IR 05000334/2021012

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Biennial Problem Identification and Resolution Inspection Report 05000334/2021012 and 05000412/2021012
ML21083A102
Person / Time
Site: Beaver Valley
Issue date: 03/24/2021
From: Matt Young
NRC/RGN-I/DRP/PB5
To: Grabnar J
Energy Harbor Nuclear Corp
Young M
References
IR 2021012
Download: ML21083A102 (14)


Text

March 24, 2021

SUBJECT:

BEAVER VALLEY POWER STATION, UNITS 1 AND 2 - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000334/2021012 AND 05000412/2021012

Dear Mr. Grabnar:

On February 26, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your 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.

The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment.

Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

No findings or violations of more than minor significance were identified during this inspection. 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, X /RA/

Signed by: Matthew R. Young Matt R. Young, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket Nos. 05000334 and 05000412 License Nos. DPR-66 and NPF-73

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000334 and 05000412 License Numbers: DPR-66 and NPF-73 Report Numbers: 05000334/2021012 and 05000412/2021012 Enterprise Identifier: I-2021-012-0008 Licensee: Energy Harbor Nuclear Corporation Facility: Beaver Valley Power Station, Units 1 and 2 Location: Shippingport PA Inspection Dates: February 8, 2021 to February 26, 2021 Inspectors: L. Cline, Senior Project Engineer S. Monarque, Resident Inspector R. Rolph, Resident Inspector R. Vadella, Project Engineer Approved By: Matt R. Young, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution 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

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

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.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), inspectors were directed to begin telework. In addition, regional baseline inspections were evaluated to determine if all or portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

OTHER ACTIVITIES - BASELINE

71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)

(1) The inspectors performed a biennial assessment of the licensees problem identification and resolution performance in the following areas:
  • Corrective Action Program Effectiveness in problem identification, prioritization, evaluation, and corrective action, which also included a review of corrective actions for issues identified in the Unit 1 chemical volume control system, Unit 2 service water system, and the Unit 2 auxiliary feedwater system and aging management issues identified and evaluated in the last five years.
  • Use of Operating Experience.
  • Completed Self-Assessments and Audits.
  • Health of the Safety Conscious Work Environment.

INSPECTION RESULTS

Assessment 71152B Corrective Action Program Effectiveness -

Problem Identification: The inspectors determined that, in general, the licensee identified issues and entered them into the corrective action program at a low threshold.

Problem Prioritization and Evaluation: Based on the samples reviewed, the inspectors determined that, in general, the licensee appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem. The licensee appropriately screened condition reports for operability and reportability, categorized condition reports by significance, and assigned actions to the appropriate department for evaluation and resolution. However, the inspectors identified one minor performance deficiency associated with condition report categorization/prioritization, that is documented in the applicable section below.

Corrective Actions: The inspectors determined that the overall corrective action program performance related to resolving problems was effective. In most cases, the licensee implemented corrective actions to resolve problems in a timely manner.

Assessment 71152B Use of Operating Experience -

The team determined that the licensee appropriately evaluated industry operating experience for its relevance to the facility. The licensee appropriately incorporated both internal and external operating experience into plant procedures and processes.

Self-Assessments and Audits -

The team reviewed a sample of self-assessments and audits to assess whether the licensee was identifying and addressing performance trends. The team concluded that the licensee had an effective self-assessment and audit process.

Assessment 71152B Safety-Conscious Work Environment -

The inspectors interviewed a total of 18 individuals using the questions included in Appendix A of Inspection Procedure 71152. The purpose of these interviews was to evaluate the willingness of licensee staff to raise nuclear safety issues and to evaluate the perceived effectiveness of the corrective action program at resolving identified problems. The personnel interviewed were selected from the Operations, Engineering, Maintenance, Security, and the Chemistry/Radiation Protection work groups. To supplement these discussions, the inspectors interviewed the Employee Concerns Program (ECP) representative and reviewed the ECP case log and selected case files. The inspectors also reviewed the licensee's programs for monitoring and maintaining a safety-conscious work environment. This included the results from the last employee safety-conscious work environment survey and the most recent semi-annual nuclear safety culture monitoring panel meetings and corrective actions to address the areas for improvement identified by these programs.

