ML111310328
| ML111310328 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 05/13/2011 |
| From: | Doerflein L Engineering Region 1 Branch 2 |
| To: | Harden P FirstEnergy Nuclear Operating Co |
| Shared Package | |
| ML111300540 | List: |
| References | |
| IR-11-008 | |
| Download: ML111310328 (27) | |
See also: IR 05000412/2011008
Text
ttnu,oro UNITED STATES
NUCLEAR REGULATORY COMMISSION
W
"."* REGION I
475 ALLENDALE ROAD
KlNG OF PRUSSTA. PA 19406-1415
+**tt
May 13, 20LL
Mr. PaulA. Harden
Site Vice President
FirstEnergy Nuclear Operating Company
Beaver Valley Power Station
P.O. Box4, Route 168
Shippingport, PA 15077
SUBJECT: BEAVER VALLEY POWER STATION - NRC TEMPORARY INSTRUCTION
2515t 183 INSPECTION REPORT 05000334/201 1 008 AND 05000412t201 1oO8
Dear Mr. Harden:
On April 29,2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at
your Beaver Valley Power Station Units 1 and 2, using Temporary instrubtion 2St 5/183,
"Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event." The enclosed
inspection report documents the inspection results which were discussed on April 2g, 2011, with
you and other members of your staff.
The objective of this inspectio.n was to promptly assess the capabilities of Beaver Valley power
Station to respond to extrlordinary consequenbes similar to those that have recently oicurred at
the Japanese Fukushima Daiichi Nuclear Station. The results from this inspection, ilong with
the results from this inspection performed at other operating commercial nuclear piants in the
United States will be used to evaluate the U.S. nuclear indrlstry's readiness to saiely respond to
similar events. These results will also help the NRC to determine if additional regulitory actions
are warranted.
All of the potential issues and observations identified by this inspection are contained in this
report. The NRC's Reactor Oversight Process will further evaluate any issues to determine if
they are re^gulatory findings or violations. Any resulting findings or violations will be documented
by the NRC in a separate report. You are not required to resfond to this letter.
P. Harden
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter
and its enclosure will be made available electronically for public inspection in the NRC
Public Document Room or from the Publicly Available Records (PARS) component of
NRC's Agency Documents Access and Management System (ADAMS), accessible from the
NRC Web site at http://www.nrc.qov/readinq-rm/adams.html (the Public Electronic Reading
Room).
Sincerely,
,-\
/\ I0^
n
"..V
(\.Za^,r-,1-.-, T(
/,\ L'oe^-
Lawrence T. Doerflein, Chief I
Engineering Branch 2 '
Division of Reactor Safety
Docket Nos.: 50-334, 50-412
Enclosure: Inspection Report Nos. 0500033412011008 and 0500041212011008
cc w/encl: Distribution via ListServ
P. Harden 2
ln accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter
and its enclosure will be made available electronically for public inspection in the NRC
Public Document Room or from the Publicly Available Records (PARS) component of
NRC's Agency Documents Access and Management System (ADAMS), accessible from the
NRC Web site at http://www.nrc.oov/readinq-rm/adams.html (the Public Electronic Reading
Room).
Sincerely,
/RN
Lawrence T. Doerflein, Chief
Engineering Branch 2
Division of Reactor Safety
Docket Nos.: 50-334, 50-412
Enclosure: Inspection Report Nos. 0500033412011008 and 050004121201 1008
cc w/encl: Distribution via ListServ
ADAMS PACKAGE: ML11 1300168 ADAMS DOCUMENT ACCESSION: MLI 11310328
SUNSI Review Complete: LTD (Reviewer's Initials)
DOCUMENT NAME: G:\DRS\Tl-183 Inspection Reports\BV Tl-183 lR 2011008.docx
After declaring this document "An Official Agency Record' it will be released to the Public.
To receive a copy of this document, indicate in the box: 'G' = without attachmenYenclosure = coov with attachmenvenclosure "N" = No
OFFICE RI/DRP RI/DRS RI/DRP RI/DRS
NAME DWerkheiser WCookAtVAC RBellamy/SB LDoerfleiniLTD
Via email
DATE 511212011 5t11t2011 511212011 5t13t2011
OFFICIAL RECORD COPY
P. Harden
Distribution Mencl:
W. Dean, RA
D. Lew, DRA
D. Roberts, DRP
J. Clifford, DRP
C. Miller, DRS
P. Wilson, DRS
R. Bellamy, DRP
S. Barber, DRP
C. Newport, DRP
N. Lafferty, DRP
E. Bonney, DRP, Rl
P. Garrett, DRP, Resident OA
S. Bush-Goddard, Rl, OEDO
T. Kobetz, NRR, DIRS
D. Bearde, DRS
RidsNRRPM BeaverValley Resource
RidsNrrDorlLpll -1 Resource
ROPreports Resource
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket No.: 50-334, 50-412
Report Nos.: 05000334/201 1 008 and 050004121201 10OB
Licensee: FirstEnergy Nuclear Operating Company (FENOC)
Facility: Beaver Valley Power Station, Units 1 and 2
Location: Post Office Box 4
Shippingport, PA 15077
Dates: March 31, 2011 through April 29, 2Q11
Inspectors: D. Werkheiser, Senior Resident lnspector
E. Bonney, Resident Inspector
T. Ziev, Reactor Inspector
Approved by: Lawrence T. Doerflein, Ghief
Engineering Branch 2
Division of Reactor Safety
Enclosure
SUMMARY OF FINDINGS
lR 0500033412011008 and 0500041212011008; 0313112011 -0412912011; BeaverValley Power
Station, Units 1 and 2;Temporary lnstruction 2515/183 - Followup to the Fukushima Daiichi
Nuclear Station Fuel Damage Event.
