ML25113A002
| ML25113A002 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/23/2025 |
| From: | Glenn Dentel Division of Operating Reactors |
| To: | Blair B Vistra Operations Company |
| References | |
| IR 2025011 | |
| Download: ML25113A002 (1) | |
Text
April 23, 2025 Barry Blair Site Vice President Vistra Operations Company, LLC Beaver Valley Power Station P.O. Box 4 - Route 168 Shippingport, PA 15077-0004
SUBJECT:
BEAVER VALLEY POWER STATION, UNITS 1 AND 2 - FIRE PROTECTION TEAM INSPECTION REPORT 05000334/2025011 AND 05000412/2025011
Dear Barry Blair:
On March 20, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Beaver Valley Power Station, Units 1 and 2, and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Beaver Valley Power Station, Units 1 and 2.
If you disagree with a cross-cutting aspect assignment 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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; and the NRC Resident Inspector at Beaver Valley Power Station, Units 1 and 2.
B. Blair 2
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Glenn T. Dentel, Chief Engineering Branch 2 Division of Operating Reactor Safety Docket Nos. 05000334 and 05000412 License Nos. DPR-66 and NPF-73
Enclosure:
As stated cc w/ encl: Distribution via LISTSERV GLENN DENTEL Digitally signed by GLENN DENTEL Date: 2025.04.23 14:42:21 -04'00'
ML25113A002 SUNSI Review Non-Sensitive Sensitive Publicly Available Non-Publicly Available OFFICE RI/DORS RI/DORS NAME LDumont GDentel DATE 4/21/2025 4/21/2025
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Numbers:
05000334 and 05000412 License Numbers:
DPR-66 and NPF-73 Report Numbers:
05000334/2025011 and 05000412/2025011 Enterprise Identifier: I-2025-011-0012 Licensee:
Vistra Operations Company, LLC Facility:
Beaver Valley Power Station, Units 1 and 2 Location:
Shippingport, PA Inspection Dates:
March 3, 2025 to March 20, 2025 Inspectors:
L. Dumont, Senior Reactor Inspector D. McHugh, Reactor Inspector J. Tifft, Senior Reactor Inspector Approved By:
Glenn T. Dentel, Chief Engineering Branch 2 Division of Operating Reactor Safety
2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a fire protection team inspection at Beaver Valley Power Station, Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations Failure to Implement Required Incipient Detectors Transport Time Testing Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000334,05000412/2025011-01 Open/Closed
[P.3] -
Resolution 71111.21N.
05 The inspection team identified a Green finding and associated non-cited violation (NCV) of the Beaver Valley Facility Operating License Condition C.5 and 2.F, for Unit 1 and Unit 2 respectively, for failure to implement and maintain in effect all provisions of the approved Fire Protection Program (FPP). Specifically, Vistra did not perform periodic testing of the incipient fire detection system transport times as required per 1/2-ADM-1900, Fire Protection Program, Revision 52.
Failure to Perform Periodic Functional Testing on the Unit 2 Remote Shutdown Panel Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000334,05000412/2025011-02 Open/Closed None (NPP) 71111.21N.
05 The inspection team identified a Green finding and associated non-cited violation (NCV) of the Beaver Valley Unit 2 Facility Operating License Condition 2F, for failure to implement and maintain in effect all provisions of the approved Fire Protection Program (FPP). Specifically, Vistra did not perform periodic functional testing of all contacts required to operate components on the Unit 2 alternate shutdown panel, (ASP) as required in section 7.8.1 of 1/2-ADM-1900, Fire Protection Program, Revision 52.
Additional Tracking Items None.
3 INSPECTION SCOPES Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY 71111.21N.05 - Fire Protection Team Inspection (FPTI)
Structures, Systems, and Components (SSCs) Credited for Fire Prevention, Detection, Suppression, or Post-Fire Safe Shutdown Review (IP Section 03.01) (4 Samples)
The inspectors verified that components and/or systems will function as required to support the credited functions stated for each sample. Additional inspection considerations are located in the fire hazards analysis (FHA) or safe shutdown analysis (SSA).
