IR 05000334/2011008: Difference between revisions

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| issue date = 05/13/2011
| issue date = 05/13/2011
| title = IR 05000334/2011008 and 05000412/2011008; 03/31/2011 - 04/29/2011; Beaver Valley Power Station, Units 1 and 2; Temporary Instruction 2515/183 - Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event
| title = IR 05000334/2011008 and 05000412/2011008; 03/31/2011 - 04/29/2011; Beaver Valley Power Station, Units 1 and 2; Temporary Instruction 2515/183 - Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event
| author name = Doerflein L T
| author name = Doerflein L
| author affiliation = NRC/RGN-I/DRS/EB2
| author affiliation = NRC/RGN-I/DRS/EB2
| addressee name = Harden P A
| addressee name = Harden P
| addressee affiliation = FirstEnergy Nuclear Operating Co
| addressee affiliation = FirstEnergy Nuclear Operating Co
| docket = 05000334, 05000412
| docket = 05000334, 05000412
Line 19: Line 19:


=Text=
=Text=
{{#Wiki_filter:"."* ttnu,oro W+**tt UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 475 ALLENDALE ROAD KlNG OF PRUSSTA. PA 19406-1415 May 13, 20LL Mr. Paul Site Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station P.O. Box4, Route 168 Shippingport, PA 15077
{{#Wiki_filter:==SUBJECT:==
 
BEAVER VALLEY POWER STATION - NRC TEMPORARY INSTRUCTION 2515t 183 INSPECTION REPORT 05000334/201 1 008 AND 05000412t201 1oO8
SUBJECT: BEAVER VALLEY POWER STATION - NRC TEMPORARY INSTRUCTION 2515t 183 INSPECTION REPORT 05000334/201 1 008 AND 05000412t201 1oO8


==Dear Mr. Harden:==
==Dear Mr. Harden:==
On April 29,2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Beaver Valley Power Station Units 1 and 2, using Temporary instrubtion 2St 5/183,"Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event." The enclosed inspection report documents the inspection results which were discussed on April 2g, 2011, with you and other members of your staff.The objective of this inspectio.n was to promptly assess the capabilities of Beaver Valley power Station to respond to extrlordinary consequenbes similar to those that have recently oicurred at the Japanese Fukushima Daiichi Nuclear Station. The results from this inspection, ilong with the results from this inspection performed at other operating commercial nuclear piants in the United States will be used to evaluate the U.S. nuclear indrlstry's readiness to saiely respond to similar events. These results will also help the NRC to determine if additional regulitory actions are warranted.
On April 29,2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Beaver Valley Power Station Units 1 and 2, using Temporary instrubtion 2St 5/183,
"Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event." The enclosed inspection report documents the inspection results which were discussed on April 2g, 2011, with you and other members of your staff.


All of the potential issues and observations identified by this inspection are contained in this report. The NRC's Reactor Oversight Process will further evaluate any issues to determine if they are re^gulatory findings or violations.
The objective of this inspectio.n was to promptly assess the capabilities of Beaver Valley power Station to respond to extrlordinary consequenbes similar to those that have recently oicurred at the Japanese Fukushima Daiichi Nuclear Station. The results from this inspection, ilong with the results from this inspection performed at other operating commercial nuclear piants in the United States will be used to evaluate the U.S. nuclear indrlstry's readiness to saiely respond to similar events. These results will also help the NRC to determine if additional regulitory actions are warranted.


Any resulting findings or violations will be documented by the NRC in a separate report. You are not required to resfond to this letter. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's Agency Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.qov/readinq-rm/adams.html (the Public Electronic Reading Room).
All of the potential issues and observations identified by this inspection are contained in this report. The NRC's Reactor Oversight Process will further evaluate any issues to determine if they are re^gulatory findings or violations. Any resulting findings or violations will be documented by the NRC in a separate report. You are not required to resfond to this letter. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's Agency Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.qov/readinq-rm/adams.html (the Public Electronic Reading Room).


Sincerely,,-\ n"..V T( /\ I0^(\.Za^,r-,1-.-, /,\ L'oe^-Lawrence T. Doerflein, Chief I Engineering Branch 2 'Division of Reactor Safety Docket Nos.: 50-334, 50-412 License Nos.: DPR-66, NPF-73  
Sincerely,
,-\\
n
"..V T( /\\
I0^
(\\.Za^,r-,1-.-, /,\\ L'oe^-
Lawrence T. Doerflein, Chief I Engineering Branch 2  
'
Division of Reactor Safety Docket Nos.: 50-334, 50-412 License Nos.: DPR-66, NPF-73 Enclosure: Inspection Report Nos. 0500033412011008 and 0500041212011008 cc w/encl: Distribution via ListServ


===Enclosure:===
=SUMMARY OF FINDINGS=
Inspection Report Nos. 0500033412011008 and 0500041212011008 cc w/encl: Distribution via ListServ
lR 0500033412011008 and 0500041212011008; 0313112011 -0412912011; BeaverValley Power


=SUMMARY OF FINDINGS=
Station, Units 1 and 2;Temporary lnstruction 2515/183 - Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event.
lR 0500033412011008 and 0500041212011008; 0313112011
-0412912011;
BeaverValley Power Station, Units 1 and 2;Temporary lnstruction 2515/183 - Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event.This report covers an announced Temporary lnstruction (Tl) inspection.


The inspection was conducted by two resident inspectors and a region based inspector.
This report covers an announced Temporary lnstruction (Tl) inspection. The inspection was conducted by two resident inspectors and a region based inspector. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.


The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
=INSPECTION SCOPE=


=INSPECTION
SCOPE=
The intent of the Tl is to provide a broad overview of the industry's preparedness for events that may exceed the current design basis for a plant. The focus of the Tl was on
The intent of the Tl is to provide a broad overview of the industry's preparedness for events that may exceed the current design basis for a plant. The focus of the Tl was on
: (1) assessing the licensee's capability to mitigate consequences from large fires or explosions on site,
: (1) assessing the licensee's capability to mitigate consequences from large fires or explosions on site,
: (2) assessing the licensee's capability to mitigate station blackout (SBO) conditions,
: (2) assessing the licensee's capability to mitigate station blackout (SBO) conditions,
: (3) assessing the licensee's capability to mitigate internal and external flooding events accounted for by the station's design, and
: (3) assessing the licensee's capability to mitigate internal and external flooding events accounted for by the station's design, and
: (4) assessing the thoroughness of the licensee's walkdowns and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipment's function could be lost during seismic events possible for the site. lf necessary, a more specific followup inspection will be performed at a later date.INSPECTION RESULTS All of the potential issues and observations identified by this inspection are contained in this report. The NRC's Reactor Oversight Process will further evaluate any issues to determine if they are regulatory findings or violations.
: (4) assessing the thoroughness of the licensee's walkdowns and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipment's function could be lost during seismic events possible for the site. lf necessary, a more specific followup inspection will be performed at a later date.


Any resulting findings or violations will be documented by the NRC in a separate report.Enclosure 03.01 Assess the licensee's capability to mitigate conditions that result from beyond design basis events, typically bounded by security threats, committed to as part of NRC Security Order Section B.5.b issued February 25, 2002, and severe accident management guidelines and as required by Title 10 of the Code of Federal Regulations
==INSPECTION RESULTS==
('10 CFR) 50.54(hh).
All of the potential issues and observations identified by this inspection are contained in this report. The NRC's Reactor Oversight Process will further evaluate any issues to determine if they are regulatory findings or violations. Any resulting findings or violations will be documented by the NRC in a separate report.


Use Inspection Procedure (lP) 71111.05T, "Fire Protection (Triennial)," Section 02.03 and 03.03 as a guideline.
03.01 Assess the licensee's capability to mitigate conditions that result from beyond design basis events, typically bounded by security threats, committed to as part of NRC Security Order Section B.5.b issued February 25, 2002, and severe accident management guidelines and as required by Title 10 of the Code of Federal Regulations ('10 CFR) 50.54(hh). Use Inspection Procedure (lP) 71111.05T, "Fire Protection (Triennial)," Section 02.03 and 03.03 as a guideline. lf lP 71111.05T was recently performed at the facility the inspector should review the inspection results and findings to identify any other potential areas of inspection. Particular emphasis should be placed on strategies related to the spent fuel pool. The inspectjon should include, but not be limited to, an assessment of any licensee actions to:
Licensee Action Describe what the licensee did to test or inspect equipment.


lf lP 71111.05T was recently performed at the facility the inspector should review the inspection results and findings to identify any other potential areas of inspection.
Verify through test or inspection that equipment is available and functional. Active equipment shall be tested and passive equipment shall be walked down and inspected. lt is not expected that permanently installed equipment that is tested under an existing regulatory testing program be retested.


Particular emphasis should be placed on strategies related to the spent fuel pool. The inspectjon should include, but not be limited to, an assessment of any licensee actions to: Licensee Action Describe what the licensee did to test or inspect equipment.
Licensee actions included the identification of equipment (active and passive) utilized for implementation of B.5.b actions and any equipment used in Severe Accident Management Guidelines (SAMGs). The scope of the equipment was defined as that equipment specifically designated for 8.5.b or SAMG mitigation (i.e., special hoses, fittings, diesel fire pumps, etc.).
Permanent plant equipment (i.e., in situ equipment) was not considered in the scope, since it is normally in service, subjected to planned maintenance, and/or checked on operator rounds. The licensee then identified surveillances/tests and performance frequencies for the identified equipment, and reviewed the results of recent tests. Active equipment within the scope defined above that did not have recent test results were verified to have tests planned. Passive equipment within the scope was walked down and inspected. Specific condition reports (CRs) are noted in the supplemental information section.


Verify through test or inspection that equipment is available and functional.
Describe inspector actions taken to confirm equipment readiness (e.9., observed a test, reviewed test results, discussed actions, reviewed records, etc.).
This review should be done for a reasonable sample of mitigating strateg ies/eq uipment.


Active equipment shall be tested and passive equipment shall be walked down and inspected.
The licensee's actions as discussed above were completed prior to the issuance of NRC Tl 2515/183. The inspectors assessed the licensee's capabilities by conducting a review of the licensee's walkdown activities. In addition, the inspectors independently walked down and inspected all major B.5.b contingency response equipment staged throughout the site. The results of the inspectors' independent walkdowns confirmed the results obtained by the licensee.


lt is not expected that permanently installed equipment that is tested under an existing regulatory testing program be retested.Licensee actions included the identification of equipment (active and passive) utilized for implementation of B.5.b actions and any equipment used in Severe Accident Management Guidelines (SAMGs). The scope of the equipment was defined as that equipment specifically designated for 8.5.b or SAMG mitigation (i.e., special hoses, fittings, diesel fire pumps, etc.).Permanent plant equipment (i.e., in situ equipment)was not considered in the scope, since it is normally in service, subjected to planned maintenance, and/or checked on operator rounds. The licensee then identified surveillances/tests and performance frequencies for the identified equipment, and reviewed the results of recent tests. Active equipment within the scope defined above that did not have recent test results were verified to have tests planned. Passive equipment within the scope was walked down and inspected.
Discuss general results including corrective actions by licensee.


