IR 05000334/2013008

IR 05000334-13-008 and 05000412-13-008; 11/18/2013 - 12/06/2013; Beaver Valley Power Station, Units 1 and 2; Biennial Baseline Inspection of Problem Identification and Resolution

ML14016A414
Person / Time
Site:	Beaver Valley
Issue date:	01/16/2014
From:	Cook W NRC/RGN-I/DRP/PB6
To:	Emily Larson FirstEnergy Nuclear Operating Co
COOK, WA
References
IR-13-008
Download: ML14016A414 (24)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ary 16, 2014

SUBJECT:

BEAVER VALLEY POWER STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000334/2013008 AND 05000412/2013008

Dear Mr. Larson:

On December 6, 2013, the United States Nuclear Regulatory Commission (NRC) completed an inspection at your Beaver Valley Power Station, Units 1 and 2. The enclosed report documents the inspection results, which were discussed on December 6, 2013, with you and other members of your staff.

This inspection examined activities conducted under your license as they relate to identification and resolution of problems and compliance with the Commissions rules and regulations and conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.

Based on the samples selected for review, the inspectors concluded that FirstEnergy Nuclear Operating Company (FENOC) was generally effective in identifying, evaluating, and resolving problems. FENOC personnel identified problems and entered them into the corrective action program at a low threshold. FENOC prioritized and evaluated issues commensurate with the safety significance of the problems and corrective actions were generally implemented in a timely manner.

This report documents one NRC-identified finding of very low safety significance (Green). The inspectors determined that this finding also involved a violation of NRC requirements. However, because of the very low safety significance and because it was entered into your corrective action program, the NRC is treating this finding as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest this non-cited violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC

E. Lorson 2 Resident Inspector at Beaver Valley Power Station. In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response, within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at Beaver Valley Power Station.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

William A. Cook, Acting Chief Reactor Projects Branch 6 Division of Reactor Projects Docket Nos.: 50-334, 50-412 License Nos.: DPR-66, NPF-73

Enclosure:

Inspection Report 05000334/2013008 and 05000412/2013008 w/Attachment: Supplementary Information

REGION I==

Docket Nos.: 50-334, 50-412 License Nos.: DPR-66, NPF-73 Report No.: 05000334/2013008 and 05000412/2013008 Licensee: FirstEnergy Nuclear Operating Company (FENOC)

Facility: Beaver Valley Power Station, Units 1 and 2 Location: Shippingport, PA 15077 Dates: November 18 to December 6, 2013 Team Leader: D. Kern, Senior Reactor Inspector Inspectors: A. Bolger, Project Engineer E. Carfang, Resident Inspector T. OHara, Reactor Inspector Approved by: W. Cook, Chief (Acting)

Reactor Projects Branch 6 Division of Reactor Projects Enclosure

SUMMARY

IR 05000334/2013008 and 05000412/2013008; 11/18/2013 - 12/06/2013; Beaver Valley Power

Station, Units 1 and 2; Biennial Baseline Inspection of Problem Identification and Resolution.

The inspectors identified one finding in the area of effectiveness of corrective actions.

This NRC team inspection was performed by three regional inspectors and one resident inspector. The inspectors identified one finding of very low safety significance (Green) during this inspection and classified this finding as a non-cited violation. The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process, dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Components Within Cross-Cutting Areas, dated October 28, 2011. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated July 9, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4.

Problem Identification and Resolution The inspectors concluded that FENOC was generally effective in identifying, evaluating, and resolving problems. FENOC personnel identified problems, entered them into the corrective action program (CAP) at a low threshold, and prioritized issues commensurate with their safety significance. Notwithstanding, the inspectors identified several examples of low significance deficiencies which had not been entered into the CAP, despite meeting FENOCs criteria for entry into the CAP. In most cases, FENOC appropriately screened issues for operability and reportability, and performed causal analyses that appropriately considered extent-of-condition, generic issues, and previous occurrences. The inspectors identified one violation of NRC requirements in the area of problem evaluation. The inspectors also determined that FENOC typically implemented corrective actions to address the problems identified in the corrective action program in a timely manner.

