IR 05000334/2018010
| ML18124A002 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 05/03/2018 |
| From: | Marc Ferdas Division Reactor Projects I |
| To: | Bologna R FirstEnergy Nuclear Operating Co |
| Arner F | |
| References | |
| IR 2018010 | |
| Download: ML18124A002 (11) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION I
2100 RENAISSANCE BOULEVARD, SUITE 100 KING OF PRUSSIA, PA 19406-2713 May 3, 2018 Mr. Richard Bologna Site Vice President First Energy Nuclear Operating Company Beaver Valley Power Station P. O. Box 4 - Route 168 Shippingport, PA 15077-0004 SUBJECT: BEAVER VALLEY POWER STATION - UNITS 1 AND 2 TEMPORARY INSTRUCTION 2515/191, MITIGATION STRATEGIES SPENT FUEL POOL INSTRUMENTATION AND EMERGENCY PREPAREDNESS INSPECTION REPORT 05000334/2018010 AND 05000412/2018010
Dear Mr. Bologna:
On February 23, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Beaver Valley Power Station (BVPS) Units 1 and 2; and the team discussed the preliminary results of this inspection with you, and other members of your staff. An exit meeting was conducted with Mr. Brian Kremer, Regulatory Compliance Manager, via telephone on March 21, 2018, to discuss the final results of the inspection. The results of this inspection are documented in the enclosed report.
NRC inspectors documented one finding of very low safety significance (Green) in this report.
The finding did not involve a violation of NRC requirements.
If you disagree with a cross-cutting aspect assignment or the 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 denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; and the NRC resident Inspector at Beaver Valley. 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 (10 CFR ), Part 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Marc S. Ferdas, Chief Technical Support and Assessment Branch Division of Reactor Projects Docket Numbers: 50-334 and 50-412 License Numbers: DPR-66 and NPF-73
Enclosure:
Inspection Report 05000334/2018010 and 05000412/2018010
Inspection Report
Docket Number: 50-334 and 50-412 License Number: DPR-66 and NPF-73 Report Number: 05000334/2018010 and 05000412/2018010 Enterprise Identifier: I-2018-010-0047 Licensee: FirstEnergy Nuclear Operating Company (FENOC)
Facility: Beaver Valley Power Station, Units 1 and 2 Location: Shippingport, PA 15077 Inspection Dates: February 20, 2018 to February 23, 2018 Inspectors: F. Arner, Senior Reactor Analyst (Team Leader)
M. Patel, Operations Inspector S. Horvitz, Resident Inspector Approved By: Marc S. Ferdas, Chief Technical Support and Assessment Branch Division of Reactor Projects Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring FENOCs performance at Beaver Valley Units 1 and 2 by conducting Temporary Instruction 2515/191, Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC and self-revealed findings, violations, and additional items are summarized in the table below.
List of Findings and Violations Inadequate Diesel Fuel Oil Temperature Protection Cornerstone Significance Cross-cutting Report Aspect Section Mitigating Green H.7- TI 2515/191 Systems FIN 05000334 and 05000412/2018010-01 Documentation The team identified a finding of very low safety significance (Green) for the failure to ensure that diesel powered Diverse and Flexible Coping Strategies (FLEX) equipment would be reliable to mitigate postulated beyond-design basis external events during very low temperature conditions.
Specifically, at temperatures below the site fuel cloud point (4 degrees Fahrenheit (F) to -7 degrees F), portable FLEX equipment, such as emergency diesel powered pumps, were susceptible to conditions in which their capability of starting and operating would be impacted due to fuel crystallizing or gelling and subsequent coating of fuel filter elements.
INSPECTION SCOPES
This inspection was conducted using the appropriate portions of the Temporary Instruction (TI)in effect at the beginning of the inspection unless otherwise noted. Currently approved TIs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Documents reviewed by inspectors are listed in the documents reviewed section of this report. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
OTHER ACTIVITIES
TEMPORARY INSTRUCTION, INFREQUENT AND ABNORMAL TI 2515/191Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans The inspectors verified plans for complying with NRC Orders EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, (ADAMS Accession No. ML12056A045) and EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, (ADAMS Accession No. ML12054A679) are in place and are being implemented by the licensee.