Specific condition reports (CRs) are noted in the supplemental information section.Describe inspector actions taken to confirm equipment readiness (e.9., observed a test, reviewed test results, discussed actions, reviewed records, etc.).Enclosure This review should be done for a reasonable sample of mitigating strateg ies/eq uipment.The licensee's actions as discussed above were completed prior to the issuance of NRC Tl 2515/183.
The licensee has no equipment designated for use in the SAMGs that is not considered in-situ plant equipment. Most equipment (active and passive) designated for 8.5.b was verified by the licensee to be in applicable procedures. Deficiencies were noted by the licensee and were corrected. All passive equipment was walked down and verified to be in place and ready for use.


The inspectors assessed the licensee's capabilities by conducting a review of the licensee's walkdown activities.
Passive equipment which had surveillance and/or preventive maintenance tasks had those activities performed to verify readiness for use.


In addition, the inspectors independently walked down and inspected all major B.5.b contingency response equipment staged throughout the site. The results of the inspectors' independent walkdowns confirmed the results obtained by the licensee.Discuss general results including corrective actions by licensee.The licensee has no equipment designated for use in the SAMGs that is not considered in-situ plant equipment.
All active equipment located at the site was verified in place by the licensee. The licensee verified allactive equipment had been tested satisfactory, with one exception. The licensee identified an active component that did not have preventive maintenance or a surveillance procedure available.


Most equipment (active and passive) designated for 8.5.b was verified by the licensee to be in applicable procedures.
The component was verified to have previously operated successfully. The licensee identified this deficiency and entered it into the corrective action program (CAP) as CR 11-91290. The licensee identified a number of minor inventory deficiencies and took action to document and promptly correct.


Deficiencies were noted by the licensee and were corrected.
Based on the reviews conducted, the inspectors concluded that the required equipment is available and functional.


All passive equipment was walked down and verified to be in place and ready for use.Passive equipment which had surveillance and/or preventive maintenance tasks had those activities performed to verify readiness for use.All active equipment located at the site was verified in place by the licensee.
Licensee Action Describe the licensee's actions to verify that procedures are in place and can be executed (e.g.


The licensee verified allactive equipment had been tested satisfactory, with one exception.
walkdowns, demonstrations, tests, etc.).
b. Verify through walkdowns or demonstration that procedures to implement the strategies associated with B.5.b and 10 CFR 50.54(hh) are in place and are executable.


The licensee identified an active component that did not have preventive maintenance or a surveillance procedure available.
Licensees may choose not to connect or operate permanently installed equipment during this verification.


The component was verified to have previously operated successfully.
This review should be done for a reasonable sample of mitigating strategies/eq uipment.


The licensee identified this deficiency and entered it into the corrective action program (CAP) as CR 11-91290.
Licensee actions included the identification of those procedures utilized to mitigate the consequences of a B.5.b related event and severe accidents. The licensee then compiled verification documentation for procedure validations and identified any procedure not issued or validated and any with open change requests. Open change requests were reviewed for potential impacts on procedure functionality. Licensee personnel were then dispatched to walk down all applicable procedures to verify the ability of the procedures to be executed.


The licensee identified a number of minor inventory deficiencies and took action to document and promptly correct.Based on the reviews conducted, the inspectors concluded that the required equipment is available and functional.
Describe inspector actions and the sample strategies reviewed. Assess whether procedures were in place and could be used as intended.


Licensee Action Describe the licensee's actions to verify that procedures are in place and can be executed (e.g.walkdowns, demonstrations, tests, etc.).Enclosure b.Verify through walkdowns or demonstration that procedures to implement the strategies associated with B.5.b and 10 CFR 50.54(hh)are in place and are executable.
The licensee's actions as discussed above were completed prior to the issuance of NRC Tl 25151183. The inspectors assessed the licensee's capabilities by conducting a review of the licensee's documented walkdown activities. In addition, the inspectors selected several sections of a sample of the B.5.b procedures walked down by the licensee and walked those down to independently verify the licensee's conclusions.


Licensees may choose not to connect or operate permanently installed equipment during this verification.
Discuss general results including corrective actions by licensee.


This review should be done for a reasonable sample of mitigating strategies/eq uipment.Licensee actions included the identification of those procedures utilized to mitigate the consequences of a B.5.b related event and severe accidents.
The licensee reviewed SAMG strategies and did not identify any significant issues. Procedures used for 8.5.b were reviewed by the licensee and walkdowns were performed by operators to ensure actions taken in the field in response to a 8.5.b event could be performed. Open procedure change requests were reviewed by the licensee to verify there were no immediate procedure changes required. Some minor corrections and enhancements were identified by the licensee and entered into the CAP:
CR 11-91338 was initiated to evaluate the creation of procedures and staging of equipment to ensure implementation of the strategies; and CR 11-912O2was initiated for several issues related to B.5.b procedure corrections.


The licensee then compiled verification documentation for procedure validations and identified any procedure not issued or validated and any with open change requests.
Based on the reviews conducted, the inspectors concluded that the procedures to implement the strategies associated with B.5.b and'10 CFR 50.54(hh) are in place and are executable.


Open change requests were reviewed for potential impacts on procedure functionality.
Licensee Action Describe the licensee's actions and conclusions regarding training and qualifications of operators and support staff.


Licensee personnel were then dispatched to walk down all applicable procedures to verify the ability of the procedures to be executed.Describe inspector actions and the sample strategies reviewed.
Verify the training and qualifications of operators and the support staff needed to implement the procedures and work instructions are current for activities related to Security Order Section 8.5.b and severe accident management guidelines as required by 10 cFR 50.54 (hh).


Assess whether procedures were in place and could be used as intended.The licensee's actions as discussed above were completed prior to the issuance of NRC Tl 25151183.
Licensee actions included the identification of training/qualification requirements for operators for the implementation of actions needed to mitigate a B.5.b related event, and for the implementation of actions needed for the SAMGs. The licensee documented that operator training requirements were current, and identified those operators with qualification requirements that were not current.


The inspectors assessed the licensee's capabilities by conducting a review of the licensee's documented walkdown activities.
ln addition, the licensee identified the training/qualification requirements for applicable emergency response organization (ERO) command and support staff for the implementation of actions needed to mitigate a B.S.b related event, and for the implementation of actions needed for the SAMGs, and documented that ERO command and support staff training requirements were current. Where applicable, the licensee identified those ERO command and support staff with qualification requirements that were not current.


In addition, the inspectors selected several sections of a sample of the B.5.b procedures walked down by the licensee and walked those down to independently verify the licensee's conclusions.
Describe inspector actions and the sample strategies reviewed to assess training and qualifications of operators and support staff.


Discuss general results including corrective actions by licensee.Enclosure The licensee reviewed SAMG strategies and did not identify any significant issues. Procedures used for 8.5.b were reviewed by the licensee and walkdowns were performed by operators to ensure actions taken in the field in response to a 8.5.b event could be performed.
The licensee's actions as discussed above were completed prior to the issuance of NRC Tl 25151183. The inspectors assessed the licensee's training and qualification activities by conducting a review of training and qualification materials and records related to 8.5.b and SAMG event response.


Open procedure change requests were reviewed by the licensee to verify there were no immediate procedure changes required.
Discuss general results including corrective actions by licensee.


Some minor corrections and enhancements were identified by the licensee and entered into the CAP: CR 11-91338 was initiated to evaluate the creation of procedures and staging of equipment to ensure implementation of the strategies; and CR 11-912O2was initiated for several issues related to B.5.b procedure corrections.
The training requirements, qualifications, and associated records needed for operators for the implementation of SAMGs and 8.5.b event response were reviewed by the licensee. Training was identified for shift managers, shift engineers, and unit supervisors, and the licensee verified that the training requirements were embedded within the position qualifications for the operators. The licensee confirmed that all shift operators verify their qualifications prior to assuming a shift position. The training requirements, qualifications, and associated records needed for ERO command and support staff for the implementation of actions needed to mitigate a B.5.b event or implement the SAMGs were also reviewed. All ERO command and support staff training requirements were verified as current by the licensee with two exceptions:
. The Assistant to Emergency Director Position does not currently include training on the severe accident management guidelines. The Assistant to Emergency Director position is currently located in the Technical Support Center (TSC) and is a technical position.


Based on the reviews conducted, the inspectors concluded that the procedures to implement the strategies associated with B.5.b and'10 CFR 50.54(hh)are in place and are executable.
. Some personnel are not current due to medical restrictions or long term illnesses. Training is completed as personnel are physically able to return to their normal duties.


Licensee Action Describe the licensee's actions and conclusions regarding training and qualifications of operators and support staff.Verify the training and qualifications of operators and the support staff needed to implement the procedures and work instructions are current for activities related to Security Order Section 8.5.b and severe accident management guidelines as required by 10 cFR 50.54 (hh).Licensee actions included the identification of training/qualification requirements for operators for the implementation of actions needed to mitigate a B.5.b related event, and for the implementation of actions needed for the SAMGs. The licensee documented that operator training requirements were current, and identified those operators with qualification requirements that were not current.ln addition, the licensee identified the training/qualification requirements for applicable emergency response organization (ERO) command and support staff for the implementation of actions needed to mitigate a B.S.b related event, and for the implementation of actions needed for the SAMGs, and documented that ERO command and support staff training requirements were current. Where applicable, the licensee identified those ERO command and support staff with qualification requirements that were not current.Enclosure Describe inspector actions and the sample strategies reviewed to assess training and qualifications of operators and support staff.The licensee's actions as discussed above were completed prior to the issuance of NRC Tl 25151183.
The licensee documented this issue as CR 11-91296 to review the gap identified with the SAMG training for the Assistant to Emergency Director.


The inspectors assessed the licensee's training and qualification activities by conducting a review of training and qualification materials and records related to 8.5.b and SAMG event response.Discuss general results including corrective actions by licensee.The training requirements, qualifications, and associated records needed for operators for the implementation of SAMGs and 8.5.b event response were reviewed by the licensee.
The inspectors reviewed the licensee's assessment and corrective actions, and completed an independent assessment. Based on these actions, the inspectors concluded that the training and qualifications of operators and the support staff needed to implement the procedures and work instructions are current for activities related to Security Order Section 8.5.b and severe accident management guidelines as required by 10 CFR 50.54 (hh).


Training was identified for shift managers, shift engineers, and unit supervisors, and the licensee verified that the training requirements were embedded within the position qualifications for the operators.
Licensee Action Describe the licensee's actions and conclusions regarding applicable agreements and contracts are in place.


The licensee confirmed that all shift operators verify their qualifications prior to assuming a shift position.
d. Verify that any applicable agreements and contracts are in place and are capable of meeting the conditions needed to mitigate the consequences of these events.


The training requirements, qualifications, and associated records needed for ERO command and support staff for the implementation of actions needed to mitigate a B.5.b event or implement the SAMGs were also reviewed.
This review should be done for a reasonable sample of mitigating strategies/eq uipment.


All ERO command and support staff training requirements were verified as current by the licensee with two exceptions:. The Assistant to Emergency Director Position does not currently include training on the severe accident management guidelines.
Licensee actions included the identification of all applicable contracts and agreements committed to be in place for the mitigation of a B.5.b related event. The licensee verified that the contracts and agreements were current, and documented whether or not the contracts/agreements were capable of meeting the mitigation strategy.