(1)
Fire Detection System (2)
Fire suppression System - CO2 and Halon system (3)
Unit 1 Reactor Coolant System (4)
Unit 2 Service Water Fire Protection Program Administrative Controls (IP Section 03.02) (2 Samples)
The inspectors verified that the selected control or process is implemented in accordance with the licensees current licensing basis. If applicable, ensure that the licensees FPP contains adequate procedures to implement the selected administrative control. Verify that the selected administrative control meets the requirements of all committed industry standards.
(1)
Control of Transient Combustible Materials (2)
Probabilistic Risks Assessment Configuration Control (Operating Experience Smart Sample 2023/02)
Fire Protection Program Changes/Modifications (IP Section 03.03) (1 Sample)
The inspectors verified the following:
- a. Changes to the approved FPP do not constitute an adverse effect on the ability to safely shutdown.
- b. The adequacy of the design modification, if applicable.
- c. Assumptions and performance capability stated in the SSA have not been degraded through changes or modifications.
4
- d. The FPP documents, such as the Updated Final Safety Analysis Report, fire protection report, FHA, and SSA were updated consistent with the FPP or design change.
- e. Post-fire safe shutdown (SSD) operating procedures, such as abnormal operating procedures, affected by the modification were updated.
(1)
ECP 23-1193-001, Convert 1-CV-3 Halon system from automatic to manual INSPECTION RESULTS Failure to implement Required Incipient Detectors Transport Time Testing Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000334,05000412/2025011-01 Open/Closed
[P.3] -
Resolution 71111.21N.05 The inspection team identified a Green finding and associated NCV of the Beaver Valley Facility Operating License Condition C.5 and 2.F, for Unit 1 and Unit 2 respectively, for failure to implement and maintain in effect all provisions of the approved FPP. Specifically, Vistra did not perform periodic testing of the incipient fire detection system transport times as required per 1/2-ADM-1900, Fire Protection Program, Revision 52.
==
Description:==
At Beaver Valley, incipient fire detectors are installed in Units 1 and 2 Process Instrumentation Rooms to monitor electrical cabinets for fire precursor indications. Incipient fire detectors work via air sampling from electrical cabinets. Each detector is connecting by tubing to a string of electrical cabinets. The air flow from each cabinet is adjusted using a sample manifold installed at the connector point to the cabinet such that all the cabinets have an acceptable transport time. The transport time is the time between combustion particles entering the cabinet sample tube to the detector recording an increase in combustion particles. This is accomplished by injecting a test gas beyond the most distant cabinet.
1/2 - ADM-1900, Fire Protection Program, Revision 52 is the FPP procedure at Beaver Valley Power Station (BVPS) that implemented the requirements of the Facility Operating Licenses, 10 CFR 50.48(a) & (c), applicable Regulatory Guidance, and applicable NFPA codes. 1/2 - ADM-1900, Fire Protection Program, Revision 52, section 1.d, Incipient Fire Detection states: Incipient Fire Detection in the Unit 1 Process Instrumentation Room, Unit 2 Process Instrumentation Room and Unit 2 West Communication Room SHALL be functional.
In addition, Surveillance Requirement 1.d.3 of 1/2 - ADM-1900, Fire Protection Program, Revision 52, which was the surveillance that verified the functionality of the incipient fire detectors in the Unit 1 Process Instrumentation Room, Unit 2 Process Instrumentation Room, and Unit 2 West Communication Room, required BVPS to perform periodic test of the incipient fire detection system transport times annually.
The inspection team identified that during Operating Experience reviews back in 2023 the licensee generated condition report (CR)-2023-08175 that documented that BVPS FPP failed to include transport time tests of their incipient detectors. The recommended action was to revise site procedures to implement transport time testing, but the CR was closed, and no corrective actions were taken.
5 The inspection team determined that Vistra did not perform the required surveillance test. The inspection team also identified that the licensee had no compensatory measures in place for the incipient detectors being non-functional.
