IR 05000334/2023011

Age-Related Degradation Inspection Report 05000334/2023011 and 05000412/2023011

ML23338A024
Person / Time
Site:	Beaver Valley
Issue date:	12/04/2023
From:	Mel Gray Division of Operating Reactors
To:	Blair B Energy Harbor Nuclear Corp
References
IR 2023011
Download: ML23338A024 (1)

Text

December 4, 2023

SUBJECT:

BEAVER VALLEY POWER STATION, UNITS 1 AND 2 - AGE-RELATED DEGRADATION INSPECTION REPORT 05000334/2023011 AND 05000412/2023011

Dear Barry Blair:

On November 2, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Beaver Valley Power Station, Units 1 and 2 and discussed the results of this inspection with Robert Kristophel, General Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation 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, Mel Gray, Chief Engineering Branch 1 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:

05000334/2023011 and 05000412/2023011

Licensee:

Energy Harbor Nuclear Corp.

Facility:

Beaver Valley Power Station, Units 1 and 2

Location:

Shippingport, PA

Inspection Dates:

October 16, 2023 to November 02, 2023

Inspectors:

N. Floyd, Senior Reactor Inspector

K. Mangan, Senior Reactor Inspector

B. Pinson, Senior Reactor Inspector

Approved By:

Mel K. Gray, Chief

Engineering Branch 1

Division of Operating Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an age-related degradation 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

Failure to Take Actions to Identify and Correct Degradation of the Unit 1 Primary Plant Demineralized Water Storage Tank Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000334/2023011-01 Open/Closed

[H.12] - Avoid Complacency 71111.21N.

The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, because the licensee did not take actions to identify and correct degradation of the Unit 1 primary plant demineralized water storage tank (PPDWST).

Additional Tracking Items

None.

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 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

71111.21N.04 - Age-Related Degradation Age-Related Focused Engineering Inspection (section 03.01)

The inspectors selected a sample of components and structures to verify that engineering performance and maintenance activities addressed age-related degradation and that problems were appropriately identified, addressed, and corrected.

Samples were selected considering risk insights and the potential for degradation. Specifically, the inspectors selected samples that were risk-significant and either had indications of age-related degradation or were exposed to environments that could cause age-related degradation.

The inspectors considered site-specific and industry-wide operating experience to identify samples and included both active and passive sub-components within each component or structure.

For each selected sample listed below, the inspectors reviewed the licensees engineering and maintenance activities credited to address age-related degradation to assess whether they were being performed using applicable standards and procedures, evaluated against appropriate acceptance criteria, and that maintenance and condition monitoring was completed at an appropriate interval. The inspectors also assessed whether issues identified during licensee activities were being entered into and addressed by the applicable station processes including the corrective action program, and whether periodic assessments of maintenance effectiveness and operating experience were being completed, including feedback and process adjustments.

(1) ABB HK circuit breakers installed in Units 1 and 2

(2) O-ring shaft seals installed in Unit 2 chemical volume control system and safety injection system weighted arm check valves

(3) ITE-50D relays installed in Unit 2 4160V bus 2AE and 2DF

(4) Units 1 and 2 refueling water storage tank level transmitters

(5) Units 1 and 2 river water / service water expansion joints

(6) Unit 1 emergency diesel generator 1-1 jacket water cooling subsystem

(7) Unit 1 emergency diesel generator 1-2 fuel oil subsystem

(8) Unit 1 residual heat removal return isolation valve 720A

(9) Unit 1 primary plant demineralized water storage tank TK-10

(10) Unit 1 turbine-driven auxiliary feedwater pump lube oil cooling subsystem

(11) Unit 2 charging pump 21B lube oil temperature controller TC150B and switch TSH150B

(12) Unit 2 protection relays on 480V bus 2N

(13) Unit 2 service water pump 21B

(14) Unit 2 steam generator B and C atmospheric dump valve close speed control valves PCV101B / C

(15) Unit 2 turbine-driven auxiliary feedwater steam line isolation solenoid operated valves SOV105A - F

INSPECTION RESULTS

Failure to Take Actions to Identify and Correct Degradation of the Unit 1 Primary Plant Demineralized Water Storage Tank Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems

Green NCV 05000334/2023011-01 Open/Closed

[H.12] - Avoid Complacency 71111.21N.0 The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, because the licensee did not take actions to identify and correct degradation of the Unit 1 primary plant demineralized water storage tank (PPDWST).