Additionally, the inspection verified implementation of staffing and communications information provided in response to the March 12, 2012, request for information letter (ADAMS Accession No. ML12053A340) and multiunit dose assessment information provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013, (ADAMS Accession No. ML12339A262).
- (1) Based on samples selected for review, the inspectors verified that the licensee satisfactorily implemented appropriate elements of the Diverse and Flexible Coping Strategies (FLEX) as described in the plant specific submittals and the associated safety evaluation (ADAMS Accession No. ML17095A276) and determined that the licensee is in compliance with NRC Order EA-12-049, Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events.
The inspectors verified the licensee satisfactorily:
a. Developed and issued FLEX Support Guidelines (FSGs) to implement the FLEX strategies for postulated external events; b. Integrated their FSGs into their existing plant procedures such that entry into and departure from the FSGs were clear when using existing plant procedures; c. Protected FLEX equipment from site-specific hazards; d. Developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability; e. Trained their staff to assure personnel proficiency in the mitigation of beyond-design basis events; and f.
Developed the means to ensure the necessary off-site FLEX equipment would be available from off-site locations.
- (2) Based on samples selected for review, the inspectors verified that the licensee satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittals and the associated safety evaluation and determined that the licensee is in compliance with NRC Order NRC Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation. The inspectors verified the licensee satisfactorily:
a. Installed the spent fuel pool (SFP) instrumentation sensors, cabling and power supplies to provide physical and electrical separation as described in the plant specific submittals and safety evaluation; b. Installed the SFP instrumentation display in the location, environmental conditions and accessibility as described in the plant specific submittals; c. Trained their staff to assure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation; and d. Developed and issued procedures for maintenance, testing and use of the reliable SFP instrumentation.
- (3) The inspectors reviewed information provided in the licensees multi-unit dose submittal and in response to the NRCs March 12, 2012, request for information letter, and verified that the licensee satisfactorily implemented enhancements pertaining to Near-Term Task Force (NTTF) Recommendation 9.3 response to a large scale natural emergency event that results in an extended loss of all ac power to all site units and impedes access to the site. The inspectors verified the following:
a. The licensee satisfactorily implemented required staffing changes to support a multi-unit extended loss of alternating current
- (ac) power (ELAP) scenario; b. Emergency preparedness (EP) communications equipment and facilities are sufficient for dealing with a multi-unit ELAP scenario; and c. The licensee implemented multi-unit dose assessment capabilities (including releases from spent fuel pools) using the licensees site-specific dose assessment software and approach.
The inspectors verified that non-compliances with requirements, and standards identified during the inspection were entered into the licensee's corrective action program as appropriate. The corrective action program documents generated as a result of the inspection are listed in the Documents Reviewed section of this inspection report.
This TI is considered closed.
INSPECTION RESULTS
Inadequate Diesel Fuel Oil Temperature Protection Cornerstone Significance Cross-cutting Report Aspect Section Mitigating Green H.7 - TI 2515/191 Systems FIN 05000334 and Documentation 5000412/2018010-01 The team identified a finding of very low safety significance (Green) for the failure to ensure that diesel powered Diverse and Flexible Coping Strategies (FLEX) equipment would be reliable to mitigate postulated beyond-design basis external events during very low temperature conditions. Specifically, at temperatures below the site fuel cloud point (4 degrees Fahrenheit (F) to -7 degrees F), portable FLEX equipment such as emergency diesel powered pumps, were susceptible to conditions in which their capability of starting and operating would be impacted due to fuel crystallizing or gelling and subsequent coating of fuel filter elements.
Description:
The team reviewed the ability of the FLEX equipment to operate across the sites specific temperature hazard ranges. The Nuclear Energy Institute (NEI) developed NEI 12-06, which provides guidelines for nuclear stations to assess extreme event hazards and implement mitigation strategies to ensure compliance with NRC Order EA-12-049. FENOCs Final Integrated Plan, L-16-321, Completion of Required Action by NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events, stated that Beaver Valley Power Station complies with the requirements as described in NEI 12-06, Revision 2, as endorsed by the NRC. As discussed in NEI 12-06, Section 8.2.1, all sites should consider the temperature ranges and weather conditions for their site in storing and deploying FLEX equipment consistent with normal design practices.