The Assistant to Emergency Director position is currently located in the Technical Support Center (TSC) and is a technical position.. Some personnel are not current due to medical restrictions or long term illnesses.
For a sample of mitigating strategies involving contracts or agreements with offsite entities, describe inspector actions to confirm agreements and contracts are in place and current (e.9.,
confirm that offsite fire assistance agreement is in place and current).


Training is completed as personnel are physically able to return to their normal duties.The licensee documented this issue as CR 11-91296 to review the gap identified with the SAMG training for the Assistant to Emergency Director.Enclosure The inspectors reviewed the licensee's assessment and corrective actions, and completed an independent assessment.
The licensee's actions as discussed above were completed prior to the issuance of NRC Tl 25151183. The inspectors assessed the licensee's capabilities by conducting an independent review of the licensee's emergency response letters of agreement with the Beaver County Emergency Management Agency. The inspectors' review of the agreement verified that it was current, and assessed whether or not it was adequate for meeting the licensee's mitigation strategy. The inspectors also verified that letters of agreement were in place with the surrounding three states and local counties.


Based on these actions, the inspectors concluded that the training and qualifications of operators and the support staff needed to implement the procedures and work instructions are current for activities related to Security Order Section 8.5.b and severe accident management guidelines as required by 10 CFR 50.54 (hh).Licensee Action Describe the licensee's actions and conclusions regarding applicable agreements and contracts are in place.d.Verify that any applicable agreements and contracts are in place and are capable of meeting the conditions needed to mitigate the consequences of these events.This review should be done for a reasonable sample of mitigating strategies/eq uipment.Licensee actions included the identification of all applicable contracts and agreements committed to be in place for the mitigation of a B.5.b related event. The licensee verified that the contracts and agreements were current, and documented whether or not the contracts/agreements were capable of meeting the mitigation strategy.For a sample of mitigating strategies involving contracts or agreements with offsite entities, describe inspector actions to confirm agreements and contracts are in place and current (e.9., confirm that offsite fire assistance agreement is in place and current).The licensee's actions as discussed above were completed prior to the issuance of NRC Tl 25151183.
Discuss general results including corrective actions by licensee.


The inspectors assessed the licensee's capabilities by conducting an independent review of the licensee's emergency response letters of agreement with the Beaver County Emergency Management Agency. The inspectors' review of the agreement verified that it was current, and assessed whether or not it was adequate for meeting the licensee's mitigation strategy.
' Enclosure


The inspectors also verified that letters of agreement were in place with the surrounding three states and local counties.Discuss general results including corrective actions by licensee.' Enclosure The licensee determined that agreements and contacts were in place and current. No deficiencies were noted. The inspectors concluded that applicable agreements and contracts are in place and are capable of meeting the conditions needed to mitigate the consequences of these events.Licensee Action Document the corrective action report number and briefly summarize problems noted by the licensee that have significant potential to prevent the success of any existing mitigating strategy.e.Review any open corrective action documents to assess problems with mitigating strategy implementation identified by the licensee.
The licensee determined that agreements and contacts were in place and current. No deficiencies were noted. The inspectors concluded that applicable agreements and contracts are in place and are capable of meeting the conditions needed to mitigate the consequences of these events.


Assess the impact of the problem on the mitigating capability and the remaining capability that is not impacted.FENOC determined no significant issues were identified.
Licensee Action Document the corrective action report number and briefly summarize problems noted by the licensee that have significant potential to prevent the success of any existing mitigating strategy.


However, the licensee identified that preventive maintenance (PM) activities and a surveillance procedure were currently not available for an active component utilized in a 8.5.b mitigation strategy.
e. Review any open corrective action documents to assess problems with mitigating strategy implementation identified by the licensee. Assess the impact of the problem on the mitigating capability and the remaining capability that is not impacted.


The component had previously operated successfully and the issue has been entered in the CAP under CR 11-91290.
FENOC determined no significant issues were identified. However, the licensee identified that preventive maintenance (PM) activities and a surveillance procedure were currently not available for an active component utilized in a 8.5.b mitigation strategy. The component had previously operated successfully and the issue has been entered in the CAP under CR 11-91290. Other minor issues were identified and documented in the CRs listed in the Supplemental Information.


Other minor issues were identified and documented in the CRs listed in the Supplemental Information.
The inspectors reviewed the CRs and determined there was not a significant impact to any existing mitigating strategy.


The inspectors reviewed the CRs and determined there was not a significant impact to any existing mitigating strategy.03.02 Assess the licensee's capability to mitigate station blackout (SBO) conditions, as required by 10 CFR 50.63, "Loss of All Alternating Current Power," and station design, is functional and valid. Refer to Tl 25151120, "lnspection of lmplementation of Station Blackout Rule Multi-Plant Action ltem A-22" as a guideline.
03.02 Assess the licensee's capability to mitigate station blackout (SBO) conditions, as required by 10 CFR 50.63, "Loss of All Alternating Current Power," and station design, is functional and valid. Refer to Tl 25151120, "lnspection of lmplementation of Station Blackout Rule Multi-Plant Action ltem A-22" as a guideline. lt is not intended that Tl 25151120 be completely reinspected.


lt is not intended that Tl 25151120 be completely reinspected.
The inspection should include, but not be limited to, an assessment of any licensee actions to:
Licensee Action Describe the licensee's actions to verify the adequacy of equipment needed to mitigate an SBO event.


The inspection should include, but not be limited to, an assessment of any licensee actions to: Licensee Action Describe the licensee's actions to verify the adequacy of equipment needed to mitigate an SBO event.Enclosure a. Verify through walkdowns and inspection that all required materials are adequate and properly staged, tested, and maintained.
a. Verify through walkdowns and inspection that all required materials are adequate and properly staged, tested, and maintained.


Licensee actions included the identification of equipment utilized/required for mitigation of a SBO.The licensee then conducted walkdowns to ensure this equipment was adequate and properly staged. Additionally, the licensee also conducted a review of open CAP items for potential SBO equipment impact.Describe inspector actions to verify equipment is available and useable.The inspectors assessed the licensee's capability to mitigate SBO conditions by conducting a review of the licensee's walkdown activities.
Licensee actions included the identification of equipment utilized/required for mitigation of a SBO.


ln addition, the inspectors selected a sample of equipment utilized/required for mitigation of a SBO and conducted independent walkdowns of that equipment to verify that the equipment was properly aligned and staged. The sample of equipment selected by the inspectors included, but was not limited to, the SBO cross{ie and Emergency Response Facility (ERF) diesel generator and related infrastructure.
The licensee then conducted walkdowns to ensure this equipment was adequate and properly staged. Additionally, the licensee also conducted a review of open CAP items for potential SBO equipment impact.


Discuss general results including corrective actions by licensee.The above reviews verified that SBO equipment was ready to respond to a SBO condition.
Describe inspector actions to verify equipment is available and useable.


However, the inspectors noted that challenges exist due to current UPS failures that support the ERF diesel generator, requiring extra procedure actions to power ERF buses. The licensee has entered this issue into the CAP and plans to repair the equipment deficiency The licensee initiated two conditions reports for issues identified during the walkdowns:
The inspectors assessed the licensee's capability to mitigate SBO conditions by conducting a review of the licensee's walkdown activities. ln addition, the inspectors selected a sample of equipment utilized/required for mitigation of a SBO and conducted independent walkdowns of that equipment to verify that the equipment was properly aligned and staged. The sample of equipment selected by the inspectors included, but was not limited to, the SBO cross{ie and Emergency Response Facility (ERF) diesel generator and related infrastructure.
CR 11-91206, Manual charging spring toolfor 4kV breakers could not be found, and no ladder staged in intake "C" cubicle for accessing required valves; and CR 11-91347, Components to open HW-1FW-1OOA(BXC)insufficiently labeled to ensure proper connections.


The inspectors determined these issues would not have prevented successful implementation of SBO procedures.
Discuss general results including corrective actions by licensee.


Licensee Action Describe the licensee's actions to verify the capability to mitigate an SBO event.b.Demonstrate through walkdowns that procedures for response to an SBO are executable.
The above reviews verified that SBO equipment was ready to respond to a SBO condition.


Licensee actions included the identification of procedures required for response to a SBO, along with verification that the identified procedures were current and that no critical revision requests were in place. The licensee then verified that the mitigating procedures had been properly validated and performed walkdowns of selected procedures.
However, the inspectors noted that challenges exist due to current UPS failures that support the ERF diesel generator, requiring extra procedure actions to power ERF buses. The licensee has entered this issue into the CAP and plans to repair the equipment deficiency The licensee initiated two conditions reports for issues identified during the walkdowns: CR 11-91206, Manual charging spring toolfor 4kV breakers could not be found, and no ladder staged in intake "C" cubicle for accessing required valves; and CR 11-91347, Components to open HW-1FW-1OOA(BXC) insufficiently labeled to ensure proper connections. The inspectors determined these issues would not have prevented successful implementation of SBO procedures.


Additionally, the licensee conducted a review of open CAP items for potential impact to SBO procedures.
Licensee Action Describe the licensee's actions to verify the capability to mitigate an SBO event.


Describe inspector actions to assess whether procedures were in place and could be used as intended.The inspectors assessed the licensee's capabilities by conducting a review of the licensee's walkdown activities.
b. Demonstrate through walkdowns that procedures for response to an SBO are executable.


In addition, the inspectors selected several sections of a sample of the procedures walked down by the licensee and walked those down to independently verify the licensee's conclusions.
Licensee actions included the identification of procedures required for response to a SBO, along with verification that the identified procedures were current and that no critical revision requests were in place. The licensee then verified that the mitigating procedures had been properly validated and performed walkdowns of selected procedures. Additionally, the licensee conducted a review of open CAP items for potential impact to SBO procedures.


Discuss general results including corrective actions by licensee.The licensee procedures utilized to respond to an SBO are within the scope of the site emergency operating procedures (EOPs). Actions to start the SBO diesel generator (a functional EDG on the non-affected unit) and supply power to the affected-unit vital buses are performed from the control room (as augmented with field actions) with permanently installed plant equipment.
Describe inspector actions to assess whether procedures were in place and could be used as intended.


For the purposes of this requirement, the licensee credited their original validation of the specific EOP by a crew of licensed operators on the simulator prior to the implementation of the current revision.No significant current issues were identified by the licensee, however three CRs were written to document minor issues and/or areas for improvement (CRs 11-91263,11-91353, and 11-91356).
The inspectors assessed the licensee's capabilities by conducting a review of the licensee's walkdown activities. In addition, the inspectors selected several sections of a sample of the procedures walked down by the licensee and walked those down to independently verify the licensee's conclusions.


Although the station meets the current design and licensing bases for station blackout, the inspectors concluded that coping with a dual unit SBO (a beyond design basis event) could present significant challenges.
Discuss general results including corrective actions by licensee.