The inspectors concluded that, in general, FENOC adequately identified, reviewed, and applied relevant industry operating experience to Beaver Valley operations. In addition, based on those items selected for review, the inspectors determined that FENOCs self-assessments and audits had appropriate scope and generally identified meaningful findings for site improvement.

Based on the interviews the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual corrective action program and employee concerns program issues, the inspectors did not identify any indications that site personnel were unwilling to raise safety issues nor did they identify any conditions that could have had a negative impact on the sites safety conscious work environment.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a finding of very low safety significance involving a non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, related to FENOCs problem identification and corrective action to address the November 2011 failure of steam driven auxiliary feedwater (SDAFW) pump steam supply valve 2MSS-SOV105C.

Specifically, the inspectors identified that FENOC did not promptly identify and correct the elevated valve temperature condition that led to the coil failure of a solenoid operated steam admission valve for the SDAFW pump. Consequently, 2MSS-SOV105C failed again on

June 19, 2012, due to solenoid insulation damage which resulted from elevated valve temperature. FENOC entered this issue into the corrective action program for resolution as condition report 2013-19448, updated procedures to evaluate elevated temperatures on SDAFW pump steam admission valves, and initiated condition report 2013-19250 to evaluate the adequacy of planned maintenance on the valves.

The finding was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, FENOC did not ensure that adequate operational margin was available when 2MSS-SOV105C steam leak-by caused the valve actuator solenoid temperature to exceed 356F. Consequently, seven months following the valve actuator solenoid coil replacement, coil insulation degraded and rendered 2MSS-SOV105C inoperable and unavailable. In accordance with IMC 0609.04, Initial Characterization of Findings, and IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, dated June 19, 2012, the inspectors determined that this finding was of very low safety significance (Green). This finding has a cross-cutting aspect in the area of Human Performance, Resources, because FENOC did not ensure that personnel, equipment, procedures, and other resources were available and adequate to support operability of safety-related equipment. Specifically, design margin was not maintained for a safety-related solenoid-operated valve which resulted in its failure and the long-standing equipment issue of leak-by past the valve was not addressed through adequate monitoring and preventive maintenance of the valve solenoid. H.2(a) [Section 4OA2.1.c]

REPORT DETAILS

4OA2 Problem Identification and Resolution

This inspection constitutes one biennial sample of problem identification and resolution as defined by Inspection Procedure 71152. All documents reviewed during this inspection are listed in the Attachment to this report.

.1 Assessment of Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the procedures that described FENOCs corrective action program (CAP) at Beaver Valley Power Station. FENOC used two separate processes to identify, track, and resolve issues. Those issues determined to be Adverse Conditions (i.e., any event, defect, characteristic, state, activity, or condition that could credibly impact nuclear safety, personnel safety, plant reliability, or non-compliance with federal, state, or local regulations) were documented in condition reports (CRs) and addressed using NOP-LP-2001, Corrective Action Program, Revision 32. Issues not considered adverse conditions (e.g., engineering evaluations, operating experience reviews, lessons learned, procurement evaluations, minor equipment deficiencies, maintenance actions, and document change requests) were documented in notifications and addressed using NOP-SS-8001, FENOC Activity Tracking, Revision 1.

To assess the effectiveness of the corrective action program, the inspectors reviewed performance in three primary areas: problem identification, prioritization and evaluation of issues, and corrective action implementation. The inspectors compared performance in these areas to the requirements and standards contained in 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, and FENOC procedures NOP-LP-2001 and NOP-SS-8001. For each of these areas, the inspectors considered risk insights from the stations risk analysis and reviewed CRs and notifications for the period June 2011 to September 2013 selected across the seven cornerstones of safety in the Reactor Oversight Process. Additionally, the inspectors attended multiple Management Ownership and Alignment, Management Review Board, Corrective Action Review Board, and shift turnover meetings. The inspectors selected items from the following functional areas for review: engineering, operations, maintenance, emergency preparedness, radiation protection, physical security, and oversight programs.

