ML092920008

IR 05000334-09-008, IR 05000412-09-008; 08/17/2009 - 09/03/2009; Beaver Valley Power Station, Units 1 & 2; Biennial Baseline Inspection of the Identification and Resolution of Problems

ML092920008
Person / Time
Site:	Beaver Valley
Issue date:	10/15/2009
From:	Racquel Powell NRC/RGN-I/DRP/PB7
To:	Harden P FirstEnergy Nuclear Operating Co
powell r j
References
IR-09-008
Download: ML092920008 (22)

See also: IR 05000334/2009008

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION I

475 ALLENDALE ROAD

KING OF PRUSSIA, PA 19406-1415

October 15, 2009

Mr. Paul Harden

Site Vice President

FirstEnergy Nuclear Operating Company

Beaver Valley Power Station

P. O. Box 4, Route 168

Shippingport, PA 15077

SUBJECT:

BEAVER VALLEY POWER STATION - NRC PROBLEM IDENTIFICATION

AND RESOLUTION INSPECTION REPORT 05000334/2009008 AND

05000412/2009008

Dear Mr. Harden:

On September 3,2009, the U.S. Nuclear Regulatory Commission (NRC) completed an

inspection at your Beaver Valley Power Station Units 1 and 2. The enclosed report documents

the inspection results, which were discussed on September 3,2009, with Mr. Roy Brosi and

other members of your staff.

This inspection was an examination of activities conducted under your license as they relate to

the identification and resolution of problems, and compliance with the Commission's rules and

regulations and the conditions of your operating license. Within these areas, the inspection

involved examination of selected procedures and representative records, observations of

activities, and interviews with personnel.

Based on the samples selected for review, the inspection team concluded that FirstEnergy

Nuclear Operating Company (FENOC) was generally effective in identifying, evaluating and

resolving problems. FENOC personnel identified problems at a low threshold and entered them

into the Corrective Action Program (CAP). FENOC personnel screened issues appropriately for

operability and reportability, and prioritized issues commensurate with the safety significance of

the problems. Root and apparent cause analyses appropriately considered extent of condition,

generic issues, and previous occurrences. Corrective actions addressed the identified causes

and were typically implemented in a timely manner. However, the inspectors noted several

examples for improvement in the identification of plant issues, and examples where evaluations

lacked rigor to fully explore the corrective actions needed to address the issue.

This report documents one NRC-identified finding of very low safety significance (Green). The

finding was determined to involve a violation of NRC requirements. However, because of its

very low safety significance and because it has been entered into your CAP, the NRC is

treating this finding as a non-cited violation (NCV), in accordance with Section VI.A.1 of the

NRC's Enforcement Policy. If you deny this NCV, you should provide a response with the basis

for your denial, within 30 days of the date of this inspection report, to the U.S. Nuclear

P. Harden

2

Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-0001, with

copies to the Regional Administrator, Region I; the Director, Office of Enforcement, U.S.

Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Senior Resident

Inspector at the Beaver Valley Power Station. In addition, if you disagree with the

characterization of any finding in this report, you should provide a response within 30 days of

the date of this inspection report, with the basis for your disagreement, to the Regional

Administrator, Region I, and the NRC Senior Resident Inspector at the Beaver Valley Power

Station. The information you provide will be considered in accordance with Inspection Manual

Chapter 0305.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its

enclosure, and your response (if any) will be available electronically for public inspection in the

NRC Public Document Room or from the Publicly Available Records (PARS) component of the

NRC's document system (ADAMS). ADAMS is accessible from the NRC Web Site at

~=:'::'~~~~=-'-=:::'!J..!.~~=~~",-= (the Public Electronic Reading Room).

Sincerely,

IRA!

Raymond J. Powell, Chief

Technical Support & Assessment Branch

Division of Reactor Projects

Docket Nos.: 50-334, 50-412

License Nos: DPR-66, NPF-73

Enclosures:

Inspection Report 05000334/2009008; 05000412/2009008

w/Attachment: Supplemental Information

cc w/encls: Distribution via ListServ

P. Harden

3

copies to the Regional Administrator, Region I; the Director, Office of Enforcement, U.S.

Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Senior Resident

Inspector at the Beaver Valley Power Station. In addition, if you disagree with the

characterization of any finding in this report, you should provide a response within 30 days of

the date of this inspection report, with the basis for your disagreement, to the Regional

Administrator, Region I, and the NRC Senior Resident Inspector at the Beaver Valley Power

Station. The information you provide will be considered in accordance with Inspection Manual

Chapter 0305.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its

enclosure, and your response (if any) will be available electronically for public inspection in the

NRC Public Document Room or from the Publicly Available Records (PARS) component of the

NRC's document system (ADAMS). ADAMS is accessible from the NRC Web Site at

http://www.nrc.gov/reading-rm/adams.html(the Public Electronic Reading Room).

