ML092920008
| ML092920008 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 10/15/2009 |
| From: | Racquel Powell NRC/RGN-I/DRP/PB7 |
| To: | Harden P FirstEnergy Nuclear Operating Co |
| powell r j | |
| References | |
| IR-09-008 | |
| Download: ML092920008 (22) | |
See also: IR 05000334/2009008
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
475 ALLENDALE ROAD
KING OF PRUSSIA, PA 19406-1415
October 15, 2009
Mr. Paul Harden
Site Vice President
FirstEnergy Nuclear Operating Company
Beaver Valley Power Station
P. O. Box 4, Route 168
Shippingport, PA 15077
SUBJECT: BEAVER VALLEY POWER STATION - NRC PROBLEM IDENTIFICATION
AND RESOLUTION INSPECTION REPORT 05000334/2009008 AND
Dear Mr. Harden:
On September 3,2009, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at your Beaver Valley Power Station Units 1 and 2. The enclosed report documents
the inspection results, which were discussed on September 3,2009, with Mr. Roy Brosi and
other members of your staff.
This inspection was an examination of activities conducted under your license as they relate to
the identification and resolution of problems, and compliance with the Commission's rules and
regulations and the conditions of your operating license. Within these areas, the inspection
involved examination of selected procedures and representative records, observations of
activities, and interviews with personnel.
Based on the samples selected for review, the inspection team concluded that FirstEnergy
Nuclear Operating Company (FENOC) was generally effective in identifying, evaluating and
resolving problems. FENOC personnel identified problems at a low threshold and entered them
into the Corrective Action Program (CAP). FENOC personnel screened issues appropriately for
operability and reportability, and prioritized issues commensurate with the safety significance of
the problems. Root and apparent cause analyses appropriately considered extent of condition,
generic issues, and previous occurrences. Corrective actions addressed the identified causes
and were typically implemented in a timely manner. However, the inspectors noted several
examples for improvement in the identification of plant issues, and examples where evaluations
lacked rigor to fully explore the corrective actions needed to address the issue.
This report documents one NRC-identified finding of very low safety significance (Green). The
finding was determined to involve a violation of NRC requirements. However, because of its
very low safety significance and because it has been entered into your CAP, the NRC is
treating this finding as a non-cited violation (NCV), in accordance with Section VI.A.1 of the
NRC's Enforcement Policy. If you deny this NCV, you should provide a response with the basis
for your denial, within 30 days of the date of this inspection report, to the U.S. Nuclear
P. Harden 2
Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-0001, with
copies to the Regional Administrator, Region I; the Director, Office of Enforcement, U.S.
Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Senior Resident
Inspector at the Beaver Valley Power Station. In addition, if you disagree with the
characterization of any finding 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 Regional
Administrator, Region I, and the NRC Senior Resident Inspector at the Beaver Valley Power
Station. The information you provide will be considered in accordance with Inspection Manual
Chapter 0305.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response (if any) will be available electronically for public inspection in the
NRC Public Document Room or from the Publicly Available Records (PARS) component of the
NRC's document system (ADAMS). ADAMS is accessible from the NRC Web Site at
~=:'::'~~~~=-'-=:::'!J..!.~~=~~",-= (the Public Electronic Reading Room).
Sincerely,
IRA!
Raymond J. Powell, Chief
Technical Support & Assessment Branch
Division of Reactor Projects
Docket Nos.: 50-334, 50-412
Enclosures: Inspection Report 05000334/2009008; 05000412/2009008
w/Attachment: Supplemental Information
cc w/encls: Distribution via ListServ
P. Harden 3
copies to the Regional Administrator, Region I; the Director, Office of Enforcement, U.S.
Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Senior Resident
Inspector at the Beaver Valley Power Station. In addition, if you disagree with the
characterization of any finding 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 Regional
Administrator, Region I, and the NRC Senior Resident Inspector at the Beaver Valley Power
Station. The information you provide will be considered in accordance with Inspection Manual
Chapter 0305.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response (if any) will be available electronically for public inspection in the
NRC Public Document Room or from the Publicly Available Records (PARS) component of the
NRC's document system (ADAMS). ADAMS is accessible from the NRC Web Site at
http://www.nrc.gov/reading-rm/adams.html(the Public Electronic Reading Room).
Sincerely,
IRAJ
Raymond J. Powell, Chief
Technical Support & Assessment Branch
Division of Reactor Projects
Docket Nos.: 50-334, 50-412
Enclosures: Inspection Report 05000334/2009008; 05000412/2009008
w/Attachment: Supplemental Information
Distribution w/encl: (via e-mail)
S. Collins, RA (R10RAMAILRESOURCE)
M. Dapas, DRA (R10RAMAILRESOURCE) D. Spindler, DRP, RI
D. Lew, DRP (R1 DRPMAILRESOURCE) P. Garrett, DRP, OA
J. Clifford, DRP (R1DRPMAIL RESOURCE) L. Trocine, RI OEDO
R. Bellamy, DRP RIDSNRRPMBEAVERVAllEY RESOURCE
G. Barber, DRP ROPreportsResource@nrc.qov
C. Newport, DRP Region I Docket Room (with concurrences)
J. Greives, DRP
SUNSI Review Complete: tcs (Reviewer's Initials) ML092920008
DOCUMENT NAME: G:\DRP\BRANCH TSAB\lnspection Reports\Beaver Valley PI&R 2009\BV PIR
IR2009008revO.doc
After declaring this document "An Official Agency Record" it will be released to the Public.