1/2 - ADM-1900, Fire Protection Program, Revision 52, section 7.8.2 stated in part: Failure to perform a surveillance requirement of fire protection features required to meet NRC regulations within the required time interval SHALL require that the associated system/component SHALL be considered nonfunctional and the appropriate compensatory measures. The inspection team determined that Vistra failed to perform the required testing associated with incipient detectors contrary to the above requirements.
On March 21, 2025, the licensee performed the incipient detectors transport times tests on both Unit 1 and Unit 2. The test results concluded that transport time being less than 30 seconds. In addition, on April 4, 2025, Vistra provided their risk evaluations for Unit 1 and Unit 2 based on its fire probability risk assessment (PRA) determining that any potential impact to response timing due to the failure to test the incipient detection system transport time yields a CDF increase of 7.89E-9 /yr. This issue was therefore determined to be of very low safety significance.
Corrective Actions: Vistra documented the performance deficiency in their corrective action program. Vistras recommended actions included completing the revision process and instituting necessary changes to comply with the requirement.
Corrective Action References: CR-2025-01962 Performance Assessment:
Performance Deficiency: The inspection team determined that BVPSs failure to perform periodic testing of the incipient fire detection system transport times was a performance deficiency. Specifically, the licensee did not perform annual transport time testing of the incipient fire detectors in the Unit 1 Process Instrumentation Room, Unit 2 Process Instrumentation Room, and Unit 2 West Communication Room annually as required by their surveillance requirements.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors 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, not performing the transport times testing of the incipient fire detectors have prevented Vistra from ensuring the reliability and the capability of their incipient detection system.
Significance: The inspection team assessed the significance of the finding using IMC 0609, Appendix F, Fire Protection and Post - Fire Safe Shutdown Significance Dtermination Process (SDP). The inspection team determined this finding to be under the "Fixed Fire Protection Systems" category, in accordance with Table 1.2.1, "Finding Categories" of IMC 0609, Appendix F. The inspection team determined that the performance deficiency was not a low degradation rating because the test was never performed at the time of the inspection, so the time delay of detections were unknown. (NO, step1.3.1-A). The inspection team also determined the non-functional detection system adversely affect the ability of the system to protect any equipment important to SSD, because the Unit 1 Process Instrumentation Room, the Unit 2 Process Instrumentation Room, and the Unit 2 West Communication Room contain
6 several components credited for SSD success path (YES, to step 1.4.2-A). Since BVPS had a fire PRA, the results of the licensees PRA-based risk evaluation were utilized as the basis for screening the finding. Vistra provided their risk evaluations for Unit 1 and Unit 2 based on its fire PRA determining that any potential impact to response timing due to the failure to test the incipient detection system transport time yields a CDF increase of 7.89E-9 /yr. This issue was therefore determined to be of very low safety significance. A regional Senior Reactor Analyst (SRA) reviewed the results of the licensee PRA-based risk evaluations and agreed with the licensee conclusions.
As a result, the inspectors determined the finding was of very low safety significance (Green.)
Cross-Cutting Aspect: P.3 - Resolution: The organization takes effective corrective actions to address issues in a timely manner commensurate with their safety significance. Specifically, Vistra has documented the issue in their corrective action program and generated a recommended action to revise site procedures to implement transport time testing, but closed the CR without ensuring the issue was resolved timely (i.e., the incipient detectors transport times testing was implemented as required).
Enforcement:
Violation: Beaver Valley Facility Operating License Condition C.5 and 2.F, for Unit 1 and Unit 2 respectively, required BVPS, in part, to implement and maintain in effect all provisions of the approve FPP.
1/2 - ADM-1900, Fire Protection Program, Revision 52 is the FPP procedure at BVPS that implemented the requirements of the Facility Operating Licenses, 10 CFR 50.48(a) & (c),
applicable Regulatory Guidance, and applicable NFPA codes. Section 1.d, Incipient Fire Detection, requires incipient fire detectors in the Unit 1 Process Instrumentation Room, Unit 2 Process Instrumentation Room, and Unit 2 West Communication Room to be functional.