Sincerely,

IRAJ

Raymond J. Powell, Chief

Technical Support & Assessment Branch

Division of Reactor Projects

Docket Nos.: 50-334, 50-412

License Nos: DPR-66, NPF-73

Enclosures:

Inspection Report 05000334/2009008; 05000412/2009008

w/Attachment: Supplemental Information

Distribution w/encl: (via e-mail)

S. Collins, RA (R10RAMAILRESOURCE)

M. Dapas, DRA (R10RAMAILRESOURCE)

D. Spindler, DRP, RI

D. Lew, DRP (R1 DRPMAILRESOURCE)

P. Garrett, DRP, OA

J. Clifford, DRP (R1DRPMAIL RESOURCE)

L. Trocine, RI OEDO

R. Bellamy, DRP

RIDSNRRPMBEAVERVAllEY RESOURCE

G. Barber, DRP

ROPreportsResource@nrc.qov

C. Newport, DRP

Region I Docket Room (with concurrences)

J. Greives, DRP

D. Werkheiser, DRP, SRI

SUNSI Review Complete: tcs

(Reviewer's Initials)

ML092920008

DOCUMENT NAME: G:\\DRP\\BRANCH TSAB\\lnspection Reports\\Beaver Valley PI&R 2009\\BV PIR

IR2009008revO.doc

After declaring this document "An Official Agency Record" it will be released to the Public.

To receive acopy of this document, indicate In the box: 'C' =Copy without attachment/enclosure 'E" =Copy with attachment/enclosure "N" =No copy

OFFICE:

RI/DRP

RI/DRP

NAME:

TSetzer/tcs

RBeliamy/rjp for

DATE:

10/13109

10/14/09

Docket Nos.

License Nos.

Report Nos.

Licensee:

Facility:

Location:

Dates:

Team Leader:

Inspectors:

Approved by:

1

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

50-334, 50-412

DPR-66, NPF-73

05000334/2009008 and 05000412/2009008

FirstEnergy Nuclear Operating Company (FENOC)

Beaver Valley Power Station, Units 1 and 2

Post Office Box 4

Shippingport, PA 15077

August 17 through September 3, 2009

Thomas Setzer, PE, Senior Project Engineer

Division of Reactor Projects (DRP)

Jeffery Bream, Project Engineer, DRP

Elizabeth Keighley, Reactor Inspector, DRP

David Spindler, Beaver Valley Resident Inspector, DRP

Raymond J. Powell, Chief

Technical Support &Assessment Branch

Division of Reactor Projects

Enclosure

2

SUMMARY OF FINDINGS

IR 05000334/2009008, IR 05000412/2009008; 08/17/2009 - 09/03/2009; Beaver Valley Power

Station, Units 1 & 2; Biennial Baseline Inspection of the Identification and Resolution of Problems.

One finding was identified in the area of prioritization and evaluation of issues.

This team inspection was performed by three NRC regional inspectors and one resident

inspector. One finding of very low safety significance (Green) was identified during this

inspection and was classified as a non-cited violation (NCV). The significance of most findings is

indicated by their color (Green, White, Yellow, Red) using NRC Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SOP). The cross-cutting aspect was determined

using IMC 0305, "Operating Reactor Assessment Program." Findings for which the SOP does

not apply may be Green or be assigned a severity level after NRC management review. The

NRC's program for overseeing the safe operation of commercial nuclear power reactors is

described in NUREG-1649, "Reactor Oversight Process," Revision 4, December 2006.

Identification and Resolution of Problems

The inspectors concluded that FENOC was, in general, effective in identifying, evaluating, and

resolving problems. Beaver Valley personnel identified problems at a low threshold and entered

them into the Corrective Action Program (CAP). The inspectors determined that Beaver Valley

personnel screened issues appropriately for operability and reportability, and prioritized issues

commensurate with the safety significance of the problems. Root and apparent cause analyses

appropriately considered extent of condition, generic issues, and previous occurrences. The

inspectors determined that corrective actions addressed the identified causes and were typically

implemented in a timely manner. However, the inspectors noted one NCV of very low safety

significance in the area of prioritization and evaluation of issues. This issue was entered into

FENOC's CAP during the inspection.

FENOC's audits and self-assessments reviewed by the inspectors were thorough and probing.

Additionally, the inspectors concluded that FENOC adequately identified, reviewed, and applied

relevant industry operating experience (OE) to the Beaver Valley Power Station. Based on

interviews, observations of plant activities, and reviews of the CAP and the Employees Concerns

Program (ECP), the inspectors did not identify any concerns with site personnel willingness to

raise safety issues, nor did the inspectors identify conditions that could have had a negative

impact on the site's safety conscious work environment (SCWE).

Cornerstone: Mitigating Systems

Green. The inspectors identified an NCV of very low safety significance (Green) of

10 CFR 50.65(a)(2), "Requirements for Monitoring the Effectiveness of Maintenance at

Nuclear Power Plants," due to FENOC personnel's failure to demonstrate that the

10 CFR 50.65(a)(2) performance of the containment isolation valve limit switches was

effectively controlled through the performance of appropriate preventive maintenance.

