IR 05000334/2023004

Integrated Inspection Report 05000334/2023004 and 05000412/2023004

ML24043A001
Person / Time
Site:	Beaver Valley
Issue date:	02/12/2024
From:	Matt Young Division of Operating Reactors
To:	Blair B Energy Harbor Nuclear Corp
References
IR 2023004
Download: ML24043A001 (1)

Text

February 12, 2024

SUBJECT:

BEAVER VALLEY POWER STATION, UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000334/2023004 AND 05000412/2023004

Dear Barry Blair:

On December 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Beaver Valley Power Station, Units 1 and 2. On January 17, 2024, the NRC inspectors 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.

Three findings of very low safety significance (Green) are documented in this report. Three of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations or the significance or severity of the violations documented in this inspection 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; the Director, Office of Enforcement; and the NRC Resident Inspector at Beaver Valley Power Station, Units 1 and 2.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the 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 Power Station, Units 1 and 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 at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 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:

DPR-66 and NPF-73

Report Numbers:

05000334/2023004 and 05000412/2023004

Licensee:

Energy Harbor Nuclear Corporation

Facility:

Beaver Valley Power Station, Units 1 and 2

Location:

Shippingport, PA

Inspection Dates:

October 01, 2023 to December 31, 2023

Inspectors:

N. Day, Senior Resident Inspector

C. Borman, Health Physicist

L. Dumont, Senior Reactor Inspector

B. Edwards, Health Physicist

A. Nugent, Project Engineer

B. Pinson, Senior Reactor Inspector

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

Inappropriate Work Instructions Resulting in Unplanned Inoperability of the 2-2 Direct Current (DC) Bus Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000334,05000412/2023004-01 Open/Closed

[H.12] - Avoid Complacency 71111.04 A self-revealed finding of very low safety significance (Green) and associated non-cited violation (NCV) of Beaver Valley Power Station Unit 2 Technical Specification (TS) 5.4.1a,

"Procedures," on December 15, 2023, was identified when the station inadvertently opened the 2-2 battery charger disconnect switch during routine maintenance. Specifically, the licensee failed to preplan and perform procedures and instructions appropriate for that work activity.

Failure to Implement Procedure Requirements Resulting in Inadequate Administrative Controls While a Missile Shield Door Was Open Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000412/2023004-03 Open/Closed

[H.4] -

Teamwork 71152A A self-revealed Green finding and associated non-cited violation was identified associated with a failure to meet 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," which requires, in part, that "Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."

Specifically, the licensee failed to implement requirements in procedure 1/2-ADM-2021,

Control of Penetrations (Including HELB Doors), resulting in inadequate administrative controls for the opening of an Updated Final Safety Analysis Report (UFSAR) credited missile barrier.

Failure to perform Preventive Maintenance (PM) Replacement strategy Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000412,05000334/2023004-02 Open/Closed None 71152A A self-revealed Green finding and associated non-cited violation (NCV) of TS 5.4.1,

Administrative Controls - Procedures, was identified when Energy Harbor failed to replace an aged circuit card, 2HVD-TKC21B, as required by the licensees PM replacement strategy. Specifically, Energy Harbor failed to replace circuit card 2HVD-TKC21B within the 15 year PM replacement schedule as required by licensee procedure, NORM-ER-3881, "I&C Circuit Cards - Westinghouse," Revision 4. Subsequently, the circuit card failed which required the 2-2 emergency diesel generator (EDG) to be declared inoperable.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000412/2023-002-00 LER 2023-002-00 for Beaver Valley Power Station, Unit 2,

Automatic Actuation of Auxiliary Feedwater System 71153 Closed LER 05000412/2023-003-00 LER 2023-003-00 for Beaver Valley Power Station, Unit 2,

Missile Barrier Door Left Open Resulting in a Loss of Safety Function 71153 Closed

PLANT STATUS

Unit 1 started the inspection period at rated thermal power. On the morning of October 1, 2023, the unit was downpowered to 28 percent power to repair the 'A' steam generator feedwater flow control valve. Following repairs, Unit 1 returned to full power on October 3, 2023. Unit 1 remained at rated thermal power for the remainder of the inspection period.

Unit 2 started the inspection period at rated thermal power. On the morning of October 5, 2023, the unit was downpowered to approximately 95 percent to perform a planned 'C' steam generator water level instrument calibration, and returned to full power level the same afternoon.

Unit 2 remained at rated thermal 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 onsite 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.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (2 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Unit 2, containment isolation valve lineup following the failure of isolation valve 2VRS-AOV109A2, October 16, 2023

(2) Unit 2, 125V DC bus 2-02, December 17, 2023

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 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 1, primary component cooling water (CCW) pump areas, October 26, 2023

(2) Unit 2, primary CCW heat exchanger areas, November 6, 2023

(3) Unit 2, control building instrumentation and relay areas, December 23, 2023

(4) Unit 2, cable spreading and cable tunnel areas, December 23, 2023

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the onsite fire brigade training and performance during an unannounced fire drill on October 18, 2023.