To receive acopy of this document, indicate In the box: 'C' = Copy without attachment/enclosure 'E" = Copy with attachment/enclosure "N" = No copy
OFFICE: RI/DRP RI/DRP
NAME: TSetzer/tcs RBeliamy/rjp for
DATE: 10/13109 10/14/09
1
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket Nos. 50-334, 50-412
Report Nos. 05000334/2009008 and 05000412/2009008
Licensee: FirstEnergy Nuclear Operating Company (FENOC)
Facility: Beaver Valley Power Station, Units 1 and 2
Location: Post Office Box 4
Shippingport, PA 15077
Dates: August 17 through September 3, 2009
Team Leader: Thomas Setzer, PE, Senior Project Engineer
Division of Reactor Projects (DRP)
Inspectors: Jeffery Bream, Project Engineer, DRP
Elizabeth Keighley, Reactor Inspector, DRP
David Spindler, Beaver Valley Resident Inspector, DRP
Approved by: Raymond J. Powell, Chief
Technical Support & Assessment Branch
Division of Reactor Projects
Enclosure
2
SUMMARY OF FINDINGS
IR 05000334/2009008, IR 05000412/2009008; 08/17/2009 - 09/03/2009; Beaver Valley Power
Station, Units 1 & 2; Biennial Baseline Inspection of the Identification and Resolution of Problems.
One finding was identified in the area of prioritization and evaluation of issues.
This team inspection was performed by three NRC regional inspectors and one resident
inspector. One finding of very low safety significance (Green) was identified during this
inspection and was classified as a non-cited violation (NCV). The significance of most findings is
indicated by their color (Green, White, Yellow, Red) using NRC Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SOP). The cross-cutting aspect was determined
using IMC 0305, "Operating Reactor Assessment Program." Findings for which the SOP does
not apply may be Green or be assigned a severity level after NRC management review. The
NRC's program for overseeing the safe operation of commercial nuclear power reactors is
described in NUREG-1649, "Reactor Oversight Process," Revision 4, December 2006.
Identification and Resolution of Problems
The inspectors concluded that FENOC was, in general, effective in identifying, evaluating, and
resolving problems. Beaver Valley personnel identified problems at a low threshold and entered
them into the Corrective Action Program (CAP). The inspectors determined that Beaver Valley
personnel screened issues appropriately for operability and reportability, and prioritized issues
commensurate with the safety significance of the problems. Root and apparent cause analyses
appropriately considered extent of condition, generic issues, and previous occurrences. The
inspectors determined that corrective actions addressed the identified causes and were typically
implemented in a timely manner. However, the inspectors noted one NCV of very low safety
significance in the area of prioritization and evaluation of issues. This issue was entered into
FENOC's CAP during the inspection.
FENOC's audits and self-assessments reviewed by the inspectors were thorough and probing.
Additionally, the inspectors concluded that FENOC adequately identified, reviewed, and applied
relevant industry operating experience (OE) to the Beaver Valley Power Station. Based on
interviews, observations of plant activities, and reviews of the CAP and the Employees Concerns
Program (ECP), the inspectors did not identify any concerns with site personnel willingness to
raise safety issues, nor did the inspectors identify conditions that could have had a negative
impact on the site's safety conscious work environment (SCWE).
Cornerstone: Mitigating Systems
Green. The inspectors identified an NCV of very low safety significance (Green) of
10 CFR 50.65(a)(2), "Requirements for Monitoring the Effectiveness of Maintenance at
Nuclear Power Plants," due to FENOC personnel's failure to demonstrate that the
10 CFR 50.65(a)(2) performance of the containment isolation valve limit switches was
effectively controlled through the performance of appropriate preventive maintenance.
Specifically, as evidenced by repeat dual position indications of containment isolation
valves in the control room between 2007 and 2009 resulting in 21 unplanned entries into
Technical Specification 3.6.3, the containment isolation valve system 10 CFR 50.65(a)(2)
performance demonstration was no longer justified in accordance with Maintenance Rule
Enclosure
3
implementing procedure guidance. This should have resulted in placement of the
containment isolation valve system in 10 CFR 50.65(a)(1) for goal setting and monitoring.
FENOC entered this issue into the CAP (CR 09-64040).
The inspectors determined the finding was more than minor because it is associated with
the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely
affected the cornerstone objective of ensuring the reliability of systems that respond to
initiating events to prevent undesirable consequences. The finding was determined to be
of very low safety significance (Green) because the finding did not involve a design or
qualification deficiency resulting in loss of operability or functionality, did not result in a
loss of system safety function, and did not screen as potentially risk significant due to
external initiating events. The inspectors determined that this finding had a cross-cutting
aspect in the "Corrective Action Program" component of the Problem Identification and
Resolution cross-cutting area because FENOC did not take appropriate corrective actions
to address safety issues and adverse trends associated with faulty containment isolation
valve limit switches in a timely manner, commensurate with their safety significance and
complexity P.1(d). (Section 40A2.1c)
Enclosure
4
REPORT DETAILS
4. OTHER ACTIVITIES (OA)
40A2 Problem Identification and Resolution (PI&R) (71152B)
.1 Assessment of the Corrective Action Program Effectiveness
a. Inspection Scope
The inspectors reviewed FENOC's procedures that describe the CAP at the Beaver Valley
Power Station. FENOC personnel identified problems by initiating condition reports (CRs)
for conditions adverse to quality, plant equipment deficiencies, industrial or radiological
safety concerns, and other significant issues. Condition reports were subsequently
screened for operability and reportability, and categorized by significance, which included
levels SR (significant condition adverse to quality, root cause), AR (adverse condition, root
cause), AA (adverse condition, full apparent cause), AL (adverse condition, limited
apparent cause), AF (adverse condition, fix), and AC (adverse condition, close). CRs
were assigned to personnel for evaluation and resolution or trending.
The inspectors evaluated the process for assigning and tracking issues to ensure that
issues were screened for operability and reportability, prioritized for evaluation and
resolution in a timely manner commensurate with their safety significance, and tracked to
identify adverse trends and repetitive issues. In addition, the inspectors interviewed plant
staff and management to determine their understanding of, and involvement with, the
CAP.
The inspectors reviewed CRs selected across the seven cornerstones of safety in the
NRC's Reactor Oversight Process (ROP) to determine if site personnel properly identified,
characterized, and entered problems into the CAP for evaluation and resolution. The
inspectors selected items from functional areas that included physical security,
emergency preparedness, engineering, maintenance, operations, and radiation safety to
ensure that FENOC appropriately addressed problems identified in these functional areas.
The inspectors selected a risk-informed sample of CRs that had been issued since the
last NRC Problem Identification and Resolution (PI&R) inspection conducted in April 2007.