Specifically, as evidenced by repeat dual position indications of containment isolation

valves in the control room between 2007 and 2009 resulting in 21 unplanned entries into

Technical Specification 3.6.3, the containment isolation valve system 10 CFR 50.65(a)(2)

performance demonstration was no longer justified in accordance with Maintenance Rule

Enclosure

3

implementing procedure guidance. This should have resulted in placement of the

containment isolation valve system in 10 CFR 50.65(a)(1) for goal setting and monitoring.

FENOC entered this issue into the CAP (CR 09-64040).

The inspectors determined the finding was more than minor because it is associated with

the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely

affected the cornerstone objective of ensuring the reliability of systems that respond to

initiating events to prevent undesirable consequences. The finding was determined to be

of very low safety significance (Green) because the finding did not involve a design or

qualification deficiency resulting in loss of operability or functionality, did not result in a

loss of system safety function, and did not screen as potentially risk significant due to

external initiating events. The inspectors determined that this finding had a cross-cutting

aspect in the "Corrective Action Program" component of the Problem Identification and

Resolution cross-cutting area because FENOC did not take appropriate corrective actions

to address safety issues and adverse trends associated with faulty containment isolation

valve limit switches in a timely manner, commensurate with their safety significance and

complexity P.1(d). (Section 40A2.1c)

Enclosure

.1

4

REPORT DETAILS

4.

OTHER ACTIVITIES (OA)

40A2 Problem Identification and Resolution (PI&R) (71152B)

Assessment of the Corrective Action Program Effectiveness

a.

Inspection Scope

The inspectors reviewed FENOC's procedures that describe the CAP at the Beaver Valley

Power Station. FENOC personnel identified problems by initiating condition reports (CRs)

for conditions adverse to quality, plant equipment deficiencies, industrial or radiological

safety concerns, and other significant issues. Condition reports were subsequently

screened for operability and reportability, and categorized by significance, which included

levels SR (significant condition adverse to quality, root cause), AR (adverse condition, root

cause), AA (adverse condition, full apparent cause), AL (adverse condition, limited

apparent cause), AF (adverse condition, fix), and AC (adverse condition, close). CRs

were assigned to personnel for evaluation and resolution or trending.

The inspectors evaluated the process for assigning and tracking issues to ensure that

issues were screened for operability and reportability, prioritized for evaluation and

resolution in a timely manner commensurate with their safety significance, and tracked to

identify adverse trends and repetitive issues. In addition, the inspectors interviewed plant

staff and management to determine their understanding of, and involvement with, the

CAP.

The inspectors reviewed CRs selected across the seven cornerstones of safety in the

NRC's Reactor Oversight Process (ROP) to determine if site personnel properly identified,

characterized, and entered problems into the CAP for evaluation and resolution. The

inspectors selected items from functional areas that included physical security,

emergency preparedness, engineering, maintenance, operations, and radiation safety to

ensure that FENOC appropriately addressed problems identified in these functional areas.

The inspectors selected a risk-informed sample of CRs that had been issued since the

last NRC Problem Identification and Resolution (PI&R) inspection conducted in April 2007.

Insights from the station's risk analyses were considered to focus the sample selection

and plant walkdowns on risk-significant systems and components. The corrective action

review was expanded to five years for evaluation of identified concerns within CRs relative

to radiation monitors.

The inspectors selected items from various processes at Beaver Valley to verify that they

were appropriately considered for entry into the CAP. Specifically, the inspectors

reviewed a sample of Maintenance Rule functional failure evaluations, operability

determinations, system health reports, work orders (WOs), and issues entered into the

Employee Concerns Program (ECP). The inspectors inspected plant areas including the

turbine buildings, safeguards buildings, intake structure, emergency diesel generator

buildings, yard areas, security areas, and control room.

Enclosure

5

The inspectors reviewed CRs to assess whether FENOC personnel adequately evaluated

and prioritized issues. The CRs reviewed encompassed the full range of evaluations,

including root cause analyses, full apparent cause evaluations, limited apparent cause

analyses, and common cause analyses. A sample of CRs that were assigned lower

levels of significance which did not include formal cause evaluations (AF and AC

significance levels) were also reviewed by the inspectors to ensure they were

appropriately classified. The inspectors' review included the appropriateness of the

assigned significance, the scope and depth of the analysis, and the timeliness of

resolution. The inspectors assessed whether the evaluations identified likely causes for

the issues and identified appropriate corrective actions to address the identified causes.

As part of this review, the inspectors interviewed various station personnel to fully

understand details within the evaluations and the proposed and completed corrective

actions. The inspectors observed management review board (MRB) meetings in which

FENOC personnel reviewed new CRs for prioritization and assignment. Further, the

inspectors reviewed equipment operability determinations and extent-of-condition reviews

for selected CRs to verify these specific reviews adequately addressed equipment

operability and the extent of problems.