71111.07A - Heat Exchanger/Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) The Unit 2 'B' primary CCW heat exchanger 'B,' November 6, 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 Unit 1 licensed operator annual requalification results on November 1, 2023, for the annual operating exam completed on March 30, 2023.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated anticipated transient without scram scenarios on November 28, 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) Periodic evaluation of Maintenance Rule Program a(3) periodic evaluation, November 8, 2023

(2) Unit 2, EDG 2-01 loose cylinder #11 petcock line as described in Condition Report (CR) 2023-09396 and corrected in Order 200933407, December 26, 2023

Quality Control (IP Section 03.02) (1 Sample)

The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:

(1) Unit 2, EDG 2-02 with a focus on fuel oil procurement, November 16, 2023

Aging Management (IP Section 03.03) (1 Sample)

The inspectors evaluated the effectiveness of the aging management program for the following SSCs that did not meet their inspection or test acceptance criteria:

(1) Unit 1, structural monitoring inspections documented in Fourth Five Year Cycle Report, dated September 29, 2021

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (2 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 2, planned downpower to 95 percent reactor power to perform steam generator

'C' narrow range level channel 3 calibration, October 5, 2023

(2) Unit 1, planned train 'B' solid state protection testing, November 9, 2023

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (1 Sample)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Unit 1, operability of the EDG 1 due to leak identified in CR 2023-08686

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) (2 Samples)

(1) Unit 1, steam generator 'A' feedwater regulator valve following positioner replacement during work order (WO) 200924398, October 3, 2023

(2) Unit 2, containment isolation valve, 2VRS-AOV109A2, testing following limit switch and contact repairs per WO 200925175, November 2, 2023

Surveillance Testing (IP Section 03.01) (3 Samples)

(1) Unit 2, quench spray pump 'B' quarterly test, October 17, 2023

(2) Unit 2, charging pump 'A" quarterly test, December 13, 2023

(3) Unit 1, auxiliary building TS rounds, December 20, 2023

Reactor Coolant System Leakage Detection Testing (IP Section 03.01) (1 Sample)

(1) Unit 2, unidentified leakage as documented in CR 2023-08237, increase in unidentified leakage, October 31,

71124.06 - Radioactive Gaseous and Liquid Effluent Treatment

Walkdowns and Observations (IP Section 03.01) (4 Samples)

The inspectors evaluated the following radioactive effluent systems during walkdowns:

(1) Unit 1, gaseous effluent monitor and sampling location #RM-1GW-109

(2) Unit 1, liquid waste tank monitoring and sampling location #R1-LW116

(3) Unit 2, containment vent wide range effluent monitor #2HVS-RQI109C

(4) Unit 2, liquid effluent monitor #2SGC-RQI100-S1

Sampling and Analysis (IP Section 03.02) (4 Samples)

Inspectors evaluated the following effluent samples, sampling processes and compensatory samples:

(1) Unit 1, particulate filter air sample from RM-1GW-109 process vent August 14, 2023 through August 21, 2023

(2) Analysis of weekly iodine cartridge October 4, 2023, 210006 from sample location 2HVS-RQ-101

(3) Analysis of weekly particulate filter October 4, 2023, 210007 from sample location 2HVS-RQ-101

(4) Analysis of weekly gaseous grab sample October 4, 2023, 210003 from sample location 2HVS-RQ-109

Dose Calculations (IP Section 03.03) (2 Samples)

The inspectors evaluated the following dose calculations:

(1) Unit 1, gaseous and liquid release projected dose estimate for October 2023

(2) Unit 2, gaseous and liquid release projected dose estimate for October 2023

Abnormal Discharges (IP Section 03.04) (2 Samples)

The inspectors evaluated the following abnormal discharges:

(1) Analysis of Cobalt-58 detection in particulate filter sample September 13, 2023,

===210011 from sample location 2RMQ-RQ-303

(2) Analysis of Cobalt-58 detection in particulate filter sample September 20, 2023, 210011 from sample location 2RMQ-RQ-303

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10)===

(1) Unit 1, October 1, 2022 through September 30, 2023

(2) Unit 2, October 1, 2022 through September 30, 2023

BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)

(1) Unit 1, October 1, 2022 through September 30, 2023

(2) Unit 2, October 1, 2022 through September 30, 2023

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) October 1, 2022 through September 30, 2023

PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)

(1) October 1, 2022 through September 30, 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) Corrective actions associated with LER 05000412/2023-002-00, Automatic Actuation of Auxiliary Feedwater System (ML23193A364)

(2) Age related degradation associated with Beaver Valley Unit 2 electrical circuit cards

(3) Lack of administrative controls resulting in missile shield door A-35-5A being left open during and after refueling outage 2R23

71153 - Follow-Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000412/2023-002-00, Automatic Actuation of Auxiliary Feedwater System, (ADAMS Accession No. ML23193A364). The inspection conclusions associated with this LER are documented in this report under the Inspection Results, Observation:

Minor Performance Deficiency Associated with Inadequate Work Instructions. This LER is Closed.

(2) LER 05000412/2023-003-00, Missile Barrier Door Left Open Resulting in a Loss of Safety Function, (ADAMS Accession No. ML23221A239) The inspection conclusions associated with this LER are documented in this report under Inspection Results Section 71153. This LER is Closed.