Insights from the station's risk analyses were considered to focus the sample selection
and plant walkdowns on risk-significant systems and components. The corrective action
review was expanded to five years for evaluation of identified concerns within CRs relative
to radiation monitors.
The inspectors selected items from various processes at Beaver Valley to verify that they
were appropriately considered for entry into the CAP. Specifically, the inspectors
reviewed a sample of Maintenance Rule functional failure evaluations, operability
determinations, system health reports, work orders (WOs), and issues entered into the
Employee Concerns Program (ECP). The inspectors inspected plant areas including the
turbine buildings, safeguards buildings, intake structure, emergency diesel generator
buildings, yard areas, security areas, and control room.
Enclosure
5
The inspectors reviewed CRs to assess whether FENOC personnel adequately evaluated
and prioritized issues. The CRs reviewed encompassed the full range of evaluations,
including root cause analyses, full apparent cause evaluations, limited apparent cause
analyses, and common cause analyses. A sample of CRs that were assigned lower
levels of significance which did not include formal cause evaluations (AF and AC
significance levels) were also reviewed by the inspectors to ensure they were
appropriately classified. The inspectors' review included the appropriateness of the
assigned significance, the scope and depth of the analysis, and the timeliness of
resolution. The inspectors assessed whether the evaluations identified likely causes for
the issues and identified appropriate corrective actions to address the identified causes.
As part of this review, the inspectors interviewed various station personnel to fully
understand details within the evaluations and the proposed and completed corrective
actions. The inspectors observed management review board (MRB) meetings in which
FENOC personnel reviewed new CRs for prioritization and assignment. Further, the
inspectors reviewed equipment operability determinations and extent-of-condition reviews
for selected CRs to verify these specific reviews adequately addressed equipment
operability and the extent of problems.
The inspectors' review of CRs also focused on the associated corrective actions in order
to determine whether the actions addressed the identified causes of the problems. The
inspectors reviewed CRs for adverse trends and repetitive problems to determine whether
corrective actions were effective in addressing the broader issues. The inspectors
reviewed FENOC's timeliness in implementing. corrective actions and effectiveness in
precluding recurrence for significant conditions adverse to quality. Lastly, the inspectors
reviewed CRs associated with NRC non-cited violations (NCV) and findings since the last
PI&R inspection to determine whether FENOC personnel properly evaluated and resolved
the issues. Specific documents reviewed during the inspection are listed in the
Attachment to this report.
b. Assessment
Effectiveness of Problem Identification
Based on the selected samples reviewed, plant walkdowns, and interviews of site
personnel, the inspectors determined that, in general, FENOC personnel identified
problems and entered them into the CAP at a low threshold. For the issues reviewed, the
inspectors noted that problems or concerns had been appropriately documented in
enough detail to understand the issues. Approximately 19,000 CRs had been written by
FENOC personnel since January 2007. The inspectors noted that the Security
department had generated significantly less CRs when compared to the rest of the site.
Interviews with Security personnel revealed that they had received adequate training,
displayed a willingness to raise issues, and had ample access to computers; however,
there was a reliance on the shift Captain to enter issues into the CAP.
The inspectors observed managers and supervisors at MRB meetings appropriately
questioning and challenging CRs to ensure clarity of the issues. The inspectors
determined that FENOC personnel trended equipment and programmatic issues, and CR
descriptions appropriately included reference to repeat occurrences of issues. The
Enclosure
6
inspectors concluded that personnel were identifying trends at low levels.
The inspectors toured plant areas including the turbine buildings, safeguards buildings,
intake structure, emergency diesel generator buildings, yard areas, security areas and
control room to determine if FENOC personnel identified plant issues at the proper
threshold. Housekeeping in all areas, with the exception of the Unit 2 intake structure,
was noted to be improved since the 2007 NRC PI&R inspection. During the plant
walkdown, the inspectors identified three examples of adverse conditions that had not
been identified by FENOC. The following issues were entered into the CAP for evaluation
and resolution:
- During an inspection of the east end of the main intake structure, the inspectors
identified an oxygen bottle strapped to an Appendix R ladder (a ladder used by
plant personnel for implementing the site fire protection program). Restraining the
oxygen bottle and Appendix R ladder together in this fashion represented a minor
procedure violation of Beaver Valley procedure, 1/2-PIP-G01, "Securing
Transient/Temporary/Stored Equipment in Safety-Related Areas." This issue is
minor because there was no adverse impact to plant safety equipment, and there
was only minimal impact on operator fire response times. FENOC entered this
into the CAP (CR 09-63536).
- During an inspection of the 'D' intake structure cubicle, the inspectors identified
rigging scaffolding with a chainfall that had been left draped over a safety related
component. Scaffold contacting plant equipment represented a minor procedure
violation of Beaver Valley procedure, 1/2-ADM-0810, "Scaffold Erection and
Tagging." The component was not damaged nor had any reduced capability as a
result of the contact with the chainfall. This issue is minor because there was no
loss of operability or adverse impact to the safety related component. FENOC
entered this into the CAP (CR 09-63532).
- During an inspection of the Unit 2 Safeguards Building, the inspectors identified
four plastic buckets filled with lubricating oil totaling 20 gallons. The unattended oil
in a safety related fire area represented a minor procedure violation of Beaver
Valley procedure, 1/2-ADM-1906, "Control of Transient Combustible and
Flammable Materials." This issue is minor because the increase in combustible
loading in the room as a result of the unattended oil did not violate the plant fire
hazard analysis. FENOC entered this into the CAP (CR 09-63441).
In accordance with NRC Inspection Manual Chapter 0612, "Power Reactor Inspection
Reports," the above issues constitute violations of minor significance that are not subject
to enforcement action in accordance with the NRC's Enforcement Policy.
Effectiveness of Prioritization and Evaluation of Issues
The inspectors determined that, in general, FENOC personnel appropriately prioritized
and evaluated issues commensurate with their safety significance. CRs were screened
for operability and reportability, categorized by significance, and assigned to a department
for evaluation and resolution. The CR screening process considered human performance
issues, radiological safety concerns, repetitiveness and adverse trends. The inspectors
observed managers and supervisors at MRB meetings appropriately questioning and
challenging CRs to ensure appropriate prioritization.