Description:

The inspectors reviewed the monitoring results and corrective action program inputs for the Unit 1 PPDWST, designated as 1WT-TK-10, to assess the licensees performance to address age-related degradation. The inspectors selected this tank for review because of the high risk significance reflected in the Beaver Valley probabilistic risk models.

As described in the Beaver Valley Unit 1 UFSAR, the PPDWST is the safety-related water supply for the steam generator auxiliary feedwater pumps which provide a heat sink function to cooldown the plant during a loss of normal power. The tank was constructed using carbon steel with a coating applied to the interior and exterior for corrosion protection. This tank was in-scope for license renewal to extend the operating license to 60 years and was subject to one-time inspections of the tank interior and inaccessible bottom surfaces as well as periodic inspections through the external surfaces monitoring program. The inspectors noted the licensee credited and committed to a one-time inspection to verify there were no aging effects occurring on the tank. In response to request for additional information B.2.30-1, the licensee stated the tank was located within a reinforced concrete structure that provided additional protection from the outside environment and that the one-time inspection program was also assigned to confirm the absence of aging effects on the external bottom surface of the tank.

The inspectors performed walkdowns of the PPDWST and identified degraded coating and corrosion along the base of the tank exterior, corrosion on the tank supports, and standing water inside the tank enclosure building. The inspectors also reviewed several condition reports dating back to 2005 that identified standing water in the enclosure building, including instances that submerged portions of the tank base perimeter. The licensee determined the cause of the water inside the building was due to a weephole (designed to drain water in the event of tank overfill) at the bottom of the building wall which provided a flow path for external water to enter the building. The inspectors did not observe engineering features such as grout or sealant at the base of the tank to prevent water intrusion under the tank. The inspectors noted that engineering features and building protection from the outside environment were part of the basis to conclude that there were no aging management mechanisms present on the external bottom surface of the tank in the license renewal response. In addition, the inspectors noted that the external surfaces monitoring program was credited to identify and manage corrosion on the tank exterior; however, the licensee did not have a record of condition reports or work orders that identified the corrosion on the tank exterior or tank supports observed by the inspectors. Based on discussions with licensee staff, the inspectors ascertained that engineers did not walk down this area as part of the external surfaces program and alternatively relied on routine operator tours to monitor the tank. The inspectors determined the licensees failure to identify and correct degradation on the tank exterior at the interface of the tank base and concrete floor following multiple instances of standing water in the tank enclosure room and in contact with the tank was a performance deficiency.

The inspectors reviewed the results of the internal inspections (visual and volumetric testing)under WO 200513534, dated October 12, 2013, to meet the one-time inspection license renewal commitment for the PPDWST. The inspectors noted that licensee staff identified the internal coating had not remained adhered in some locations and that there were indications of corrosion internal to the tank. Licensee staff entered these deficiencies into the corrective action program under CR-2013-16289. The inspectors reviewed the corrective actions to repair and recoat the tank interior surfaces under ECP 15-0020-001 and WO 200582291 and noted the actions were completed in May 2015. However, the inspectors observed that the licensee did not perform corrective actions to add or evaluate aging management activities (e.g., periodic internal examination to monitor coating condition) following the identification of aging effects on the tank. The inspectors also observed the licensee did not consider the potential long-term effects of standing water in contact with the tank bottom surface. The inspectors determined the failure to perform actions to monitor the tank was also a related performance deficiency.

Licensee procedure NOP-LP-2001, Corrective Action Program, Step 4.3.2, states CRs shall be initiated for any issue, event, defect, characteristic that could credibly impact nuclear safety, personnel safety, plant reliability or compliance with federal, state or local regulations.

Step 4.4.1.12 states IF the condition relates to a long-term degradation of passive structures or components that may be applicable to components in similar material/environment combinations THEN, check the box for an Aging Management Evaluation (AME). The inspectors identified two examples of issues, discussed above, where the licensee did not initiate a condition report to identify the aging issue, evaluate the aging management program, or implement corrective action to monitor the tank. The inspectors noted that volumetric testing results of the tank bottom in 2013 did not identify significant degradation (i.e., all results above minimum wall thickness). The licensee determined the tank remained operable based on results of previous wall thickness measurements of the tank bottom and adjacent carbon steel piping showing degradation was not rapid and because there were no active tank leaks (i.e., wetting or loss of level).