INSPECTION RESULTS

Inappropriate Work Instructions Resulting in Unplanned Inoperability of the 2-2 Direct Current (DC) Bus Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems

Green NCV 05000334,05000412/2023004-01 Open/Closed

[H.12] - Avoid Complacency 71111.04 A self-revealed finding of very low safety significance (Green) and associated non-cited violation (NCV) of Beaver Valley Power Station Unit 2 Technical Specification (TS) 5.4.1a, "Procedures," on December 15, 2023, was identified when the station inadvertently opened the 2-2 battery charger disconnect switch during routine maintenance. Specifically, the licensee failed to preplan and perform procedures and instructions appropriate for that work activity.

Description:

On December 15, 2023, during performance of WO 200841035 to clean and inspect 2-4 battery charger disconnect switch, BAT-BKR2-4-SWGR-SW1, the maintenance was inadvertently performed on the 2-2 battery charger disconnect switch instead of the 2-4 battery charger disconnect switch. Licensee procedures and instructions call for various human performance error reduction processes such as a jobsite hazard evaluation and touch-read-read component verification. Neither of these were done for this maintenance order. Additionally, identifying the switch to be worked on was not a specific step in the work instructions but it is identified in the Functional Location section of the work order.

WO 200841035 step 6, was not specific with a component identification and was worded to open the switch. However, the 2-2 battery charger disconnect switch was inadvertently opened at 11:20 a.m. At this time, the licensee took unplanned unavailability and inoperability of the 2-2 battery, charger, and the 2-2 DC bus which were unplanned 2-hour shutdown action statements. At 11:24, per work instruction step 10, the disconnect switch for the 2-2 charger switch was closed restoring the charger and began to bring the bus back up to voltage.

A partial performance of the weekly DC bus distribution surveillance was completed at 12:45 with no issues. At this time, the 2-2 DC battery, charger, and bus were all declared operable.

A resident walkdown was conducted ensuring affected equipment was returned to the appropriate alignment.

The licensee promptly entered this issue in their corrective action program.

Corrective Actions: The licensee returned the switch to the closed position and performed a surveillance to ensure 2-2 battery parameters were satisfactory.

Additionally, the site suspended all maintenance for the remainder of the weekend and implemented increased management oversight upon resuming activities. The licensee entered the performance deficiency in the site corrective action program to correct the deficiency.

Corrective Action References: CR-2023-09226

Performance Assessment:

Performance Deficiency: The licensees failure to preplan and perform procedures and instructions appropriate for work on the 2-4 battery charger disconnect switch is a performance deficiency. Specifically, on December 15, 2023, while performing WO 200841035, the licensee inadvertently misconfigured the 2-2 battery charger disconnect switch, causing unplanned unavailability and inoperability of electrical components and distribution systems.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The failure to preplan and perform maintenance procedures and instructions adversely affected the reliability and availability of the battery charger. Specifically, improper manipulation of the 2-2 battery charger switch resulted in an inoperable condition and unavailability of the associated battery charger.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined the finding to be of very low safety significance (Green) because (1)the finding is a deficiency affecting the design or qualification of a mitigating SSC; however, it did not maintain its operability or probabilistic risk assessment (PRA) functionality,

(2) the degraded condition does not represent a loss of the PRA function of a single train TS system for greater than its TS allowed outage time,

(3) the degraded condition does not represent a loss of the PRA function of one train of a multi-train TS system for greater than its TS allowed outage time,

(4) the degraded condition does not represent a loss of the PRA function of two separate TS systems for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />,

(5) the degraded condition does not represent a loss of a PRA system and/or function as defined in the Plant Risk Information Book or the licensees PRA for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and

(6) the degraded does not condition represent a loss of the PRA function of one or more non-TS trains of equipment designated as risk significant in accordance with the licensees maintenance rule program for greater than 3 days.

Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. This finding had a cross-cutting aspect in the area of Human Performance, Avoid Complacency because the station did not implement appropriate error reduction tools (e.g., Jobsite Hazard Evaluation, Touch-Read-Read) in accordance with station processes (H.12).

Enforcement:

Violation: Beaver Valley Unit 2 TS 5.4.1a, Procedures, states that written procedures shall be established, implemented, and maintained covering the activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Section 9.a of Regulatory Guide 1.33 Revision 2, 1978, Appendix A states in part that Maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.

Contrary to the above, on December 15, 2023, the licensee failed to preplan and perform maintenance procedures and instructions appropriate for the circumstances. Specifically, the licensee failed to properly preplan and perform an appropriate procedure for maintenance of the 2-4 battery charger disconnect. These failures led to the maintenance that was intended for the 2-4 battery charger disconnect switch to instead be done to the 2-2 battery charger disconnect switch. This error resulted in the 2-2 disconnect switch being opened, which caused the unavailability and inoperability of the associated charger and putting the 2-2 bus on backup battery power.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Implement Procedure Requirements Resulting in Inadequate Administrative Controls While a Missile Shield Door Was Open Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems

Green NCV 05000412/2023004-03 Open/Closed

[H.4] -

Teamwork 71152A A self-revealed Green finding and associated non-cited violation was identified associated with a failure to meet 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," which requires, in part, that "Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."