The team identified that Beaver Valleys Diesel Flex Fuel powered equipment with fuel filters when exposed to an extreme cold weather event were susceptible to conditions in which their capability of starting and operating could be impacted. The team noted that based on the site fuel cloud point which ranged from 4 degrees to -7 degrees F, diesel fuel crystallization or gelling could occur below these temperatures. The FLEX program for Beaver Valley supports extreme cold weather conditions down to -20 degrees F as documented in the site final integrated plan (FIP). The cloud point of the fuel is the temperature at which paraffin (a wax-like gel, which is naturally present in #2 diesel fuel), begins to form cloudy wax crystals. At the cloud point, these wax crystals flow with the fuel, coat the fuel filter element, and can quickly reduce the fuel flow, potentially challenging the engines.
When deployment begins, the equipment could be subjected to temperatures which could be well below the cloud point for the fuel, with the equipment potentially not being started for many hours. Specifically, once deployed, the diesel driven pumps could be subjected to harsh ambient conditions, potentially as low as -20 degrees F, prior to their start. The team noted FENOC had Hard Card procedures which referenced the use of an additive (anti-gel)when ambient temperatures fell below 20 degrees F. However the team noted that the additive wouldnt have been added until the equipment was being placed into service. The affected FLEX equipment may remain idle and positioned in the field for many hours after deployment in the extreme conditions before this fuel additive would be added. If crystallization and gelling had already begun, the additive would be ineffective.
The team noted that 10M-53E.1.FSG-5, Initial Assessment and FLEX Equipment Staging, provides guidelines for deployment of FLEX equipment with priority based on system conditions. Table 1, Key FLEX Actions, states that the FLEX Alternate Auxiliary Feedwater Pump is to be staged at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> from the loss of all alternating current (AC) power event, prior to plant cooldown, and used as backup to the Turbine Driven Auxiliary Feedwater Pump (TDAFW). FSG-11, Alternate Spent Fuel Pool (SFP) Makeup and Cooling, was referenced to be implemented for pump deployment no later than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the event.
The NRC safety evaluation report (SER) states that the preferred strategy for core cooling in Phase 1 and Phase 2 is to use the TDAFW pump and it is expected to maintain functionality by FENOC given their cooldown strategies throughout Phase 2. However, FLEX requirements and FENOC procedures deploy the alternate AFW pump as a backup to the TDAFW during Phase 2 which could result in being subjected to extreme cold conditions for many hours. The SFP FLEX pumps may also sit idle in extreme conditions for many hours.
The team noted with normal decay heat levels, it would take a nominal 71 hours8.217593e-4 days <br />0.0197 hours <br />1.173942e-4 weeks <br />2.70155e-5 months <br /> of boil-off before SFP inventory reaches 15 feet above the top of the fuel racks before makeup would be required.
Corrective Action(s): Immediate actions taken by the licensee included adding the fuel additive to all diesel fuel operated equipment (including the N+1 equipment) that has a fuel filter and all associated 110 gallon fuel tanks. All engines were operated to distribute the treated diesel fuel through the fuel filters and system. This action will remove the dependence on operator actions to add the fuel additive during a FLEX event. This was also performed on all diesel fuel tanks in the FLEX building.
Corrective Action Reference(s): CR-2018-01549
Performance Assessment:
Performance Deficiency: Per the NEI 12-06 FLEX guidelines, all sites should consider the temperature ranges and weather conditions for their site in storing and deploying FLEX equipment. FENOCs FIP, section 2.6.4, states that all FLEX pumps are specified to ensure they are capable of starting and operating for the most challenging low temperature conditions. FENOCs procedures failed to ensure that the portable diesel equipment would be capable of starting and operating for the most challenging low temperature conditions and this was considered a performance deficiency.
Screening: The performance deficiency was more than minor because it was associated with the protection against external factors attribute of the Mitigating Systems cornerstone and adversely affected the Mitigating Systems cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, FENOCs procedures did not ensure that the alternate AFW FLEX and SFP portable diesel pumps would be capable of starting and operating for the most challenging low temperature conditions.