Enclosure
7
CRs were categorized for evaluation and resolution commensurate with the significance of
the issues. Based on the sample of CRs reviewed, the guidance provided by the FENOC
implementing procedures appeared sufficient to ensure consistency in categorization of
the issues. Operability and reportability determinations were performed when conditions
warranted and the evaluations supported the conclusions. Causal analyses appropriately
considered extent of condition, generic issues, and previous occurrences. During this
inspection, the inspectors noted that, in general, FENOC's root cause analyses were
thorough, and corrective and preventive actions addressed the identified causes.
Additionally, the identified causes were well supported. An NCV was identified for
FENOC's failure to demonstrate that the 10 CFR 50.65(a)(2) performance of the
containment isolation valve limit switches was effectively controlled through the
performance of appropriate preventive maintenance. This NCV is discussed in the
findings section of this assessment area. The inspectors identified the following two
examples of issues that were not fully evaluated or prioritized for corrective action:
- A root cause evaluation (CR 08-39835) associated with a 2.5 inch drain down of
the Unit 2 reactor coolant system during refueling outage 2R13 did not identify all
corrective actions necessary to address all failed barriers. The inspectors noted
that the root cause evaluation had not included corrective actions to address the
communication failure within operations shifts, and the work management
scheduling issues which contributed to a component tagoutlctearance being
inappropriately implemented. The issue is minor because while corrective actions
were not assigned to address all failed barriers, FENOC had discussed
communication expectations with each operating crew and there have not been
any repeat issues. FENOC entered these issues into the CAP (CR 09-63454 and
09-63479).
- The inspectors identified three CRs describing component mispositioning events
(CR 09-59541, CR 09-58355, and CR 09-57224) that were prioritized as CR level
OlAF." The failure to prioritize these CRs as a limited apparent cause (CR level
"AL") represented a minor procedure violation of Beaver Valley procedure, NOBP
OP-0004, "Component Mispositioning." The inspectors reviewed NRC Inspection
Manual Chapter 0612, Appendix E, "Minor Examples," and determined this issue
was minor because there was no loss of operability or safety impact. FENOC
entered this issue into the CAP (CR 09-64004 and CR 09-63975).
In accordance with NRC Inspection Manual Chapter 0612, "Power Reactor Inspection
Reports," these issues constitute violations of minor significance that are not subject
to enforcement action in accordance with the NRC's Enforcement Policy.
Effectiveness of Corrective Actions
The inspectors concluded that corrective actions for identified deficiencies were generally
timely and adequately implemented. For significant conditions adverse to quality,
corrective actions were identified to prevent recurrence. The inspectors concluded that
corrective actions to address NCVs and findings since the last PI&R inspection were
timely and effective. The inspectors identified the following example where corrective
actions were not fully effective in addressing an issue:
Enclosure
8
- The inspectors reviewed corrective actions taken in response to an NCV
documented in NRC report 05000334/05000412 2007004. CR 07-24074 was
written to ensure bearing temperatures would be monitored when performing
surveillance testing on the turbine driven auxiliary feedpumps (TDAFWP). The
inspectors found that the comprehensive surveillance tests for Unit 1 and Unit 2
(Beaver Valley procedures 10ST-24.9 and 20ST-24.4A, respectively) did not have
a precaution stating that this surveillance was not suitable to be used for post
maintenance testing as there is no guidance prescribed to monitor and achieve
steady bearing temperatures. The inspectors determined that the issue was minor
because the preventive maintenance work order had contained the appropriate
guidance. FENOC entered this issue into the CAP (CR 09-64015).
c. Findings
Introduction: The inspectors identified an NCV of very low safety significance (Green) of
10 CFR 50.65(a)(2), "Requirements for Monitoring the Effectiveness of Maintenance at
Nuclear Power Plants," due to FENOC personnel's failure to demonstrate that the
10 CFR 50.65(a)(2) performance of the containment isolation valve limit switches was
effectively controlled through the performance of appropriate preventive maintenance.
Specifically, as evidenced by repeat dual position indications of containment isolation
valves in the control room resulting in 21 unplanned entries into Technical Specification 3.6.3, the containment isolation valve system 10 CFR 50.65(a)(2) performance
demonstration was no longer justified in accordance with Maintenance Rule implementing
procedure guidance.
Description: The containment isolation valve system is a risk-significant system that is
scoped within the Maintenance Rule because it is a system, structure, or component
(SSC) required to mitigate accidents/transients and is identified in emergency operating
procedures. The primary Maintenance Rule function of the containment isolation valve
system is to provide a containment isolation function during an event to prevent offsite
radiological release. Additionally, limit switches associated with each containment
isolation valve are scoped within the Maintenance Rule because they provide a function to
indicate valve position in the control room for operators to use during emergency
operating procedures.
In February 2009, during stroke-time testing, an air-operated containment isolation valve
displayed dual indication in the control room, causing the stroke times of the valve to be
indeterminate and causing an unplanned entry into Technical Specification 3.6.3.
Additionally, between January 2007 and July 2009, Technical Specification 3.6.3 had 21
unplanned entries as a result of faulty limit switches on similar containment isolation
valves. This resulted in the FENOC established containment isolation valve system
Maintenance Rule condition monitoring criteria being exceeded, which required FENOC to
perform a Maintenance Rule 10 CFR 50.65(a)(1) evaluation. The Maintenance Rule
(a)(1) evaluation was completed in February 2009 and concluded that the containment
isolation valve system should continue to be monitored in accordance with Maintenance
Rule 10 CFR 50.65(a)(2)., This reinforced a similar decision made in 2007 based on a
Maintenance Rule (a)(1) evaluation recommendation to keep the system in (a)(2) despite
Enclosure
9
the condition monitoring criteria being exceeded due to multiple dual indications in the
control room. The basis of the decision was that the dual indication issue was a result of
faulty limit switches, and that this did not affect the valve's safety related function to close
during an event to prevent offsite radiological release. Site personnel determined the
direct cause was the limit switch being out of adjustment due to a problem with the
required torque. Despite the repeat failures, FENOC failed to implement or revise
preventive maintenance practices for these limit switches. Subsequently, the
Maintenance Rule Steering Committee approved a revision to clarify the monitoring
criteria for the containment isolation valve system, which would exclude future indication
problems that did not affect the valve's ability to isolate containment. However, it failed to
take into account the limit switches' Maintenance Rule function in emergency operating
procedures, specifically, the ability to accurately indicate valve position in the control room
during an event. Following the change to the condition monitoring criteria, the site had
seven valves display dual indication in the control room between February 2009 and June
2009 that FENOC concluded did not affect valve operability.