Specifically, the licensee failed to implement requirements in procedure 1/2-ADM-2021, Control of Penetrations (Including HELB Doors), resulting in inadequate administrative controls for the opening of an Updated Final Safety Analysis Report (UFSAR) credited missile barrier.

Description:

The Beaver Valley Unit 2 UFSAR states that SSCs important to safety are appropriately protected against or designed to accommodate dynamic effects, including the effects of missiles, pipe whipping, and discharging fluids, that may result from equipment failures, and from events and conditions outside the nuclear power unit. The UFSAR also credits the Primary Auxiliary Building structure as part of the missile protection for the primary CCW pumps. Part of the Primary Auxiliary Building missile protection is provided by a missile shield door (door A-35-5A) that protects against externally generated missiles, like those that could be generated during a tornado.

On June 11, 2023, while in Mode 1, plant personnel discovered that door A-35-5A was not closed and latched, and not open under appropriate administrative controls. With door A-35-5A not in a closed and latched position, or under appropriate administrative controls as detailed in procedure 1/2-ADM-2021, the missile shield function of the Primary Auxiliary Building was determined to be degraded, and the primary CCW pumps were declared inoperable. Upon discovery, the door was immediately closed and latched, restoring the missile shield protection function of the door.

The licensee determined that the door was opened prior to the start of the Unit 2 refueling outage, which began on April 7, 2023, to allow for movement of material through the door by the Radiation Protection department. The opening of the door was controlled in accordance with 1/2-ADM-2021, which requires, in part, that equipment required to shut the door is staged, the work group is briefed that the door shall be shut and latched at the end of the work period, and that a narrative log entry is made by the Operations department detailing the door status. Following completion of the work activity, the controlling work group is required to notify Operations that the door is shut and latched, and Operations is required to make a narrative log entry that the door is shut.

Following the movement of material through the door by Radiation Protection staff, a second narrative log entry was made stating that Operations support staff was moving equipment through the door. The door remained open for the duration of the outage until it was discovered open on June 11, 2023 during Mode 1 operation. The licensee determined that the Operations support staff believed that the Radiation Protection group still had overall control for the door and thus administrative controls in 1/2-ADM-2021 were not maintained.

The administrative requirements in 1/2-ADM-2021, including those that require a positive notification to Operations that the door is closed and latched, and that the door is closed and latched prior to moving from Mode 5 to Mode 4, were not followed.

Corrective Actions: The licensee immediately closed and latched the door, wrote a condition report, and submitted an eight hour Emergency Notification System report in accordance with 10 CFR 50.72, Immediate notification requirements for operating nuclear power reactors, for any event or condition that at the time of discovery could have prevented the fulfillment of the safety function of structures or systems that are needed to remove residual heat

[50.72(b)(3)(v)(B)] and for the reactor being in an Unanalyzed Condition that significantly degrades plant safety [50.72(b)(3)(ii)(B)]. The licensee performed a Root Cause Evaluation and developed planned corrective actions including establishing a door closure team whenever door A-35-5A is open, development of two new procedures specific to door openings, revisions to procedure 1/2-ADM-2021, and added checks of the door status to operator round requirements.

Corrective Action References: CR 2023-04732

Performance Assessment:

Performance Deficiency: Inspectors determined that the licensees failure to follow the requirements of procedure 1/2-ADM-2021 was a performance deficiency. Specifically, the controlling work group did not close and latch door A-35-5A after completion of the work activity or give a positive report to Operations that the door was closed and latched.

Additionally, a narrative log entry was not made and carried over to signify that the door was open in Mode 5 and must be shut prior to transition to Mode 4.

Screening: The inspectors determined 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 cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, with door A-35-5A not in a closed and latched position, the CCW pumps were declared inoperable and could have affected the availability of cooling water to allow for residual heat removal.

Significance: The inspectors assessed the significance of the finding using Detailed Risk Evaluation. The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors used Exhibit 2 and determined that the finding represented a loss of the PRA function of one train of a multi-train TS system for greater than its TS allowed outage time (Exhibit 2, Question 3 answered "Yes") and required a detailed risk evaluation.

A Region I senior reactor analyst performed the detailed risk evaluation and estimated the increase in core damage frequency associated with this performance deficiency to be below 1E-7/yr. or of very low safety significance (Green). The analyst also reviewed the licensees risk assessment, which applied an Electric Power Research Institute NP-768 methodology to predict the risk posed to a nuclear plant by tornado-generated missiles. The method evaluates potential wind fields, missile injection and transportation, missile impact velocities and potential damage to structures. PRA-BV2-23-003-R00, "Risk Determination for Open Auxiliary Building Missile Door A-34-5A," concluded an issue of very low safety significance with a core damage frequency of 2.9E-9/yr with a bounding sensitivity of 8.3E-9/yr.