The inspectors' review of CRs also focused on the associated corrective actions in order

to determine whether the actions addressed the identified causes of the problems. The

inspectors reviewed CRs for adverse trends and repetitive problems to determine whether

corrective actions were effective in addressing the broader issues. The inspectors

reviewed FENOC's timeliness in implementing. corrective actions and effectiveness in

precluding recurrence for significant conditions adverse to quality. Lastly, the inspectors

reviewed CRs associated with NRC non-cited violations (NCV) and findings since the last

PI&R inspection to determine whether FENOC personnel properly evaluated and resolved

the issues. Specific documents reviewed during the inspection are listed in the

Attachment to this report.

b.

Assessment

Effectiveness of Problem Identification

Based on the selected samples reviewed, plant walkdowns, and interviews of site

personnel, the inspectors determined that, in general, FENOC personnel identified

problems and entered them into the CAP at a low threshold. For the issues reviewed, the

inspectors noted that problems or concerns had been appropriately documented in

enough detail to understand the issues. Approximately 19,000 CRs had been written by

FENOC personnel since January 2007. The inspectors noted that the Security

department had generated significantly less CRs when compared to the rest of the site.

Interviews with Security personnel revealed that they had received adequate training,

displayed a willingness to raise issues, and had ample access to computers; however,

there was a reliance on the shift Captain to enter issues into the CAP.

The inspectors observed managers and supervisors at MRB meetings appropriately

questioning and challenging CRs to ensure clarity of the issues. The inspectors

determined that FENOC personnel trended equipment and programmatic issues, and CR

descriptions appropriately included reference to repeat occurrences of issues. The

Enclosure

6

inspectors concluded that personnel were identifying trends at low levels.

The inspectors toured plant areas including the turbine buildings, safeguards buildings,

intake structure, emergency diesel generator buildings, yard areas, security areas and

control room to determine if FENOC personnel identified plant issues at the proper

threshold. Housekeeping in all areas, with the exception of the Unit 2 intake structure,

was noted to be improved since the 2007 NRC PI&R inspection. During the plant

walkdown, the inspectors identified three examples of adverse conditions that had not

been identified by FENOC. The following issues were entered into the CAP for evaluation

and resolution:

During an inspection of the east end of the main intake structure, the inspectors

identified an oxygen bottle strapped to an Appendix R ladder (a ladder used by

plant personnel for implementing the site fire protection program). Restraining the

oxygen bottle and Appendix R ladder together in this fashion represented a minor

procedure violation of Beaver Valley procedure, 1/2-PIP-G01, "Securing

Transient/Temporary/Stored Equipment in Safety-Related Areas." This issue is

minor because there was no adverse impact to plant safety equipment, and there

was only minimal impact on operator fire response times. FENOC entered this

into the CAP (CR 09-63536).

During an inspection of the 'D' intake structure cubicle, the inspectors identified

rigging scaffolding with a chainfall that had been left draped over a safety related

component. Scaffold contacting plant equipment represented a minor procedure

violation of Beaver Valley procedure, 1/2-ADM-0810, "Scaffold Erection and

Tagging." The component was not damaged nor had any reduced capability as a

result of the contact with the chainfall. This issue is minor because there was no

loss of operability or adverse impact to the safety related component. FENOC

entered this into the CAP (CR 09-63532).

During an inspection of the Unit 2 Safeguards Building, the inspectors identified

four plastic buckets filled with lubricating oil totaling 20 gallons. The unattended oil

in a safety related fire area represented a minor procedure violation of Beaver

Valley procedure, 1/2-ADM-1906, "Control of Transient Combustible and

Flammable Materials." This issue is minor because the increase in combustible

loading in the room as a result of the unattended oil did not violate the plant fire

hazard analysis. FENOC entered this into the CAP (CR 09-63441).

In accordance with NRC Inspection Manual Chapter 0612, "Power Reactor Inspection

Reports," the above issues constitute violations of minor significance that are not subject

to enforcement action in accordance with the NRC's Enforcement Policy.

Effectiveness of Prioritization and Evaluation of Issues

The inspectors determined that, in general, FENOC personnel appropriately prioritized

and evaluated issues commensurate with their safety significance. CRs were screened

for operability and reportability, categorized by significance, and assigned to a department

for evaluation and resolution. The CR screening process considered human performance

issues, radiological safety concerns, repetitiveness and adverse trends. The inspectors

observed managers and supervisors at MRB meetings appropriately questioning and

challenging CRs to ensure appropriate prioritization.

Enclosure

7

CRs were categorized for evaluation and resolution commensurate with the significance of

the issues. Based on the sample of CRs reviewed, the guidance provided by the FENOC

implementing procedures appeared sufficient to ensure consistency in categorization of

the issues. Operability and reportability determinations were performed when conditions

warranted and the evaluations supported the conclusions. Causal analyses appropriately

considered extent of condition, generic issues, and previous occurrences. During this

inspection, the inspectors noted that, in general, FENOC's root cause analyses were

thorough, and corrective and preventive actions addressed the identified causes.