This report covers an announced Temporary lnstruction (Tl) inspection. The inspection was
conducted by two resident inspectors and a region based inspector. The NRC's program for
overseeing the safe operation of commercial nuclear power reactors is described in
NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
INSPECTION SCOPE
The intent of the Tl is to provide a broad overview of the industry's preparedness for events that
may exceed the current design basis for a plant. The focus of the Tl was on (1) assessing the
licensee's capability to mitigate consequences from large fires or explosions on site,
(2) assessing the licensee's capability to mitigate station blackout (SBO) conditions,
(3) assessing the licensee's capability to mitigate internal and external flooding events
accounted for by the station's design, and (4) assessing the thoroughness of the licensee's
walkdowns and inspections of important equipment needed to mitigate fire and flood events to
identify the potential that the equipment's function could be lost during seismic events possible
for the site. lf necessary, a more specific followup inspection will be performed at a later date.
INSPECTION RESULTS
All of the potential issues and observations identified by this inspection are contained in this
report. The NRC's Reactor Oversight Process will further evaluate any issues to determine if
they are regulatory findings or violations. Any resulting findings or violations will be documented
by the NRC in a separate report.
Enclosure
03.01 Assess the licensee's capability to mitigate conditions that result from beyond design basis events, typically bounded by
security threats, committed to as part of NRC Security Order Section B.5.b issued February 25, 2002, and severe accident
management guidelines and as required by Title 10 of the Code of Federal Regulations ('10 CFR) 50.54(hh). Use Inspection
Procedure (lP) 71111.05T, "Fire Protection (Triennial)," Section 02.03 and 03.03 as a guideline. lf lP 71111.05T was recently
performed at the facility the inspector should review the inspection results and findings to identify any other potential areas of
inspection. Particular emphasis should be placed on strategies related to the spent fuel pool. The inspectjon should include, but not
be limited to, an assessment of any licensee actions to:
Licensee Action Describe what the licensee did to test or inspect equipment.
Verify through test or Licensee actions included the identification of equipment (active and passive) utilized for
inspection that implementation of B.5.b actions and any equipment used in Severe Accident Management
equipment is available Guidelines (SAMGs). The scope of the equipment was defined as that equipment specifically
and functional. Active designated for 8.5.b or SAMG mitigation (i.e., special hoses, fittings, diesel fire pumps, etc.).
equipment shall be Permanent plant equipment (i.e., in situ equipment) was not considered in the scope, since it is
tested and passive normally in service, subjected to planned maintenance, and/or checked on operator rounds. The
equipment shall be licensee then identified surveillances/tests and performance frequencies for the identified
walked down and equipment, and reviewed the results of recent tests. Active equipment within the scope defined
inspected. lt is not above that did not have recent test results were verified to have tests planned. Passive
expected that equipment within the scope was walked down and inspected. Specific condition reports
permanently installed (CRs) are noted in the supplemental information section.
equipment that is tested
under an existing
regulatory testing Describe inspector actions taken to confirm equipment readiness (e.9., observed a test, reviewed
program be retested. test results, discussed actions, reviewed records, etc.).
Enclosure
This review should be The licensee's actions as discussed above were completed prior to the issuance of NRC Tl
done for a reasonable 2515/183. The inspectors assessed the licensee's capabilities by conducting a review of the
sample of mitigating licensee's walkdown activities. In addition, the inspectors independently walked down and
strateg ies/eq uipment. inspected all major B.5.b contingency response equipment staged throughout the site. The results
of the inspectors' independent walkdowns confirmed the results obtained by the licensee.
Discuss general results including corrective actions by licensee.
The licensee has no equipment designated for use in the SAMGs that is not considered in-situ
plant equipment. Most equipment (active and passive) designated for 8.5.b was verified by the
licensee to be in applicable procedures. Deficiencies were noted by the licensee and were
corrected. All passive equipment was walked down and verified to be in place and ready for use.
Passive equipment which had surveillance and/or preventive maintenance tasks had those
activities performed to verify readiness for use.
All active equipment located at the site was verified in place by the licensee. The licensee verified
allactive equipment had been tested satisfactory, with one exception. The licensee identified an
active component that did not have preventive maintenance or a surveillance procedure available.
The component was verified to have previously operated successfully. The licensee identified this
deficiency and entered it into the corrective action program (CAP) as CR 11-91290. The licensee
identified a number of minor inventory deficiencies and took action to document and promptly
correct.
Based on the reviews conducted, the inspectors concluded that the required equipment is
available and functional.
Describe the licensee's actions to verify that procedures are in place and can be executed (e.g.
Licensee Action
walkdowns, demonstrations, tests, etc.).
Enclosure
b. Verify through Licensee actions included the identification of those procedures utilized to mitigate the
walkdowns or consequences of a B.5.b related event and severe accidents. The licensee then compiled
demonstration that verification documentation for procedure validations and identified any procedure not issued or
procedures to implement validated and any with open change requests. Open change requests were reviewed for potential
the strategies associated impacts on procedure functionality. Licensee personnel were then dispatched to walk down all
with B.5.b and 10 CFR applicable procedures to verify the ability of the procedures to be executed.
50.54(hh) are in place
and are executable.
Licensees may choose Describe inspector actions and the sample strategies reviewed. Assess whether procedures were
not to connect or in place and could be used as intended.
operate permanently
installed equipment
during this verification. The licensee's actions as discussed above were completed prior to the issuance of NRC Tl
25151183. The inspectors assessed the licensee's capabilities by conducting a review of the
This review should be licensee's documented walkdown activities. In addition, the inspectors selected several sections
done for a reasonable of a sample of the B.5.b procedures walked down by the licensee and walked those down to
sample of mitigating independently verify the licensee's conclusions.
strategies/eq uipment.