For example: the SBO cross-tie equipment is located in non-seismically qualified areas (normal switchgear)of each unit; and Unit 1 requires AC power to the MOVs to isolate the safety injection accumulators during RCS depressurization.
The licensee procedures utilized to respond to an SBO are within the scope of the site emergency operating procedures (EOPs). Actions to start the SBO diesel generator (a functional EDG on the non-affected unit) and supply power to the affected-unit vital buses are performed from the control room (as augmented with field actions) with permanently installed plant equipment. For the purposes of this requirement, the licensee credited their original validation of the specific EOP by a crew of licensed operators on the simulator prior to the implementation of the current revision.


The licensee documented the general issue of a dual unit SBO under CR 1 1-93717.03.03 Assess the licensee's capability to mitigate internal and external flooding events required by station design. Refer to lP 71111.01, "Adverse Weather Protection," Section 02.04, "Evaluate Readiness to Cope with External Flooding" as a guideline.
No significant current issues were identified by the licensee, however three CRs were written to document minor issues and/or areas for improvement (CRs 11-91263,11-91353, and 11-91356).


The inspection should include, but not be limited to, an assessment of any licensee actions to verify through walkdowns and inspections that all required materials and equipment are adequate and properly staged. These walkdowns and inspections shall include verification that accessible doors, barriers, and penetration seals are functional.
Although the station meets the current design and licensing bases for station blackout, the inspectors concluded that coping with a dual unit SBO (a beyond design basis event) could present significant challenges. For example: the SBO cross-tie equipment is located in non-seismically qualified areas (normal switchgear) of each unit; and Unit 1 requires AC power to the MOVs to isolate the safety injection accumulators during RCS depressurization.


Licensee Action Describe the licensee's actions to verify the capability to mitigate existing design basis flooding events.a. Verify through walkdowns and inspection that all required materials are adequate and properly staged, tested, and maintained.
The licensee documented the general issue of a dual unit SBO under CR 1 1-93717.


Licensee actions included the identification of equipment and penetration seals utilized/required for mitigation of internal and external flooding.
03.03 Assess the licensee's capability to mitigate internal and external flooding events required by station design. Refer to lP 71111.01, "Adverse Weather Protection," Section 02.04, "Evaluate Readiness to Cope with External Flooding" as a guideline. The inspection should include, but not be limited to, an assessment of any licensee actions to verify through walkdowns and inspections that all required materials and equipment are adequate and properly staged. These walkdowns and inspections shall include verification that accessible doors, barriers, and penetration seals are functional.


The licensee then conducted walkdowns of this equipment to ensure it was adequate and properly staged. Doors, barriers, and penetration seals that were utilized for mitigation of flooding were identified, and checked to see if they were routinely inspected to ensure functionality.
Licensee Action Describe the licensee's actions to verify the capability to mitigate existing design basis flooding events.


Where routine inspections were not performed or could not be relied upon to ensure functionality, the licensee performed walkdowns and inspections to ensure that the components were functional.
a. Verify through walkdowns and inspection that all required materials are adequate and properly staged, tested, and maintained.


Describe inspector actions to verify equipment is available and useable. Assess whether procedures were in place and could be used as intended.Enclosure The inspectors assessed the licensee's capabilities to mitigate flooding by conducting a review of the licensee's walkdown activities.
Licensee actions included the identification of equipment and penetration seals utilized/required for mitigation of internal and external flooding. The licensee then conducted walkdowns of this equipment to ensure it was adequate and properly staged. Doors, barriers, and penetration seals that were utilized for mitigation of flooding were identified, and checked to see if they were routinely inspected to ensure functionality. Where routine inspections were not performed or could not be relied upon to ensure functionality, the licensee performed walkdowns and inspections to ensure that the components were functional.


In addition, the inspectors conducted independent walkdowns of selected flood mitigation equipment to contribute to the overall assessment of the licensee's flood mitigating capabitities.
Describe inspector actions to verify equipment is available and useable. Assess whether procedures were in place and could be used as intended.


Licensee flood mitigation procedures were reviewed to verify usability.
The inspectors assessed the licensee's capabilities to mitigate flooding by conducting a review of the licensee's walkdown activities. In addition, the inspectors conducted independent walkdowns of selected flood mitigation equipment to contribute to the overall assessment of the licensee's flood mitigating capabitities. Licensee flood mitigation procedures were reviewed to verify usability. The inspectors' conclusions aligned with the results obtained by the licensee.


The inspectors' conclusions aligned with the results obtained by the licensee.Discuss general results including corrective actions by licensee.The inspectors concluded that all required materials are adequate and properly staged, tested, and maintained to respond to an internal or external flood within the plant's design basis. While no operability or significant concerns were identified, the licensee identified that two portable pumps credited in the flood analysis did not have periodic testing performed, and that flood barriers and penetrations that were not part of the fire protection program were not routinely inspected.
Discuss general results including corrective actions by licensee.
 
These and several other minor deficiencies were entered into the CAP and the associated condition reports are listed in the Attachment to this report. The inspectors reviewed these condition reports and determined the licensee's initial responses, including their assessment and prioritization, were appropriate.


03.04 Assess the thoroughness of the licensee's walkdowns and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipment's function could be lost during seismic events possible for the site. Assess the licensee's development of any new mitigating strategies for identified vulnerabilities (e.9., entered it in to the corrective action program and any immediate actions taken). As a minimum, the licensee should have performed walkdowns and inspections of important equipment (permanent and temporary)such as storage tanks, plant water intake structures, and fire and flood response equipment; and developed mitigating strategies to cope with the loss of that important function.
The inspectors concluded that all required materials are adequate and properly staged, tested, and maintained to respond to an internal or external flood within the plant's design basis. While no operability or significant concerns were identified, the licensee identified that two portable pumps credited in the flood analysis did not have periodic testing performed, and that flood barriers and penetrations that were not part of the fire protection program were not routinely inspected. These and several other minor deficiencies were entered into the CAP and the associated condition reports are listed in the Attachment to this report. The inspectors reviewed these condition reports and determined the licensee's initial responses, including their assessment and prioritization, were appropriate.


Use lP 71111.21, "Component Design Basis lnspection," Appendix 3, "Component Walkdown Considerations," as a guideline to assess the thoroughness of the licensee's walkdowns and inspections.
03.04 Assess the thoroughness of the licensee's walkdowns and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipment's function could be lost during seismic events possible for the site. Assess the licensee's development of any new mitigating strategies for identified vulnerabilities (e.9., entered it in to the corrective action program and any immediate actions taken). As a minimum, the licensee should have performed walkdowns and inspections of important equipment (permanent and temporary) such as storage tanks, plant water intake structures, and fire and flood response equipment; and developed mitigating strategies to cope with the loss of that important function. Use lP 71111.21, "Component Design Basis lnspection," Appendix 3, "Component Walkdown Considerations," as a guideline to assess the thoroughness of the licensee's walkdowns and inspections.


Licensee Action Describe the licensee's actions to assess the potential impact of seismic events on the availability of equipment used in fire and flooding mitigation strategies.
Licensee Action Describe the licensee's actions to assess the potential impact of seismic events on the availability of equipment used in fire and flooding mitigation strategies.
Line 212: Line 220:
Licensee actions included the identification of equipment utilized/required for mitigation of fire and flood events. An engineering inspection plan was established by the licensee to govern the conduct of walkdowns and inspections of the equipment, both permanent and temporary.
Licensee actions included the identification of equipment utilized/required for mitigation of fire and flood events. An engineering inspection plan was established by the licensee to govern the conduct of walkdowns and inspections of the equipment, both permanent and temporary.


Licensee engineering personnel determined if the equipment was seismically qualified, or assessed whether it would be possible to evaluate the equipment as being seismically rugged.Seismic vulnerabilities, including storage locations, were identified, along with mitigating strategies for equipment that was not seismically qualified.
Licensee engineering personnel determined if the equipment was seismically qualified, or assessed whether it would be possible to evaluate the equipment as being seismically rugged.
 
Describe inspector actions to verify equipment is available and useable. Assess whether procedures were in place and could be used as intended.Enclosure The inspectors conducted multiple independent walkdowns of important equipment needed to mitigate fire and flood events to identify the potential that the equipment's function could be lost during a seismic event. This equipment included, but was not limited to:. all major B.5.b contingency response equipment staged throughout the site;. the installed diesel and electric fire pumps, their controls, and other fire equipment; r the Emergency Response Facility diesel generator; and o watertight doors and floor plugs at the plant's main and alternate intake structures.
 
Licensee flood and fire mitigation procedures were reviewed to verify usability.
 
The results of the inspectors' reviews aligned with the licensee's conclusions that there were a number of seismic vulnerabilities that may need to be addressed, as described below. The inspectors concluded that the licensee meets the current design and licensing bases for B.5.b, fire and flood protection.


Discuss general results including corrective actions by licensee.
Seismic vulnerabilities, including storage locations, were identified, along with mitigating strategies for equipment that was not seismically qualified.


Briefly summarize any new mitigating strategies identified by the licensee as a result of their reviews."Seismically qualifled" is defined as the SSCs that have been formally qualified to function during and after a design basis earthquake, as applicable.
Describe inspector actions to verify equipment is available and useable. Assess whether procedures were in place and could be used as intended.


The licensee's reviews for this issue determined that non-safety related SSCs, in general, were not considered to be either seismically qualified or seismically rugged. The majority of room flood mitigation sump pumps and flooding detectors were not designed as seismically qualified, and have not been evaluated as being seismically rugged. Similarly, the vast majority of the fire protection system / piping, including both installed fire pumps, were not designed as seismically qualified and cannot be considered seismically rugged. Firefighting equipment staged to respond to 8.5.b events was not stowed in seismically qualified buildings and locations, as a seismic event and 8.5.b event were not assumed to occur coincidentally.
The inspectors conducted multiple independent walkdowns of important equipment needed to mitigate fire and flood events to identify the potential that the equipment's function could be lost during a seismic event. This equipment included, but was not limited to:
. all major B.5.b contingency response equipment staged throughout the site;
. the installed diesel and electric fire pumps, their controls, and other fire equipment; r the Emergency Response Facility diesel generator; and o watertight doors and floor plugs at the plant's main and alternate intake structures.


The licensee's reviews identified instances where response capability could be enhanced.
Licensee flood and fire mitigation procedures were reviewed to verify usability. The results of the inspectors' reviews aligned with the licensee's conclusions that there were a number of seismic vulnerabilities that may need to be addressed, as described below. The inspectors concluded that the licensee meets the current design and licensing bases for B.5.b, fire and flood protection.


These included improving procedural guidance, reviewing the locations of portable equipment, and reviewing the need for supplemental portable equipment to compensate for the possible loss of the fire water storage tank, the fire pumps, and much of the fire suppression system pipinq.Enclosure Further, reviews by the licensee identified that, in the event of a postulated earthquake, equipment may not function properly due to loss of vital power or being subjected to physical displacement.
Discuss general results including corrective actions by licensee. Briefly summarize any new mitigating strategies identified by the licensee as a result of their reviews.