Significance: The significance of the finding was evaluated using NRC inspection Manual Chapter 0609, Appendix O, Significance Determination Process for Mitigating Strategies and Spent Fuel Pool Instrumentation (Orders EA-12-049 and EA-12-051), dated October 7, 2016.
The finding was determined to be of very low safety significance (Green) because the team answered no to all questions in Appendix O. Specifically, this condition was not associated with Spent Fuel Pool Level Instrumentation and did not result in a complete loss of function to maintain or restore core cooling, containment pressure control/heat removal and/or spent fuel pooling cooling capabilities. FENOC Phase 2 cooling strategies are designed to permit continued use of the TDAFW pump. The FLEX AFW pumps serve as backups, and functionality of the TDAFW pump is expected throughout Phase 2 associated with the event.
Additionally, the Phase 3 FLEX strategy results in additional equipment delivered onsite, which could allow the spent fuel pool cooling and inventory function to be maintained given the expected time available before water addition is required. Therefore there would not be a complete loss of any function given existing procedures and FENOCs FLEX strategy.
Cross-cutting Aspect: The team determined that this finding had a cross-cutting aspect in the area of Human Performance, Documentation, because FENOC had not created complete and accurate documentation in that the development of the existing FLEX procedures had not adequately considered protection of the FLEX equipment fuel throughout the time of deployment through starting of the equipment. [H.7]
Enforcement:
The inspectors did not identify a violation of regulatory requirements associated with this finding.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On February 23, 2018, the team presented the preliminary FLEX inspection results to Mr. Rich Bologna, Site Vice President, and other members of the licensee staff. An exit meeting was conducted with Mr. Brian Kremer, Regulatory Compliance Manager, via telephone on March 21, 2018, to discuss the final results of the inspection.
DOCUMENTS REVIEWED
Condition Reports initiated in response to inspection
CR-2018-01582
CR-2018-01549
CR-2018-01591
Calculations
10080-DEC-3586, FLEX Electrical Load and Voltage Evaluation, Revision 0
Miscellaneous
Beaver Valley Power Station, Units 1 and 2 -Safety Evaluation Regarding Implementation of
Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders
EA 12 049 and EA-12-051), dated May 18, 2017 Final Integrated Plan, L-16-321,
Completion of Required Action by NRC Order EA-12-049 Order Modifying Licenses with
Regard to Requirements for Mitigation Strategies For Beyond-Design-Basis External Events
Procedures
1OM-53A.1.ECA-0.0(ISS3), Loss of All Emergency 4Kv Ac Power, Revision 1
2OM-53A.1.ECA-0.0(ISS3), Loss of All Ac Power, Revision 0
1OM-53C.4.1.36.1, Loss of All Emergency 4Kv Ac Power While On Shutdown Cooling,
Revision 7
2OM-53C.4.2.36.1, Loss Of All Ac Power When Shutdown, Revision 10
2OM-53E.1.FSG-8, Alternate RCS Boration, Revision 1
2OM-53E.1.FSG-10, Passive RCS Management, Revision 0
1OM-53E.1.FSG-4, ELAP Dc Bus Load Shed / Management, Revision 1
1OM-53E.1.FSG-5, Initial Assessment and Flex Equipment Staging, Revision 2
1OM-53E.1.FSG-6, Alternate PPDWST Makeup, Revision 2
2OM-53E.1.FSG-4, ELAP Dc Bus Load Shed / Management, Revision 1
R. Bologna
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
2100 RENAISSANCE BOULEVARD, SUITE 100
KING OF PRUSSIA, PA 19406-2713
May 3, 2018
Mr. Richard Bologna
Site Vice President
First Energy Nuclear Operating Company
Beaver Valley Power Station
P. O. Box 4 - Route 168
Shippingport, PA 15077-0004
SUBJECT: BEAVER VALLEY POWER STATION - UNITS 1 AND 2
TEMPORARY INSTRUCTION 2515/191, MITIGATION STRATEGIES
SPENT FUEL POOL INSTRUMENTATION AND EMERGENCY
PREPAREDNESS INSPECTION REPORT 05000334/2018010 AND
Dear Mr. Bologna:
On February 23, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at Beaver Valley Power Station (BVPS) Units 1 and 2; and the team discussed the
preliminary results of this inspection with you, and other members of your staff. An exit meeting
was conducted with Mr. Brian Kremer, Regulatory Compliance Manager, via telephone on
March 21, 2018, to discuss the final results of the inspection. The results of this inspection are
documented in the enclosed report.