Discuss general results including corrective actions by licensee.
Enclosure
The licensee reviewed SAMG strategies and did not identify any significant issues. Procedures
used for 8.5.b were reviewed by the licensee and walkdowns were performed by operators to
ensure actions taken in the field in response to a 8.5.b event could be performed. Open
procedure change requests were reviewed by the licensee to verify there were no immediate
procedure changes required. Some minor corrections and enhancements were identified by the
licensee and entered into the CAP:
CR 11-91338 was initiated to evaluate the creation of procedures and staging of equipment to
ensure implementation of the strategies; and CR 11-912O2was initiated for several issues related
to B.5.b procedure corrections.
Based on the reviews conducted, the inspectors concluded that the procedures to implement the
strategies associated with B.5.b and'10 CFR 50.54(hh) are in place and are executable.
Describe the licensee's actions and conclusions regarding training and qualifications of operators
Licensee Action
and support staff.
Verify the training and Licensee actions included the identification of training/qualification requirements for operators for
qualifications of the implementation of actions needed to mitigate a B.5.b related event, and for the implementation
operators and the of actions needed for the SAMGs. The licensee documented that operator training requirements
support staff needed to were current, and identified those operators with qualification requirements that were not current.
implement the ln addition, the licensee identified the training/qualification requirements for applicable emergency
procedures and work response organization (ERO) command and support staff for the implementation of actions
instructions are current needed to mitigate a B.S.b related event, and for the implementation of actions needed for the
for activities related to SAMGs, and documented that ERO command and support staff training requirements were
Security Order Section current. Where applicable, the licensee identified those ERO command and support staff with
8.5.b and severe qualification requirements that were not current.
accident management
guidelines as required by
10 cFR 50.54 (hh).
Enclosure
Describe inspector actions and the sample strategies reviewed to assess training and
qualifications of operators and support staff.
The licensee's actions as discussed above were completed prior to the issuance of NRC Tl
25151183. The inspectors assessed the licensee's training and qualification activities by
conducting a review of training and qualification materials and records related to 8.5.b and SAMG
event response.
Discuss general results including corrective actions by licensee.
The training requirements, qualifications, and associated records needed for operators for the
implementation of SAMGs and 8.5.b event response were reviewed by the licensee. Training was
identified for shift managers, shift engineers, and unit supervisors, and the licensee verified that
the training requirements were embedded within the position qualifications for the operators. The
licensee confirmed that all shift operators verify their qualifications prior to assuming a shift
position. The training requirements, qualifications, and associated records needed for ERO
command and support staff for the implementation of actions needed to mitigate a B.5.b event or
implement the SAMGs were also reviewed. All ERO command and support staff training
requirements were verified as current by the licensee with two exceptions:
. The Assistant to Emergency Director Position does not currently include training on the
severe accident management guidelines. The Assistant to Emergency Director position is
currently located in the Technical Support Center (TSC) and is a technical position.
. Some personnel are not current due to medical restrictions or long term illnesses. Training
is completed as personnel are physically able to return to their normal duties.
The licensee documented this issue as CR 11-91296 to review the gap identified with the SAMG
training for the Assistant to Emergency Director.
Enclosure
The inspectors reviewed the licensee's assessment and corrective actions, and completed an
independent assessment. Based on these actions, the inspectors concluded that the training and
qualifications of operators and the support staff needed to implement the procedures and work
instructions are current for activities related to Security Order Section 8.5.b and severe accident
management guidelines as required by 10 CFR 50.54 (hh).
Describe the licensee's actions and conclusions regarding applicable agreements and contracts
Licensee Action
are in place.
d. Verify that any Licensee actions included the identification of all applicable contracts and agreements committed
applicable agreements to be in place for the mitigation of a B.5.b related event. The licensee verified that the contracts
and contracts are in and agreements were current, and documented whether or not the contracts/agreements were
place and are capable of capable of meeting the mitigation strategy.
meeting the conditions
needed to mitigate the
consequences of these For a sample of mitigating strategies involving contracts or agreements with offsite entities,
events. describe inspector actions to confirm agreements and contracts are in place and current (e.9.,
confirm that offsite fire assistance agreement is in place and current).
This review should be
done for a reasonable
sample of mitigating The licensee's actions as discussed above were completed prior to the issuance of NRC Tl
25151183. The inspectors assessed the licensee's capabilities by conducting an independent
strategies/eq uipment.
review of the licensee's emergency response letters of agreement with the Beaver County
Emergency Management Agency. The inspectors' review of the agreement verified that it was
current, and assessed whether or not it was adequate for meeting the licensee's mitigation
strategy. The inspectors also verified that letters of agreement were in place with the surrounding
three states and local counties.
Discuss general results including corrective actions by licensee.
' Enclosure
The licensee determined that agreements and contacts were in place and current. No deficiencies
were noted. The inspectors concluded that applicable agreements and contracts are in place and
are capable of meeting the conditions needed to mitigate the consequences of these events.
Document the corrective action report number and briefly summarize problems noted by the
Licensee Action
licensee that have significant potential to prevent the success of any existing mitigating strategy.
e. Review any open FENOC determined no significant issues were identified. However, the licensee identified that
corrective action preventive maintenance (PM) activities and a surveillance procedure were currently not available
documents to assess for an active component utilized in a 8.5.b mitigation strategy. The component had previously
problems with mitigating operated successfully and the issue has been entered in the CAP under CR 11-91290. Other
strategy implementation minor issues were identified and documented in the CRs listed in the Supplemental Information.
identified by the The inspectors reviewed the CRs and determined there was not a significant impact to any
licensee. Assess the existing mitigating strategy.
impact of the problem on
the mitigating capability
and the remaining
capability that is not
impacted.