The analyst used two independent methods to evaluate the impact of the loss of control of the Auxiliary Building Missile Door. The first method calculated the Tornado Missile Strike Probability (Pms) for the missile door, A-34-5A. This method is described in NUREG/CR-4710 and has previously been used by other nuclear power utilities to calculate the missile strike probabilities in their probabilistic risk assessments. Additionally, the method was referenced in a 1995 safety evaluation performed for a nuclear power plant tornado missile hazard analysis. However, this is being used as a bounding PRA technique within the significance determination process (SDP) and does not support any licensing bases impacts or conclusions.

Based on NUREG/CR-4710, Pms is defined as follows: Pms= A (the area of the target - the A-34-5A missile door opening) x Nm (the number of missiles) x Psi - Greek letter representing the tornado missile impact parameter. This impact parameter is defined as the probability of impact/missile/unit target area/tornado point strike frequency. This value is normalized based on the size of the targets, the relative Fujita-scale distribution in the region surrounding the site, and parameters associated with potential missiles in the area. When normalizing tornado intensity data for two power plants (reference: Regulatory Guide 1.76), it was found the relative Fujita-scale distribution between the regions does not have a significant effect on this value.

The Psi, tornado missile impact parameter, for a small target (i.e., door) applies the NUREG 4710 method using a distribution for exposure between low, medium and high. For this door, the analyst determined the best estimate value to be 2.85E-10 per missile/per square foot of target area/per tornado point strike frequency. Sensitivities applied to this number did not impact the risk conclusion.

The assumption applied in this evaluation for the number of missiles onsite used data from existing analysis previously performed for other sites. The analyst assumed the maximum number of missiles (taken from a 2-Unit pressurized water reactor (PWR) site) which considers missiles within 1 mile. The average number of missiles used in these evaluations is 69,000, however 100,000 missiles will be used as a bounding value.

The Beaver Valley Standardized Plant Analysis Risk (SPAR) model, version 8.82, uses six tornado initiating event bins for tornado strength (wind speed) and frequency. An enhanced Fujita (EF) Intensity Scale (wind speed range) implements tornado initiating events for EF2, (111-135 miles per hour (mph)), EF3 (136-165 mph) and E4 and above (greater than 200 mph). The model includes binning which represents point strike probability and life-line terms.

The latter is included because if a structure is large enough, the probability of being struck by a tornado is greater than that based on the tornado dimensions. The data neglects F0 and F1 tornadoes due to light or moderate damage assumed. The summation of all the binning is tornado frequencies of a nominal 5E-5/yr in the present SPAR model. The licensees analysis included a Bayesian approach which updates historical averages near the site but also included lower intensity tornadoes for conservatism which resulted in an annualized tornado frequency of 1.66E-4/yr for the Beaver Valley site. This frequency was used in the licensees evaluation.

The core damage frequency effect of the degraded condition would be represented by the calculated tornado missile strike probability for the target multiplied by the annualized site tornado frequency. Based on the data, the Pms would be equal to: The Area of the target (96 square feet for the door) x 100,000 missiles assumed near the site (conservative number)and the missile impact parameter, Psi of 2.85E-10 per missile/per square foot of target area.

This results in a

.002 7 value. The annualized frequency of a tornado taken from the SPAR

model and NUREG/CR-4461, Revision 2, Tornado Climatology of the Contiguous United States was determined to be 5E-5/yr.

When the tornado frequency is multiplied by the tornado missile strike probability the result is the frequency of a missile generated from a tornado causing impact through the target door on the safety-related target of concern. This was 1.4E-7/yr for this degraded case. This was the frequency for the year that the CCW trains would be assumed damaged due to a tornado strike. This failure of the CCW system would then need to be assessed for a resultant increase in conditional core damage probability (CCDP). However, for the sake of conservatism and simplicity, this analysis assumes a CCDP probability of 1.0, or if the CCW system fails there will be certain core damage. When applying the approximate two-month exposure time from April 6, 2023 until June 11, 2023, the final result was a delta core damage frequency/yr increase in the low E-8/yr, or of very low safety significance. If the higher value of 1.66E-4/yr for tornado frequency was used it would still result in a high E-8/yr. result. The analyst noted that the CCDP assumption of 1.0 bounds the potential that there would be notably more risk during the timeframe of the refueling outage, due in part to the importance of CCW for decay heat removal and residual heat removal system support.

The analyst performed a second independent quantitative method for evaluating this degraded condition. A test/limited use model had recently been developed for the Watts Bar station including shutdown postulated initiating events. This was determined to be a representative PWR model and was used as a surrogate for the Beaver Valley Unit for the time CCW was degraded during the refueling outage. The shutdown model was used to assess an actual incremental core damage probability change due to the assumed complete loss of the CCW system because CCW is a key system in supporting decay heat removal.