The inspectors concluded that the numerous dual indications of the limit switches should
have been evaluated against FENOC's Maintenance Rule condition monitoring criteria
and should have resulted in placement of the containment isolation valve system in
10 CFR 50.65(a)(1) for goal setting and monitoring. FENOC performed an extent of
condition review on two other valves of the same model, and determined that the torque
on the limit switch fasteners needed to be adjusted. FENOC corrected the torque issue
and has implemented plans to install a button tab on the limit switches to minimize
misalignment causing dual indications.
Analysis: The inspectors determined that the failure to demonstrate that the
10 CFR 50.65{a)(2) performance of the containment isolation valve limit switches was
effectively controlled through the performance of appropriate preventive maintenance was
a performance deficiency within FENOC personnel's ability to foresee and correct and
should have been prevented. Traditional Enforcement did not apply, as the issue did not
have actual or potential safety consequence, had no willful aspects, nor did it impact the
NRC's ability to perform its regulatory function.
A review of NRC Inspection Manual Chapter (IMC) 0612, Appendix E, "Minor Examples,"
revealed that no minor examples were applicable to this finding. The inspectors
determined the finding was more than minor because it is associated with the Equipment
Performance attribute of the Mitigating Systems cornerstone and adversely affected the
cornerstone objective of ensuring the reliability of systems that respond to initiating events
to prevent undesirable consequences. Specifically, the dual indication of containment
isolation valves in the control room due to faulty limit switches presents a challenge to the
operators during event response while implementing emergency operating procedures,
and has resulted in 21 unplanned Technical Specification entries. The numerous dual
indication instances should have caused the containment isolation valve system to be
placed in 10 CFR 50.65(a)(1) for goal setting and monitoring. The inspectors determined
the significance of the finding using IMC 0609.04, "Phase 1 Initial Screening and
Characterization of Findings." The finding was determined to be of very low safety
significance (Green) because the finding did not involve a design or qualification
deficiency resulting in loss of operability or functionality, did not result in a loss of system
Enclosure
10
safety function, and did not screen as potentially risk significant due to external initiating
events.
The inspectors determined that this finding had a cross-cutting aspect in the "Corrective
Action Program" component of the Problem Identification and Resolution cross-cutting
area because FENOC did not take appropriate corrective actions to address safety issues
and adverse trends associated with faulty containment isolation valve limit switches in a
timely manner, commensurate with their safety significance and complexity [P.1 (d)).
Enforcement: 10 CFR 50.65(a)(1) requires, in part, that holders of an operating license
shall monitor the performance or condition of SSCs within the scope of the monitoring
program as defined in 10 CFR 50.65(b) against licensee-established goals, in a manner
sufficient to provide reasonable assurance that such SSCs are capable of fulfilling their
intended functions. 10 CFR 50.65(a)(2) states, in part, that monitoring as specified in
10 CFR 50.65(a)(1) is not required where it has been demonstrated that the performance
or condition of an SSC is being effectively controlled through the performance of
appropriate preventative maintenance, such that the SSC remains capable of performing
its intended function.
Contrary to the above, between 2007 and 2009, FENOC personnel failed to demonstrate
that the 10 CFR 50.65(a)(2) performance of the containment isolation valve limit switches
was effectively controlled through the performance of appropriate preventive
maintenance. FENOC has performed an extent of condition review and has initiated
corrective actions to install a button tab on the limit switches to minimize misalignment
causing the dual indications. Because this violation was of very low safety significance
and has been entered into the CAP (CR 09-64040), this violation is being treated as an
NCV, consistent with the NRC Enforcement Policy (NCV 05000314,412/2009008-01:
Containment Isolation Valve System 10 CFR 50.65 (a)(2) Performance
Demonstration Not Met) .
.2 Assessment of the Use of Operating Experience
a. Inspection Scope
The inspectors selected a sample of CRs associated with the review of industry Operating
Experience (OE) to determine whether FENOC personnel appropriately evaluated the OE
information for applicability to Beaver Valley and had taken appropriate actions, when
warranted. The inspectors reviewed CR evaluations of OE documents associated with a
sample of NRC Generic Letters and Information Notices to ensure that FENOC
adequately considered the underlying problems associated with the issues for resolution
via their CAP. The inspectors also observed plant activities to determine if industry OE
was considered during the performance of routine activities. Specific documents
reviewed during the inspection are listed in the Attachment to this report.
b. Assessment
The inspectors determined that, in general, FENOC appropriately considered industry OE
information for applicability, and used the information for corrective and preventive actions
Enclosure
11
to identify and prevent similar issues when appropriate. The inspectors determined that
OE was appropriately applied and lessons learned were communicated and incorporated
into plant operations. The inspectors observed that industry OE was routinely discussed
and considered during the performance of plant activities.
The inspectors reviewed a fleet-level focused self-assessment of OE performed in May
2008. The self-assessment identified a number of weaknesses, specifically:
- OE was not discussed in system health reports;
- Roles and responsibilities of Section OE Coordinators were not clearly defined;
Management and Section OE Coordinator levels; and
- Procedures describing the requirements to process OE were in need of revision to
add clarity.
Although the inspectors noted that corrective actions were not completed until June 2009,
since that time Beaver Valley has made progress in addressing OE program needs. This
has included clearly defining the roles and responsibilities of Section OE Coordinators.
Procedures have been revised and a familiarization guide has been completed with
guidance on how to use SAP efficiently. Training has been completed for Section OE
Coordinators and the backlog of unreviewed OE items has decreased (currently at 2
unreviewed items as compared to over 12 items previously). Finally, a higher level of
accountability has been placed on each department to report backlogged OE items at
weekly plant meetings. With respect to incorporating OE in system health reports, the
inspectors identified that OE continued not to be incorporated in the 2008 and 2009
reports. FENOC entered this issue into the CAP (CR 09-63999).
c. Findings
No findings of significance were identified .