All individuals interviewed by the inspectors indicated that they would raise nuclear safety concerns. Most individuals felt that their management was receptive to receiving safety concerns and generally addressed them promptly, commensurate with the significance of the concern. All interviewees were aware of the licensee's ECP. Most stated they would use the program if necessary and were confident that their identify would be protected. All others were neutral on the use of the ECP. The inspectors shared the results of the inspectors' interviews of site staff with the site's ECP representative.

Minor Performance Deficiency 71152B Minor Performance Deficiency: The inspectors identified a minor performance deficiency associated with the Mitigating Systems cornerstone because the licensee did not categorize the condition described in CR-2020-0718 in accordance with guidance provided in licensee procedure NOP-LP-2001, Corrective Action Process. CR-2020-0718 documented that on September 16, 2020, NRC inspectors identified that the flood door between the A and B cubicles in the intake structure was open when it should have been shut (see NCV 05000334/2020004-01 and NCV 05000334/2020004-02). On October 21, 2020, after completing its evaluation of this condition, the licensee determined it had caused a loss of safety-related function for both trains of Unit 1 river water. Licensee procedure NOP-LP-2001, 1, provides a list of examples of significant conditions adverse to quality (SCAQs)to aid station management in determining proper categorization of identified conditions. The first example on that list of SCAQs is entry into unplanned standard Technical Specification Limiting Condition for Operation 3.0.3, or its equivalent, for the loss of safety-related function.

Contrary to this guidance, the licensee did not categorize the condition as an SCAQ. The licensee entered this condition into the corrective action program as CR-2021-01329.

Screening: The inspectors determined the performance deficiency was minor. In accordance with Inspection Manual Chapter 0612, Appendix B, more-than-minor screening questions, it did not adversely affect the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Adequate corrective actions were in progress to prevent recurrence of the loss of control of the service water cubicle flood door that was identified on September 16, 2020. Specifically, new signs were placed on the doors that clearly described the impact of leaving the doors open on the safety systems located in the affected rooms, the doors were locked, and the licensee had generated a long-term corrective action program action to track installation of permanent locks with unique keys that will be stored in the control room.

EXIT MEETINGS AND DEBRIEFS

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

  • On February 26, 2021, the inspectors presented the biennial problem identification and resolution inspection results to Mr. John Grabnar, Site Vice President and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71152B Corrective Action CR-2019-01357 NRC Green Finding Fourth Quarter 2018 Unit 2 B

Documents (AA) Safeguards Area Air Conditioning Unit

CR-2019-02895 Missed ODCM (offsite dose calculation manual) surveillance

(AA)

CR-2019-05844 Question the effectiveness of a Beta scintillation detector

(AA) installed into a gamma detector well as a result of ECP 18-

0043

CR-2019-06200 NRC Baseline Inspection 2019-410: Site Protection:

(AA) Operations: NRC observed Main Gate Search

CR-2019-08565 Aging - Insulation Fretting on Unit-1 Pressurizer 4" Spray

(AA) Line

CR-2019-08793 Indication Reported on Weld SI-72-8-S01

(AA)

CR-2019-08793 Aging - Indication Reported on Weld SI-72-8-S01

(AA)

CR-2020-02845 Cale came free from drum of Unit 2 Fuel Elevator (2FNT-

(AR) EL21)

CR-2020-02857 Validity of sample results from Unit 1 gas waste surge tank

(AA)

CR-2020-05481 1CT-P-1A (Cooling Tower Pump 1A) Lower Motor Guide

(AA) Bearing Failure

CR-2020-06889 NRC Baseline Inspection 2020: Site Protection: Operations:

(AA) NRC Observed Main Gate Search

CR-2020-07218 2020 DBAI flood door BV-1IS05-11 (A to B intake cubicle

(AA) crosstie flood door) found open during DBAI walkdown

CR-2020-08313 Personal Injury Occurred During Main Intake Bay Cleaning -

(NC) OSHA

CRs CR-2007-20026, CR-2013-10409, CR-2016-02973, CR-

2016-11890, CR-2017-05550, CR-2017-10960, CR-2018-

09111, CR-2019-00991, CR-2019-01259, CR-2019-01260,

CR-2019-01267, CR-2019-01319, CR-2019-01326, CR-

2019-01327, CR-2019-01329, CR-2019-01342, CR-2019-

Inspection Type Designation Description or Title Revision or

Procedure Date

01357, CR-2019-01436, CR-2019-01849, CR-2019-02006,

CR-2019-02105, CR-2019-02312, CR-2019-02597, CR-

2019-02598, CR-2019-02857, CR-2019-02895, CR-2019-

2948, CR-2019-03037, CR-2019-03133, CR-2019-03414,

CR-2019-03591, CR-2019-03723, CR-2019-03817, CR-

2019-03949, CR-2019-04071, CR-2019-04414, CR-2019-

04781, CR-2019-04815, CR-2019-04884, CR-2019-05522,

CR-2019-05844, CR-2019-05973, CR-2019-07576, CR-

2019-07583, CR-2019-07601, CR-2019-07663, CR-2019-

08133, CR-2019-08565, CR-2019-08565, CR-2019-08595,

CR-2019-08596, CR-2019-08793, CR-2019-08793, CR-

2019-08919, CR-2019-09938, CR-2019-10253, CR-2019-

10455, CR-2019-10621, CR-2019-12089, CR-2020-00580,

CR-2020-01436, CR-2020-02101, CR-2020-02168, CR-

20-02857, CR-2020-03333, CR-2020-03418, CR-2020-

03509, CR-2020-03575, CR-2020-03619, CR-2020-03936,

CR-2020-03949, CR-2020-03964, CR-2020-04953, CR-

20-05330, CR-2020-05557, CR-2020-05557, CR-2020-

05846, CR-2020-06003, CR-2020-06213, CR-2020-06214,

CR-2020-06215, CR-2020-06497, CR-2020-06498, CR-

20-06567, CR-2020-06659, CR-2020-06838, CR-2020-

06919, CR-2020-06928, CR-2020-07218, CR-2020-07218,

CR-2020-07389, CR-2020-07509, CR-2020-07622, CR-

20-07622, CR-2020-07881, CR-2020-08194, CR-2020-

261, CR-2020-08313, CR-2020-08354, CR-2020-08739,

CR-2020-08800, CR-2020-09081, CR-2020-09366, CR-

20-09398, CR-2020-09468, CR-2020-09578, CR-2021-

00137, CR-2021-00349, CR-2021-00375, CR-2021-00501,

CR-2021-00613, CR-2021-00985

Corrective Action CR 2021-01126, CR 2021-01191, CR 2021-01326, CR 2021-

Documents 01327, CR 2021-01329

Resulting from

Inspection

Engineering ECP-08-0496- Temporary modification for Clamping 3 way valve HCV-1CH-

Changes 007 244 in position to isolate from Volume Control Tank for

Inspection Type Designation Description or Title Revision or

Procedure Date

Repair of 1CH-11

ECP-08-0496- Removal of Temporary Modification for Clamping 3 way

008 valve HCV-1CH-244 in Position to Isolate from Volume

Control Tank for Repair of 1CH-11

Engineering OE-2019-0122 IN1901, Inadequate Evaluation of Temporary Alterations

Evaluations OE-2019-0238 June 3, 2019 NRC INFORMATION NOTICE 2019-02:

EMERGENCY DIESEL GENERATOR EXCITATION

SYSTEM DIODE FAILURES

OE-2019-0240 IN1903, Inadequate Implementation of Clearance Processes

Results in Configuration Control Issues

OE-2019-0290 August 26, 2019 NRC INFORMATION NOTICE 2019-05:

POTENTIAL OVER-PRESSURIZATION OF HIGH

SPECIFIC-ACTIVITY ALPHA- EMITTING RADIOACTIVITY

SOURCES

OE-2019-0363 October 8, 2019 NRC INFORMATION NOTICE 2019-08:

FLOW-ACCELERATED CORROSION EVENTS

OE-2020-0272 IN 20-02, Flex Diesel Generator Operational Challenges

OE-2020-0375 IN20-03, Recall of Mechanical Rate of Rise and Fixed-

Temperature Heat Detectors

Miscellaneous Beaver Valley SCWE Survey Results for September 2020 October

20

Beaver Valley System - 07 - Unit 1 Chemical and Volume Control System 02/01/2021

Unit 1 System

Health Report

20-2

Beaver Valley System - 24B - Unit 2 Auxiliary Feedwater System 02/01/2021

Unit 2 System

Health Report

20-2

Beaver Valley System - 30 - Unit 2 Service Water System 02/01/2021

Unit 2 System

Health Report

20-2

FORM 1/2-ADM- Heat Exchanger Inspection Report (2EGS-E21B - 2R21) 04/23/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

