IR 05000334/2024003

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Integrated Inspection Report 05000334/2024003 & 05000412/2024003
ML24318C435
Person / Time
Site: Beaver Valley
Issue date: 11/13/2024
From: Matt Young
Division of Operating Reactors
To: Blair B
Vistra Operations Company
References
EPID I-2024-003-0034 IR 2024003
Download: ML24318C435 (1)


Text

November 13, 2024

SUBJECT:

BEAVER VALLEY POWER STATION, UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000334/2024003 AND 05000412/2024003

Dear Barry Blair:

On September 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Beaver Valley Power Station, Units 1 and 2. On October 9, 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.

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. 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:

DPR-66 and NPF-73

Report Numbers:

05000334/2024003 and 05000412/2024003

Enterprise Identifier: I-2024-003-0034

Licensee:

Vistra Operations Company, LLC

Facility:

Beaver Valley Power Station, Units 1 and 2

Location:

Shippingport, PA

Inspection Dates:

July 1, 2024 to September 30, 2024

Inspectors:

N. Day, Senior Resident Inspector

A. Nugent, Resident Inspector

J. Cunningham, Reactor Inspector

S. Elkhiamy, Branch Chief

S. Lichvar, Technical Assistant

T. Marshall, Cyber Security Specialist

A. Nugent, Resident Inspector

B. Pinson, Senior Reactor 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

Unplanned Inoperability of the 'A' Train of offsite power due to inappropriately torqued

charging spring motor fasteners

Cornerstone

Significance

Cross-Cutting

Aspect

Report

Section

Initiating Events

Green

NCV 05000334/2024003-01

Open/Closed

None (NPP)

71152A

A self-revealed Green finding and associated non-cited violation of Technical Specification

Limited Condition for Operation 3.8.1 was identified when breaker 4KVS-1A-1A4(ACB-

41A) failed to close.

Additional Tracking Items

Type

Issue Number

Title

Report Section

Status

LER 05000334/2024-001-00

LER 2024-001-00 for Beaver

Valley Power Station, Unit 1,

Offsite AC Power Source

Inoperable due to Breaker

Failure Resulting in

Condition Prohibited by

Technical Specification

71153

Closed

PLANT STATUS

Units 1 and 2 operated at or near rated thermal power for the entire 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 DProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 2515,</br></br>Appendix D" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., 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)

Unit 2, low head safety injection system train 'A', August 14, 2024

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 2, 4KVS-2AE emergency switchgear, 2-1 battery room, and 2-3 battery room,

July 24, 2024

(2)

Unit 2, 4KVS-2DF emergency switchgear, 2-2 battery room, and 2-4 battery room,

July 24, 2024

(3)

Unit 2, 2-1 emergency diesel generator room, 2-2 emergency diesel generator room,

August 13, 2024

(4)

Unit 2, turbine building feedwater pump areas, August 28, 2024

71111.06 - Flood Protection Measures

Flooding Sample (IP Section 03.01) (1 Sample)

(1)

The inspectors evaluated external flooding mitigation protections in the intake

structure cable tray manholes on August 21, 2024.

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 Unit 2 'A' service water system full flow testing on August 27, 2024.

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

(1)

The inspectors observed and evaluated operator response to a simulated pressurizer

level transients in the Unit 1 simulator on August 15, 2024.

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)

Station switchyard and high voltage distribution system

(2)

Station 4kv distribution system

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (1 Sample)

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, high head safety injection pump 'C' hand switch at power replacement,

August 6, 2024

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the

following operability determinations and functionality assessments:

(1)

Unit 2, process rack 8 power supply functionality per operational decision-making

instruction BV2-24-3, August 14, 2024

(2)

Unit 1, surveillance requirement 3.2.1.2 due to data point issue described in Condition

Report (CR) 2024-07211 and CR 2024-07291, September 10, 2024

(3)

Unit 1, 1-1 emergency diesel generator operability determination following associated

fuel transfer positive displacement pump functionality assessment per CR 2024-

07484 and Engineering Evaluation Report 601467155, September 23, 2024

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)

The inspectors evaluated the following temporary or permanent modifications:

(1)

Unit 1, 'C' charging pump hand switch temporary modification using engineering

change 24-1132-001 and Work Order (WO) 200951451 on August 20, 2024

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 Sample)

(1)

Unit 1, high head safety injection pump 'B' valve work post-maintenance test run per

1OST-7.5, August 13, 2024

Surveillance Testing (IP Section 03.01) (5 Samples)

(1)

Unit 2, turbine driven auxiliary feedwater pump quarterly performance test,

July 2, 2024

(2)

Unit 2, motor driven auxiliary feedwater pump 'B' quarterly performance test per

2OST-24.3, July 23, 2024

(3)

Unit 2, 4KV emergency bus degraded voltage relay biennial calibration per

2MSP-36.37-E, July 24, 2024

(4)

Unit 2, steam generator 'C' water level narrow range channel III calibration per

2MSP-24.23-I, July 30, 2024

(5)

Unit 1, low head safety injection pump 'A' test per 1OST-11.1A, September 4, 2024