03.02 Assess the licensee's capability to mitigate station blackout (SBO) conditions, as required by 10 CFR 50.63, "Loss of All
Alternating Current Power," and station design, is functional and valid. Refer to Tl 25151120, "lnspection of lmplementation of
Station Blackout Rule Multi-Plant Action ltem A-22" as a guideline. lt is not intended that Tl 25151120 be completely reinspected.
The inspection should include, but not be limited to, an assessment of any licensee actions to:
Describe the licensee's actions to verify the adequacy of equipment needed to mitigate an SBO
Licensee Action
event.
Enclosure
a. Verify through Licensee actions included the identification of equipment utilized/required for mitigation of a SBO.
walkdowns and The licensee then conducted walkdowns to ensure this equipment was adequate and properly
inspection that all staged. Additionally, the licensee also conducted a review of open CAP items for potential SBO
required materials are equipment impact.
adequate and properly
staged, tested, and
maintained. Describe inspector actions to verify equipment is available and useable.
The inspectors assessed the licensee's capability to mitigate SBO conditions by conducting a
review of the licensee's walkdown activities. ln addition, the inspectors selected a sample of
equipment utilized/required for mitigation of a SBO and conducted independent walkdowns of that
equipment to verify that the equipment was properly aligned and staged. The sample of
equipment selected by the inspectors included, but was not limited to, the SBO cross{ie and
Emergency Response Facility (ERF) diesel generator and related infrastructure.
Discuss general results including corrective actions by licensee.
The above reviews verified that SBO equipment was ready to respond to a SBO condition.
However, the inspectors noted that challenges exist due to current UPS failures that support the
ERF diesel generator, requiring extra procedure actions to power ERF buses. The licensee has
entered this issue into the CAP and plans to repair the equipment deficiency
The licensee initiated two conditions reports for issues identified during the walkdowns: CR 11-
91206, Manual charging spring toolfor 4kV breakers could not be found, and no ladder staged in
intake "C" cubicle for accessing required valves; and CR 11-91347, Components to open HW-
1FW-1OOA(BXC) insufficiently labeled to ensure proper connections. The inspectors determined
these issues would not have prevented successful implementation of SBO procedures.
Enclosure
Licensee Action Describe the licensee's actions to verify the capability to mitigate an SBO event.
b. Demonstrate through Licensee actions included the identification of procedures required for response to a SBO, along
walkdowns that with verification that the identified procedures were current and that no critical revision requests
procedures for response were in place. The licensee then verified that the mitigating procedures had been properly
to an SBO are validated and performed walkdowns of selected procedures. Additionally, the licensee conducted
executable. a review of open CAP items for potential impact to SBO procedures.
Describe inspector actions to assess whether procedures were in place and could be used as
intended.
The inspectors assessed the licensee's capabilities by conducting a review of the licensee's
walkdown activities. In addition, the inspectors selected several sections of a sample of the
procedures walked down by the licensee and walked those down to independently verify the
licensee's conclusions.
Discuss general results including corrective actions by licensee.
The licensee procedures utilized to respond to an SBO are within the scope of the site emergency
operating procedures (EOPs). Actions to start the SBO diesel generator (a functional EDG on the
non-affected unit) and supply power to the affected-unit vital buses are performed from the control
room (as augmented with field actions) with permanently installed plant equipment. For the
purposes of this requirement, the licensee credited their original validation of the specific EOP by
a crew of licensed operators on the simulator prior to the implementation of the current revision.
No significant current issues were identified by the licensee, however three CRs were written to
document minor issues and/or areas for improvement (CRs 11-91263,11-91353, and 11-91356).
Enclosure
Although the station meets the current design and licensing bases for station blackout, the
inspectors concluded that coping with a dual unit SBO (a beyond design basis event) could
present significant challenges. For example: the SBO cross-tie equipment is located in non-
seismically qualified areas (normal switchgear) of each unit; and Unit 1 requires AC power to the
MOVs to isolate the safety injection accumulators during RCS depressurization.
The licensee documented the general issue of a dual unit SBO under CR 1 1-93717.
03.03 Assess the licensee's capability to mitigate internal and external flooding events required by station design. Refer to lP
71111.01, "Adverse Weather Protection," Section 02.04, "Evaluate Readiness to Cope with External Flooding" as a guideline. The
inspection should include, but not be limited to, an assessment of any licensee actions to verify through walkdowns and inspections
that all required materials and equipment are adequate and properly staged. These walkdowns and inspections shall include
verification that accessible doors, barriers, and penetration seals are functional.
Describe the licensee's actions to verify the capability to mitigate existing design basis flooding
Licensee Action
events.
a. Verify through Licensee actions included the identification of equipment and penetration seals utilized/required
walkdowns and for mitigation of internal and external flooding. The licensee then conducted walkdowns of this
inspection that all equipment to ensure it was adequate and properly staged. Doors, barriers, and penetration seals
required materials are that were utilized for mitigation of flooding were identified, and checked to see if they were
adequate and properly routinely inspected to ensure functionality. Where routine inspections were not performed or could
staged, tested, and not be relied upon to ensure functionality, the licensee performed walkdowns and inspections to
maintained. ensure that the components were functional.
Describe inspector actions to verify equipment is available and useable. Assess whether
procedures were in place and could be used as intended.
Enclosure
The inspectors assessed the licensee's capabilities to mitigate flooding by conducting a review of
the licensee's walkdown activities. In addition, the inspectors conducted independent walkdowns
of selected flood mitigation equipment to contribute to the overall assessment of the licensee's
flood mitigating capabitities. Licensee flood mitigation procedures were reviewed to verify
usability. The inspectors' conclusions aligned with the results obtained by the licensee.