2106.F01, Rev. 6

FORM 1/2-ADM- Heat Exchanger Inspection Report (2EGS-E22B - 2R21) 04/14/2020

2106.F01, Rev. 6

FORM 1/2-ADM- Heat Exchanger Inspection Report (2EGS-E21A - 2R21) 04/23/2020

2106.F01, Rev. 6

FORM 1/2-ADM- Heat Exchanger Inspection Report (2EGS-E22A - 2R21) 04/23/2020

2106.F01, Rev. 6

Procedures 1/2-ENV-05.04 Radioactive Discharge Authorization - Liquid Revision 4

1/2-PMP-M-30- New Traveling Water Screen Inspection Revision 2

2

1/2OST-30.21A Beaver Valley Power Station Unit 1/2 Group 1 Flood Door Revision 12

Seal System Operability Check

1/2OST-30.21B Beaver Valley Unit 1/2 Group 2 Flood Door Seal System Revision 12

Operability Check

10M-30.2A Beaver Valley Power Station Unit 1 Precautions and Revision 13

Limitations

20M-30.2.A Beaver Valley Power Station Unit 2 Precautions and Revision 13

Limitations

2OST-30.13A Train A Service Water System Full Flow Test Revision 48

2OST-30.13B Train B Service Water System Full Flow Test Revision 47

2OST-30.3 Service Water Pump [2SWS*P21B] Test Revision 53

2OST-30.6B Service Water Pump [2SWS*P21C] Test on Train B Header Revision 36

BV-1OST-07-05 1CH-P-1B Centrifugal Charging Pump Operational Test 04/15/2019

Quarterly

BV-1OST-07-06 1CH-P-1C Centrifugal Charging Pump Operational Test 01/31/2020

BV-1OST-47-124 Type C leak Test Penetration Number 28 10/18/2019

NOBP-LP-20011 Cause Analysis Revision 27

NOBP-LP-2008 Corrective Action Review Board Revision 25

NOBP-LP-2100 Operating Experience Process Revision 21

NOBP-LP-2501 Safety Culture Assessment Revision 19

NOBP-LP-2502 Safety Culture Monitoring Revision 14

NOP-ER-2001 Boric Acid Corrosion Control Program 2/27/2020

NOP-ER-2001 Boric Acid Corrosion Control Program 02/27/2020

NOP-LP-2001 Corrective Action Program Revision 48

Inspection Type Designation Description or Title Revision or

Procedure Date

NOP-OP-1004 Reactivity Management Revision 17

NOP-OP-1004 Reactivity Event Classification Revision 3

NORM-LP-2003 Analytical Methods Guidebook Revision 13

Self-Assessments PA-BV-2019- Control of Transient Combustibles and Flammable Materials 03/14/2019

0001-005

PA-BV-2019- Equipment Tagged in the Control Room 03/28/2019

0001-006

PA-BV-2019- Assessment of the pre job Brief for the Reactor Vessel Head 10/26/2019

25-013 Installation, October 26, 2019

PA-BV-2020- Resolution of Safety Relief and Valve Issues

0040-002

PA-BV-2020- Adherence to Conduct of Operations Standards 08/21/2020

0063-005

SA-2020-8414 71130.02 access control (2020)

SA-BN-2018- Pre-PI&R 2019 NRC Inspection Assessment 02/18/2019

298

SA-BN-2019- Unannounced quarterly ERO call In Drill -2019 Second

26 Quarter

Work Orders WOs WO 200520844, WO 200631412, WO 200635176, WO 200635813, WO 200635813, WO 200651457, WO 200673444, WO 200682247, WO 200685128, WO 200685129, WO 200694986, WO 200696791, WO 200696791, WO 200699695, WO 200699904, WO 200701456, WO 200701456, WO 200704682, WO 200709497, WO 200725699, WO 200737447, WO 200742874, WO 200744641, WO 200745425, WO 200756444, WO 200759434, WO 200759623, WO 200761676, WO 200761676, WO 200761677, WO 200761677, WO 200764217, WO 200764408, WO 200768652, WO 200771131, WO 200780726, WO 200780726, WO 200780726, WO 200781041, WO 200781851, WO 200783636, WO 200783637, WO 200783640, WO 200783641, WO 200788338, WO 200803106, WO 200803118, WO 200808349, WO 200820987, WO 200820999, WO 200821115, WO

Inspection Type Designation Description or Title Revision or

Procedure Date

200821883, WO 200826408, WO 200833299, WO 200841279, WO 200841286, WO 200841286, WO 200841306, WO 200841306

11