(1) Effectiveness of Problem Identification In addition to the items described above, the inspectors reviewed system health reports, a sample of completed corrective and preventative maintenance work orders, completed surveillance test procedures, operator logs, and periodic trend reports. The inspectors also performed field walkdowns of various systems on site, such as the service water, river water, 120 volt direct current power, auxiliary feedwater, fire protection, control room ventilation, and switchgear room ventilation. Additionally, the inspectors reviewed a sample of CRs written to document issues identified through internal self-assessments, audits, emergency preparedness drills, and the operating experience program. The inspectors completed this review to verify that FENOC entered conditions adverse to quality into their corrective action program as appropriate.

(2) Effectiveness of Prioritization and Evaluation of Issues The inspectors reviewed the evaluation and prioritization of a sample of CRs issued since the last NRC biennial Problem Identification and Resolution inspection completed in September 2011. The inspectors also reviewed CRs that were assigned lower levels of significance that did not include formal cause evaluations to ensure that they were properly classified. The inspectors review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate corrective actions to address the identified causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of the issues.

(3) Effectiveness of Corrective Actions The inspectors reviewed FENOCs completed corrective actions through documentation review and, in some cases, field walkdowns to determine whether the actions addressed the identified causes of the problems. The inspectors also reviewed CRs for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed FENOCs timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of CRs associated with selected non-cited violations and findings to verify that FENOC personnel properly evaluated and resolved these issues. In addition, the inspectors expanded the corrective action review to five years to evaluate FENOCs actions related to Unit 1 and Unit 2 4 kilovolt (kV) power systems and Unit 2 SDAFW pump steam supply valve issues.

b.

Assessment

(1) Effectiveness of Problem Identification Based on the selected samples, plant walkdowns, and interviews of site personnel in multiple functional areas, the inspectors determined that FENOC typically identified problems and entered them into the corrective action program at a low threshold.

FENOC staff at Beaver Valley Power Station initiated approximately 14,300 CRs and a similar number of notifications between June 2011 and September 2013. The inspectors observed supervisors at Management Ownership and Alignment, Management Review Board, and Corrective Action Review Board meetings appropriately questioning and challenging condition reports to ensure clarification of the issues. Based on the samples reviewed, the inspectors determined that FENOC trended equipment and programmatic issues, and appropriately identified problems in condition reports and notifications.

The inspectors concluded that station personnel were identifying trends at low levels.

The inspectors did not identify any significant issues or concerns that had not been appropriately entered into the corrective action program for evaluation and resolution.

However, the inspectors identified several deficiencies of lower significance, which had not been entered into the CAP despite meeting FENOCs criteria for entry into the CAP.

In some cases, workers didnt write CRs because they incorrectly assumed the issues were already in the CAP. In other cases, the degraded condition developed slowly and station personnel did not recognize that the condition had changed or accepted the degraded condition as normal. Examples of these observations included the following issues:

• Unit 1 control room air conditioning condenser circulation water pump 1VS-P-3A had excessive seal leakage (active leak extended a fifteen foot puddle around the base of the pump). Further seal degradation could render the control room air conditioner unavailable and adversely affect operators ability to maintain designed control room temperature (CRs 2013-18705, 2013-18707, 2013-18720).

• The Unit 1 plant process computer (PPC) inverter had a low current warning light.

The vendor manual stated the warning light indicates degrading inverter components and provides an early indication of a potential inverter internal fault. A failed PPC inverter would complicate operators ability to operate the plant and monitor important plant parameters. A notification was written on January 23, 2013 and subsequently cancelled without notifying the originator. Procedure 1OM-38.4, Uninterruptible Power Supply Startup, Revision 17 proceduralized this alarm light as a normal condition. In response to the inspectors concern, engineers determined the inverter was functioning normally and the alarm light was an unintended consequence of a plant modification. The inspectors determined that the alarm light now masked the ability to detect early indication of a PPC fault (CR 2013-18774, 2013-18947).

• Heavy debris/dirt partially blocked the Unit 2 vital switchgear ventilation duct grills.

The blockage could adversely affect room cooling and adversely affect electrical switchgear relay contact operation (CR 2013-19273).