Discuss general results including corrective actions by licensee.
The inspectors concluded that all required materials are adequate and properly staged, tested,
and maintained to respond to an internal or external flood within the plant's design basis. While
no operability or significant concerns were identified, the licensee identified that two portable
pumps credited in the flood analysis did not have periodic testing performed, and that flood
barriers and penetrations that were not part of the fire protection program were not routinely
inspected. These and several other minor deficiencies were entered into the CAP and the
associated condition reports are listed in the Attachment to this report. The inspectors reviewed
these condition reports and determined the licensee's initial responses, including their assessment
and prioritization, were appropriate.
Enclosure
03.04 Assess the thoroughness of the licensee's walkdowns and inspections of important equipment needed to mitigate fire and
flood events to identify the potential that the equipment's function could be lost during seismic events possible for the site. Assess
the licensee's development of any new mitigating strategies for identified vulnerabilities (e.9., entered it in to the corrective action
program and any immediate actions taken). As a minimum, the licensee should have performed walkdowns and inspections of
important equipment (permanent and temporary) such as storage tanks, plant water intake structures, and fire and flood response
equipment; and developed mitigating strategies to cope with the loss of that important function. Use lP 71111.21, "Component
Design Basis lnspection," Appendix 3, "Component Walkdown Considerations," as a guideline to assess the thoroughness of the
licensee's walkdowns and inspections.
Describe the licensee's actions to assess the potential impact of seismic events on the availability
Licensee Action
of equipment used in fire and flooding mitigation strategies.
a. Verify through Licensee actions included the identification of equipment utilized/required for mitigation of fire and
walkdowns that all flood events. An engineering inspection plan was established by the licensee to govern the
required materials are conduct of walkdowns and inspections of the equipment, both permanent and temporary.
adequate and properly Licensee engineering personnel determined if the equipment was seismically qualified, or
staged, tested, and assessed whether it would be possible to evaluate the equipment as being seismically rugged.
maintained. Seismic vulnerabilities, including storage locations, were identified, along with mitigating strategies
for equipment that was not seismically qualified.
Describe inspector actions to verify equipment is available and useable. Assess whether
procedures were in place and could be used as intended.
Enclosure
The inspectors conducted multiple independent walkdowns of important equipment needed to
mitigate fire and flood events to identify the potential that the equipment's function could be lost
during a seismic event. This equipment included, but was not limited to:
. all major B.5.b contingency response equipment staged throughout the site;
. the installed diesel and electric fire pumps, their controls, and other fire equipment;
r the Emergency Response Facility diesel generator; and
o watertight doors and floor plugs at the plant's main and alternate intake structures.
Licensee flood and fire mitigation procedures were reviewed to verify usability. The results of the
inspectors' reviews aligned with the licensee's conclusions that there were a number of seismic
vulnerabilities that may need to be addressed, as described below. The inspectors concluded that
the licensee meets the current design and licensing bases for B.5.b, fire and flood protection.
Discuss general results including corrective actions by licensee. Briefly summarize any new
mitigating strategies identified by the licensee as a result of their reviews.
"Seismically qualifled" is defined as the SSCs that have been formally qualified to function during
and after a design basis earthquake, as applicable. The licensee's reviews for this issue
determined that non-safety related SSCs, in general, were not considered to be either seismically
qualified or seismically rugged. The majority of room flood mitigation sump pumps and flooding
detectors were not designed as seismically qualified, and have not been evaluated as being
seismically rugged. Similarly, the vast majority of the fire protection system / piping, including both
installed fire pumps, were not designed as seismically qualified and cannot be considered
seismically rugged. Firefighting equipment staged to respond to 8.5.b events was not stowed in
seismically qualified buildings and locations, as a seismic event and 8.5.b event were not
assumed to occur coincidentally.
The licensee's reviews identified instances where response capability could be enhanced. These
included improving procedural guidance, reviewing the locations of portable equipment, and
reviewing the need for supplemental portable equipment to compensate for the possible loss of
the fire water storage tank, the fire pumps, and much of the fire suppression system pipinq.
Enclosure
Further, reviews by the licensee identified that, in the event of a postulated earthquake, equipment
may not function properly due to loss of vital power or being subjected to physical displacement.
The existing mitigation strategy, to conduct station surveys per emergency plan off normal
occurrence procedure RA-EP-02820, "Earthquake," was considered presently sufficient by the
licensee. Further mitigation strategies, the licensee determined, will entailfollowing industry
recommendations from other plants that have identified similar beyond-design-bases
vulnerabilities. The licensee entered the issues identified into their CAP CRs 11-92571. and
11-93717.
Enclosure
Meetinqs
40A6 Exit Meetinq
The inspectors presented the inspection results to Mr. Paul Harden and other members
of licensee management at the conclusion of the inspection on April 29,2011. The
inspectors asked the licensee whether any materials examined during the inspection
should be considered proprietary. No proprietary information was identified.