.3 Assessment of Self-Assessments and Audits
a. Inspection Scope
The inspectors reviewed a sample of snapshot self-assessments, focused self
assessments, fleet-level assessments, and a variety of self-assessments focused on
various plant programs. These reviews were performed to determine if problems
identified through these assessments were entered into the CAP, and whether corrective
actions were initiated to address identified deficiencies. The effectiveness of the
assessments was evaluated by comparing audit and assessment results against
self-revealing and NRC-identified observations made during the inspection. A list of
documents reviewed is included in the Attachment to this report.
b. Assessment
The inspectors concluded that QA audits and self-assessments were critical, thorough,
and effective in identifying issues. The inspectors observed that these audits and self-
Enclosure
12
assessments were completed by personnel knowledgeable in the subject areas and were
completed to a sufficient depth to identify issues that were then entered into the CAP for
evaluation. Corrective actions associated with the issues were implemented
commensurate with their safety significance. FENOC managers evaluated the results and
initiated appropriate actions to focus on areas identified for improvement.
c. Findings
No findings of significance were identified .
.4 Assessment of Safety Conscious Work Environment
a. Inspection Scope
The inspectors performed interviews with station personnel to assess the safety conscious
work environment (SCWE) at Beaver Valley. Specifically, the inspectors interviewed
personnel to determine whether they were hesitant to raise safety concerns to their
management and/or the NRC. The inspectors also interviewed the station Employee
Concerns Program (ECP) coordinator to determine what actions were implemented to
ensure employees were aware of the program and its availability with regard to raising
concerns. The inspectors reviewed the ECP files to ensure that issues were entered into
the CAP when appropriate. The inspectors reviewed site SCWE surveys from 2007 and
2008 to assess any adverse trends in department and site safety culture. A list of
documents reviewed is included in the Attachment to this report.
b. Assessment
During interviews, plant staff expressed a willingness to use the CAP to identify plant
issues and deficiencies, and stated that they were willing to raise safety issues. All
persons interviewed demonstrated an adequate knowledge of the CAP and ECP. Based
on these limited interviews, the inspectors concluded that there was no evidence of
SCWE concerns and no significant challenges to the free flow of information.
SCWE surveys in 2007 and 2008 showed that the overall SCWE health at Beaver Valley
remained positive. The surveys indicated the staff understands and accepts expectations
and responsibilities for identifying concerns. The surveys indicated FENOC personnel
feel free to approach management with issues and management expectations on safety
and quality are clearly communicated. The surveys indicated lower than average scores
for Radiation Protection, Chemistry, Security, and Site Projects departments. CRs were
generated to help promote improvement in the safety culture of these departments, and
corrective actions were implemented. The inspectors noted that when compared to the
2007 survey, the Operations department had an increase in negative responses in the
2008 survey. This trend had not been entered into the CAP for evaluation since the
negative score averages did not exceed a ten percent cutoff "trigger" for CR generation.
The inspectors questioned this cutoff in that it appeared to potentially limit FENOC's ability
to fully explore year-to-year trends in departments that may not exceed ten percent
negative responses, but decline significantly from the previous survey_ FENOC entered
this issue into the CAP (CR 09-63998).
Enclosure
13
As a result of the survey review, the inspectors completed additional SCWE interviews
with operators to determine if there was a reluctance to raise safety issues. No individuals
expressed any fear to raise issues.
c. Findings
No findings of significance were identified.
40A6 Meetings, Including Exit
On September 3, 2009, the inspectors presented the inspection results to Mr. Roy Brosi,
Director of Site Performance Improvement, and other members of the Beaver Valley staff.
The inspectors verified that no proprietary information was documented in the report.
ATTACHMENT: SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
Harold Szklinski, Staff Nuclear Specialist
Fulton Schaffner, Staff Nuclear Specialist
Daniel Butor, Staff Nuclear Specialist
Robert Lubert, Supervisor, Nuclear Electrical System Engineering
Francy Mantine, Staff Nuclear Engineer
David Jones, Staff Nuclear Engineer
Philip Slifkin, Staff Nuclear Engineer
Giuseppe Cerasi, Senior Nuclear Specialist
Brian Goff, Supervisor, Nuclear Work Planning
Michael Kienzle, Nuclear Engineering
Pat Pauvlinch, Supervisor, Nuclear Plant System Engineering
Robert Williams, Staff Nuclear Engineer
Joann West, Staff Nuclear Engineer
John Kaminskas, Nuclear Engineer
David Hauser, Superintendent Shift Operations, Unit 2
Christopher Makowka, Root Cause Evaluator
Michael Mitchell, Superintendent Nuclear Work Planning
John Bowden, Superintendent Nuclear Operations Services
Jim Mauck, Senior Nuclear Specialist
Brian Sepelak, Supervisor, Nuclear Compliance
Karl Wolfson, Supervisor, Nuclear Performance Improvement
Colin Keller, Manager, Site Regulatory Compliance
Rich Dibler, Security Support Supervisor
Sue Vincinie, Performance Improvement Senior Consultant
Darrel Batina, Employee Concerns Program Representative
Dutch Chancey, Manager, Employee Concerns (Fleet)
Wayne Mcintire, Beaver Valley Site Safety Specialist
Gary Shildt, Supervisor, Nuclear Projects Engineering
Jack Patterson, Staff Nuclear Engineer
Thomas King, Plant Engineer
Robert Lubert, Plant Engineering Supervisor
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
05000334, 412/2009008-01 Containment Isolation Valve System 10 CFR 50.65
(a)(2) Performance Demonstration Not Met.