The existing mitigation strategy, to conduct station surveys per emergency plan off normal occurrence procedure RA-EP-02820, "Earthquake," was considered presently sufficient by the licensee.
"Seismically qualifled" is defined as the SSCs that have been formally qualified to function during and after a design basis earthquake, as applicable. The licensee's reviews for this issue determined that non-safety related SSCs, in general, were not considered to be either seismically qualified or seismically rugged. The majority of room flood mitigation sump pumps and flooding detectors were not designed as seismically qualified, and have not been evaluated as being seismically rugged. Similarly, the vast majority of the fire protection system / piping, including both installed fire pumps, were not designed as seismically qualified and cannot be considered seismically rugged. Firefighting equipment staged to respond to 8.5.b events was not stowed in seismically qualified buildings and locations, as a seismic event and 8.5.b event were not assumed to occur coincidentally.


Further mitigation strategies, the licensee determined, will entailfollowing industry recommendations from other plants that have identified similar beyond-design-bases vulnerabilities.
The licensee's reviews identified instances where response capability could be enhanced. These included improving procedural guidance, reviewing the locations of portable equipment, and reviewing the need for supplemental portable equipment to compensate for the possible loss of the fire water storage tank, the fire pumps, and much of the fire suppression system pipinq.


The licensee entered the issues identified into their CAP CRs 11-92571.
Further, reviews by the licensee identified that, in the event of a postulated earthquake, equipment may not function properly due to loss of vital power or being subjected to physical displacement.


and 11-93717.Enclosure Meetinqs 40A6 Exit Meetinq The inspectors presented the inspection results to Mr. Paul Harden and other members of licensee management at the conclusion of the inspection on April 29,2011. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary.
The existing mitigation strategy, to conduct station surveys per emergency plan off normal occurrence procedure RA-EP-02820, "Earthquake," was considered presently sufficient by the licensee. Further mitigation strategies, the licensee determined, will entailfollowing industry recommendations from other plants that have identified similar beyond-design-bases vulnerabilities. The licensee entered the issues identified into their CAP CRs 11-92571. and 11-93717.


No proprietary information was identified.
Meetinqs 40A6 Exit Meetinq The inspectors presented the inspection results to Mr. Paul Harden and other members of licensee management at the conclusion of the inspection on April 29,2011. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.


A-1  
A-1


=SUPPLEMENTAL
=SUPPLEMENTAL INFORMATION=
INFORMATION=


==KEY POINTS OF CONTACT==
==KEY POINTS OF CONTACT==
Licensee  
Licensee
: [[contact::P. Harden]], Site Vice President, Beaver Valley Power Station  
: [[contact::P. Harden]], Site Vice President, Beaver Valley Power Station
: [[contact::R. Lieb]], Director of Site Operations, Beaver Valley Power Station  
: [[contact::R. Lieb]], Director of Site Operations, Beaver Valley Power Station
: [[contact::G. Cramer]], Manager, Emergency
: [[contact::G. Cramer]], Manager, Emergency Response
Response  
: [[contact::C. Hynes]], Manager, Site Training
: [[contact::C. Hynes]], Manager, Site Training  
: [[contact::C. Mancuso]], Manager, Design Engineering
: [[contact::C. Mancuso]], Manager, Design Engineering
: [[contact::C. McFeaters]], Manager, Operations
: [[contact::C. McFeaters]], Manager, Operations
: [[contact::J. Miller]], Site Fire Marshal  
: [[contact::J. Miller]], Site Fire Marshal
: [[contact::D. Price]], Supervisor, Design Engineering
: [[contact::D. Price]], Supervisor, Design Engineering
: [[contact::M. Ressler]], Supervisor, Engineering
: [[contact::M. Ressler]], Supervisor, Engineering Analysis
Analysis  
: [[contact::B. Rudolph]], Superintendent, Operations Training
: [[contact::B. Rudolph]], Superintendent, Operations
: [[contact::K. Woessener]], Staff Nuclear Engineer, Beaver Valley IER 11-1 Response Team Lead
Training  
Nuclear Requlatory Commission
: [[contact::K. Woessener]], Staff Nuclear Engineer, Beaver Valley IER 11-1 Response Team Lead Nuclear Requlatory
: [[contact::C. Cahill]], Senior Reactor Analyst
Commission
W, Cook, Senior Reactor Analyst
: [[contact::C. Cahill]], Senior Reactor Analyst W, Cook, Senior Reactor Analyst Other Personnel  
Other Personnel
: [[contact::L. Ryan]], Inspector, Pennsylvania
: [[contact::L. Ryan]], Inspector, Pennsylvania Bureau of Radiation Protection
Bureau of Radiation
Protection