15 Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
P. Harden, Site Vice President, Beaver Valley Power Station
R. Lieb, Director of Site Operations, Beaver Valley Power Station
G. Cramer, Manager, Emergency Response
C. Hynes, Manager, Site Training
C. Mancuso, Manager, Design Engineering
C. McFeaters, Manager, Operations
J. Miller, Site Fire Marshal
D. Price, Supervisor, Design Engineering
M. Ressler, Supervisor, Engineering Analysis
B. Rudolph, Superintendent, Operations Training
K. Woessener, Staff Nuclear Engineer, Beaver Valley IER 11-1 Response Team Lead
Nuclear Requlatory Commission
C. Cahill, Senior Reactor Analyst
W, Cook, Senior Reactor Analyst
Other Personnel
L. Ryan, Inspector, Pennsylvania Bureau of Radiation Protection
LIST OF DOCUMENTS REVTEWED
The following is a list of documents reviewed during the inspection. Inclusion on this list does
not imply that the NRC inspectors reviewed the documents in their entirety but rather that
selected'sections of portions of the documents were evaluated as part of the overall inspection
effort. Inclusion of a document on this list does not imply NRC acceptance of the document or
any part of it, unless this is stated in the body of the inspection report.
03.01 Assess the licensee's capability to mitigate conditions that result from beyond
design basis events
Procedures:
1/2OM-53C.4A.100.1, 8.5.b and Threat-Related Mitigation Procedures, Rev. 2
1/2OM-53C.4A.100.2, B.5.b and Threat-Related Mitigation Procedures, Rev. 3
1/2OM-53C.4A.100.3, 8.5.b and Threat-Related Mitigation Procedures, Rev. 2
1/2OM-53C.4A.100.4, 8.5.b and Threat-Related Mitigation Procedures, Rev. 4
Attachment
A-2
1/2OM-53C.4A.100.5, B.5.b and Threat-Related Mitigation Procedures, Rev. 0
1/2OM-53C.4A.100.6, B.5.b and Threat-Related Mitigation Procedures, Rev. 5
1/2OST-33.33, Fire Protection Equipment lnventory, Rev.4
2OM-53A.1.A-1.8, Makeup to PPDWST [2FWE.TK210l, Rev.5
2OM-53A.1.A-1.11, Manual Handpump Operation of Hydraulically Actuated Valves, Rev. 5
Condition Reports:
11-91202,100 Series AOPs Missing Steps
11-91206, Missing Tools/Ladders to Support SBO Response
11-91260,100 Series AOPs Missing lnventory
11-91261, 1/2OST-33.33 Attachment 6 Deficiencies
11-91290, Active Component Without PM
1 1 -91294, Missing Flashlights
11-91296, Assistant to Emergency Director Training on SAMGs
1 1-91319, Operations Training for Security Threat
1 1 -9 1 325, Phone-Control Room Satel ite Coverage
I
1 1-91338, Equipment and Procedures not Designated for 8.5.b
1 1-91345, Equipment Availability lssues
11-93575, High-Pressure Godwin Pump Duplex Strainer Operation lssues
03.02 Assess the licensee's capability to mitigate station blackout (SBO) conditions
Procedures:
1OM-53A.1.ECA-0.0(lSS1C), Loss of all Emergency 4kV AC Power, Rev. 8
1OM-S3A.1.ECA-g.1(lSS1C), Loss of allAC Power RecoveryWithout Sl Required, Rev.5
1OM-53A.1 .ECA-0.2(ISS1C), Loss of all AC Power Recovery With Sl Required, Rev. 5
1OM-53A.1.2-D, AC Power Restoration from Offsite, Rev.2
1OM-53A.1 .2-E(ISS1 C), Local Action to Restore AC Power, Rev. 3
1OM-S3A.1.2-F(lSS1C), Diesel GeneratorAuto Loading and Auxiliary Equipment, Rev.2
1OM-53A.1.2-G(lSS1C), Natural Circulation Verification, Rev. 1
1OM-53A.1.2-H(lSS1C), Makeup to PPDWST [1WT-TK-10], Rev. 2
1OM-53A.1.2-1, Response to Loss of AFW Pump Suction Flow, Rev. 1
1OM-53A.1.2-J(lSS1C), Feeding Steam Generators from Condensate System, Rev. 1
1OM-53A.1.2-K(lSS1C), Dedicated AFW Pump [1FW-P-4] Startup, Rev. 1
1OM-S3A.1.2-O-AE(ISS1C), Starting River Water Pump on Bus 1AE During SBO, Rev. 0
1OM-S3A.1.2-O-DF(lSS1C), Starting RiverWater Pump on Bus 1DF During SBO, Rev.0
1OM-S3A.1.2-P-AE(lSS1C), Starting Charging/HHSI Pump on Bus 1AE During SBO, Rev. 0
1OM-53A.1.2-P-DF(lSS1C), Starting Charging/HHSI Pump on Bus 1DF During SBO, Rev.0
1OM-S3A.1 .2-O-AE(lSS1C), Restoring Equipment from Bus 1AE after SBO at BV-1, Rev. 0
1OM-S3A.1 .2-O-DF(lSS1C), Restoring Equipment from Bus 1 DF after SBO at BV-1 , Rev. 0
1OM-53A.1.2-S(lSS1C), Monitoring AFW Pump Performance During Loss of Station Instrument
Air, Rev.3
1OM-S3A.1 .2-T, Opening One SG Main FW Containment lsolation Valve Without Power, Rev' 0
1OM-53A.1.2-U, Local Operation of SG Atmospheric Steam Dump Valves, Rev- 1