• Two vital area security access card readers status lights did not indicate correct status when processing personnel badges for area access. Personnel were entering the vital areas without verifying correct reader status. The inspectors discussed access card reader functions with security staff and expressed concerns regarding vital area access control and testing. FENOC verified only authorized personnel accessed the spaces, tested all vital area card readers, corrected the card reader faults, verified the identified circuit card faults did not affect the access latching mechanism or alarms, and initiated changes to the periodic card reader test procedures (CR 2013-19185).

• Combustible material loading (e.g., storage of spare 4 kV electrical breakers) was not monitored and evaluated for the Unit 1 non-vital 4 kV switchgear room (CR 2013-19636).

The inspectors discussed these observations with station management, who promptly initiated CRs, notifications, and/or took immediate action to address the issues. These issues were determined to be minor because no equipment operability was affected. In accordance with IMC 0612, Power Reactor Inspection Reports, the above issues constituted violations of minor significance that are not subject to enforcement action in accordance with the Enforcement Policy. (CRs listed in the Attachment)

(2) Effectiveness of Prioritization and Evaluation of Issues The inspectors determined that, in general, FENOC appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem.

FENOC screened CRs for operability and reportability, categorized the CRs by significance, and assigned actions to the appropriate department for evaluation and resolution. The CR screening process considered human performance issues, radiological safety concerns, repetitiveness, adverse trends, and potential impact on the safety conscious work environment.

Based on the sample of CRs reviewed, the inspectors noted that the guidance provided by FENOC CAP implementing procedures was sufficient to support consistency in categorization of issues. The operability and reportability determinations were generally performed when conditions warranted and in most cases, the evaluations supported the conclusion. Causal analyses appropriately considered the extent-of-condition or problem, generic issues, and previous occurrences of the issue. However, the inspectors had observations associated with FENOCs prioritization and evaluation of the following issues:

• The Unit 2 A primary component cooling water heat exchanger (HX) tubes degraded due to corrosion and the HX was declared inoperable in 2012 (CRs 2012-13945 and 2012-18146). Corrective action included HX replacement and expansion of periodic HX eddy current testing (ECT) to additional HXs. The inspectors determined the extent-of-condition review had not thoroughly evaluated and documented the basis for continued reliability of the other HXs until their scheduled ECT (CR 2011-01747).

• During two 2013 NRC focused problem identification and resolution inspections (Expansion Joint Degradation and Heat Exchanger Reliability), station personnel were slow to initiate CRs and incorrectly characterized the NRC-identified performance deficiencies as enhancements and performance improvement opportunities, rather than violations of regulatory requirements. Untimely or incorrect issue characterization may challenge station personnel to correct the issues in a timely manner (CRs 2013-14041, 2013-14302).

• The inspectors identified several minor CAP-related procedure deficiencies, including the inadvertent deletion of significant conditions adverse to quality (SCAQ) from NOP-LP-2001. Based on interviews, the inspectors determined station personnel did not have a consistent understanding of the threshold difference between designating an issue as a condition adverse to quality versus an SCAQ (CRs 2013-18750).

• The inspectors also determined that several station personnel did not consistently understand and properly implement the threshold for initiating CRs in lieu of notifications. This was important, because CRs and their resolution receive wider visibility and more levels of review than issues processed as notifications. The inspectors performed a supplemental review of notifications from 2012 and 2013 and did not identify any significant issues directly affecting safety, which had bypassed the CR process (CRs 2013-18720, 2013-19302).

The inspectors discussed these observations with station management, who promptly initiated CRs, notifications, and/or took immediate action to address the issues. These issues were determined to be minor because no equipment operability was affected and other actions to address HX corrosion were implemented. In accordance with IMC 0612, Power Reactor Inspection Reports, the above issues constituted violations of minor significance that are not subject to enforcement action in accordance with the Enforcement Policy. (CRs listed in the Attachment)

Additionally, the inspectors identified one example of more than minor significance where FENOC personnel were not effective in evaluating and implementing effective corrective actions. This finding is documented in Section 4OA2.1.c.