The shutdown loss-of-offsite power and shutdown Loss of residual heat removal event trees were solved failing all offsite power recoveries and the turbine driven feedwater pump to best represent what a tornado condition would represent during an outage. The initiating Shutdown events were set to a frequency of 1.0 in a change set. The CCDPs were solved for a base case and condition case (CCW failed) and then the delta CCDP was multiplied by the tornado frequencies per year. The delta CCDP was 4E-3. When multiplied by the tornado bin frequencies and by the exposure time the resultant increase in core damage frequency/yr was 1.6E-8 for the one month refueling exposure time. This bounded the at-power additional one month exposure time. The diverse and flexible coping strategies (FLEX) credit is not applied for the refueling condition, as the FLEX strategy assumes Phase 1 equipment is available, which may not apply in an outage. The analyst noted the second method completely assumes a missile strike probability of 1.0 (conservative) but calculates an actual CCDP change, where the first method uses a CCDP of 1.0 (conservative) and calculates a missile strike probability. Given the independent methods used along with the licensees independent evaluation, this issue was determined to be of very low safety significance. The increase in core damage frequency result of below 1E-7 indicates large early release frequency would have no impact on this final determination.

Cross-Cutting Aspect: H.4 - Teamwork: Individuals and work groups communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety is maintained. Specifically, the Radiation Protection and Operations department did not maintain clear and effective communication regarding the status of door A-35-5A and who had responsibility to close and latch it following completion of work activities that required it to be open.

Enforcement:

Violation: 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawings,"

requires, in part, that "Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."

Contrary to the above, from April 6, 2023 until June 11, 2023, the licensee did not implement the requirements of procedure 1/2-ADM-2021. Specifically, 1/2-ADM-2021 requires, in part, that while in Mode 1, the controlling work group shall close and latch door A-35-5A upon completion of work and shall notify the Operations department that the door is shut and latched, and the Operations department shall make a narrative log entry that the door is shut.

In Mode 5, 1/2-ADM-2021 requires, in part, that when door A-35-5A is open, a narrative log entry shall be made, and carried over, that the door is open, material is staged, and that the door shall be shut and latched prior to entry into Mode 4.

While in Mode 1, the controlling work group did not close and latch the door and did not notify the Operations department that the door was shut and latched, and while in Mode 5, the Operations department did not make or carry over a log entry that door A-35-5A was open and must be shut prior to entry into Mode 4.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to perform Preventive Maintenance (PM) Replacement strategy Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems

Green NCV 05000412,05000334/2023004-02 Open/Closed

None 71152A A self-revealed Green finding and associated non-cited violation (NCV) of TS 5.4.1, Administrative Controls - Procedures, was identified when Energy Harbor failed to replace an aged circuit card, 2HVD-TKC21B, as required by the licensees PM replacement strategy. Specifically, Energy Harbor failed to replace circuit card 2HVD-TKC21B within the 15 year PM replacement schedule as required by licensee procedure, NORM-ER-3881, "I&C Circuit Cards - Westinghouse," Revision 4. Subsequently, the circuit card failed which required the 2-2 emergency diesel generator (EDG) to be declared inoperable.

Description:

On August 9, 2022, Beaver Valley Unit 2 received unexpected A4-7H PRI/SEC Process Rack Power Supply Failure in the control room. Upon investigation, the licensee identified that Westinghouse 7300 Tracker Driver NTD Secondary Process Rack Card CF3 Card 27 for 2HVD-TKC21B, EDG room B primary inlet air temperature controller, did not have a power supply light. The card failure caused 2HVD-MOD22B, 2-2 EDG room air intake damper to fail full shut, and 2HVD-MOD23B, 2-2 EDG room air recirculation damper to fail full open, therefore configuring the 2-2 EDG supply ventilation in full recirculation mode. Since the outdoor and return air dampers had failed, they could not modulate to maintain air temperature and, EDG 2-2 was declared inoperable.

Energy Harbor developed procedures for PM strategies including circuit cards. Specifically, NORM-ER-3381A, "I&C Circuit Cards - Westinghouse," Revision 4, which provided the required replacement frequency for instrument & controls (I&C) circuit cards, required the licensee to replace Westinghouse 7300 Process I&C NTD critical circuit card every 15 years.

2HVD-TKC21B circuit card was in service since 2003. The circuit card was 19 years old at the time of its failure. However, prior to the unexpected 2HVD-TKC21B circuit card failure, it was erroneously classified as a non-critical circuit card. Therefore, 2HVD-TKC21B circuit card was not replaced within its required replacement schedule due to that misclassification.

Based on PRA analysis for damper 2HVD-MOD22B, 2-2 EDG room air intake damper was classified as critical for its function to open and support the operation of EDG 2-2. 2HVD-TKC21B circuit card controlled the opening of the damper; therefore, it should have been classified as critical because it was within the component boundary of the damper for PRA purposes. If the circuit card was correctly classified, it would have been replaced during its required replacement schedule, which would have prevented the circuit card from exceeding its proceduralized service life. After the failure of 2HVD-TKC21B circuit card, Energy Harbor reclassified the circuit card from non-critical to critical.

Corrective Actions: Energy Harbor documented the performance deficiency in the site corrective action program to correct the deficiency. The licensees corrective actions included the replacement of the failed circuit card and reclassification of 2HVD-TKC21B circuit card as a critical component.