Additionally, the identified causes were well supported. An NCV was identified for

FENOC's failure to demonstrate that the 10 CFR 50.65(a)(2) performance of the

containment isolation valve limit switches was effectively controlled through the

performance of appropriate preventive maintenance. This NCV is discussed in the

findings section of this assessment area. The inspectors identified the following two

examples of issues that were not fully evaluated or prioritized for corrective action:

• A root cause evaluation (CR 08-39835) associated with a 2.5 inch drain down of

the Unit 2 reactor coolant system during refueling outage 2R13 did not identify all

corrective actions necessary to address all failed barriers. The inspectors noted

that the root cause evaluation had not included corrective actions to address the

communication failure within operations shifts, and the work management

scheduling issues which contributed to a component tagoutlctearance being

inappropriately implemented. The issue is minor because while corrective actions

were not assigned to address all failed barriers, FENOC had discussed

communication expectations with each operating crew and there have not been

any repeat issues. FENOC entered these issues into the CAP (CR 09-63454 and

09-63479).

The inspectors identified three CRs describing component mispositioning events

(CR 09-59541, CR 09-58355, and CR 09-57224) that were prioritized as CR level

OlAF." The failure to prioritize these CRs as a limited apparent cause (CR level

"AL") represented a minor procedure violation of Beaver Valley procedure, NOBP

OP-0004, "Component Mispositioning." The inspectors reviewed NRC Inspection

Manual Chapter 0612, Appendix E, "Minor Examples," and determined this issue

was minor because there was no loss of operability or safety impact. FENOC

entered this issue into the CAP (CR 09-64004 and CR 09-63975).

In accordance with NRC Inspection Manual Chapter 0612, "Power Reactor Inspection

Reports," these issues constitute violations of minor significance that are not subject

to enforcement action in accordance with the NRC's Enforcement Policy.

Effectiveness of Corrective Actions

The inspectors concluded that corrective actions for identified deficiencies were generally

timely and adequately implemented. For significant conditions adverse to quality,

corrective actions were identified to prevent recurrence. The inspectors concluded that

corrective actions to address NCVs and findings since the last PI&R inspection were

timely and effective. The inspectors identified the following example where corrective

actions were not fully effective in addressing an issue:

Enclosure

8

• The inspectors reviewed corrective actions taken in response to an NCV

documented in NRC report 05000334/05000412 2007004. CR 07-24074 was

written to ensure bearing temperatures would be monitored when performing

surveillance testing on the turbine driven auxiliary feedpumps (TDAFWP). The

inspectors found that the comprehensive surveillance tests for Unit 1 and Unit 2

(Beaver Valley procedures 10ST-24.9 and 20ST-24.4A, respectively) did not have

a precaution stating that this surveillance was not suitable to be used for post

maintenance testing as there is no guidance prescribed to monitor and achieve

steady bearing temperatures. The inspectors determined that the issue was minor

because the preventive maintenance work order had contained the appropriate

guidance. FENOC entered this issue into the CAP (CR 09-64015).

c.

Findings

Introduction: The inspectors identified an NCV of very low safety significance (Green) of

10 CFR 50.65(a)(2), "Requirements for Monitoring the Effectiveness of Maintenance at

Nuclear Power Plants," due to FENOC personnel's failure to demonstrate that the

10 CFR 50.65(a)(2) performance of the containment isolation valve limit switches was

effectively controlled through the performance of appropriate preventive maintenance.

Specifically, as evidenced by repeat dual position indications of containment isolation

valves in the control room resulting in 21 unplanned entries into Technical Specification 3.6.3, the containment isolation valve system 10 CFR 50.65(a)(2) performance

demonstration was no longer justified in accordance with Maintenance Rule implementing

procedure guidance.

Description: The containment isolation valve system is a risk-significant system that is

scoped within the Maintenance Rule because it is a system, structure, or component

(SSC) required to mitigate accidents/transients and is identified in emergency operating

procedures. The primary Maintenance Rule function of the containment isolation valve

system is to provide a containment isolation function during an event to prevent offsite

radiological release. Additionally, limit switches associated with each containment

isolation valve are scoped within the Maintenance Rule because they provide a function to

indicate valve position in the control room for operators to use during emergency

operating procedures.

In February 2009, during stroke-time testing, an air-operated containment isolation valve

displayed dual indication in the control room, causing the stroke times of the valve to be

indeterminate and causing an unplanned entry into Technical Specification 3.6.3.

Additionally, between January 2007 and July 2009, Technical Specification 3.6.3 had 21

unplanned entries as a result of faulty limit switches on similar containment isolation

valves. This resulted in the FENOC established containment isolation valve system

Maintenance Rule condition monitoring criteria being exceeded, which required FENOC to

perform a Maintenance Rule 10 CFR 50.65(a)(1) evaluation. The Maintenance Rule

(a)(1) evaluation was completed in February 2009 and concluded that the containment

isolation valve system should continue to be monitored in accordance with Maintenance

Rule 10 CFR 50.65(a)(2)., This reinforced a similar decision made in 2007 based on a

Maintenance Rule (a)(1) evaluation recommendation to keep the system in (a)(2) despite