(3) Effectiveness of Corrective Actions The inspectors concluded that corrective actions for identified deficiencies were generally timely and adequately implemented. For significant conditions adverse to quality, FENOC identified actions to prevent recurrence. The inspectors concluded that corrective actions to address the sample of NRC non-cited violations and findings since the last problem identification and resolution inspection were timely and effective. The inspectors identified one example of deficiencies in FENOCs resolution of a degraded condition, as follows:

Vital 120 volt battery 2-4 was declared inoperable (with associated 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> technical specification (TS) allowed outage times (AOT)) three times during the last operating cycle due to low individual cell voltage. The battery reached the end of useful life in about 7 years, which was about half of normal expected life (CR 2011-01337).

FENOC categorized this issue as a condition adverse to quality and performed a full apparent cause evaluation. FENOC determined the failure was due to elevated battery room temperatures. Corrective actions included battery replacement and installation of temporary room chillers. The inspectors determined that corrective actions were adequate to restore operability and reduce battery room temperature. However, implementation of the temporary room chillers was not fully effective. Specifically, alignment of the chiller suction and discharge near the room exhaust duct limited the cooling effect of the chiller. Additionally, procedures for monitoring room temperature did not provide limits or guidance for action. As a result battery room temperature still rose 10-15 degrees Fahrenheit above the vendor recommended temperature during the summer period following implementation of corrective actions. The inspectors concluded the battery remained operable, but continued battery operation above vendor recommended temperature would shorten battery life.

The inspectors independently evaluated this issue for significance in accordance with IMC 0612, Power Reactor Inspection Reports. Battery room temperature continued to exceed the vendor recommended temperature during the summer, which may shorten battery life. However, equipment operability was not affected, the 2-4 battery was newly replaced, a periodic test program to monitor battery condition was implemented in accordance with TS requirements, and engineers were developing a permanent plant modification to provide reliable battery room cooling. The inspectors determined this issue was of minor significance, and is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

c. Findings

Untimely Problem Identification and Corrective Action for Degraded Auxiliary Feedwater Pump Steam Supply Valve

Introduction.

The inspectors identified a Green non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, related to FENOCs problem identification and corrective action to address the November 2011 failure of steam driven auxiliary feedwater (SDAFW) pump steam supply valve 2MSS-SOV105C. Specifically, the inspectors identified that FENOC did not promptly identify and correct the elevated valve temperature condition that led to the coil failure of a solenoid-operated steam admission valve for the SDAFW pump. Consequently, 2MSS-SOV105C failed again on June 19, 2012, due to solenoid insulation damage which resulted from elevated valve temperature.

Description.

Unit 2 experienced two SDAFW pump steam supply valve failures over a 7-month period. The SDAFW pump has three independent steam supply lines, each of which has two solenoid-operated isolation valves (SOV) installed in series. Each SOV has a safety function in the open direction to admit steam to the SDAFW pump. The SOVs other safety function is to close to provide a containment isolation function in the event of a steam generator tube rupture. Technical Specifications require two of three steam admission lines to be operable to support SDAFW pump operability. The inspectors reviewed Unit 2 SDAFW steam supply valve maintenance and testing records for the past 5 years to assess whether FENOC properly identified, evaluated, and corrected associated conditions adverse to quality and effectively maintained the valves to support reliable operation.

On November 8, 2011, operators declared one of the SOVs (2MSS-SOV105C)inoperable based on smoke issuing from the solenoid (CR 2011-05088). Operators deenergized the SOV and isolated the associated steam supply line as required by TS.

Technicians found the SOV coil and rectifier burnt. Engineers determined elevated valve temperature, caused by steam leak-by past 2MSS-SOV105C, contributed to the failure. Corrective action to repair the valve internals during the next refueling outage (October 2012) was developed to correct the steam leak-by. 2MSS-SOV105C was returned to service following coil and rectifier replacement. The damaged SOV was discarded without further evaluating the heat-related degradation. No corrective actions were established to monitor 2MSS-SOV105C temperatures while exposed to continued valve leak-by or to evaluate accelerated SOV aging due to exposure to elevated temperatures.

On June 19, 2012, a 100Vdc electrical bus ground was identified and isolated to 2MSS-SOV105C. Operators again de-energized the SOV and isolated the associated steam supply line to the SDAFW pump as required by TS. Technicians identified damaged SOV coil insulation. Laboratory testing confirmed the coil insulation damage caused the ground. Engineers determined that steam leak-by past the valve elevated SOV temperature, which caused the SOV coil insulation damage. The SOV had only been in service 7 months prior to its failure.

