluations to ensure that they were properly classified. The inspectors review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution.

The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate corrective actions to address the identified causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of the issues.

(3) Effectiveness of Corrective Actions The inspectors reviewed FENOCs completed corrective actions through documentation review and, in some cases, field walkdowns to determine whether the actions addressed the identified causes of the problems. The inspectors also reviewed condition reports for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed FENOCs timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of condition reports associated with selected NRC Non-Cited Violations (NCVs) and findings to verify that FENOC personnel properly evaluated and resolved these issues.

In addition, the inspectors expanded the corrective action review to five years for issues related to the Unit 2 power operated relief valves.

Assessment

(1) Effectiveness of Problem Identification Based on the selected samples, plant walkdowns, and interviews of site personnel in multiple functional areas, the inspectors determined that FENOC identified problems and entered them into the corrective action program at a low threshold. FENOC staff at BVPS initiated approximately 13,000 condition reports (CRs) between June 2015 and May 2017. The inspectors observed supervisors at the Management Ownership and Alignment meetings; Management Review Committee meetings; and Corrective Action Review Board meetings appropriately questioning and challenging condition reports to ensure clarification of the issues. Based on the samples reviewed, the inspectors determined that FENOC trended equipment and programmatic issues, and appropriately identified problems in condition reports. The inspectors verified that conditions adverse to quality identified through this review were entered into the corrective action program as appropriate. Additionally, inspectors concluded that personnel were identifying trends at low levels. In general, inspectors did not identify any issues or concerns that had not been appropriately entered into the corrective action program for evaluation and resolution. In response to several questions and minor equipment observations identified by the inspectors during plant walkdowns, FENOC personnel initiated condition reports and/or took immediate action to address the issues.

(2) Effectiveness of Prioritization and Evaluation of Issues The inspectors determined that FENOC appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem. FENOC screened condition reports for operability and reportability, categorized the condition reports by significance, and assigned actions to the appropriate department for evaluation and resolution. The condition report screening process considered human performance issues, radiological safety concerns, repetitiveness, adverse trends, and potential impact on the safety conscious work environment.

Based on the sample of condition reports reviewed, the inspectors noted that the guidance provided by FENOC corrective action program implementing procedures was sufficient to ensure consistency in the categorization of issues. Operability and reportability determinations were performed when conditions warranted, and the evaluations generally supported the conclusions. Causal analyses appropriately considered the extent of condition or problem, generic issues, and previous occurrences of the issue.

(3) Effectiveness of Corrective Actions The inspectors concluded that corrective actions for identified deficiencies were timely and adequately implemented. For significant conditions adverse to quality, FENOC identified actions to prevent recurrence. The inspectors concluded that corrective actions to address the sample of NRC NCVs and findings since the last problem identification and resolution inspection were timely and effective. However, the inspectors did identify one instance for which a corrective action (CA) for an NRC NCV was not implemented prior to closure of the CR.

Specifically, FENOC did not implement one of the CAs in CR 2015-00267 identified by the station after evaluating the cause for NRC NCV 05000334/2014005-01. The inspectors concluded that to date the apparent cause that led to the unplanned extended yellow risk, had not been adequately addressed or corrected. The inspectors did not identify any other recent occurrences of inadequate or non-implemented RMAs resulting in additional time in elevated risk at BVPS. The inspectors determined that the failure to correct a condition adverse to quality was a violation of 10 CFR 50 Appendix B, Criterion XVI. The inspectors independently evaluated this issue for significance in accordance with IMC 0612, Appendix B, Issue Screening, and IMC 0612, Appendix E, Examples of Minor Issues, and determined this issue was of minor significance, and, as a result, was not subject to enforcement action in accordance with the NRCs Enforcement Policy. BVPS personnel acknowledged the inspectors observations and entered this deficiency into their corrective action program as CR 2017-06611.

b. Findings

No findings were identified.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed a sample of condition reports associated with review of industry operating experience to determine whether FENOC appropriately evaluated the operating experience information for applicability to BVPS and had taken appropriate actions, when warranted. The inspectors also reviewed evaluations of operating experience documents associated with a sample of NRC generic communications to ensure that FENOC adequately considered the underlying problems associated with the issues for resolution via their corrective action program. In addition, the inspectors observed various plant activities to determine if the station considered industry operating experience during the performance of routine and infrequently performed activities.

Assessment The inspectors determined that FENOC appropriately considered industry operating experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The inspectors determined that operating experience was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable. The inspectors also observed that industry operating experience was routinely discussed and considered during the conduct of Management Ownership and Alignment meetings and pre-job briefs.

b. Findings

No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed a sample of audits, including the most recent audit of the corrective action program, departmental self-assessments, and assessments performed by independent organizations. Inspectors performed these reviews to determine if FENOC entered problems identified through these assessments into the corrective action program, when appropriate, and whether FENOC initiated corrective actions to address identified deficiencies. The inspectors evaluated the effectiveness of the audits and assessments by comparing audit and assessment results against self-revealing and NRC-identified observations made during the inspection.

Assessment The inspectors concluded that self-assessments, audits, and other internal FENOC assessments were critical, thorough, and effective in identifying issues. The inspectors observed that FENOC personnel knowledgeable in the subject completed these audits and self-assessments in a methodical manner. FENOC completed these audits and self-assessments to a sufficient depth to identify issues which were then entered into the corrective action program for evaluation. The station implemented corrective actions associated with the identified issues commensurate with their safety significance.

b. Findings

No findings were identified.

.4 Assessment of Safety Conscious Work Environment

a. Inspection Scope

During interviews with station personnel, the inspectors assessed the safety conscious work environment at BVPS. Specifically, the inspectors interviewed personnel to determine whether they were hesitant to raise safety concerns to their management and/or the NRC. The inspectors also interviewed the station Employee Concerns Program coordinator to determine what actions are implemented to ensure employees were aware of the program and its availability with regards to raising safety concerns.

The inspectors reviewed the Employee Concerns Program files to ensure that FENOC entered issues into the corrective action program when appropriate.

Assessment During interviews, BVPS staff expressed a willingness to use the corrective action program to identify plant issues and deficiencies and stated that they were willing to raise safety issues. The inspectors noted that no one interviewed stated that they personally experienced or were aware of a situation in which an individual had been retaliated against for raising a safety issue. All persons interviewed demonstrated an adequate knowledge of the corrective action program and the Employee Concerns Program. Based on these interviews, the inspectors concluded that there was no evidence of an unacceptable safety conscious work environment and no significant challenges to the free flow of information.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On June 22, 2017, the inspectors presented the inspection results to Mr. Richey and other members of the BVPS staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

M. Richey, Site Vice President

R. Bologna, Plant Manager

C. Battistone, Oversight Supervisor

R. Boyle, Site Projects Manager

E. Crosby, Radiation Protection Manager

A. Donectrovich, Regulatory Compliance

M. Enos, Outage Manager

M. Fox, Site Protection Manager

B. Kremer, Regulatory Compliance Manager

R. Kurkiewicz, Work Week Manager

E. Lueheon, Maintenance Manager

M. Mertens, Work Week SRO

J. Miller, Fire marshal

R. Miller, Performance Improvement

P. Pauvlinch, Design Engineering Manager

D. Salaera, Chemistry Manager

S. Sawtschenko, Emergency Preparedness Manager

D. Shurbaugh, Operations Manager

E. Stalnecker, Performance Improvement

T. Steed, Performance Improvement Director

E. Thomas, Regulatory Compliance Supervisor

D. Wacher, Regulatory Compliance

B. Winters Ph.D., Chemistry

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened and Closed

None.