NRC inspectors documented one finding of very low safety significance (Green) in this report.
The finding did not involve a violation of NRC requirements.
If you disagree with a cross-cutting aspect assignment or the 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 denial, to the U.S. Nuclear Regulatory
Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the
Regional Administrator, Region I; and the NRC resident Inspector at Beaver Valley.
R. Bologna 2
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 (10 CFR ), Part 2.390,
Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Marc
- S. Ferdas, Chief
Technical Support and Assessment Branch
Division of Reactor Projects
Docket Numbers: 50-334 and 50-412
License Numbers: DPR-66 and NPF-73
Enclosure:
Inspection Report 05000334/2018010
and 05000412/2018010
cc w/encl:
Distribution via ListServ
Non-Sensitive Publicly Available
SUNSI Review
Sensitive Non-Publicly Available
OFFICE RI/DRS RI/DRP RI/DRS
NAME FArner MYoung MFerdas
DATE 5/01/18 5/01/18 5/03/18
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number: 50-334 and 50-412
License Number: DPR-66 and NPF-73
Report Number: 05000334/2018010 and 05000412/2018010
Enterprise Identifier: I-2018-010-0047
Licensee: FirstEnergy Nuclear Operating Company (FENOC)
Facility: Beaver Valley Power Station, Units 1 and 2
Location: Shippingport, PA 15077
Inspection Dates: February 20, 2018 to February 23, 2018
Inspectors:
- F. Arner, Senior Reactor Analyst (Team Leader)
- M. Patel, Operations Inspector
- S. Horvitz, Resident Inspector
Approved By: Marc
- S. Ferdas, Chief
Technical Support and Assessment Branch
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring FENOCs performance
at Beaver Valley Units 1 and 2 by conducting Temporary Instruction 2515/191, Implementation
of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency
Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, in accordance with
the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for
overseeing the safe operation of commercial nuclear power reactors. Refer to
https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC and
self-revealed findings, violations, and additional items are summarized in the table below.
List of Findings and Violations
Inadequate Diesel Fuel Oil Temperature Protection
Cornerstone Significance Cross-cutting Report
Aspect Section
Mitigating Green H.7- TI 2515/191
Systems FIN 05000334 and 05000412/2018010-01 Documentation
The team identified a finding of very low safety significance (Green) for the failure to ensure that
diesel powered Diverse and Flexible Coping Strategies (FLEX) equipment would be reliable to
mitigate postulated beyond-design basis external events during very low temperature conditions.
Specifically, at temperatures below the site fuel cloud point (4 degrees Fahrenheit (F) to -7
degrees F), portable FLEX equipment, such as emergency diesel powered pumps, were
susceptible to conditions in which their capability of starting and operating would be impacted
due to fuel crystallizing or gelling and subsequent coating of fuel filter elements.
INSPECTION SCOPES
This inspection was conducted using the appropriate portions of the Temporary Instruction (TI)
in effect at the beginning of the inspection unless otherwise noted. Currently approved TIs with
their attached revision histories are located on the public website at http://www.nrc.gov/reading-
rm/doc-collections/insp-manual/inspection-procedure/index.html. Documents reviewed by
inspectors are listed in the documents reviewed section of this report. The inspectors reviewed
selected procedures and records, observed activities, and interviewed personnel to assess
licensee performance and compliance with Commission rules and regulations, license
conditions, site procedures, and standards.
OTHER ACTIVITIESTEMPORARY INSTRUCTION, INFREQUENT AND ABNORMAL
TI 2515/191Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool
Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit
Dose Assessment Plans
The inspectors verified plans for complying with NRC Orders EA-12-049, Order Modifying
Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis
External Events, (ADAMS Accession No. ML12056A045) and EA-12-051,
Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,
(ADAMS Accession No. ML12054A679) are in place and are being implemented by the
licensee.