==LIST OF DOCUMENTS==
==LIST OF DOCUMENTS==
REVTEWED The following is a list of documents reviewed during the inspection.
REVTEWED
: Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety but rather that selected'sections of portions of the documents were evaluated as part of the overall inspection effort. Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.03.01 Assess the licensee's capability to mitigate conditions that result from beyond design basis events Procedures:
: 1/2OM-53C.4A.100.1, 8.5.b and Threat-Related Mitigation Procedures, Rev. 2 1/2OM-53C.4A.100.2, B.5.b and Threat-Related Mitigation Procedures, Rev. 3 1/2OM-53C.4A.100.3, 8.5.b and Threat-Related Mitigation Procedures, Rev. 2 1/2OM-53C.4A.100.4, 8.5.b and Threat-Related Mitigation Procedures, Rev. 4 Attachment
: 1/2OM-53C.4A.100.5, B.5.b and Threat-Related Mitigation Procedures, Rev. 0 1/2OM-53C.4A.100.6, B.5.b and Threat-Related Mitigation Procedures, Rev. 5 1/2OST-33.33, Fire Protection Equipment lnventory, Rev.4 2OM-53A.1.A-1.8, Makeup to PPDWST [2FWE.TK210l, Rev.5 2OM-53A.1.A-1.11, Manual Handpump Operation of Hydraulically Actuated Valves, Rev. 5 Condition Reports: 11-91202,100
: Series AOPs Missing Steps 11-91206, Missing Tools/Ladders to Support SBO Response 11-91260,100
: Series AOPs Missing lnventory 11-91261, 1/2OST-33.33
: Deficiencies
: 11-91290, Active Component Without PM 1 1 -91294, Missing Flashlights
: 11-91296, Assistant to Emergency Director Training on SAMGs 1
: 1-91319, Operations Training for Security Threat 1 1 -9 1 325, Phone-Control Room Satel I ite Coverage 1
: 1-91338, Equipment and Procedures not Designated for 8.5.b 1
: 1-91345, Equipment Availability lssues 11-93575, High-Pressure Godwin Pump Duplex Strainer Operation lssues 03.02 Assess the licensee's capability to mitigate station blackout (SBO) conditions Procedures:
: 1OM-53A.1.ECA-0.0(lSS1C), Loss of all Emergency
: 4kV AC Power, Rev. 8 1OM-S3A.1.ECA-g.1(lSS1C), Loss of allAC Power RecoveryWithout Sl Required, Rev.5 1OM-53A.1 .ECA-0.2(ISS1C), Loss of all AC Power Recovery With Sl Required, Rev. 5 1OM-53A.1.2-D, AC Power Restoration from Offsite, Rev.2 1OM-53A.1
.2-E(ISS1
: C), Local Action to Restore AC Power, Rev. 3 1OM-S3A.1.2-F(lSS1C), Diesel GeneratorAuto Loading and Auxiliary Equipment, Rev.2 1OM-53A.1.2-G(lSS1C), Natural Circulation Verification, Rev. 1 1OM-53A.1.2-H(lSS1C), Makeup to PPDWST [1WT-TK-10], Rev. 2 1OM-53A.1.2-1, Response to Loss of AFW Pump Suction Flow, Rev. 1 1OM-53A.1.2-J(lSS1C), Feeding Steam Generators from Condensate System, Rev. 1 1OM-53A.1.2-K(lSS1C), Dedicated
: AFW Pump [1FW-P-4]
: Startup, Rev. 1 1OM-S3A.1.2-O-AE(ISS1C), Starting River Water Pump on Bus 1AE During SBO, Rev. 0 1OM-S3A.1.2-O-DF(lSS1C), Starting RiverWater Pump on Bus 1DF During SBO, Rev.0 1OM-S3A.1.2-P-AE(lSS1C), Starting Charging/HHSI
: Pump on Bus 1AE During SBO, Rev. 0 1OM-53A.1.2-P-DF(lSS1C), Starting Charging/HHSI
: Pump on Bus 1DF During SBO, Rev.0 1OM-S3A.1
.2-O-AE(lSS1C), Restoring Equipment from Bus 1AE after SBO at
: BV-1, Rev. 0 1OM-S3A.1
.2-O-DF(lSS1C), Restoring Equipment from Bus 1 DF after SBO at
: BV-1 , Rev. 0 1OM-53A.1.2-S(lSS1C), Monitoring
: AFW Pump Performance During Loss of Station Instrument Air, Rev.3 1OM-S3A.1
.2-T, Opening One SG Main FW Containment lsolation Valve Without Power, Rev' 0 1OM-53A.1.2-U, Local Operation of SG Atmospheric Steam Dump Valves, Rev- 1 1OM-S3A.1 .A-1.14(lSS1C),
: BV-1 Actions to Establish
: SBO Cross-Tie to
: BV-2, Rev. 2 1
: OM-53A.1 .A-1 .1 7(lSS1 C), Restoring
: BV-1 Equipment after SBO at
: BV-2, Rev. 0 Attachment
: 1OM-53A.1.2-M-AE, Actions to Establish
: BV-2 Cross-tie to Bus 1AE During SBO, Rev. 3 2OM-53A.1.ECA-0.0(ISS1C), Loss of all AC Power, Rev. 10 2OM-53A.1.ECA-O.1(lSS1C), Loss of all AC Power Recovery Without Sl Required, Rev. 7 2OM-53A.1.ECA-0.2(lSS1C), Loss of all AC Power Recovery With Sl Required, Rev. 5 2OM-53A.1.2-N(1SS1C),
: BV-2 Actions to Establish
: SBO Cross-Tie to
: BV-1, Rev. 1 2OM-53A.1.2-N(1SS1C),
: BV-2 Actions to Establish
: SBO Cross-Tie to
: BV-1, Rev. 1 2OM-53A.1.2-R(ISS1C), Restoring
: BV-2 Equipment after SBO at
: BV-1, Rev. 0 2OM-53A.1.A-1.10(lSS1C), Feeding Steam Generators from Condensate System, Rev. 0 2OM-53A.1.A-1.1
: 1, Manual Handpump Operation of Hydraulically Actuated Valves, Rev. 5 2OM-53A.1.A-1.12, Local Actions to Restore AFW Flow, Rev. 4 2OM-53A.1.A-1.15AE, Starting Charging/HHSI
: Pump on BUS 2AE During SBO, Rev. 0 2OM-53A.1.A-1.1SDF, Starting Charging/HHSI
: Pump on BUS 2DF During SBO, Rev.0 2OM-53A.1.A-1.16AE, Restoring
: BV-2 Equip from Bus 2AE after SBO at
: BV-2, Rev. 1 2OM-53A.1.A-1.16DF, Restoring
: BV-2 Equip from Bus 2DF after SBO at
: BV-2, Rev. 1 2OM-53A.1 .A-1 .1 8(lSS1 C), ERFS Diesel Generator Startup, Rev. 0 2OM-53A.1 .A-1.4, AC Power Restoration from Offsite, Rev. 1 2OM-53A.1.A-1.5(lSS1C), LocalAction to Restore AC Power, Rev. 5 2OM-53A.1.A-1.6, GeneratorAuto Loading and Auxiliary Equipment, Rev' 3 2OM-53A.1.A-1.8, Makeup to PPDWST [2FWE.TK21O), Rev' 5 2DD.ECA-0.2, Loss of All AG Power Recovery with Sl Required Deviation Document, Rev. 1C-5 2OM-53A.1 .A-1.15AE, Starting Charging/HHSI
: Pump on Bus 2AE During an SBO, Rev. 1C-0 2OM-53A.1.ECA-0.0, Loss of AIIAC Power, Rev. 1C-10 2OM-53A.a.A-1.13AE, Actions to Establish
: BV-1 Cross-Tie to Bus 2AE During SBO, Rev. 2 2OM-53A.a.A-1.22, Steam Generator Makup During SBO Using [3FP-P-7], Godwin High-Pressure Pump, Rev. 0 Condition Reports: 1
: 1-91263, SBO Procedure Corrections
: 11-91347, EOP Attachment
: 2-T lssues ldentified During Walkdown 11-91353, U2 Lighting Deficiency at ASD Panel 1
: 1-91356, Pre-staged
: SBO Equipment lmprovements
: 11-91549, Testing lssues for 1RW-60 and 2SWS-60 11-91671, Equipment Needed for
: AOP 75.2 Not Staged 11-92242, ERFS - UPS#2 Failure 11-93717*, lnspector Questions
: BVPS Dual Unit SBO Assumptions
* Condition Report written as a result of inspection.
: Calculations/Evaluations:
: 10080-E-048, SBO Loading Analysis, Rev. 12-AB Attachment
: 03.03 Assess the licensee's capability to mitigate internal and external flooding events required by station design Procedures:
: 1/2OM-53C.4A.75.2, Acts of Nature - Flood, Rev. 28 1i2OM-53C.4A.75.4, Acts Of Nature - Dam Failure, Rev. 7 1BVT1.33.07, Flood Seals Visual Inspection, Rev. 4 1OM-30.4.AAA, CC WTR HT EXCH RiverWTR PP DISH Line'A'Press Low, Rev. l3-R2 1OM-30.4.AA8, CC WTR HT EXCH River WTR PP DISH Line 'B' Press Low, Rev. l3-R2 1OM-30.4.AAC, Intake Struct Water Pump Discharge Line'A' Press Low, Rev. 3 1OM-30.4.AAD, Intake Struct River Water Pump Discharge Line 'B' Pressure Low, Rev. l3-R2 1OM-36.4.AEY, Diesel Generator Room No. 1 or No. 2 Sump Level High, Rev. 0 1OM-41D.4.AA8, Service Building Water Accumulation, Rev. 5 1OM-9.4.AA1, Aux Bldg Well Sump Level High, Rev. 1 1OM-9.4.AAJ, Aux Building North Sump Level High, Rev. 2 1OM-9.4.AAK, Tunnel Sump Level High, Rev. 3 1OM-9.4.AAM, Safeguards Area Sump Level High, Rev. 0 1OM-9.4.AAN, Fuel Building Sump Level High, Rev. 2 1OM-9.4.AAO, Aux Building South Sump Level High, Rev. 1 1OM-9.4.AAQ, Charging Pump 1A Cubicle Sump Level High, Rev. 0 1OM-9.4.AAR, Charging Pump 1B Cubicle Sump Level High, Rev.0 1OM-9.4.AAS, Charging Pump 1C Cubicle Sump Level High, Rev. 1 28l/l1.33.7, Flood Seals Visual Inspection, Rev. 3 2OM-41D.4.AAA, Diesel Generator Building Sump Level High, Rev' 3 2OM-41D.4.AAF, Elect Cable Tunnel/Contiguous Area Sump Level High, Rev. 6 2OM-9,4.AAE, Fuel Building Sump Level High, Rev. 2 2OM-9.4.AAH, Rod ControlArea Pipe Tunnel Sump Level High, Rev. 3 2OM-9.4.AA1, Auxiliary Building Sump Level High, Rev. 2 2OM-9.4.AAJ, Safeguards Area Sump Level High, Rev. 1 2OST-33.35A, Fire Rated Penetration Seals Visual lnspection Outage Required, Rev. 0 Condition Reports: 11-91736, No Procedure for Intake Structures Pump Cubicle Internal Flooding Response 11-91840, Flood Seal Inspection
: BWs Require Revision 11-91843, Unit 1 Internal Conduit Flood Seals lnaccessible for Inspection
: 1-91846, Unit 2 Flood Seals Inaccessible for Inspection
: 11-91853, Periodic Flood Seal Inspections by BWs Not Performed Since 2005 11-91860, Review of Open Orders for Flood Seal lmpact 1 1 -91887, Flood Equipment ldentified Without Inventory/OST
'11-91890, Flood Door Not Electronically Supervised and Not Periodically Verified 1
: 1-91894, Credited Door Not Supervised and Not Periodically Verified 11-91899, Undesignated Flood Barriers in BVPS -1 Main Steam Valve Area 11-91900, BVPS 1 & 2 Sump Level Switches Not in Calibration Program 11-92062, Credited Floor Drains do Not Have a PM Task 11-92065, Passive Flood Barriers are Not Specified in Admin Procedure Attachment Calculations/Evaluations:
: ES-M-036, Report of the Effects of a Piping System Break Outside Containment, Rev. 0 Drawinqs: 8700-RA-19A, Intake Structure, Plan & Elevation, Rev. I 8700-RA-198, Intake Structure, Wall Sections & Details, Rev. 9 Other:
: BVPS-1 UFPARR,
: BVPS-1 Updated Fire Protection Appendix R Review, Rev. 30
: BVPS-1 UFSAR Section 2J.3.2.5, Other Plant Areas and Equipment, Rev. 25
: BVPS-1 UFSAR Section 9.7.2, Vent and Drain System Description, Rev.25
: BVPS-2 FPSSR,
: BVPS-2 Fire Protection Safe Shutdown Report, Rev. 36 03.04 Assess the thoroughness of the licensee's walkdowns and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipment's function could be lost during seismic events Procedures:
: 1OM-30.4.AAA, CC WTR HT EXCH River WTR PP DISH Line 'A' Press Low, Rev. l3-R2 1OM-30.4.AAC, Intake Struct Water Pump Discharge Line 'A' Press Low, Rev. 3 1OM-53E.1.SAG-2, Depressurize the RCS, Rev. 3 1OM-53A.1.E-0(lSS1C), Reactor Trip or Safety Injection, Rev. 11 1OM-53A.1.E-1(lSS1C), Loss of Reactor or Secondary Coolant, Rev. 14 1OM-53A.1.FR-C.1(lSS1C), Response to lnadequate Core Cooling, Rev. 8 1OM-53A.1.FR-l.3(lSS1C), Response to Voids in Reactor Vessel, Rev. 6 1OM-53A.1.FR-S.2(lSS1C), Response to Loss of Core Shutdown, Rev. 1 1OM-53A.1 .FR-2.1(lSS1C), Response to High Containment Pressure, Rev' 2 1OM-53A.1.FR-Z.2(lSS1C), Response to Containment Flooding, Rev. 2 2OM-53E.1.SAG-2, Depressurize the RCS, Rev.2 2OM-53A.1.E-0(lSS1C), Reactor Trip or Safety Injection, Rev. 8 2OM-53A.1 .E-1(lSS1C), Loss of Reactor or Secondary Coolant, Rev. 12 2OM-53A.1.FR-C.1(1SS1C), Response to Inadequate Core Cooling, Rev. 5 2OM-53A.1.FR-l.3(lSS1C), Response to Voids in Reactor Vessel, Rev. 8 2OM-53A.1.FR-S.2(ISS1C), Response to Loss of Core Shutdown, Rev' 1 2OM-53A.1.FR-Z.1(lSS1C), Response to High Containment Pressure, Rev. 2 2OM-53A.1.FR-2.2(lSS1C), Response to Containment Flooding, Rev. 2 2OM-53A.1.FR-Z.3(lSS1C), Response to High Containment Radiation Level, Rev. 2 Condition Reports 11-91720, Buried Fire Protection Piping Vulnerability
: 11-91794, Potential For lnadvertent
: CO2 Discharge with Seismic Event 11-91922, Storage for Beyond Design Basis Equipment Lacks Quality 11-92160, Material Condition of Portable Diesel Fire Pumps 11-92343, Fire Line Corrosion ldentified During Inspection
: 11-92388, Fire Protection System Vulnerabilities During a Seismic Event 11-92393, Unit 1 Fire Protection Systems Inaccessible for lnspection
: 11-92394, Specific Fire Protection Deficiencies ldentified During Walkdown 11-92415, Vulnerabilities During a Flood Event Following an Earthquake
: 11-92531, Aggregate lmpact Evaluation
: BVPS OSS Fire Protection Equipment Other: Active and Passive Equipment Credited Inventory Spreadsheet,3l23l11
: Basic Instruction Card for Godwin Low Pressure Driven Prime Pump
: BV-1 &
: BV-2 Updated Final Safety Analysis Reports, Rev. 23 & 6
: BV-1 Shift Operations Logs Regarding
: ERFS UPS lssues,4l2ll1
: Mutual Response Agreements, current as of
: 4128111 ADAMS AFW ARM CAM CAP CFR NRC SBO
==LIST OF ACRONYMS==
USED Agencyruide
Documents
Access and Management
System Auxiliary
Feedwater Area Radiation
Monitors Continuous
Air Monitors Corrective
Action Program Code of Federal Regulations
United States Nuclear Regulatory
Commission
Station Blackout Attachment
}}
}}

Latest revision as of 06:23, 13 January 2025

IR 05000334/2011008 and 05000412/2011008; 03/31/2011 - 04/29/2011; Beaver Valley Power Station, Units 1 and 2; Temporary Instruction 2515/183 - Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event
ML111310328
Person / Time
Site: Beaver Valley
Issue date: 05/13/2011
From: Doerflein L
Engineering Region 1 Branch 2
To: Harden P
FirstEnergy Nuclear Operating Co
Shared Package
ML111300540 List:
References
IR-11-008
Download: ML111310328 (27)
v • d • e


Text

SUBJECT:

BEAVER VALLEY POWER STATION - NRC TEMPORARY INSTRUCTION 2515t 183 INSPECTION REPORT 05000334/201 1 008 AND 05000412t201 1oO8

Dear Mr. Harden:

On April 29,2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Beaver Valley Power Station Units 1 and 2, using Temporary instrubtion 2St 5/183,

"Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event." The enclosed inspection report documents the inspection results which were discussed on April 2g, 2011, with you and other members of your staff.

The objective of this inspectio.n was to promptly assess the capabilities of Beaver Valley power Station to respond to extrlordinary consequenbes similar to those that have recently oicurred at the Japanese Fukushima Daiichi Nuclear Station. The results from this inspection, ilong with the results from this inspection performed at other operating commercial nuclear piants in the United States will be used to evaluate the U.S. nuclear indrlstry's readiness to saiely respond to similar events. These results will also help the NRC to determine if additional regulitory actions are warranted.