Corrective Action References: CR-2023-08586

Performance Assessment:

Performance Deficiency: Energy Harbor's failure to replace the 2HVD-TKC21B circuit card within its required PM replacement schedule was a performance deficiency. NORM-ER-3381A, "I&C Circuit Cards - Westinghouse," Revision 4, required the licensee to replace the Westinghouse 7300 Process I&C NTD critical circuit card on a 15 year frequency.

This deficiency resulted in the aged circuit card to run until it exceeded its service life and subsequently led to the 2-2 EDG to be declared inoperable.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, Energy Harbors failure to replace circuit card 2HVD-TKC21B within its appropriate PM replacement schedule resulted in the circuit card to exceed its service life, which could have been prevented if the circuit card was replaced within its required replacement frequency of 15 years.

Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The Inspector used IMC 0609, Exhibit 2, for Mitigating Systems, sub-section Mitigating SSCs and PRA Functionality (except Reactivity Control Systems) and determined the finding to screen GREEN.

Cross-Cutting Aspect: None (not present performance)

Enforcement:

Violation: Beaver Valley Unit 2 TS 5.4.1a, "Procedures," states that written procedures shall be established, implemented, and maintained covering activities referenced in Appendix A of the Regulatory Guide 1.33, Revision 2, February 1978.

Section 9.a of the Regulatory Guide 1.33, Revision 2, 1978, Appendix A, states, in part, that "Maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances."

NORM-ER-3381A, "I&C Circuit Cards - Westinghouse," Revision 4, required the licensee to replace the Westinghouse 7300 Process I&C NTD critical circuit card every 15 years.

Contrary to the above, from 2018 until 2022, Energy Harbor failed to replace 2HVD-TKC21B circuit card within the 15 year required replacement schedule as described in NORM-ER-3381A. This resulted in 2HVD-MOD22B, 2-2 EDG room air intake damper, and 2HVD-MOD23B, 2-2 EDG room air recirculation damper, to fail and subsequently rendered EDG 2-2 inoperable.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Minor Performance Deficiency 71152A Minor Performance Deficiency Associated with Inadequate Work Instructions

Minor Performance Deficiency: The inspectors identified a minor performance deficiency related to the station providing inadequate work instructions for the replacement of the main feedwater lube oil pressure relief valve 2FWS-RV205B. This issue was self-revealed when the 'B' main feedwater pump failed to start on May 19, 2023, while in Mode 3 exiting the 2R23 refueling outage. The feedwater pump trip resulted in the automatic actuation of the motor driven auxiliary feedwater pumps, as documented in LER 05000412/2023-002-00, Automatic Actuation of Auxiliary Feedwater System. The inspectors reviewed the LER and as well as the associated causal analysis under CR 2023-04187.

The station's causal analysis confirmed that the automatic actuation of the auxiliary feedwater system was an expected plant response to the 'B' main feedwater pump failing to start upon operator demand. The 'B' main feedwater pump failure to start was due to the lube oil system pressure being below the pump start permissive. The station's investigation revealed that the lube oil pressure relief valve had been replaced during the 2R23 refueling outage, and the work order provided an incorrect setpoint value. Specifically, Order 20084923 instructed technicians to set the new relief valve to 12 psig, and it referenced a setpoint document (SPD-2FWS-RV205B), which also contained a value of 12 psig. However, further investigation revealed that the vendor drawing for the lube oil system specified that the relief valve should be set to ensure a lube oil system operating pressure of 12 psig. To ensure a system operating pressure of 12 psig, the lube oil relief valve setpoint needed several psig higher.

The station implemented several corrective actions including:

(1) increasing the set point for the relief valve, which allowed the feedwater pump to be successfully started,

(2) revising the setpoint documents (SPD-2FWS-RV205B and SPD-2FWS-RV205A),

(3) updating the maintenance plan for future relief valve replacements, and

(4) performing an extent of condition review for Unit 1. The station also performed an evaluation to disable the auxiliary feedwater pump auto-start circuit when starting a main feedwater pump in Mode 3. That modification was not reviewed as part of this sample.

Screening: The inspectors determined the performance deficiency was minor. The inspectors reviewed station procedure NOP-WM-1001, "Order Planning Process," which provides the requirements for developing work packages, including PM orders. Section 4.3.12, step 1, states, in part, that "Engineering shall review the Order to validate the accuracy of all Engineering-related technical information..." The inspectors determined that the station's failure to validate the accuracy of the main feedwater pump lube oil relief valve setpoint was a performance deficiency that was reasonably within the licensee's ability to foresee and correct and should have been prevented. The inspectors screened the issue in accordance with IMC 0612, Appendix B, "Issue Screening Directions," and determined that it was not of more than minor significance. Although the improper relief valve setpoint resulted in a feedwater pump trip and auxiliary feedwater system initiation, the plant conditions at the time were such that the transient did not challenge plant stability.

Observation: Aged-Related Failure Associated with I&C Circuit Cards 71152A The inspector performed a review of Energy Harbors corrective actions associated with recently identified aged-related failures of I&C circuit cards. During the review the inspector assessed CR-2022-06115 and identified a performance deficiency associated with a self-revealed Westinghouse NTD circuit card failure. The failed card caused 2-2 EDG room air intake damper to fail close, and 2-2 EDG room air recirculation damper to fail open. As a result, EDG 2-2 was declared inoperable. The inspector screened the performance deficiency and determined it was more than minor. Subsequently, a self-revealed Green finding and associated with a NCV was issued to Energy Harbor and is discussed in the 71152A section of this report.