Additionally, the inspection verified implementation of staffing and communications
information provided in response to the March 12, 2012, request for information letter
(ADAMS Accession No. ML12053A340) and multiunit dose assessment information
provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency
Preparedness for Japan Lessons Learned, dated March 27, 2013, (ADAMS Accession
No. ML12339A262).
(1) Based on samples selected for review, the inspectors verified that the licensee
satisfactorily implemented appropriate elements of the Diverse and Flexible Coping
Strategies (FLEX) as described in the plant specific submittals and the associated safety
evaluation (ADAMS Accession No. ML17095A276) and determined that the licensee is in
compliance with NRC Order EA-12-049, Order Modifying Licenses With Regard to
Requirements for Mitigation Strategies for Beyond-Design-Basis External Events.
The inspectors verified the licensee satisfactorily:
a. Developed and issued FLEX Support Guidelines (FSGs) to implement the FLEX
strategies for postulated external events;
b. Integrated their FSGs into their existing plant procedures such that entry into and
departure from the FSGs were clear when using existing plant procedures;
c. Protected FLEX equipment from site-specific hazards;
d. Developed and implemented adequate testing and maintenance of FLEX equipment to
ensure their availability and capability;
e. Trained their staff to assure personnel proficiency in the mitigation of
beyond-design basis events; and
f. Developed the means to ensure the necessary off-site FLEX equipment would be
available from off-site locations.
(2) Based on samples selected for review, the inspectors verified that the licensee satisfactorily
implemented appropriate elements of the FLEX strategy as described in the plant specific
submittals and the associated safety evaluation and determined that the licensee is in
compliance with NRC Order NRC Order EA-12-051, Order Modifying Licenses with
Regard to Reliable Spent Fuel Pool Instrumentation. The inspectors verified the licensee
satisfactorily:
a. Installed the spent fuel pool (SFP) instrumentation sensors, cabling and power supplies
to provide physical and electrical separation as described in the plant specific submittals
and safety evaluation;
b. Installed the SFP instrumentation display in the location, environmental conditions and
accessibility as described in the plant specific submittals;
c. Trained their staff to assure personnel proficiency with the maintenance, testing, and use
of the SFP instrumentation; and
d. Developed and issued procedures for maintenance, testing and use of the reliable SFP
instrumentation.
(3) The inspectors reviewed information provided in the licensees multi-unit dose submittal and
in response to the NRCs March 12, 2012, request for information letter, and verified that the
licensee satisfactorily implemented enhancements pertaining to Near-Term Task Force
(NTTF) Recommendation 9.3 response to a large scale natural emergency event that results
in an extended loss of all ac power to all site units and impedes access to the site. The
inspectors verified the following:
a. The licensee satisfactorily implemented required staffing changes to support a multi-unit
extended loss of alternating current (ac) power (ELAP) scenario;
b. Emergency preparedness (EP) communications equipment and facilities are sufficient
for dealing with a multi-unit ELAP scenario; and
c. The licensee implemented multi-unit dose assessment capabilities (including releases
from spent fuel pools) using the licensees site-specific dose assessment software and
approach.
The inspectors verified that non-compliances with requirements, and standards identified
during the inspection were entered into the licensee's corrective action program as
appropriate. The corrective action program documents generated as a result of the
inspection are listed in the Documents Reviewed section of this inspection report.
This TI is considered closed.
INSPECTION RESULTS
Inadequate Diesel Fuel Oil Temperature Protection
Cornerstone Significance Cross-cutting Report
Aspect Section
Mitigating Green H.7 - TI 2515/191
Systems FIN 05000334 and Documentation
The team identified a finding of very low safety significance (Green) for the failure to ensure
that diesel powered Diverse and Flexible Coping Strategies (FLEX) equipment would be
reliable to mitigate postulated beyond-design basis external events during very low
temperature conditions. Specifically, at temperatures below the site fuel cloud point
(4 degrees Fahrenheit (F) to -7 degrees F), portable FLEX equipment such as emergency
diesel powered pumps, were susceptible to conditions in which their capability of starting and
operating would be impacted due to fuel crystallizing or gelling and subsequent coating of fuel
filter elements.