Enclosure

9

the condition monitoring criteria being exceeded due to multiple dual indications in the

control room. The basis of the decision was that the dual indication issue was a result of

faulty limit switches, and that this did not affect the valve's safety related function to close

during an event to prevent offsite radiological release. Site personnel determined the

direct cause was the limit switch being out of adjustment due to a problem with the

required torque. Despite the repeat failures, FENOC failed to implement or revise

preventive maintenance practices for these limit switches. Subsequently, the

Maintenance Rule Steering Committee approved a revision to clarify the monitoring

criteria for the containment isolation valve system, which would exclude future indication

problems that did not affect the valve's ability to isolate containment. However, it failed to

take into account the limit switches' Maintenance Rule function in emergency operating

procedures, specifically, the ability to accurately indicate valve position in the control room

during an event. Following the change to the condition monitoring criteria, the site had

seven valves display dual indication in the control room between February 2009 and June

2009 that FENOC concluded did not affect valve operability.

The inspectors concluded that the numerous dual indications of the limit switches should

have been evaluated against FENOC's Maintenance Rule condition monitoring criteria

and should have resulted in placement of the containment isolation valve system in

10 CFR 50.65(a)(1) for goal setting and monitoring. FENOC performed an extent of

condition review on two other valves of the same model, and determined that the torque

on the limit switch fasteners needed to be adjusted. FENOC corrected the torque issue

and has implemented plans to install a button tab on the limit switches to minimize

misalignment causing dual indications.

Analysis: The inspectors determined that the failure to demonstrate that the

10 CFR 50.65{a)(2) performance of the containment isolation valve limit switches was

effectively controlled through the performance of appropriate preventive maintenance was

a performance deficiency within FENOC personnel's ability to foresee and correct and

should have been prevented. Traditional Enforcement did not apply, as the issue did not

have actual or potential safety consequence, had no willful aspects, nor did it impact the

NRC's ability to perform its regulatory function.

A review of NRC Inspection Manual Chapter (IMC) 0612, Appendix E, "Minor Examples,"

revealed that no minor examples were applicable to this finding. The inspectors

determined the finding was more than minor because it is associated with the Equipment

Performance attribute of the Mitigating Systems cornerstone and adversely affected the

cornerstone objective of ensuring the reliability of systems that respond to initiating events

to prevent undesirable consequences. Specifically, the dual indication of containment

isolation valves in the control room due to faulty limit switches presents a challenge to the

operators during event response while implementing emergency operating procedures,

and has resulted in 21 unplanned Technical Specification entries. The numerous dual

indication instances should have caused the containment isolation valve system to be

placed in 10 CFR 50.65(a)(1) for goal setting and monitoring. The inspectors determined

the significance of the finding using IMC 0609.04, "Phase 1

Initial Screening and

Characterization of Findings." The finding was determined to be of very low safety

significance (Green) because the finding did not involve a design or qualification

deficiency resulting in loss of operability or functionality, did not result in a loss of system

Enclosure

10

safety function, and did not screen as potentially risk significant due to external initiating

events.

The inspectors determined that this finding had a cross-cutting aspect in the "Corrective

Action Program" component of the Problem Identification and Resolution cross-cutting

area because FENOC did not take appropriate corrective actions to address safety issues

and adverse trends associated with faulty containment isolation valve limit switches in a

timely manner, commensurate with their safety significance and complexity [P.1 (d)).

Enforcement: 10 CFR 50.65(a)(1) requires, in part, that holders of an operating license

shall monitor the performance or condition of SSCs within the scope of the monitoring

program as defined in 10 CFR 50.65(b) against licensee-established goals, in a manner

sufficient to provide reasonable assurance that such SSCs are capable of fulfilling their

intended functions. 10 CFR 50.65(a)(2) states, in part, that monitoring as specified in

10 CFR 50.65(a)(1) is not required where it has been demonstrated that the performance

or condition of an SSC is being effectively controlled through the performance of

appropriate preventative maintenance, such that the SSC remains capable of performing

its intended function.

Contrary to the above, between 2007 and 2009, FENOC personnel failed to demonstrate

that the 10 CFR 50.65(a)(2) performance of the containment isolation valve limit switches

was effectively controlled through the performance of appropriate preventive

maintenance. FENOC has performed an extent of condition review and has initiated

corrective actions to install a button tab on the limit switches to minimize misalignment

causing the dual indications. Because this violation was of very low safety significance

and has been entered into the CAP (CR 09-64040), this violation is being treated as an

NCV, consistent with the NRC Enforcement Policy (NCV 05000314,412/2009008-01:

Containment Isolation Valve System 10 CFR 50.65 (a)(2) Performance

Demonstration Not Met) .

. 2

Assessment of the Use of Operating Experience

a.

Inspection Scope

The inspectors selected a sample of CRs associated with the review of industry Operating

Experience (OE) to determine whether FENOC personnel appropriately evaluated the OE

information for applicability to Beaver Valley and had taken appropriate actions, when

warranted. The inspectors reviewed CR evaluations of OE documents associated with a

sample of NRC Generic Letters and Information Notices to ensure that FENOC

adequately considered the underlying problems associated with the issues for resolution

via their CAP. The inspectors also observed plant activities to determine if industry OE

was considered during the performance of routine activities. Specific documents

reviewed during the inspection are listed in the Attachment to this report.

b.

