IR 05000334/2023003
| ML23310A040 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 11/06/2023 |
| From: | Matt Young Division of Operating Reactors |
| To: | Blair B Energy Harbor Nuclear Corp |
| References | |
| IR 2023003 | |
| Download: ML23310A040 (1) | |
Text
November 6, 2023
SUBJECT:
BEAVER VALLEY POWER STATION, UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000334/2023003 AND 05000412/2023003
Dear Barry Blair:
On September 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Beaver Valley Power Station, Units 1 and 2. On October 18, 2023, the NRC inspectors discussed the results of this inspection with Barry Blair, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
No findings or violations of more than minor significance were identified during this inspection.
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 at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Matt R. Young, Chief Projects Branch 2 Division of Operating Reactor Safety
Docket Nos. 05000334 and 05000412 License Nos. DPR-66 and NPF-73
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000334 and 05000412
License Numbers:
Report Numbers:
05000334/2023003 and 05000412/2023003
Enterprise Identifier: I-2023-003-0026
Licensee:
Energy Harbor Nuclear Corp.
Facility:
Beaver Valley Power Station, Units 1 and 2
Location:
Shippingport, PA
Inspection Dates:
July 01, 2023 to September 30, 2023
Inspectors:
N. Day, Senior Resident Inspector
A. Nugent, Project Engineer
R. Clagg, Senior Project Engineer
J. Demarshall, Senior Operations Engineer
E. Eve, Senior Project Engineer
T. Fish, Senior Operations Engineer
K. Hussar, Senior Physical Security Inspector
D. Kern, Senior Reactor Inspector
S. Mercurio, Emergency Preparedness Inspector
R. Rolph, Senior Health Physicist
Approved By:
Matt R. Young, Chief
Projects Branch 2
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Beaver Valley Power Station, Units 1 and 2, 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.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
PLANT STATUS
Unit 1 started the inspection period at full power. On September 15, 2023, the unit was downpowered to 48 percent power to repair the 'B' main feedwater pump. Following repairs, Unit 1 returned to full power on September 22, 2023. Unit 1 remained at full power for the remainder of the inspection period.
Unit 2 started the inspection period at full power. On the morning of August 14, 2023, the unit was downpowered to perform a planned 'C' steam generator water level instrument calibration, and returned to full power level the same afternoon. Unit 2 remained at full power for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs 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. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. 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.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (1 Sample)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Protected area systems and barriers, September 6, 2023
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Unit 2, safeguards building, July 26, 2023
- (2) Unit 1, emergency diesel generators, July 27, 2023
- (3) Diverse and flexible coping strategies (FLEX) building, August 7, 2023
- (4) Units 1 and 2, service water/river water intake building, September 6, 2023
- (5) Unit 2, train 'B' service water valve pit room due to hotwork activities, September 13, 2023
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
- (1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the Unit 2 requalification annual operating exam administered July 24-28, 2023, and for the Unit 2 biennial written exams completed February - March 2023.
71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)
- (1) Biennial Requalification Written Examinations
The inspectors evaluated the quality of the Unit 2 licensed operator biennial requalification written examinations administered February - March 2023.
Annual Requalification Operating Tests
The inspectors evaluated the adequacy of the Unit 2 licensed operator annual requalification operating test administered July 24-28, 2023.
Administration of an Annual Requalification Operating Test
The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.
Requalification Examination Security
The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.
Remedial Training and Re-Examinations
The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.
Operator License Conditions
The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.