Description: The team reviewed the ability of the FLEX equipment to operate across the
sites specific temperature hazard ranges. The Nuclear Energy Institute (NEI) developed NEI 2-06, which provides guidelines for nuclear stations to assess extreme event hazards and
implement mitigation strategies to ensure compliance with NRC Order EA-12-049. FENOCs
Final Integrated Plan, L-16-321, Completion of Required Action by NRC Order EA-12-049,
Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond
Design Basis External Events, stated that Beaver Valley Power Station complies with the
requirements as described in NEI 12-06, Revision 2, as endorsed by the NRC. As discussed
in NEI 12-06, Section 8.2.1, all sites should consider the temperature ranges and weather
conditions for their site in storing and deploying FLEX equipment consistent with normal
design practices.
The team identified that Beaver Valleys Diesel Flex Fuel powered equipment with fuel filters
when exposed to an extreme cold weather event were susceptible to conditions in which their
capability of starting and operating could be impacted. The team noted that based on the site
fuel cloud point which ranged from 4 degrees to -7 degrees F, diesel fuel crystallization or
gelling could occur below these temperatures. The FLEX program for Beaver Valley supports
extreme cold weather conditions down to -20 degrees F as documented in the site final
integrated plan (FIP). The cloud point of the fuel is the temperature at which paraffin (a wax-
like gel, which is naturally present in #2 diesel fuel), begins to form cloudy wax crystals. At
the cloud point, these wax crystals flow with the fuel, coat the fuel filter element, and can
quickly reduce the fuel flow, potentially challenging the engines.
When deployment begins, the equipment could be subjected to temperatures which could be
well below the cloud point for the fuel, with the equipment potentially not being started for
many hours. Specifically, once deployed, the diesel driven pumps could be subjected to
harsh ambient conditions, potentially as low as -20 degrees F, prior to their start. The team
noted FENOC had Hard Card procedures which referenced the use of an additive (anti-gel)
when ambient temperatures fell below 20 degrees F. However the team noted that the
additive wouldnt have been added until the equipment was being placed into service. The
affected FLEX equipment may remain idle and positioned in the field for many hours after
deployment in the extreme conditions before this fuel additive would be added. If
crystallization and gelling had already begun, the additive would be ineffective.
The team noted that 10M-53E.1.FSG-5, Initial Assessment and FLEX Equipment Staging,
provides guidelines for deployment of FLEX equipment with priority based on system
conditions. Table 1, Key FLEX Actions, states that the FLEX Alternate Auxiliary Feedwater
Pump is to be staged at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> from the loss of all alternating current (AC) power event, prior
to plant cooldown, and used as backup to the Turbine Driven Auxiliary Feedwater Pump
(TDAFW). FSG-11, Alternate Spent Fuel Pool (SFP) Makeup and Cooling, was referenced
to be implemented for pump deployment no later than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the event.
The NRC safety evaluation report (SER) states that the preferred strategy for core cooling in
Phase 1 and Phase 2 is to use the TDAFW pump and it is expected to maintain functionality
by FENOC given their cooldown strategies throughout Phase 2. However, FLEX
requirements and FENOC procedures deploy the alternate AFW pump as a backup to the
TDAFW during Phase 2 which could result in being subjected to extreme cold conditions for
many hours. The SFP FLEX pumps may also sit idle in extreme conditions for many hours.
The team noted with normal decay heat levels, it would take a nominal 71 hours8.217593e-4 days <br />0.0197 hours <br />1.173942e-4 weeks <br />2.70155e-5 months <br /> of boil-off
before SFP inventory reaches 15 feet above the top of the fuel racks before makeup would be
required.
Corrective Action(s): Immediate actions taken by the licensee included adding the fuel
additive to all diesel fuel operated equipment (including the N+1 equipment) that has a fuel
filter and all associated 110 gallon fuel tanks. All engines were operated to distribute the
treated diesel fuel through the fuel filters and system. This action will remove the
dependence on operator actions to add the fuel additive during a FLEX event. This was also
performed on all diesel fuel tanks in the FLEX building.
Corrective Action Reference(s): CR-2018-01549
Performance Assessment:
Performance Deficiency: Per the NEI 12-06 FLEX guidelines, all sites should consider the
temperature ranges and weather conditions for their site in storing and deploying FLEX
equipment. FENOCs FIP, section 2.6.4, states that all FLEX pumps are specified to ensure
they are capable of starting and operating for the most challenging low temperature
conditions. FENOCs procedures failed to ensure that the portable diesel equipment would
be capable of starting and operating for the most challenging low temperature conditions and
this was considered a performance deficiency.