Assessment

The inspectors determined that, in general, FENOC appropriately considered industry OE

information for applicability, and used the information for corrective and preventive actions

Enclosure

11

to identify and prevent similar issues when appropriate. The inspectors determined that

OE was appropriately applied and lessons learned were communicated and incorporated

into plant operations. The inspectors observed that industry OE was routinely discussed

and considered during the performance of plant activities.

The inspectors reviewed a fleet-level focused self-assessment of OE performed in May

2008. The self-assessment identified a number of weaknesses, specifically:

• OE was not discussed in system health reports;

• Roles and responsibilities of Section OE Coordinators were not clearly defined;

Familiarization with SAP, the database used to manage OE, was low at the

Management and Section OE Coordinator levels; and

• Procedures describing the requirements to process OE were in need of revision to

add clarity.

Although the inspectors noted that corrective actions were not completed until June 2009,

since that time Beaver Valley has made progress in addressing OE program needs. This

has included clearly defining the roles and responsibilities of Section OE Coordinators.

Procedures have been revised and a familiarization guide has been completed with

guidance on how to use SAP efficiently. Training has been completed for Section OE

Coordinators and the backlog of unreviewed OE items has decreased (currently at 2

unreviewed items as compared to over 12 items previously). Finally, a higher level of

accountability has been placed on each department to report backlogged OE items at

weekly plant meetings. With respect to incorporating OE in system health reports, the

inspectors identified that OE continued not to be incorporated in the 2008 and 2009

reports. FENOC entered this issue into the CAP (CR 09-63999).

c.

Findings

No findings of significance were identified .

. 3

Assessment of Self-Assessments and Audits

a.

Inspection Scope

The inspectors reviewed a sample of snapshot self-assessments, focused self

assessments, fleet-level assessments, and a variety of self-assessments focused on

various plant programs. These reviews were performed to determine if problems

identified through these assessments were entered into the CAP, and whether corrective

actions were initiated to address identified deficiencies. The effectiveness of the

assessments was evaluated by comparing audit and assessment results against

self-revealing and NRC-identified observations made during the inspection. A list of

documents reviewed is included in the Attachment to this report.

b.

Assessment

The inspectors concluded that QA audits and self-assessments were critical, thorough,

and effective in identifying issues. The inspectors observed that these audits and self-

Enclosure

.4

12

assessments were completed by personnel knowledgeable in the subject areas and were

completed to a sufficient depth to identify issues that were then entered into the CAP for

evaluation. Corrective actions associated with the issues were implemented

commensurate with their safety significance. FENOC managers evaluated the results and

initiated appropriate actions to focus on areas identified for improvement.

c.

Findings

No findings of significance were identified .

Assessment of Safety Conscious Work Environment

a.

Inspection Scope

The inspectors performed interviews with station personnel to assess the safety conscious

work environment (SCWE) at Beaver Valley. Specifically, the inspectors interviewed

personnel to determine whether they were hesitant to raise safety concerns to their

management and/or the NRC. The inspectors also interviewed the station Employee

Concerns Program (ECP) coordinator to determine what actions were implemented to

ensure employees were aware of the program and its availability with regard to raising

concerns. The inspectors reviewed the ECP files to ensure that issues were entered into

the CAP when appropriate. The inspectors reviewed site SCWE surveys from 2007 and

2008 to assess any adverse trends in department and site safety culture. A list of

documents reviewed is included in the Attachment to this report.

b.

Assessment

During interviews, plant staff expressed a willingness to use the CAP to identify plant

issues and deficiencies, and stated that they were willing to raise safety issues. All

persons interviewed demonstrated an adequate knowledge of the CAP and ECP. Based

on these limited interviews, the inspectors concluded that there was no evidence of

SCWE concerns and no significant challenges to the free flow of information.

SCWE surveys in 2007 and 2008 showed that the overall SCWE health at Beaver Valley

remained positive. The surveys indicated the staff understands and accepts expectations

and responsibilities for identifying concerns. The surveys indicated FENOC personnel

feel free to approach management with issues and management expectations on safety

and quality are clearly communicated. The surveys indicated lower than average scores

for Radiation Protection, Chemistry, Security, and Site Projects departments. CRs were

generated to help promote improvement in the safety culture of these departments, and

corrective actions were implemented. The inspectors noted that when compared to the

2007 survey, the Operations department had an increase in negative responses in the

2008 survey. This trend had not been entered into the CAP for evaluation since the

negative score averages did not exceed a ten percent cutoff "trigger" for CR generation.

The inspectors questioned this cutoff in that it appeared to potentially limit FENOC's ability

to fully explore year-to-year trends in departments that may not exceed ten percent

negative responses, but decline significantly from the previous survey_ FENOC entered

this issue into the CAP (CR 09-63998).

Enclosure

13

As a result of the survey review, the inspectors completed additional SCWE interviews

with operators to determine if there was a reluctance to raise safety issues. No individuals

expressed any fear to raise issues.

c.