Attachment
A-2
LIST OF DOCUMENTS REVIEWED
Condition ReQorts
08-38146 09-60763 09-55789 08-50881 08-47439 08-46291
08-45288 08-42054 08-36772 07-26862 08-32856 07-14885
07-14208 09-62156 09-62106 09-61128 09-60432 09-59875
09-56773 09-54230 09-52736 08-39941 08-48160 09-57390
09-52275 08-49681 08-33109 07-28371 07-15761 09-61333
08-42790 09-62268 09-59641 09-58307 09-57580 09-57463
09-55267 09-52029 08-48296 09-57822 09-61026 09-60359
09-56525 09-61753 09-57743 08-51000 07-23937 09-59057
09-53803 08-41802 08-32965 03-01371 09-61679 09-62681
09-57726 08-39835 07-18191 07-21962 08-48581 08-50283
09-52719 09-61026 09-63451 09-61453 08-48268 08-44941
08-44947 08-37921 08-44960 07-24074 07-30275 09-63317
08-48482 09-52857 09-63269 09-57857 09-56402 08-34526
08-33776 09-55350 09-52043 07-28809 07-12360 07-14181
07-14185 07-14530 07-14761 07-14934 09-61430 09-61631
09-61878 09-62202 09-62810 07-15636 07-17006 07-17236
07-20147 07-20158 07-22189 07-24552 07-25283 07-28203
07-22004 07-29608 07-30073 09-57198 09-57688 09-57815
09-58598 09-60492 09-60672 09-59088 09-60547 09-61017
07-31483 07-28809 07-12120 08-35376 08-49694 08-43202
08-43205 09-62787 08-48664 08-49518 09-53081 09-53243
09-53762 09-54051 09-55146 09-55719 09-56851 09-56874
09-57268 09-57784 09-58142 07-26688 09-54051 08-48664
07-25046 07-30273 08-38146 07-13076 08-48581 09-60218
04-09895 07-30390 07-32095 08-40472 08-48688 09-60450
06-11217 07-30430 08-32447 08-40490 08-49073 09-60763
07-13021 07-30431 08-32887 08-40519 08-49368 09-61744
07-15001 07-30447 08-33126 08-40575 08-49750 09-62348
07-15444 07-30484 08-33306 08-40579 08-49983 09-62705
07-18894 07-30575 08-33398 08-40587 08-50137 08-37743
07-20907 07-30677 08-33725 08-40753 08-50151 08-37925
07-22891 07-30823 08-35048 08-40867 08-51024 08-38276
07-23543 07-30847 08-35517 08-40932 08-51136 08-38687
07-23933 07-30911 08-35674 08-40970 08-51385 08-38750
07-26020 07-30912 08-36383 08-41330 09-52096 08-39233
Attachment
A-3
07-26065 07-30988 08-36471 08-41450 09-52351 08-39304
07-26326 07-30999 08-36539 08-41691 09-53214 08-39946
07-27423 07-31040 08-37026 08-41723 09-53275 08-46995
07-27469 07-31083 08-37250 08-41801 09-53803 08-47282
07-28007 07-31107 08-37304 08-42046 09-53938 08-47455
07-28012 07-31110 08-37318 08-42627 09-54227 08-47767
07-28471 07-31112 08-37320 08-42847 09-54737 09-58483
07-28724 07-31221 08-37330 08-43510 09-54836 09-58878
07-29217 07-31350 08-37373 08-44047 09-55439 09-58985
07-30075 07-30383 08-37405 08-45833 09-56328 09-59541
07-30318 08-37676 08-37450 08-46143 09-57224 09-58355
07-30362 08-46883 08-37646 08-46662 09-57244 07-22603
07-28652 08-38049 08-41776 08-47368 08-47539 08-48966
09-53197 09-53372 09-53569 09-55916 09-57165 07-12368
07-16667 07-17938 07-19218 07-20942 07-23163 07-23960
07-24034 07-25474 07-27222 07-28474 08-34940 08-35010
08-36384 08-37168 08-37252 08-40090 08-40292 08-47830
08-48144 08-48160 08-49360 08-49836 09-51664 09-54128
09-54942 09-55267 09-56250 09-56291 09-56315 09-57553
09-57617 09-58071 09-58215 09-58481 09-58495 09-59460
09-59654 09-60890 *09-63801 *09-63391 *09-63416 *09-63982
- 09-63532 *09-63546 *09-63536 *09-63454 *09-63479 *09-63441
- 09-63916 *09-63975 *09-63998 *09-63999 *09-64004 *09-64015
- 09-64040
- CR written as a result of NRC inspection
Audits and Self-assessments
BV-SA-08-086, "BVPS Inservice Testing (1ST) Program Snapshot Self-Assessment Plan."
BV-SA-08-007, "CAP Effectiveness."
Fleet Self-assessment of Use of Operating Experience at Beaver Valley, Perry and Davis Berry,
May 2008.