Surveillance Requirement 1.d.3 of 1/2 - ADM-1900, Fire Protection Program, Revision 52, which was the surveillance that verified the functionality of the incipient fire detectors in the Unit 1 Process Instrumentation Room, Unit 2 Process Instrumentation Room, and Unit 2 West Communication Room required BVPS to perform periodic testing of the incipient fire detection system transport times annually.
Contrary to the above, as of March 20, 2025, at the time of the exit meeting, Vistra failed to perform periodic testing of the incipient fire detectors in the Unit 1 Process Instrumentation Room, Unit 2 Process Instrumentation Room, and Unit 2 West Communication Room as required by 1/2 - ADM 1900.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
7 Failure to Perform Periodic Functional Testing on the Unit 2 Remote Shutdown Panel Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000334,05000412/2025011-02 Open/Closed None (NPP) 71111.21N.05 The inspection team identified a Green finding and associated NCV of the Beaver Valley Unit 2 Facility Operating License Condition 2F, for failure to implement and maintain in effect all provisions of the approved FPP. Specifically, Vistra did not perform periodic functional testing of all contacts required to operate components on the Unit 2 ASP as required in section 7.8.1 of 1/2-ADM-1900, Fire Protection Program, Revision 52.
==
Description:==
The Unit 2 remote shutdown panel is used to manipulate and control components required for SSD following some fire scenarios, such as control room abandonment. The functionality of the individual components is checked through periodic testing done via various surveillance tests. In the case of 2SWS-P21A, functionality was intended to be verified by performing two surveillances: 2OST-45.9, Alternate Shutdown Panel Checks in MODES 1, 2, and 3, and 2OST-45.9B, Alternate Shutdown Panel Control Checks. 2OST-45.9 transfers control from the control room to the ASP and transfers control back to the control room. The surveillance steps to verify the transfer is as follows: Verify indicating lights for the breaker turn ON at the ASP AND turn OFF in the control room, AND Document by placing check marks in the Transfer to ASP columns of Table 4. The surveillance is not specific as to which lights should be verified. As a result, all lights (transfer contacts) are not verified during that surveillance. Surveillance 2OST-45.9B measures resistances on the start/stop switch contacts at the ASP to verify the functionality of the components not verified during the performance of 2OST-45.9. The combination of these two surveillances do not verify that all of the contacts required to operate the component from the ASP.
The inspection team determined that Vistra did not adequately perform the required testing associated with Surveillance 13.4 contained in Attachment B of 1/2-ADM-1900. Surveillance 13.4 was as follows: "Verify contacts of Alternate Shutdown Panel control switches function.
(Limited to contacts that operate the component.). The inspection team determined that Vistra did not test (i.e., verify all of the contacts required to operate the component from the ASP).
On March 21, 2025, Vistra performed a risk evaluation to assess the change in risk associated with the missed performance of Surveillance 13.4 of 1/2-ADM-1900 and determined that it was acceptable to schedule the next performance during the 2R25 refueling outage.
Corrective Actions: Vistra documented the performance deficiency in their corrective action program. Vistra evaluated the impact to the FPP to perform the missed surveillance for 2SWS-P21A during the 2R25 refueling outage. Vistra also indicated that they would perform an extent of condition review for the other pumps with control capability from the ASP.
Corrective Action References: CR-2025-001952 Performance Assessment:
Performance Deficiency: The inspection team determined that the failure to perform functional testing of all required contacts on the Unit 2 ASP was a performance deficiency. Specifically, Vistra did not perform periodic functional testing on the Unit 2 ASP as required by their fire
8 protection procedure, 1/2-ADM-1900, Fire Protection Program, Revision 52, Section 7.8.1, to ensure that manual actions required for fire SSD were available in the event of a significant fire.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors 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, Vistra did not adequately perform testing required by 1/2-ADM-1900, Fire Protection Program, Revision 52, which adversely affect the ability to reach and maintain safe and stable conditions using the credited SSD success path.