The inspectors noted the vendor manual states the SOV coil insulation has a continuous operating temperature limit of 356F, which allows for a 2.28 years of service life at that temperature. This was significantly shorter than the existing 14-year SOV replacement preventive maintenance periodicity, which engineers based on nominal SOV temperature without valve leak-by (approximately 170F - 200F). The inspectors concluded that elevated SOV temperature significantly reduced expected SOV operating life. The inspectors reviewed SOV temperature data from December 2011 to July 2012 for 2MSS-SOV105C, acquired from 2OST-24.4, Steam Driven Auxiliary Feed Pump Quarterly Test, Attachment 1-[2MSS-SOV-105A,B,C,D,E,F] Solenoid Coil Temperature Monitoring, Revision 72. The attachment recorded the temperatures of all six SOVs after the pump was secured, and checked for a downward trend. If the downward temperature trend was not observed after 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, engineering was to be contacted for guidance.

The inspectors identified two missed opportunities prior to the second SOV failure for FENOC to identify and evaluate elevated temperatures on 2MSS-SOV105C. On February 2, 2012, temperatures recorded after the surveillance test exceeded 356F in an increasing trend for fifteen hours. The final temperature recorded, 362.6F, started a decreasing trend in temperatures, and measurements were stopped after consulting engineering. On April 25, 2012, temperatures recorded after the surveillance test again exceeded 356F. The initial temperature measured was 388.8F, which declined to 378F over an eight hour period. No additional data was provided to indicate the SOV temperature lowered below 356F. Engineers reviewed the test data, but did not recognize the insulation degraded at temperatures exceeding 356F. No corrective actions were performed to assess and correct the effect of the elevated temperatures.

Consequently, 2MSS-SOV-105C was exposed to elevated temperature during the period November 2011 to June 2012, which caused SOV coil insulation breakdown and valve failure.

In November 2012, FENOC revised 2OST-24.4 to require engineering evaluation of SOVs for which recorded temperature exceeded 356F. 2MSS-SOV105C steam leak-by and SOV temperature were notably lower following valve internal repair in October 2012.

However, SOV temperatures after surveillance testing remained above 300F following four of the five surveillance tests for the SDAFW pump in 2013. This was much higher than the temperature of the other five SDAFW steam supply SOVs, which indicated the corrective action to stop SOV leak-by was not fully effective. The elevated SOV data was not tracked or evaluated by engineering. FENOC did not reconcile the effect of continued SOV elevated temperature with the existing SOV replacement schedule (14 year replacement interval). The inspectors concluded that FENOC did not promptly identify and correct the adverse condition of elevated SDAFW pump steam supply SOV temperature.

Analysis.

The inspectors determined that FENOCs failure to promptly identify and correct elevated temperatures on SDAFW pump steam admission valve 2MSS-SOV105C in accordance with NOP-LP-2001, Corrective Action Program, was a performance deficiency (PD) that was within the ability of FENOC to foresee and correct, and should have been prevented. The PD was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, FENOC did not ensure that adequate operational margin was available to maintain operability of 2MSS-SOV105C when temperatures exceeded 356F. Consequently, seven months following SOV coil replacement, the coil insulation degraded and rendered 2MSS-SOV105C inoperable and unavailable.

The inspectors evaluated the significance of this finding using IMC 0609.04, Initial Characterization of Finding, and IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, dated June 19, 2012. The inspectors determined that this finding was of very low safety significance (Green) because it was not a design or qualification deficiency, did not involve an actual loss of safety function, did not represent actual loss of a safety function of a single train for greater than its technical specification allowed outage time, and did not screen as potentially risk-significant due to external events.

This finding has a cross-cutting aspect in the area of Human Performance, Resources, because FENOC did not ensure that personnel, equipment, procedures and other resources were available and adequate to support operability of safety related equipment. Specifically, design margin was not maintained for a safety related solenoid-operated valve which resulted in its failure and the long-standing equipment issue of leak-by past the valve was not addressed through adequate monitoring and preventive maintenance of the valve solenoids. H.2(a)

Enforcement.