1OM-S3A.1 .A-1.14(lSS1C), BV-1 Actions to Establish SBO Cross-Tie to BV-2, Rev. 2
1 OM-53A.1 .A-1 .1 7(lSS1 C), Restoring BV-1 Equipment after SBO at BV-2,
Rev. 0
Attachment
A-3
1OM-53A.1.2-M-AE, Actions to Establish BV-2 Cross-tie to Bus 1AE During SBO, Rev. 3
2OM-53A.1.ECA-0.0(ISS1C), Loss of all AC Power, Rev. 10
2OM-53A.1.ECA-O.1(lSS1C), Loss of all AC Power Recovery Without Sl Required, Rev. 7
2OM-53A.1.ECA-0.2(lSS1C), Loss of all AC Power Recovery With Sl Required, Rev. 5
2OM-53A.1.2-N(1SS1C), BV-2 Actions to Establish SBO Cross-Tie to BV-1, Rev. 1
2OM-53A.1.2-N(1SS1C), BV-2 Actions to Establish SBO Cross-Tie to BV-1, Rev. 1
2OM-53A.1.2-R(ISS1C), Restoring BV-2 Equipment after SBO at BV-1, Rev. 0
2OM-53A.1.A-1.10(lSS1C), Feeding Steam Generators from Condensate System, Rev. 0
2OM-53A.1.A-1.1 1, Manual Handpump Operation of Hydraulically Actuated Valves, Rev. 5
2OM-53A.1.A-1.12, Local Actions to Restore AFW Flow, Rev. 4
2OM-53A.1.A-1.15AE, Starting Charging/HHSI Pump on BUS 2AE During SBO, Rev. 0
2OM-53A.1.A-1.1SDF, Starting Charging/HHSI Pump on BUS 2DF During SBO, Rev.0
2OM-53A.1.A-1.16AE, Restoring BV-2 Equip from Bus 2AE after SBO at BV-2, Rev. 1
2OM-53A.1.A-1.16DF, Restoring BV-2 Equip from Bus 2DF after SBO at BV-2, Rev. 1
2OM-53A.1 .A-1 .1 8(lSS1 C), ERFS Diesel Generator Startup, Rev. 0
2OM-53A.1 .A-1.4, AC Power Restoration from Offsite, Rev. 1
2OM-53A.1.A-1.5(lSS1C), LocalAction to Restore AC Power, Rev. 5
2OM-53A.1.A-1.6, GeneratorAuto Loading and Auxiliary Equipment, Rev' 3
2OM-53A.1.A-1.8, Makeup to PPDWST [2FWE.TK21O), Rev' 5
2DD.ECA-0.2, Loss of All AG Power Recovery with Sl Required Deviation Document, Rev. 1C-5
2OM-53A.1 .A-1.15AE, Starting Charging/HHSI Pump on Bus 2AE During an SBO, Rev. 1C-0
2OM-53A.1.ECA-0.0, Loss of AIIAC Power, Rev. 1C-10
2OM-53A.a.A-1.13AE, Actions to Establish BV-1 Cross-Tie to Bus 2AE During SBO, Rev. 2
2OM-53A.a.A-1.22, Steam Generator Makup During SBO Using [3FP-P-7], Godwin High-
Pressure Pump, Rev. 0
Condition Reports:
1 1-91263, SBO Procedure Corrections
11-91347, EOP Attachment 2-T lssues ldentified During Walkdown
11-91353, U2 Lighting Deficiency at ASD Panel
1 1-91356, Pre-staged SBO Equipment lmprovements
11-91549, Testing lssues for 1RW-60 and 2SWS-60
11-91671, Equipment Needed for AOP 75.2 Not Staged
11-92242, ERFS - UPS#2 Failure
11-93717*, lnspector Questions BVPS Dual Unit SBO Assumptions
- Condition Report written as a result of inspection.
Calculations/Evaluations:
10080-E-048, SBO Loading Analysis, Rev. 12-AB
Attachment
A-4
03.03 Assess the licensee's capability to mitigate internal and external flooding events
required by station design
Procedures:
1/2OM-53C.4A.75.2, Acts of Nature - Flood, Rev. 28
1i2OM-53C.4A.75.4, Acts Of Nature - Dam Failure, Rev. 7
1BVT1.33.07, Flood Seals Visual Inspection, Rev. 4
1OM-30.4.AAA, CC WTR HT EXCH RiverWTR PP DISH Line'A'Press Low, Rev. l3-R2
1OM-30.4.AA8, CC WTR HT EXCH River WTR PP DISH Line 'B' Press Low, Rev. l3-R2
1OM-30.4.AAC, Intake Struct Water Pump Discharge Line'A' Press Low, Rev. 3
1OM-30.4.AAD, Intake Struct River Water Pump Discharge Line 'B' Pressure Low, Rev. l3-R2
1OM-36.4.AEY, Diesel Generator Room No. 1 or No. 2 Sump Level High, Rev. 0
1OM-41D.4.AA8, Service Building Water Accumulation, Rev. 5
1OM-9.4.AA1, Aux Bldg Well Sump Level High, Rev. 1
1OM-9.4.AAJ, Aux Building North Sump Level High, Rev. 2
1OM-9.4.AAK, Tunnel Sump Level High, Rev. 3
1OM-9.4.AAM, Safeguards Area Sump Level High, Rev. 0
1OM-9.4.AAN, Fuel Building Sump Level High, Rev. 2
1OM-9.4.AAO, Aux Building South Sump Level High, Rev. 1
1OM-9.4.AAQ, Charging Pump 1A Cubicle Sump Level High, Rev. 0
1OM-9.4.AAR, Charging Pump 1B Cubicle Sump Level High, Rev.0
1OM-9.4.AAS, Charging Pump 1C Cubicle Sump Level High, Rev. 1
28l/l1.33.7, Flood Seals Visual Inspection, Rev. 3
2OM-41D.4.AAA, Diesel Generator Building Sump Level High, Rev' 3
2OM-41D.4.AAF, Elect Cable Tunnel/Contiguous Area Sump Level High, Rev. 6
2OM-9,4.AAE, Fuel Building Sump Level High, Rev. 2
2OM-9.4.AAH, Rod ControlArea Pipe Tunnel Sump Level High, Rev. 3
2OM-9.4.AA1, Auxiliary Building Sump Level High, Rev. 2
2OM-9.4.AAJ, Safeguards Area Sump Level High, Rev. 1
2OST-33.35A, Fire Rated Penetration Seals Visual lnspection Outage Required, Rev. 0