Screening: The performance deficiency was more than minor because it was associated with
the protection against external factors attribute of the Mitigating Systems cornerstone and
adversely affected the Mitigating Systems cornerstone objective of ensuring the availability,
reliability, and capability of systems that respond to initiating events to prevent undesirable
consequences. Specifically, FENOCs procedures did not ensure that the alternate AFW
FLEX and SFP portable diesel pumps would be capable of starting and operating for the most
challenging low temperature conditions.
Significance: The significance of the finding was evaluated using NRC inspection Manual
Chapter 0609, Appendix O, Significance Determination Process for Mitigating Strategies and
Spent Fuel Pool Instrumentation (Orders EA-12-049 and EA-12-051), dated October 7, 2016.
The finding was determined to be of very low safety significance (Green) because the team
answered no to all questions in Appendix
- O. Specifically, this condition was not associated
with Spent Fuel Pool Level Instrumentation and did not result in a complete loss of function to
maintain or restore core cooling, containment pressure control/heat removal and/or spent fuel
pooling cooling capabilities. FENOC Phase 2 cooling strategies are designed to permit
continued use of the TDAFW pump. The FLEX AFW pumps serve as backups, and
functionality of the TDAFW pump is expected throughout Phase 2 associated with the event.
Additionally, the Phase 3 FLEX strategy results in additional equipment delivered onsite,
which could allow the spent fuel pool cooling and inventory function to be maintained given
the expected time available before water addition is required. Therefore there would not be a
complete loss of any function given existing procedures and FENOCs FLEX strategy.
Cross-cutting Aspect: The team determined that this finding had a cross-cutting aspect in the
area of Human Performance, Documentation, because FENOC had not created complete
and accurate documentation in that the development of the existing FLEX procedures had not
adequately considered protection of the FLEX equipment fuel throughout the time of
deployment through starting of the equipment. [H.7]
Enforcement:
The inspectors did not identify a violation of regulatory requirements associated with this
finding.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On February 23, 2018, the team presented the preliminary FLEX inspection results to
Mr. Rich Bologna, Site Vice President, and other members of the licensee staff. An exit
meeting was conducted with Mr. Brian Kremer, Regulatory Compliance Manager, via
telephone on March 21, 2018, to discuss the final results of the inspection.
DOCUMENTS REVIEWED
Condition Reports initiated in response to inspection
CR-2018-01582
CR-2018-01549
CR-2018-01591
Calculations
10080-DEC-3586, FLEX Electrical Load and Voltage Evaluation, Revision 0
Miscellaneous
Beaver Valley Power Station, Units 1 and 2 -Safety Evaluation Regarding Implementation of
Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders
EA 12 049 and EA-12-051), dated May 18, 2017 Final Integrated Plan, L-16-321,
Completion of Required Action by NRC Order EA-12-049 Order Modifying Licenses with
Regard to Requirements for Mitigation Strategies For Beyond-Design-Basis External Events
Procedures
1OM-53A.1.ECA-0.0(ISS3), Loss of All Emergency 4Kv Ac Power, Revision 1
2OM-53A.1.ECA-0.0(ISS3), Loss of All Ac Power, Revision 0
1OM-53C.4.1.36.1, Loss of All Emergency 4Kv Ac Power While On Shutdown Cooling,
Revision 7
2OM-53C.4.2.36.1, Loss Of All Ac Power When Shutdown, Revision 10
2OM-53E.1.FSG-8, Alternate RCS Boration, Revision 1
2OM-53E.1.FSG-10, Passive RCS Management, Revision 0
1OM-53E.1.FSG-4, ELAP Dc Bus Load Shed / Management, Revision 1
1OM-53E.1.FSG-5, Initial Assessment and Flex Equipment Staging, Revision 2
1OM-53E.1.FSG-6, Alternate PPDWST Makeup, Revision 2
2OM-53E.1.FSG-4, ELAP Dc Bus Load Shed / Management, Revision 1