10 CFR 50 Appendix B, Criterion XVI, Corrective Action, requires that conditions adverse to quality are promptly identified and corrected. Contrary to the above, FENOC did not promptly identify and correct the elevated valve temperature adverse condition that led to the coil failure of a solenoid-operated steam admission valve for the SDAFW pump. Specifically, following the November 8, 2011 valve failure, FENOC recorded elevated 2MSS-SOV105C temperatures on February 2, 2012 and April 25, 2012. However, the elevated temperature trend that challenged operability of the valve was not entered into the corrective action program. The solenoid subsequently failed on June 19, 2012, because the elevated temperature caused solenoid coil insulation damage. FENOC entered this issue into the corrective action program for resolution as CR 2013-19448, updated procedures to evaluate elevated temperatures on SDAFW pump steam admission valves, and initiated CR 2013-19250 to evaluate the adequacy of planned maintenance on the valves. Because this finding was of very low safety significance (Green), and was entered into the corrective action program for resolution this violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000412/2013008-01, Untimely Problem Identification and Corrective Action for Degraded Auxiliary Feedwater Pump Steam Supply Valve)

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed a sample of notifications and CRs associated with review of industry operating experience to determine whether FENOC appropriately evaluated the operating experience information for applicability to Beaver Valley Power Station and had taken appropriate actions, when warranted. The inspectors also reviewed evaluations of operating experience documents associated with a sample of NRC generic communications to ensure that FENOC adequately considered the underlying problems associated with the issues for resolution via their corrective action program.

The inspectors included a number of older NRC generic communications to verify FENOC had maintained associated corrective actions in their current station programs.

In addition, the inspectors observed various plant activities to determine if the station considered industry operating experience during the performance of routine and infrequently performed activities.

b. Assessment The inspectors determined that FENOC appropriately considered industry operating experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The inspectors determined that operating experience was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable. The inspectors also observed that industry operating experience was routinely discussed and considered during the conduct of Management Ownership and Alignment meetings, shift turnover briefs, and pre-job briefs.

c. Findings

No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed a sample of audits, including the most recent audit of the corrective action program, departmental self-assessments, and assessments performed by independent organizations. Inspectors performed these reviews to determine if FENOC entered problems identified through these assessments into the corrective action program, when appropriate, and whether FENOC initiated corrective actions to address identified deficiencies. The inspectors evaluated the effectiveness of the audits and assessments by comparing audit and assessment results against self-revealing and NRC-identified observations made during the inspection.

b. Assessment The inspectors concluded that self-assessments, audits, and other internal FENOC assessments were generally thorough and effective in identifying issues. The inspectors observed that FENOC personnel knowledgeable in the subject completed these audits and self-assessments in a methodical manner. FENOC completed these audits and self-assessments to a sufficient depth to identify issues which were then entered into the corrective action program for evaluation. In general, the station implemented corrective actions associated with the identified issues commensurate with their safety significance.

c. Findings

No findings were identified.

.4 Assessment of Safety Conscious Work Environment

a. Inspection Scope

During interviews with station personnel, the inspectors assessed the safety conscious work environment (SCWE) at Beaver Valley Power Station. Specifically, the inspectors interviewed personnel to determine whether they were hesitant to raise safety concerns to their management and/or the NRC. The inspectors reviewed results of the annual FENOC SCWE Surveys (2011 - 2013) and the Safety Culture Surveys (quarterly, semi-annual, and biennial from 2011 to 2013) to assess the breadth of questions, participation, response trends, and action taken by FENOC to address trends or concerns identified in the surveys. The inspectors also interviewed the station Employee Concerns Program coordinator to determine what actions are implemented to ensure employees were aware of the program and its availability with regards to raising safety concerns. The inspectors reviewed a selection of the Employee Concerns Program (ECP) files from January 2011 to September 2013 to ensure that FENOC entered issues into the corrective action program when appropriate.

b. Assessment During interviews, Beaver Valley Power Station staff expressed a willingness to use the CAP to identify plant issues and deficiencies and stated that they were willing to raise safety issues. The inspectors noted that no one interviewed stated that they personally experienced or were aware of a situation in which an individual had been retaliated against for raising a safety issue. All persons interviewed demonstrated an adequate knowledge of the CAP and the ECP. Based on the ECP program review and employee/contractor interviews, the inspectors concluded that there was no evidence of an unacceptable safety conscious work environment and no significant challenges to the free flow of information.

c. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On December 6, 2013, the inspectors presented the inspection results to Mr. Eric Larson, Site Vice President and other members of the Beaver Valley Power Station staff.