Inservice Testing (IST) (IP Section 03.01) (1 Sample)

(1)

Unit 1, low head safety injection pump 'B' surveillance per 1OST-11.2, July 22, 2024

Diverse and Flexible Coping Strategies (FLEX) Testing (IP Section 03.02) (1 Sample)

(1)

Flex makeup pump, FLEX-MU-PP-002 per 1/2OST-76.12, August 7, 2024

71114.06 - Drill Evaluation

Additional Drill and/or Training Evolution (2 Samples)

The inspectors evaluated:

(1)

White team training/focused area drill, August 8, 2024

(2)

Blue team integrated drill, September 19, 2024

RADIATION SAFETY

71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &

Transportation

Radioactive Material Storage (IP Section 03.01) (2 Samples)

The inspectors evaluated the licensees performance in controlling, labeling and securing

the following radioactive materials:

(1)

Radioactive material storage area in the west yard

(2)

Radioactive material stored in the Interim Waste Storage Facility

Radioactive Waste System Walkdown (IP Section 03.02) (2 Samples)

The inspectors walked down the following accessible portions of the solid radioactive waste

systems and evaluated system configuration and functionality:

(1)

Unit 1, Solid Radioactive Waste, High Integrity Container (HIC) truck bay loading area

(2)

Unit 2, Dry Drum Storage Area and truck bay loading area

Waste Characterization and Classification (IP Section 03.03) (2 Samples)

The inspectors evaluated the following characterization and classification of radioactive

waste:

(1)

Shipment B-5454 2 sea-land vans of Type A radioactive material

(2)

Shipment B-5455 spent resin class C radioactive material

Shipping Records (IP Section 03.05) (4 Samples)

The inspectors evaluated the following non-excepted radioactive material shipments through

a record review:

(1)

Shipment #B-5261 HIC Spent Resin Class B, July 20, 2022

(2)

Shipment #B-5378 7-55 gallon high radiation drums class A/B, June 15, 2023

(3)

Shipment #B-5377 14-55 gallon drums class A waste, October 23, 2023

(4)

Shipment #B-5457 Metal Cask/HIC Spent Resin class B material, June 10, 2024

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)

(1)

Unit 1, July 1, 2023, through June 30, 2024

(2)

Unit 2, July 1, 2023, through June 30, 2024

MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)

(1)

Unit 1, July 1, 2023, through June 30, 2024

(2)

Unit 2, July 1, 2023, through June 30, 2024

MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)

(1)

Unit 1, July 1, 2023, through June 30, 2024

(2)

Unit 2, July 1, 2023, through June 30, 2024

71152A - Annual Follow-up Problem Identification and Resolution

Annual Follow-up of Selected Issues (Section 03.03) (2 Samples)

The inspectors reviewed the licensees implementation of its corrective action program

related to the following issues:

(1)

Unit 1, offsite power supply breaker 41A failure as discussed in CR 2024-03128

(2)

Selected non-compliances with the Beaver Valley cybersecurity plan. The results of

this review are documented in NRC Inspection Report 05000334/2024403 and

05000412/2024403 due to the information being security-related and non-publicly

available.

71152S - Semiannual Trend Problem Identification and Resolution

Semiannual Trend Review (Section 03.02) (1 Sample)

(1)

The inspectors reviewed the licensees corrective action program to identify potential

trends in intake structure door seals that might be indicative of a more significant

safety issue, per CR 2024-06936 on September 30, 2024.

71153 - Follow Up of Events and Notices of Enforcement Discretion

Event Report (IP Section 03.02) (1 Sample)

The inspectors evaluated the following licensees event reporting determinations to ensure it

complied with reporting requirements.

(1)

Licensee Event Report (LER) 05000334/2024-001-00. Offsite AC Power Source

Inoperable Due to Breaker Failure Resulting In Condition Prohibited By Technical

Specification (ADAMS Accession No. ML24162A104). Due to the past operability

review that was performed, the licensee determined that a condition prohibited by

technical specifications existed. The inspectors documented a Green non-cited

violation due to the failure to meet technical specification limited condition for

operation which is documented in the results section of 71152A of this report. This

LER is closed.

INSPECTION RESULTS

Unplanned Inoperability of the 'A' Train of offsite power due to inappropriately torqued

charging spring motor fasteners

Cornerstone

Significance

Cross-Cutting

Aspect

Report

Section

Initiating Events

Green

NCV 05000334/2024003-01

Open/Closed

None (NPP)

71152A

A self-revealed Green finding and associated non-cited violation of Technical Specification

Limited Condition for Operation 3.8.1 was identified when breaker 4KVS-1A-1A4(ACB-41A)

failed to close.

Description: On April 10, 2024, during swapping of 4KV normal busses from unit station

service transformer to system station service transformer supply in accordance with licensee

procedure 1OM-36.4B, breaker 4KVS-1A-1A4 (ACB-41A) failed to close. The licensee

declared the 'A' train of offsite power inoperable and unavailable and performed

troubleshooting of the issue, ultimately replacing the breaker and restoring the 'A' train of

offsite power to operable status on April 11, 2024. During the disassembly of the failed

breaker, it was determined that one fastener was completely removed and two were not

appropriately torqued. The licensee promptly entered this issue in their corrective action

program as CR-2024-03128. The licensee performed a past operability determination and

determined the breaker was unable to perform its function from February 20, 2024, to

April 11, 2024, due to the charging motor failure.