BV-SA-08-009, "Focused Self-Assessment of Beaver Valley Work Management Performance
Indicators"
BV-SA-08-080
Operating Experience
OE 28133
OE 24688
OE 24689
SEN 274, "Multiple Reactor Coolant Pump Seal Failures During Cooldown"
Attachment
A-4
Procedures
NOP-LP-2001, Corrective Action Program, Rev. 22
NOBP-LP-2011, FENOC Cause Analysis, Rev. 9
1/2-EPP-IP-7.1, Emergency Equipment Inventory and Maintenance Procedure, Rev. 22
1/2-EPP-IP-7.1, Emergency Equipment Inventory and Maintenance Procedure, Rev. 23
1/2-EPP-IP-7.1.F09, Emergency Inventory Checklist - Primary Assembly Areas, Rev. 4
1/2-EPP-IP-7.1.F09, Emergency Inventory Checklist - Primary Assembly Areas, Rev. 5
EPP-PLAN-SECTION-6, Emergency Measures, Rev. 25
EPP-PLAN-SECTION-7, Emergency Facilities and Equipment, Rev. 25
NOP-LP-5004, Equipment Important to Emergency Response, Rev. 0
BVRM-EP-5003, Equipment Important to Emergency Response, Rev. 1
1/2-EPP-IP-7.2, Administration of Emergency Preparedness Plan Drills and Exercises, Rev. 13
1/2-EPP-IP-3.2, Site Assembly and Personnel Accountability, Rev. 18
10ST-15.1, [1CC-P-1A] Quarterly Test, Rev. 19
10ST-15.1, [1CC-P-1A] Quarterly Test, Rev. 20
10ST-15.1, [1CC-P-1A] Quarterly Test, Rev. 23
20ST-11.1, Low Head Safety Injection Pump [2SIS*P21A] Test, Rev. 25
20M-11.2.B, Setpoints, Rev. 4
2CMP-11SIS-P-21A-B-1M, Low Head Safety Injection Pump Overhaul, Issue 4, Rev. 9
10ST-24.4, Steam Turbine Driven Auxiliary Feed Pump Test [1 FW-P-2], Rev. 42
10ST-24.9, Turbine-Driven AFW Pump [1 FW-P-2] Operability Test, Rev. 40
20ST-24.4, Steam Driven Auxiliary Feed Pump [2FWE*P22] Quarterly Test, Rev. 64
20ST-24.4A, Steam Driven Auxiliary Feed Pump [2FWE*P22] Full Flow Test, Rev. 20
NOBP-LP-1107, Security Operating Experience Guidelines, Rev. 0
20M-53A.1.A-0.11, Beaver Valley Power Station Unit 2 Verification of Automatic
Actions, Rev. 6
20M-53A.1.A-0.11, Beaver Valley Power Station Unit 2 Containment Isolation Phase A
Checklist, Issue 1C Rev. 0
NOP-MS-4001, Warehousing, Rev. 6
NOBP-OM-2031, Outage Management Scheduling Process, Rev. 3
NOBP-OP-0004, Component Mispositioning, Rev. 2
NOP-OP-1001, Clearance/Tagging Program, Rev. 11
BVBP-OPS-0004, Operations Clearance Coordinator, Rev. 7
1/2-ADM-2017.F01, Beaver Valley Power Station Vendor Technical Information Review Form-
Low Head Safety Injection Pump Instruction Manual, Rev. 5
NOBP-CC-7003, Structured Spare Parts List, Rev. 5
BVPM-ER-3004, Maintenance Rule (MR) Program Supplemental Guidance, Rev. 0
BVBP-OPS-0008, Supplemental Instructions For the Control of Operating Manual Procedures.
BVPS-OPS-0022, Operating Procedure Development and Revision, Rev. 0
NOP-ER-3004, FENOC Maintenance Rule Program, Rev. 1
SAP Orders/Notifications
600556345
600544389
200287486
600519950
200221237
Attachment
A-5
200309431
200287583
200276981
200042681
200172902
200371419
200310030
200254994
600375319
600422084
600423831
200283954
Non-Cited Violations and Findings
NCV 05000334/2008003-01, Inadequate Maintenance Procedure Results in Unexpected Terry
Turbine Speed Increase
NCV 05000334/2007004-02, Inadequate Procedure and Monitoring Program for Turbine Driven
Auxiliary Feedwater Pump Turbine 1FW-T-2
NCV 05000334/2008002-01, Incorrect Jumper Placement during Testing Renders
Quench Spray Chemical Addition Inoperable
NCV 05000334/2007005-05, Inadequate Inspection led to a subsequent failure of a Fuel Transfer
Up-Ender Cable
FIN 05000412/2008003-02, Deficient Control of Clearance Posting Interrupts Reactor Coolant
Charging Path while Vessel Water Level Drained Below the Flange
Surveillance Tests
20ST-11.1, Low Head Safety Injection Pump [2SIS-P21A] Test, Rev. 24, 07/28/08
20ST-11.1, Low Head Safety Injection Pump [2SIS-P21A] Test, Rev. 24, 10/20/08
20ST-11.1, Low Head Safety Injection Pump [2SIS-P21A] Test, Rev. 24, 06/30/09
10ST-24.9, Turbine-Driven AFW Pump [1 FW-P-2] Operability Test, Rev. 36,10/23/07
10ST-24.9, Turbine-Driven AFW Pump [1 FW-P-2] Operability Test, Rev. 40,05/11/09
Vendor Manual
2502.290-001-001, Low Head Safety Injection Pump Instruction Manual, Rev. S
2502.290-001-001, Low Head Safety Injection Pump Instruction Manual, Rev. T
Other
Feedback Form #2008-1448
PM Change Request BV-REV.-08-4731
SAP Report - Bill of Materials for Low Head Safety Injection Pump 2SIS-P21A
SAP Report - Bill of Materials for Low Head Safety Injection Pump 2SIS-P21B
2SIS-P21A Vibration Trend Data 03/24/1998 - 06/30/2009
Beaver Valley System Health Report 2008-1
Beaver Valley System Health Report 2008-2
Beaver Valley System Health Report 2008-3
Beaver Valley System Health Report 2008-4
Attachment
A-6
Beaver Valley System Health Report 2009-1
Weekly Operating Experience Summary - August 3, 2009
Maintenance Rule System Basis Document Unit 2 System 47, Rev. 5
Maintenance Rule System Basis Document Unit 2 System 47, Rev. 6
Licensing Requirements Manual, Rev. 52
Protective Tagout 2BVP-CYC-013-1 2R13-07-EDS-00B
Unit 2 Shift Narrative Logs May 5, 2008 to May 7, 2008
Beaver Valley Unit 2 System Health Report 2009-2, "System 43 - Unit 2 Radiation Monitoring
System"
Beaver Valley Unit 1 System Health Report 2009-2, "System 43 - Unit 1 Radiation Monitoring
System"
LIST OF ACRONYMS
ADAMS Agencywide Documents Access and Management System
BV Beaver Valley
CAP Corrective Action Program
CFR Code of Federal Regulations
CR Condition Report
DRP Division of Reactor Projects
ECP Employee Concerns Program
FENOC FirstEnergy Nuclear Operating Company
IMC Inspection Manual Chapter
IR Inspection Report
1ST Inservice Test
MRB Management Review Board
NCV Non-Cited Violation
NRC Nuclear Regulatory Commission
OA Other Activities
OE Operating Experience
PARS Publicly Available Records System
PI&R Problem Identification and Resolution
ROP Reactor Oversight Process
SCWE Safety Conscious Work Environment
SOP Significance Determination Process
TDAFWP Turbine Driven Auxiliary Feedwater Pump
WO Work Order
Attachment