All of the potential issues and observations identified by this inspection are contained in this report. The NRC's Reactor Oversight Process will further evaluate any issues to determine if they are re^gulatory findings or violations. Any resulting findings or violations will be documented by the NRC in a separate report. You are not required to resfond to this letter. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's Agency Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.qov/readinq-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

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(\\.Za^,r-,1-.-, /,\\ L'oe^-

Lawrence T. Doerflein, Chief I Engineering Branch 2

'

Division of Reactor Safety Docket Nos.: 50-334, 50-412 License Nos.: DPR-66, NPF-73 Enclosure: Inspection Report Nos. 0500033412011008 and 0500041212011008 cc w/encl: Distribution via ListServ

SUMMARY OF FINDINGS

lR 0500033412011008 and 0500041212011008; 0313112011 -0412912011; BeaverValley Power

Station, Units 1 and 2;Temporary lnstruction 2515/183 - Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event.

This report covers an announced Temporary lnstruction (Tl) inspection. The inspection was conducted by two resident inspectors and a region based inspector. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

INSPECTION SCOPE

The intent of the Tl is to provide a broad overview of the industry's preparedness for events that may exceed the current design basis for a plant. The focus of the Tl was on

(1) assessing the licensee's capability to mitigate consequences from large fires or explosions on site,
(2) assessing the licensee's capability to mitigate station blackout (SBO) conditions,
(3) assessing the licensee's capability to mitigate internal and external flooding events accounted for by the station's design, and
(4) assessing the thoroughness of the licensee's walkdowns and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipment's function could be lost during seismic events possible for the site. lf necessary, a more specific followup inspection will be performed at a later date.

INSPECTION RESULTS

All of the potential issues and observations identified by this inspection are contained in this report. The NRC's Reactor Oversight Process will further evaluate any issues to determine if they are regulatory findings or violations. Any resulting findings or violations will be documented by the NRC in a separate report.

03.01 Assess the licensee's capability to mitigate conditions that result from beyond design basis events, typically bounded by security threats, committed to as part of NRC Security Order Section B.5.b issued February 25, 2002, and severe accident management guidelines and as required by Title 10 of the Code of Federal Regulations ('10 CFR) 50.54(hh). Use Inspection Procedure (lP) 71111.05T, "Fire Protection (Triennial)," Section 02.03 and 03.03 as a guideline. lf lP 71111.05T was recently performed at the facility the inspector should review the inspection results and findings to identify any other potential areas of inspection. Particular emphasis should be placed on strategies related to the spent fuel pool. The inspectjon should include, but not be limited to, an assessment of any licensee actions to:

Licensee Action Describe what the licensee did to test or inspect equipment.

Verify through test or inspection that equipment is available and functional. Active equipment shall be tested and passive equipment shall be walked down and inspected. lt is not expected that permanently installed equipment that is tested under an existing regulatory testing program be retested.

Licensee actions included the identification of equipment (active and passive) utilized for implementation of B.5.b actions and any equipment used in Severe Accident Management Guidelines (SAMGs). The scope of the equipment was defined as that equipment specifically designated for 8.5.b or SAMG mitigation (i.e., special hoses, fittings, diesel fire pumps, etc.).

Permanent plant equipment (i.e., in situ equipment) was not considered in the scope, since it is normally in service, subjected to planned maintenance, and/or checked on operator rounds. The licensee then identified surveillances/tests and performance frequencies for the identified equipment, and reviewed the results of recent tests. Active equipment within the scope defined above that did not have recent test results were verified to have tests planned. Passive equipment within the scope was walked down and inspected. Specific condition reports (CRs) are noted in the supplemental information section.

Describe inspector actions taken to confirm equipment readiness (e.9., observed a test, reviewed test results, discussed actions, reviewed records, etc.).

This review should be done for a reasonable sample of mitigating strateg ies/eq uipment.

The licensee's actions as discussed above were completed prior to the issuance of NRC Tl 2515/183. The inspectors assessed the licensee's capabilities by conducting a review of the licensee's walkdown activities. In addition, the inspectors independently walked down and inspected all major B.5.b contingency response equipment staged throughout the site. The results of the inspectors' independent walkdowns confirmed the results obtained by the licensee.

Discuss general results including corrective actions by licensee.

The licensee has no equipment designated for use in the SAMGs that is not considered in-situ plant equipment. Most equipment (active and passive) designated for 8.5.b was verified by the licensee to be in applicable procedures. Deficiencies were noted by the licensee and were corrected. All passive equipment was walked down and verified to be in place and ready for use.

Passive equipment which had surveillance and/or preventive maintenance tasks had those activities performed to verify readiness for use.

All active equipment located at the site was verified in place by the licensee. The licensee verified allactive equipment had been tested satisfactory, with one exception. The licensee identified an active component that did not have preventive maintenance or a surveillance procedure available.

The component was verified to have previously operated successfully. The licensee identified this deficiency and entered it into the corrective action program (CAP) as CR 11-91290. The licensee identified a number of minor inventory deficiencies and took action to document and promptly correct.

Based on the reviews conducted, the inspectors concluded that the required equipment is available and functional.

Licensee Action Describe the licensee's actions to verify that procedures are in place and can be executed (e.g.

walkdowns, demonstrations, tests, etc.).

b. Verify through walkdowns or demonstration that procedures to implement the strategies associated with B.5.b and 10 CFR 50.54(hh) are in place and are executable.

Licensees may choose not to connect or operate permanently installed equipment during this verification.

This review should be done for a reasonable sample of mitigating strategies/eq uipment.

Licensee actions included the identification of those procedures utilized to mitigate the consequences of a B.5.b related event and severe accidents. The licensee then compiled verification documentation for procedure validations and identified any procedure not issued or validated and any with open change requests. Open change requests were reviewed for potential impacts on procedure functionality. Licensee personnel were then dispatched to walk down all applicable procedures to verify the ability of the procedures to be executed.

Describe inspector actions and the sample strategies reviewed. Assess whether procedures were in place and could be used as intended.

The licensee's actions as discussed above were completed prior to the issuance of NRC Tl 25151183. The inspectors assessed the licensee's capabilities by conducting a review of the licensee's documented walkdown activities. In addition, the inspectors selected several sections of a sample of the B.5.b procedures walked down by the licensee and walked those down to independently verify the licensee's conclusions.

Discuss general results including corrective actions by licensee.

The licensee reviewed SAMG strategies and did not identify any significant issues. Procedures used for 8.5.b were reviewed by the licensee and walkdowns were performed by operators to ensure actions taken in the field in response to a 8.5.b event could be performed. Open procedure change requests were reviewed by the licensee to verify there were no immediate procedure changes required. Some minor corrections and enhancements were identified by the licensee and entered into the CAP:

CR 11-91338 was initiated to evaluate the creation of procedures and staging of equipment to ensure implementation of the strategies; and CR 11-912O2was initiated for several issues related to B.5.b procedure corrections.

Based on the reviews conducted, the inspectors concluded that the procedures to implement the strategies associated with B.5.b and'10 CFR 50.54(hh) are in place and are executable.

Licensee Action Describe the licensee's actions and conclusions regarding training and qualifications of operators and support staff.

Verify the training and qualifications of operators and the support staff needed to implement the procedures and work instructions are current for activities related to Security Order Section 8.5.b and severe accident management guidelines as required by 10 cFR 50.54 (hh).

Licensee actions included the identification of training/qualification requirements for operators for the implementation of actions needed to mitigate a B.5.b related event, and for the implementation of actions needed for the SAMGs. The licensee documented that operator training requirements were current, and identified those operators with qualification requirements that were not current.

ln addition, the licensee identified the training/qualification requirements for applicable emergency response organization (ERO) command and support staff for the implementation of actions needed to mitigate a B.S.b related event, and for the implementation of actions needed for the SAMGs, and documented that ERO command and support staff training requirements were current. Where applicable, the licensee identified those ERO command and support staff with qualification requirements that were not current.

Describe inspector actions and the sample strategies reviewed to assess training and qualifications of operators and support staff.

The licensee's actions as discussed above were completed prior to the issuance of NRC Tl 25151183. The inspectors assessed the licensee's training and qualification activities by conducting a review of training and qualification materials and records related to 8.5.b and SAMG event response.

Discuss general results including corrective actions by licensee.

The training requirements, qualifications, and associated records needed for operators for the implementation of SAMGs and 8.5.b event response were reviewed by the licensee. Training was identified for shift managers, shift engineers, and unit supervisors, and the licensee verified that the training requirements were embedded within the position qualifications for the operators. The licensee confirmed that all shift operators verify their qualifications prior to assuming a shift position. The training requirements, qualifications, and associated records needed for ERO command and support staff for the implementation of actions needed to mitigate a B.5.b event or implement the SAMGs were also reviewed. All ERO command and support staff training requirements were verified as current by the licensee with two exceptions:

. The Assistant to Emergency Director Position does not currently include training on the severe accident management guidelines. The Assistant to Emergency Director position is currently located in the Technical Support Center (TSC) and is a technical position.

. Some personnel are not current due to medical restrictions or long term illnesses. Training is completed as personnel are physically able to return to their normal duties.

The licensee documented this issue as CR 11-91296 to review the gap identified with the SAMG training for the Assistant to Emergency Director.

The inspectors reviewed the licensee's assessment and corrective actions, and completed an independent assessment. Based on these actions, the inspectors concluded that the training and qualifications of operators and the support staff needed to implement the procedures and work instructions are current for activities related to Security Order Section 8.5.b and severe accident management guidelines as required by 10 CFR 50.54 (hh).

Licensee Action Describe the licensee's actions and conclusions regarding applicable agreements and contracts are in place.

d. Verify that any applicable agreements and contracts are in place and are capable of meeting the conditions needed to mitigate the consequences of these events.

This review should be done for a reasonable sample of mitigating strategies/eq uipment.

Licensee actions included the identification of all applicable contracts and agreements committed to be in place for the mitigation of a B.5.b related event. The licensee verified that the contracts and agreements were current, and documented whether or not the contracts/agreements were capable of meeting the mitigation strategy.

For a sample of mitigating strategies involving contracts or agreements with offsite entities, describe inspector actions to confirm agreements and contracts are in place and current (e.9.,

confirm that offsite fire assistance agreement is in place and current).

The licensee's actions as discussed above were completed prior to the issuance of NRC Tl 25151183. The inspectors assessed the licensee's capabilities by conducting an independent review of the licensee's emergency response letters of agreement with the Beaver County Emergency Management Agency. The inspectors' review of the agreement verified that it was current, and assessed whether or not it was adequate for meeting the licensee's mitigation strategy. The inspectors also verified that letters of agreement were in place with the surrounding three states and local counties.

Discuss general results including corrective actions by licensee.

' Enclosure

The licensee determined that agreements and contacts were in place and current. No deficiencies were noted. The inspectors concluded that applicable agreements and contracts are in place and are capable of meeting the conditions needed to mitigate the consequences of these events.

Licensee Action Document the corrective action report number and briefly summarize problems noted by the licensee that have significant potential to prevent the success of any existing mitigating strategy.

e. Review any open corrective action documents to assess problems with mitigating strategy implementation identified by the licensee. Assess the impact of the problem on the mitigating capability and the remaining capability that is not impacted.