The licensee performed a causal evaluation that determined that the failure of the charging

motor was attributed to the fasteners not being fully torqued when they were installed in 2019.

Specifically, on April 25, 2019, during performance of WO 200619449, technicians replaced

the charging motor on the Unit 1 A system station service transformer to 1A nonvital 4KV

breaker 4KVS-1A-1A4 (ACB-41) in accordance with Issue 4, Revision 25 of preventative

maintenance (PM) procedure 1/2-PMP-E-36-015. Step IV.H.5 was not specific in identifying

the required torque values for verifying the tightness of the charging motor fasteners,

instructing technicians to "Verify the charging motor fasteners are tight."

Revision 28 of licensee procedure NOP-WM-1001, "Order Planning Process," calls for a

signoff after critical operations to verify important attributes, such as torque values.

Additionally, Revision 28 of NOP-WM-1001 calls for including increased level of detail, such

as torque values, and consideration of operating experience when performing work on critical

components. This level of work instruction detail was not included for Issue 4, Revision 25 of

PM procedure 1/2-PMP-E-36-015, nor did WO 200619449 incorporate operating experience

from NRC Information Notice 88-42.

On April 24, 2019, maintenance technicians did not question the lack of torque specification

and completed the work with non-specific torque values.

Corrective Actions: The licensee took immediate actions to replace the breaker, restored the

'A' train of offsite power to operable status, and completed an extent of condition evaluation

for other 5HK-250/350 4KV breakers.

Additionally, the licensee took the long term action to update PM procedure 1/2-PM-E-36-015

to specify torque values and instructed maintenance supervisors to conduct observations

focused on identifying overreliance on skill-of-the-craft in procedures. The licensee entered

the performance deficiency in the site corrective action program to correct the deficiency. The

licensee also plans an enhancement to the 5HK-250/350 4KV breakers to provide indication

that the charging springs are energized, giving an additional assurance of breaker

configuration.

Corrective Action References: CR-2024-03128

Performance Assessment:

Performance Deficiency: The licensees failure to pre-plan and perform procedures and

instructions appropriate for work on the 4KVS-1A-1A4(ACB-41A) breaker is a performance

deficiency. Specifically, WO 200619449 did not include instructions and signoffs for torque

values in accordance with NOP-WM-1001.

Screening: The inspectors determined the performance deficiency was more than minor

because it was associated with the Procedure Quality attribute of the Initiating Events

cornerstone and adversely affected the cornerstone objective to limit the likelihood of events

that upset plant stability and challenge critical safety functions during shutdown as well as

power operations. Specifically, the inappropriate instructions caused unplanned unavailability

and inoperability of the 'A' train of offsite power when the loose charging motor fasteners

backed out.

Significance: The inspectors assessed the significance of the finding using IMC 0609,

Appendix AProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0609,</br></br>Appendix A" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., The Significance Determination Process (SDP) for Findings At-Power.

Specifically, the support system initiator questions in Exhibit 1 of IMC 0609, Appendix A were

both answered no because only the A offsite power circuit was lost, but the vital bus still had

another supply from the unit transformer and the diesel generator if needed.

Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to

this finding because the inspectors determined the finding did not reflect present licensee

performance.

Enforcement:

Violation: Technical Specification Limited Condition for Operation 3.8.1 requires that two

qualified circuits between the offsite transmission network and the onsite Class 1E AC

Electrical Power Distribution System shall be operable.

Contrary to the above, from about February 20, 2024 to April 11, 2024, the 'A' train offsite

transmission network was inoperable and Technical Specification Limited Condition for

Operation 3.8.1 was not met due to the charging motor fasteners not being appropriately

torqued.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with

Section 2.3.2 of the Enforcement Policy.

Observation: Selected Non-Compliances with the Beaver Valley Cybersecurity

Plan

71152A

Inspectors performed a review of previously identified non-compliances with the Beaver

Valley Power Station, Units 1 and 2, cybersecurity plan, including those non-compliances that

were documented in NRC Inspection Reports 05000334/2023401 and 05000412/2023401.

The scope of the inspection included evaluation of the licensee's initial, interim, and long-term

corrective actions and extent of condition related to the non-compliances in the cybersecurity

plan. The inspectors also performed walkdowns of select areas of the plant to inspect the

implementation of cybersecurity controls on critical digital assets.

The detailed results of the review are documented in NRC Inspection Reports

05000334/2024403 and 05000412/2024403 due to the information being security-related and

non-publicly available.

EXIT MEETINGS AND DEBRIEFS

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

  • On October 9, 2024, the inspectors presented the integrated inspection results to Barry

Blair, Site Vice President, and other members of the licensee staff.

On September 19, 2024, the inspectors presented the 71124.08 inspection results to

Barry Blair, Site Vice President, and other members of the licensee staff.