Condition Reports:
11-91736, No Procedure for Intake Structures Pump Cubicle Internal Flooding Response
11-91840, Flood Seal Inspection BWs Require Revision
11-91843, Unit 1 Internal Conduit Flood Seals lnaccessible for Inspection
1 1-91846, Unit 2 Flood Seals Inaccessible for Inspection
11-91853, Periodic Flood Seal Inspections by BWs Not Performed Since 2005
11-91860, Review of Open Orders for Flood Seal lmpact
1 1 -91887, Flood Equipment ldentified Without Inventory/OST
'11-91890, Flood Door Not Electronically Supervised and Not Periodically Verified
1 1-91894, Credited Door Not Supervised and Not Periodically Verified
11-91899, Undesignated Flood Barriers in BVPS -1 Main Steam Valve Area
11-91900, BVPS 1 & 2 Sump Level Switches Not in Calibration Program
11-92062, Credited Floor Drains do Not Have a PM Task
11-92065, Passive Flood Barriers are Not Specified in Admin Procedure
Attachment
A-5
Calculations/Evaluations:
ES-M-036, Report of the Effects of a Piping System Break Outside Containment, Rev. 0
Drawinqs:
8700-RA-19A, Intake Structure, Plan & Elevation, Rev. I
8700-RA-198, Intake Structure, Wall Sections & Details, Rev. 9
Other:
BVPS-1 UFPARR, BVPS-1 Updated Fire Protection Appendix R Review, Rev. 30
BVPS-1 UFSAR Section 2J.3.2.5, Other Plant Areas and Equipment, Rev. 25
BVPS-1 UFSAR Section 9.7.2, Vent and Drain System Description, Rev.25
BVPS-2 FPSSR, BVPS-2 Fire Protection Safe Shutdown Report, Rev. 36
03.04 Assess the thoroughness of the licensee's walkdowns and inspections of
important equipment needed to mitigate fire and flood events to identify the
potential that the equipment's function could be lost during seismic events
Procedures:
1OM-30.4.AAA, CC WTR HT EXCH River WTR PP DISH Line 'A' Press Low, Rev. l3-R2
1OM-30.4.AAC, Intake Struct Water Pump Discharge Line 'A' Press Low, Rev. 3
1OM-53E.1.SAG-2, Depressurize the RCS, Rev. 3
1OM-53A.1.E-0(lSS1C), Reactor Trip or Safety Injection, Rev. 11
1OM-53A.1.E-1(lSS1C), Loss of Reactor or Secondary Coolant, Rev. 14
1OM-53A.1.FR-C.1(lSS1C), Response to lnadequate Core Cooling, Rev. 8
1OM-53A.1.FR-l.3(lSS1C), Response to Voids in Reactor Vessel, Rev. 6
1OM-53A.1.FR-S.2(lSS1C), Response to Loss of Core Shutdown, Rev. 1
1OM-53A.1 .FR-2.1(lSS1C), Response to High Containment Pressure, Rev' 2
1OM-53A.1.FR-Z.2(lSS1C), Response to Containment Flooding, Rev. 2
2OM-53E.1.SAG-2, Depressurize the RCS, Rev.2
2OM-53A.1.E-0(lSS1C), Reactor Trip or Safety Injection, Rev. 8
2OM-53A.1 .E-1(lSS1C), Loss of Reactor or Secondary Coolant, Rev. 12
2OM-53A.1.FR-C.1(1SS1C), Response to Inadequate Core Cooling, Rev. 5
2OM-53A.1.FR-l.3(lSS1C), Response to Voids in Reactor Vessel, Rev. 8
2OM-53A.1.FR-S.2(ISS1C), Response to Loss of Core Shutdown, Rev' 1
2OM-53A.1.FR-Z.1(lSS1C), Response to High Containment Pressure, Rev. 2
2OM-53A.1.FR-2.2(lSS1C), Response to Containment Flooding, Rev. 2
2OM-53A.1.FR-Z.3(lSS1C), Response to High Containment Radiation Level, Rev. 2
Condition Reports
11-91720, Buried Fire Protection Piping Vulnerability
11-91794, Potential For lnadvertent CO2 Discharge with Seismic Event
11-91922, Storage for Beyond Design Basis Equipment Lacks Quality
11-92160, Material Condition of Portable Diesel Fire Pumps
11-92343, Fire Line Corrosion ldentified During Inspection
Attachment
A-6
11-92388, Fire Protection System Vulnerabilities During a Seismic Event
11-92393, Unit 1 Fire Protection Systems Inaccessible for lnspection
11-92394, Specific Fire Protection Deficiencies ldentified During Walkdown
11-92415, Vulnerabilities During a Flood Event Following an Earthquake
11-92531, Aggregate lmpact Evaluation BVPS OSS Fire Protection Equipment
Other:
Active and Passive Equipment Credited Inventory Spreadsheet,3l23l11
Basic Instruction Card for Godwin Low Pressure Driven Prime Pump
BV-1 & BV-2 Updated Final Safety Analysis Reports, Rev. 23 & 6
BV-1 Shift Operations Logs Regarding ERFS UPS lssues,4l2ll1
Mutual Response Agreements, current as of 4128111
LIST OF ACRONYMS USED
ADAMS Agencyruide Documents Access and Management System
ARM Area Radiation Monitors
CAM Continuous Air Monitors
CAP Corrective Action Program
CFR Code of Federal Regulations
NRC United States Nuclear Regulatory Commission
SBO Station Blackout
Attachment