The inspector did not identify any other performance deficiencies during the inspection.

Observation: Review of Investigation and Corrective Actions Associated With a Credited Missile Shield Door That Was Found To Be Open Without Administrative Controls 71152A The inspectors performed a review of Energy Harbors Root Cause Evaluation and corrective actions associated with CR-2023-04732, dated June 11, 2023. The inspectors reviewed and assessed the corrective actions taken or planned to address the failure to implement the administrative controls in procedure 1/2-ADM-2021, Control of Penetrations (including HELB Doors), which led to door A-35-5A being left open during and after the most recent Unit 2 refueling outage without the appropriate controls.

The licensee determined that the root cause of the issue was that the organization does not have a clear concise process for controlling ownership and responsibility for missile doors should they need to be opened temporarily, and a direct cause where operators and RP personnel did not adequately track ownership of the door over multiday evolution. Some of the corrective actions identified included creating new procedures specific to the opening of missile barrier doors, adding more robust administrative controls to the 1/2-ADM-2021 procedure, adding the missile doors to the daily Operator tour rounds, and providing training to staff on the importance of maintaining design basis associated doors in their required positions.

After reviewing the Root Cause Evaluation and identified corrective actions, the inspectors did not identify any performance deficiencies associated with the investigation or corrective actions. A finding and associated non-cited violation associated with a failure to implement procedural requirements were identified and are discussed in the 71152A section of this report.

Minor Violation 71153 Failure to Submit Accurate Dates Associated with LER 2023-003-00

Minor Violation: The licensee submitted LER 2023-003-00 on August 8, 2023, as required by 10 CFR 50.73, "Licensee Event Report System," to report a condition prohibited by TS, an unanalyzed condition, a loss of safety function, and common cause inoperability of independent trains. The LER stated that, as a result of a missile door being left open during and subsequent to the completion of a refueling outage, the Unit 2 CCW system was inoperable from May 7, 2023 until June 11, 2023. Following inspector questions, the licensee determined that the date range of inoperability for the CCW system was in fact between May 14, 2023 (when Unit 2 entered Mode 4 upon start up following the refueling outage) until June 11, 2023 (when the door was found open and returned to the closed position).

Additionally, inspectors questioned whether the CCW system should have been declared inoperable for a period of time at the start of the refueling outage, when the door was opened under administrative control and subsequently left open without the appropriate controls in place (further details discussed in Section 71152 of this report). The licensee determined that the CCW system also should have been declared inoperable for approximately 35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br /> between the dates of April 7, 2023 and April 9, 2023, due to the door being open without the required administrative controls.

The requirements in 10 CFR 50.9, "Completeness and Accuracy of Information," state that, "Information provided to the Commission by an applicant for a license or by a licensee or information required by statute or by the Commission's regulations, orders, or license conditions to be maintained by the applicant or the licensee shall be complete and accurate in all material respects."

Contrary to the above, the licensee failed to provide accurate dates in LER 05000412/2023-003-00 associated with inoperability of the CCW system.

Screening: The inspectors determined the performance deficiency was minor. Specifically, the correct dates confirmed that the total amount of inoperability associated with the CCW system decreased, and the updated date range(s) did not adversely impede the regulatory process.

Enforcement:

The licensee has taken actions to restore compliance, including documenting the identified issues into the corrective action program. This failure to comply with 10 CFR 50.9 constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On January 17, 2024, the inspectors presented the integrated inspection results to Barry Blair, Site Vice President, and other members of the licensee staff.

• On October 5, 2023, the inspectors presented the radiological effluent technical specification inspection results to Bob Kristophel, General Plant Manager, and other members of the licensee staff.

• On November 16, 2023, the inspectors presented the failure to perform preventive maintenance replacement strategy annual follow-up problem identification and resolution inspection results to Bob Kristophel, General Plant Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71152A

Corrective Action

Documents

CR-2022-06115

CR-2023-04187

Corrective Action

Documents

Resulting from

Inspection

CR-2023-08586

Miscellaneous

CAL-WHS-MD-

000002

Extreme Wind/Tornado/Tornado Missile Hazard Analysis

NUREG/CR-4461

Tornado Climatology of the Contiguous United States

NUREG/CR-4710

Shutdown Decay Heat Removal Analysis of a Combustion

Engineering 2-Loop Pressurized Water Reactor Case Study

SPD-2FWS-

RV205B

Unit 2 Main Feedwater Pump Lube Oil Relief Valve Setpoint

Document

06/2002

SPD-2FWS-

RV205B

Unit 2 Main Feedwater Pump Lube Oil Relief Valve Setpoint

Document

07/2023

Procedures

NOBP-LP-2011

Cause Analysis

NOP-LP-2001

Corrective Action Program

NORM-ER-3381A I&C Circuit Cards - Westinghouse

71153

Corrective Action

Documents

Resulting from

Inspection

23-08834

23-09126