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

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

G. Alberti, Steam Generator NDE Engineer

C. Anderson, Senior Nuclear Specialist

D. Batina, Employee Concerns Program Coordinator,

C. Battistone, Supervisor, Engineering Programs

M. Berg, Design Engineer

R. Bologna, Director, Site Operations

R. Boyle, Superintendent, Nuclear Construction Services

N. Brooks, Fleet Electrical Engineer

G. Cacciani, Senior Design Engineer

S. Cencic, Outage Planner

A. Crotty, Supervisor, Plant Engineering

A. Dometrovich, Regulatory Compliance Engineer

M. Dunning, Manager, Supply

M. Dzumba, System Engineer

K. Farzan, Regulatory Compliance Engineer

G. Fidurski, Supervisor, Security Operations

T. Fox, Maintenance Engineer

J. Gallagher, Maintenance Rule Program Engineer

D. Grabski, NDE Engineer

B. Haney, Supervisor, Performance Improvement

T. Hayward, Manager, Work Management

D. Hecht, Containment Engineer

R. Hecht, Supervisor, Technical Training

S. Hovanec, Manager, Plant Engineering

D. Huff, Director, Site Maintenance

M. Johnston, Operating Experience Coordinator

D. Jones, In-service Testing coordinator

M. Kienzle. System Engineer

T. King, System Engineering Specialist

R. Klindworth, Manager, Maintenance

J. Kowalski, Human Performance Engineer

S. Kubis, System Engineer

E. Larson, Site Vice President

B. Lubert, Supervisor, Design Engineering

J. Ludwig, Maintenance Services

C. Mancuso, Manager, Design Engineering

J. Manolareus, Environmental Qualification engineer

J. Marsh, System Engineer

B. Matty, Manager, Operations

J. Meyers, Design Engineer

C. McFeaters, Director, Site Engineering

D. Miller, Supervisor, Steam Generator Replacement

J. Miller, Site Fire Marshal

R. Miller, Corrective Action Program Coordinator

K. Mitchell, Plant Engineer

L. Montanari, Manager, Site Projects

N. Morrison, Steam Generator Replacement Project

D. Murray, Director, Site Performance Improvement

C. ONeil, Supervisor, Design Engineering

J. Patterson, Containment Engineer

B. Paul, Electrical Design Engineer

P. Pauvlivich, Manager, Technical Services.

D. Price, Supervisor, Mechanical Design Engineering

M. Ressler, Senior Design Engineer

A. Riordan, System Engineer

R. Romisher, Senior Reactor Operator

A. Ryan, Design Engineer

D. Salera, Manager, Chemistry

F. Schaffner, Emergency Preparedness Coordinator

B. Sepelak, Manager, Regulatory Compliance

S. Sewtschenkcs, Manager, Emergency Preparedness

D. Sharbough, Manager, Outages

J. Sharpless, Supervisor, Security Support

E. Stalnecker, Radiological Protection Services

J. Tanouye, System Engineer

J. Treese, Operations Corrective Action Program Analyst

S. Vincinie, Supervisor, Performance Assessment

D. Wacker, Regulatory Compliance Engineer

Z. Warchol, Supervisor, Balance of Plant Engineering

B. Welt, Measured Maintenance Data Engineer

J. West, Maintenance Rule Program Engineer

R. Winters, Chemist

D. Zelenko, Plant Engineering, Aging Management Program Engineer

NRC Personnel

R. Powell, Chief, NRC Region I Technical Support and Assessment Branch

D. Spindler, NRC Senior Resident Inspector

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened and Closed

05000412/2013008-01 NCV Untimely Problem Identification and Corrective Action for Degraded Auxiliary Feedwater Pump Steam Supply Valve (Section 4OA2.1.c)