Control Room Simulator
The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during a Unit 2 downpower to 95 percent for steam generator loop 3 channel 2 narrow range water level, 2FWSL495, "Test and Calibration," per 2MSP-24.24-I on August 14, 2023.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated Unit 2 licensed operator requalification training on September 1, 2023.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Unit 2, emergency diesel generator 2-2, following fuel oil leakage and injector replacement per Order 200919226, July 13, 2023
- (2) Unit 2, service water pump performance and condition of piping, August 30, 2023
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Unit 1, plant risk during hot weather, July 28, 2023
- (2) Unit 2, Orange integrated risk due to repairs to service water system during Mode 1 power operations, September 12, 2023
- (3) Unit 2, Yellow risk due to performance of heavy lift to remove floor plug in order to access seal injection filter, September 21, 2023
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Unit 2, emergency diesel generator 2-2, for condition described in Condition Reports (CR) 2023-05455 and 2023-05534, July 15, 2023
- (2) Unit 2, service water header 'A' piping through wall leak for condition described in CR 2023-06117, August 6, 2023
- (3) Unit 2, service water header 'B' piping through wall leak for condition described in CR 2023-06344, August 15, 2023
- (4) Unit 2, emergency diesel generator 2-2 for condition described in CR 2023-06691, August 28, 2023
- (5) Unit 1, turbine driven auxiliary feedwater pump for condition described in CR 2023-
===06908, September 7, 2023
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01)===
- (1) Diesel driven firewater pump following repairs to the starting and cooling system, September 7, 2023
- (2) Unit 2, low head safety injection pump 'B' following motor oil change, September 11, 2023
- (3) Turbine marine diesel generator 1-01 battery and periodic load testing per Order
===200867794, September 14, 2023
- (4) Unit 2, service water train 'B' through wall weld repair near 2SWS-MOV120B per Order 200921923, September 15, 2023
- (5) Unit 1, main feed pump 'B' bearing inspection following outboard bearing failure, repair, and replacement, September 22, 2023
- (6) Unit 2, motor driven auxiliary feedwater pump 'A' quarterly surveillance following motor oil change, September 25, 2023
- (7) Unit 1, centrifugal charging pump 'A' following motor maintenance, September 26, 2023.
Surveillance Testing (IP Section 03.01)===
- (1) Unit 1, emergency diesel generator 1-01 monthly test per 1OST-36.1, August 2, 2023
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
- (1) Unit 2, service water pump 'C' comprehensive and quarterly test, July 11, 2023
Diverse and Flexible Coping Strategies (FLEX) Testing (IP Section 03.02) (1 Sample)
- (1) Turbine marine diesel generator periodic load testing per Order 200860280, August 9, 2023
71114.02 - Alert and Notification System Testing
Inspection Review (IP Section 02.01-02.04) (1 Sample)
- (1) The inspectors evaluated the licensee's maintenance and testing of the licensee's alert and notification system on July 17 through July 21, 2023, for the period of June 2021 through June 2023.
71114.03 - Emergency Response Organization Staffing and Augmentation System
Inspection Review (IP Section 02.01-02.02) (1 Sample)
- (1) The inspectors evaluated the readiness of the licensee's Emergency Preparedness Organization on July 17 through July 21, 2023.
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
- (1) The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes:
- BV-2022-017-00, EPP-PLAN-SECTION 4, Emergency Conditions, Revision
- BV-2022-006-00, Accident Assessment, Revision 1
- BV-2022-007-00, Event Classification
- BV-2022-008-00, Emergency Notifications, Revision 1
- BV-2022-020-00, Alternate Meteorological Parameters
- BV-2022-025-00, Recognition and Classification of Emergency Conditions
- BV-2022-029-00, BVPS Emergency Notification Testing, Review and Trending
- BV-2022-036-00, Appendix H, BVPS Emergency Response Organization On-Shift Staffing Analysis Report, Revision 2
- BV-2023-003-00, Emergency Organization
- BV-2023-004-00, Maintaining Preparedness
This evaluation does not constitute NRC approval.
71114.05 - Maintenance of Emergency Preparedness
Inspection Review (IP Section 02.01 - 02.11) (1 Sample)
- (1) The inspectors evaluated the maintenance of the emergency preparedness program on July 17 through July 21, 2023, for the period of June 2021 through June 2023.
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated the conduct of an emergency preparedness drill in the control room simulator and Emergency Operations Facility on August 3,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS08: Heat Removal Systems (IP Section 02.07)===
- (1) Unit 1, July 1, 2022 through June 30, 2023
- (2) Unit 2, July 1, 2022 through June 30, 2023
MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)
- (1) Unit 1, July 1, 2022 through June 30, 2023
- (2) Unit 2, July 1, 2022 through June 30, 2023
MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)
- (1) Unit 1, July 1, 2022 through June 30, 2023
- (2) Unit 2, July 1, 2022 through June 30, 2023
EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)
- (1) April 1, 2022 through March 31, 2023
EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)
- (1) April 1, 2022 through March 31, 2023
EP03: Alert And Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)
- (1) April 1, 2022 through March 31, 2023
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Instrument/Relay/Switch Performance Trending
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (1) Main control room door being left unattended as documented in CRs 2023-05401 and 2023-05626
- (2) Radiation monitoring instrument reliability
INSPECTION RESULTS
Minor Performance Deficiency 71152A Instrument, Relay, Switch Performance Trending Minor Performance Deficiency
Minor Performance Deficiency: The inspectors selected instrument and relay performance trending as a focused review issue based on industry operating experience and observations that some BVPS instruments experienced drift outside of the Measured Maintenance Database Program limits. Inspection scope included a review of periodic calibration results, issue documentation and prioritization, causal evaluation, and corrective actions for 13 instruments and relays which experienced repetitive drift during periodic calibrations since 2007. The inspectors also performed plant walkdowns, interviewed engineers and operators, and reviewed setpoint calculations and the measured maintenance database calibration database to assess various instrument and relay performance.