FENOC determined no significant issues were identified. However, the licensee identified that preventive maintenance (PM) activities and a surveillance procedure were currently not available for an active component utilized in a 8.5.b mitigation strategy. The component had previously operated successfully and the issue has been entered in the CAP under CR 11-91290. Other minor issues were identified and documented in the CRs listed in the Supplemental Information.

The inspectors reviewed the CRs and determined there was not a significant impact to any existing mitigating strategy.

03.02 Assess the licensee's capability to mitigate station blackout (SBO) conditions, as required by 10 CFR 50.63, "Loss of All Alternating Current Power," and station design, is functional and valid. Refer to Tl 25151120, "lnspection of lmplementation of Station Blackout Rule Multi-Plant Action ltem A-22" as a guideline. lt is not intended that Tl 25151120 be completely reinspected.

The inspection should include, but not be limited to, an assessment of any licensee actions to:

Licensee Action Describe the licensee's actions to verify the adequacy of equipment needed to mitigate an SBO event.

a. Verify through walkdowns and inspection that all required materials are adequate and properly staged, tested, and maintained.

Licensee actions included the identification of equipment utilized/required for mitigation of a SBO.

The licensee then conducted walkdowns to ensure this equipment was adequate and properly staged. Additionally, the licensee also conducted a review of open CAP items for potential SBO equipment impact.

Describe inspector actions to verify equipment is available and useable.

The inspectors assessed the licensee's capability to mitigate SBO conditions by conducting a review of the licensee's walkdown activities. ln addition, the inspectors selected a sample of equipment utilized/required for mitigation of a SBO and conducted independent walkdowns of that equipment to verify that the equipment was properly aligned and staged. The sample of equipment selected by the inspectors included, but was not limited to, the SBO cross{ie and Emergency Response Facility (ERF) diesel generator and related infrastructure.

Discuss general results including corrective actions by licensee.

The above reviews verified that SBO equipment was ready to respond to a SBO condition.

However, the inspectors noted that challenges exist due to current UPS failures that support the ERF diesel generator, requiring extra procedure actions to power ERF buses. The licensee has entered this issue into the CAP and plans to repair the equipment deficiency The licensee initiated two conditions reports for issues identified during the walkdowns: CR 11-91206, Manual charging spring toolfor 4kV breakers could not be found, and no ladder staged in intake "C" cubicle for accessing required valves; and CR 11-91347, Components to open HW-1FW-1OOA(BXC) insufficiently labeled to ensure proper connections. The inspectors determined these issues would not have prevented successful implementation of SBO procedures.

Licensee Action Describe the licensee's actions to verify the capability to mitigate an SBO event.

b. Demonstrate through walkdowns that procedures for response to an SBO are executable.

Licensee actions included the identification of procedures required for response to a SBO, along with verification that the identified procedures were current and that no critical revision requests were in place. The licensee then verified that the mitigating procedures had been properly validated and performed walkdowns of selected procedures. Additionally, the licensee conducted a review of open CAP items for potential impact to SBO procedures.

Describe inspector actions to assess whether procedures were in place and could be used as intended.

The inspectors assessed the licensee's capabilities by conducting a review of the licensee's walkdown activities. In addition, the inspectors selected several sections of a sample of the procedures walked down by the licensee and walked those down to independently verify the licensee's conclusions.

Discuss general results including corrective actions by licensee.

The licensee procedures utilized to respond to an SBO are within the scope of the site emergency operating procedures (EOPs). Actions to start the SBO diesel generator (a functional EDG on the non-affected unit) and supply power to the affected-unit vital buses are performed from the control room (as augmented with field actions) with permanently installed plant equipment. For the purposes of this requirement, the licensee credited their original validation of the specific EOP by a crew of licensed operators on the simulator prior to the implementation of the current revision.

No significant current issues were identified by the licensee, however three CRs were written to document minor issues and/or areas for improvement (CRs 11-91263,11-91353, and 11-91356).

Although the station meets the current design and licensing bases for station blackout, the inspectors concluded that coping with a dual unit SBO (a beyond design basis event) could present significant challenges. For example: the SBO cross-tie equipment is located in non-seismically qualified areas (normal switchgear) of each unit; and Unit 1 requires AC power to the MOVs to isolate the safety injection accumulators during RCS depressurization.

The licensee documented the general issue of a dual unit SBO under CR 1 1-93717.

03.03 Assess the licensee's capability to mitigate internal and external flooding events required by station design. Refer to lP 71111.01, "Adverse Weather Protection," Section 02.04, "Evaluate Readiness to Cope with External Flooding" as a guideline. The inspection should include, but not be limited to, an assessment of any licensee actions to verify through walkdowns and inspections that all required materials and equipment are adequate and properly staged. These walkdowns and inspections shall include verification that accessible doors, barriers, and penetration seals are functional.

Licensee Action Describe the licensee's actions to verify the capability to mitigate existing design basis flooding events.

a. Verify through walkdowns and inspection that all required materials are adequate and properly staged, tested, and maintained.

Licensee actions included the identification of equipment and penetration seals utilized/required for mitigation of internal and external flooding. The licensee then conducted walkdowns of this equipment to ensure it was adequate and properly staged. Doors, barriers, and penetration seals that were utilized for mitigation of flooding were identified, and checked to see if they were routinely inspected to ensure functionality. Where routine inspections were not performed or could not be relied upon to ensure functionality, the licensee performed walkdowns and inspections to ensure that the components were functional.

Describe inspector actions to verify equipment is available and useable. Assess whether procedures were in place and could be used as intended.

The inspectors assessed the licensee's capabilities to mitigate flooding by conducting a review of the licensee's walkdown activities. In addition, the inspectors conducted independent walkdowns of selected flood mitigation equipment to contribute to the overall assessment of the licensee's flood mitigating capabitities. Licensee flood mitigation procedures were reviewed to verify usability. The inspectors' conclusions aligned with the results obtained by the licensee.

Discuss general results including corrective actions by licensee.

The inspectors concluded that all required materials are adequate and properly staged, tested, and maintained to respond to an internal or external flood within the plant's design basis. While no operability or significant concerns were identified, the licensee identified that two portable pumps credited in the flood analysis did not have periodic testing performed, and that flood barriers and penetrations that were not part of the fire protection program were not routinely inspected. These and several other minor deficiencies were entered into the CAP and the associated condition reports are listed in the Attachment to this report. The inspectors reviewed these condition reports and determined the licensee's initial responses, including their assessment and prioritization, were appropriate.

03.04 Assess the thoroughness of the licensee's walkdowns and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipment's function could be lost during seismic events possible for the site. Assess the licensee's development of any new mitigating strategies for identified vulnerabilities (e.9., entered it in to the corrective action program and any immediate actions taken). As a minimum, the licensee should have performed walkdowns and inspections of important equipment (permanent and temporary) such as storage tanks, plant water intake structures, and fire and flood response equipment; and developed mitigating strategies to cope with the loss of that important function. Use lP 71111.21, "Component Design Basis lnspection," Appendix 3, "Component Walkdown Considerations," as a guideline to assess the thoroughness of the licensee's walkdowns and inspections.

Licensee Action Describe the licensee's actions to assess the potential impact of seismic events on the availability of equipment used in fire and flooding mitigation strategies.

a. Verify through walkdowns that all required materials are adequate and properly staged, tested, and maintained.

Licensee actions included the identification of equipment utilized/required for mitigation of fire and flood events. An engineering inspection plan was established by the licensee to govern the conduct of walkdowns and inspections of the equipment, both permanent and temporary.

Licensee engineering personnel determined if the equipment was seismically qualified, or assessed whether it would be possible to evaluate the equipment as being seismically rugged.

Seismic vulnerabilities, including storage locations, were identified, along with mitigating strategies for equipment that was not seismically qualified.

Describe inspector actions to verify equipment is available and useable. Assess whether procedures were in place and could be used as intended.

The inspectors conducted multiple independent walkdowns of important equipment needed to mitigate fire and flood events to identify the potential that the equipment's function could be lost during a seismic event. This equipment included, but was not limited to:

. all major B.5.b contingency response equipment staged throughout the site;

. the installed diesel and electric fire pumps, their controls, and other fire equipment; r the Emergency Response Facility diesel generator; and o watertight doors and floor plugs at the plant's main and alternate intake structures.

Licensee flood and fire mitigation procedures were reviewed to verify usability. The results of the inspectors' reviews aligned with the licensee's conclusions that there were a number of seismic vulnerabilities that may need to be addressed, as described below. The inspectors concluded that the licensee meets the current design and licensing bases for B.5.b, fire and flood protection.

Discuss general results including corrective actions by licensee. Briefly summarize any new mitigating strategies identified by the licensee as a result of their reviews.

"Seismically qualifled" is defined as the SSCs that have been formally qualified to function during and after a design basis earthquake, as applicable. The licensee's reviews for this issue determined that non-safety related SSCs, in general, were not considered to be either seismically qualified or seismically rugged. The majority of room flood mitigation sump pumps and flooding detectors were not designed as seismically qualified, and have not been evaluated as being seismically rugged. Similarly, the vast majority of the fire protection system / piping, including both installed fire pumps, were not designed as seismically qualified and cannot be considered seismically rugged. Firefighting equipment staged to respond to 8.5.b events was not stowed in seismically qualified buildings and locations, as a seismic event and 8.5.b event were not assumed to occur coincidentally.

The licensee's reviews identified instances where response capability could be enhanced. These included improving procedural guidance, reviewing the locations of portable equipment, and reviewing the need for supplemental portable equipment to compensate for the possible loss of the fire water storage tank, the fire pumps, and much of the fire suppression system pipinq.

Further, reviews by the licensee identified that, in the event of a postulated earthquake, equipment may not function properly due to loss of vital power or being subjected to physical displacement.

The existing mitigation strategy, to conduct station surveys per emergency plan off normal occurrence procedure RA-EP-02820, "Earthquake," was considered presently sufficient by the licensee. Further mitigation strategies, the licensee determined, will entailfollowing industry recommendations from other plants that have identified similar beyond-design-bases vulnerabilities. The licensee entered the issues identified into their CAP CRs 11-92571. and 11-93717.

Meetinqs 40A6 Exit Meetinq The inspectors presented the inspection results to Mr. Paul Harden and other members of licensee management at the conclusion of the inspection on April 29,2011. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

A-1

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

P. Harden, Site Vice President, Beaver Valley Power Station
R. Lieb, Director of Site Operations, Beaver Valley Power Station
G. Cramer, Manager, Emergency Response
C. Hynes, Manager, Site Training
C. Mancuso, Manager, Design Engineering
C. McFeaters, Manager, Operations
J. Miller, Site Fire Marshal
D. Price, Supervisor, Design Engineering
M. Ressler, Supervisor, Engineering Analysis
B. Rudolph, Superintendent, Operations Training
K. Woessener, Staff Nuclear Engineer, Beaver Valley IER 11-1 Response Team Lead

Nuclear Requlatory Commission

C. Cahill, Senior Reactor Analyst

W, Cook, Senior Reactor Analyst

Other Personnel

L. Ryan, Inspector, Pennsylvania Bureau of Radiation Protection

LIST OF DOCUMENTS

REVTEWED

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