ML111310328

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IR 05000334/2011008 and 05000412/2011008; 03/31/2011 - 04/29/2011; Beaver Valley Power Station, Units 1 and 2; Temporary Instruction 2515/183 - Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event
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

License Nos.: DPR-66, NPF-73

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

License Nos.: DPR-66, NPF-73

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

D. Werkheiser, DRP, SRI

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

License No.: DPR-66, NPF-73

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

AFW Auxiliary Feedwater

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