The inspectors determined instruments and relays were typically calibrated at the normal intervals, which is a performance deficiency. Notwithstanding, the inspectors identified that since 2007, Unit 2 volume control tank level instrument 2CHS-LT115 calibration was consistently scheduled and performed late in the preventative maintenance grace window or beyond the preventative maintenance late date. The average calibration interval was two years and seven months, which exceeded the 2-year instrument calibration periodicity plus 25 percent grace period. Consequently, as-found instrument drift typically exceeded the Measured Maintenance Database Program drift limit until 2CHS-LT115 was replaced on August 29, 2022. Engineers initiated CRs 2023-06765 and 2023-07052 to document the untimely calibration issue, identify the extent of condition, and restore timely calibrations.
Screening: The inspectors determined the performance deficiency was minor. The inspectors determined untimely calibration of 2CHS-LT115 was a minor performance deficiency because the safety injection actuation circuit was operable and was credited by technical specifications to automatically swap the charging pump suction from the volume control tank to the refueling water storage tank upon sensing a significant reactor coolant system leak, independent of 2CHS-LT115. Additionally, operators performed a channel check surveillance between the two volume control tank level instruments (2CHS-LT115 and 2CHS-LT112) every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, which would identify any significant instrument drift in a timely manner.
Observation: Radiation Monitoring Equipment Reliability 71152S The inspectors performed an in-depth review of Energy Harbors analysis and corrective actions associated with CR-2022-08430, dated November 4, 2022. The inspectors also reviewed eight other recent corrective action documents addressing similar issues and the corrective actions taken or planned to increase the reliability of the radiation monitoring equipment. After reviewing the corrective action documents, the inspectors noted that the backlog of documented radiation monitor issues continues to increase in examples; however, no consequential impacts to the risk significant radiation monitors needed for the Emergency Plan or Technical Specifications were found.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 18, 2023, the inspectors presented the integrated inspection results to Barry Blair, Site Vice President, and other members of the licensee staff.
- On July 20, 2023, the inspectors presented the emergency preparedness program inspection results to Andrew Crotty, Manager, Work Control, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
Risk Plan for 2CH-FLT24A Filter Replacement
(ROUND PLUG)
Lift Plan for 2CHS-FLT24A Round Floor Plug
09/20/2023
Work Orders
Work Order for 2CH-FLT24A Filter Remove/Replace
Work Orders
WO: 200923598
Work Order for 1MFP 'B' Bearing Remove/Repair/Replace
09/22/2023
Miscellaneous
Beaver Valley Power Station Alert and Notification System
Design Report
04/21/2020
Miscellaneous
Beaver Valley Power Station Emergency Preparedness Plan
Beaver Valley Power Station Evacuation Time Estimates
08/29/2022
Corrective Action
Documents
Resulting from
Inspection
23-06690
23-06765
23-07052
Miscellaneous
BVPS Measured Maintenance Data System Calibration
Records from January 1, 2000 to August 1, 2023
BVPS Unit 2 Updated Final Safety Analysis Report (sections
6.3 and 9.3)
BV-DF-12-0234
2CHS-LT115 Calibration Deferral
10/04/2012
Procedures
NOP-WM-2003
Work Management Surveillance Process
NOP-WM-3001
Work Management PM Process
Work Orders
200434373
200518787
200567602
200639202
200707900
Corrective Action
Documents
22-03110
Monitor Failed Check Source
04/07/2022
22-06046
Failed Check Source on 2MSS-RQ101B
08/05/2022
22-06704
2MSS0RQ101B Check Source Believed to be Decayed
08/31/2022
22-06760
Extent of Condition for Rad Monitor Check Source
Degradation
09/02/2022
22-06936
Main Steam Rad Monitor Check Source Failure
09/12/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
22-08430
Radiation Monitoring Instruments Reliability Issues Due to
Calibration and Check Sources
23-04905
23 Work Order Review for Rad Monitor and Fire Protect
Work Orders
06/19/2023
Miscellaneous
Radiation Monitoring Team Action Item List
09/27/2023
Radiation Monitoring Team Action Item List
06/06/2023