Corrective Actions: Licensee staff entered the issue into their corrective action program under CR-2023-08141 and generated Notification 601424545 to clean off the corrosion, examine the component condition, and recoat the bottom edge of the tank where it meets the floor.

The licensee also generated a task to internally inspect the tank under Maintenance Plan 258517.

Corrective Action References: CR-2023-08141 and CR-2023-08366

Performance Assessment:

Performance Deficiency: The inspectors identified two examples of corrective action issues associated with the licensees performance to monitor the PPDWST for degradation.

Specifically,

(1) the licensee did not identity or correct degradation on the tank exterior at the interface of the tank base and concrete floor following standing water in the tank enclosure room and in contact with the tank, and

(2) the licensee had not planned or implemented corrective actions to monitor the condition of the tank interior or inaccessible bottom surfaces following the identification of internal tank coating failure during the one-time inspections.

Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, continued degradation of the tank without monitoring or a supporting evaluation could lead to leakage, degraded supports and impact the heat sink safety function.

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 was of very low safety significance (Green) because the tank has been currently demonstrated to maintain its operability and/or probabilistic risk assessment functionality.

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. Specifically, the licensee staff did not recognize the impact of repeated water infiltration impacts on the tank nor evaluate the aging management assumptions.

Enforcement:

Violation: 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to assure that conditions adverse to quality, such as deficiencies, defective material, and non-conformances are promptly identified and corrected.

Contrary to the above, from at least 2013 to present, Beaver Valley staff did not establish measures to identify and correct conditions adverse to quality (i.e., degradation due to coating deficiencies and corrosion) associated with the PPDWST. Specifically, the licensee did not implement corrective actions to appropriately monitor the tank following identification of conditions that would degrade the tank.

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

EXIT MEETINGS AND DEBRIEFS

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

• On November 2, 2023, the inspectors presented the age-related degradation inspection results to Robert Kristophel, General Plant Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.21N.04 Corrective Action

Documents

CR 2022-06082

CR 2022-07271

CR 2022-07945

CR-2012-14194

CR-2014-12483

CR-2015-04120

CR-2020-06195

CR-2021-07348

CR-2022-06989

CR-2023-02333

CR-2023-02442

CR-G203-2011-

90641

Corrective Action

Documents

Resulting from

Inspection

CR-2023-07851

CR-2023-07858

CR-2023-07959

CR-2023-08141

CR-2023-08190

CR-2023-08366

CR-2023-08367

CR-2023-08368

Drawings

31662-01, 10-

1500

Back Weighted Check Valve Stuffing Box Modification

Revision 1

8700-RV-34A

Demineralized Water Storage Tank WT-TK-10

Revision 5

Engineering

Changes

ECP 15-0020-

001

Recoat Tank 1WT-TK-10 Interior

Revision 0

Miscellaneous

BVPS Maintenance Rule Program Structural Monitoring

Inspections of BVPS Structures -Fourth Five Year Cycle

Report -2017

09/29/2021

2BVS-304

Specification for 4160V Metal Clad Switchgear

01/21/1987

LRBV-PED-

XI.M36

Beaver Valley External Surfaces Monitoring Program (Unit

and Unit 2)

Revision 6

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

MAP-2BV-719

Electrical Equipment Qualification Maintenance

Assessment

Revision 18

ML081280490

Reply to Request for Additional Information for the Review

of the Beaver Valley Power Station, Units 1 and 2,

License Renewal Application (TAC Nos. MD6593 and

MD6594)

05/05/2008

NORM-ER-3103

Low and Medium Voltage Switchgear and Motor Control

Centers

Revision 9

NORM-ER-3115

FENOC Protective Relays

Revision 9

NORM-ER-3420

Energy Harbor - Emergency Diesel Generator

Revision 5

NORM-ER-3605

Valve - Solenoid Operated

Revision 4

NORM-ER-3608

Valve - Hydraulic Operated

Revision 2

NORM-ER-3707

Tanks

Revision 2

Procedures

1/2-ADM-2016

General Area Structural Inspection

Revision 7

1/2-ADM-2098

System Walkdowns

Revision 3

2OST-1.10J

Cold Shutdown Valve Exercise Test (Part J) Weighted

Arm Check Valves

Revision 8

Work Orders

200014720

200148051

200371069

200541199

200542356

200603149

200643918

200652786

200663050

200698225

200698229

200743902

200863945

200879283