Significance: The inspection team assessed the significance of the finding using IMC 0609, Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The inspection team determined this finding to be under the "Post Fire SSD" category, in accordance with Table 1.2.1, "Finding Categories" of IMC 0609, Appendix F. The inspection team determined that the performance deficiency was not a low degradation rating because the issue was not a minor procedural deficiency that could be compensated by operator experience or familiarity (NO, to step 1.3.1-A). The inspection team also determined that the finding adversely affected the ability to reach and maintain safe and stable conditions using the credited SSD success path because the unverified availability and reliability of the SSD components could adversely affect the components credited for SSD success path. (YES, to step 1.4.7-C). Since BVPS had a fire PRA, the results of the licensees PRA-based risk evaluation were utilized as the basis for screening the finding. Vistra provided their risk evaluation based on its fire PRA determining that any potential impact to the availability and reliability of the credited SSD components was within the existing conservatism included in the model and there is no increase in CDF. This issue was therefore determined to be of very low safety significance. A regional SRA reviewed the results of the licensee PRA-based risk evaluations and agreed with the licensee conclusions.
As a result, the inspectors determined the finding was of very low safety significance (Green.)
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: Beaver Valley Unit 2 Facility Operating License Condition 2F required Beaver Valley Unit 2, in part, to implement and maintain in effect all provisions of the approved FPP.
1/2-ADM-1900, Fire Protection Program, Revision 52, section 7.8.1 states: Attachment B, Technical Requirements for Fire Protection System, identifies the minimum requirements for periodic testing and periodic inspection that is delineated in the UFSAR for BVPS Units 1 and
- 2. Attachment B, Surveillance 13.4 states: Verify contacts of Alternate Shutdown Panel control switchs function. (Limited to contacts that operate the component.) at a frequency of 54 months.
Contrary to the above, As of Mach 20, 2025, Vistra had not verified that all contacts of ASP control switches function for the contacts to operate the components in accordance with 1/2-ADM-1900, Revision 52.
9 Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
On March 20, 2025, the inspectors presented the fire protection team inspection results to Barry Blair, Site Vice President, and other members of the licensee staff.
10 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date 71111.21N.05 Calculations 01.062-0017 (1-CR-4)
Detailed Fire Modeling Report, Fire Compartment: 1-CR-4 8
01.062-0027 (1-NS-1)
Detailed Fire Modeling Report, Fire Compartment: 1-NS-1 5
2601.620-000-001 Detailed Fire Modeling Procedure F
Corrective Action Documents CR-2022-03269 CR-2023-04832 CR-2022-06387 CR-2024-07947 CR-2023-03132 Corrective Action Documents Resulting from Inspection CR-2025-01452 CR-2025-01495 CR-2025-01507 CR-2025-01889 CR-2025-01952 CR-2025-01953 CR-2025-01962 CR-2025-01966 Drawings 8700-10.01-0498 Service Building Elevation 713-6 CR-4 Below Raised Floor Halon Series 70 A
8700-RE-34AD Cable Tray Designation Cont & SWGR Area -SH. 2 41 Engineering Changes ECP 23-1193-001 Convert 1-CV-3 Halon system from automatic to manual 0
Engineering Evaluations FPPCE-23-031 Convert 1-CV-3 Halon System from Automatic to Manual 0
Miscellaneous Unit 1 and Unit 2 PRA Model Update Tracker Performance Monitoring Program Trending Data Sheets Procedures 1-OST-33-16A Early Warning Fire Detection Test DGP-1FP-1 Loops 7
1/2-ADM-1900 Fire Protection Program 52 1/2-ADM-1906 Control of Transient Combustible and Flammable Materials 20
11 Inspection Procedure Type Designation Description or Title Revision or Date 1/2-ADM-1908 Fire Protection Performance Monitoring Program 5
1/2OM-56B.4A.E Safe Shutdown Intent and Methodology 0
1/2OST-33.37 Halon Storage Cylinder Pressure And Agent Quantity Verifications 4
2OST-45.9 Alternate Shutdown Panel Checks in MODES 1, 2, and 3 21 2OST-45.9B Alternate Shutdown Panel Control Checks 4
BVBP-SITE-0062 Transient Combustible Storage Area 3
NOBP-CC-6001 Probabilistic Risk Assessment Model Management 14 Self-Assessments MS-S-24-05-31 Quality Assurance Audit Report 7/23/2024