Findings

No findings of significance were identified.

40A6 Meetings, Including Exit

On September 3, 2009, the inspectors presented the inspection results to Mr. Roy Brosi,

Director of Site Performance Improvement, and other members of the Beaver Valley staff.

The inspectors verified that no proprietary information was documented in the report.

ATTACHMENT: SUPPLEMENTAL INFORMATION

Enclosure

A-1

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

Harold Szklinski, Staff Nuclear Specialist

Fulton Schaffner, Staff Nuclear Specialist

Daniel Butor, Staff Nuclear Specialist

Robert Lubert, Supervisor, Nuclear Electrical System Engineering

Francy Mantine, Staff Nuclear Engineer

David Jones, Staff Nuclear Engineer

Philip Slifkin, Staff Nuclear Engineer

Giuseppe Cerasi, Senior Nuclear Specialist

Brian Goff, Supervisor, Nuclear Work Planning

Michael Kienzle, Nuclear Engineering

Pat Pauvlinch, Supervisor, Nuclear Plant System Engineering

Robert Williams, Staff Nuclear Engineer

Joann West, Staff Nuclear Engineer

John Kaminskas, Nuclear Engineer

David Hauser, Superintendent Shift Operations, Unit 2

Christopher Makowka, Root Cause Evaluator

Michael Mitchell, Superintendent Nuclear Work Planning

John Bowden, Superintendent Nuclear Operations Services

Jim Mauck, Senior Nuclear Specialist

Brian Sepelak, Supervisor, Nuclear Compliance

Karl Wolfson, Supervisor, Nuclear Performance Improvement

Colin Keller, Manager, Site Regulatory Compliance

Rich Dibler, Security Support Supervisor

Sue Vincinie, Performance Improvement Senior Consultant

Darrel Batina, Employee Concerns Program Representative

Dutch Chancey, Manager, Employee Concerns (Fleet)

Wayne Mcintire, Beaver Valley Site Safety Specialist

Gary Shildt, Supervisor, Nuclear Projects Engineering

Jack Patterson, Staff Nuclear Engineer

Thomas King, Plant Engineer

Robert Lubert, Plant Engineering Supervisor

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000334, 412/2009008-01

Containment Isolation Valve System 10 CFR 50.65

(a)(2) Performance Demonstration Not Met.

Attachment

A-2

LIST OF DOCUMENTS REVIEWED

Condition ReQorts

08-38146

09-60763

09-55789

08-50881

08-47439

08-46291

08-45288

08-42054

08-36772

07-26862

08-32856

07-14885

07-14208

09-62156

09-62106

09-61128

09-60432

09-59875

09-56773

09-54230

09-52736

08-39941

08-48160

09-57390

09-52275

08-49681

08-33109

07-28371

07-15761

09-61333

08-42790

09-62268

09-59641

09-58307

09-57580

09-57463

09-55267

09-52029

08-48296

09-57822

09-61026

09-60359

09-56525

09-61753

09-57743

08-51000

07-23937

09-59057

09-53803

08-41802

08-32965

03-01371

09-61679

09-62681

09-57726

08-39835

07-18191

07-21962

08-48581

08-50283

09-52719

09-61026

09-63451

09-61453

08-48268

08-44941

08-44947

08-37921

08-44960

07-24074

07-30275

09-63317

08-48482

09-52857

09-63269

09-57857

09-56402

08-34526

08-33776

09-55350

09-52043

07-28809

07-12360

07-14181

07-14185

07-14530

07-14761

07-14934

09-61430

09-61631

09-61878

09-62202

09-62810

07-15636

07-17006

07-17236

07-20147

07-20158

07-22189

07-24552

07-25283

07-28203

07-22004

07-29608

07-30073

09-57198

09-57688

09-57815

09-58598

09-60492

09-60672

09-59088

09-60547

09-61017

07-31483

07-28809

07-12120

08-35376

08-49694

08-43202

08-43205

09-62787

08-48664

08-49518

09-53081

09-53243

09-53762

09-54051

09-55146

09-55719

09-56851

09-56874

09-57268

09-57784

09-58142

07-26688

09-54051

08-48664

07-25046

07-30273

08-38146

07-13076

08-48581

09-60218

04-09895

07-30390

07-32095

08-40472

08-48688

09-60450

06-11217

07-30430

08-32447

08-40490

08-49073

09-60763

07-13021

07-30431

08-32887

08-40519

08-49368

09-61744

07-15001

07-30447

08-33126

08-40575

08-49750

09-62348

07-15444

07-30484

08-33306

08-40579

08-49983

09-62705

07-18894

07-30575

08-33398

08-40587

08-50137

08-37743

07-20907

07-30677

08-33725

08-40753

08-50151

08-37925

07-22891

07-30823

08-35048

08-40867

08-51024

08-38276

07-23543

07-30847

08-35517

08-40932

08-51136

08-38687

07-23933

07-30911

08-35674

08-40970

08-51385

08-38750

07-26020

07-30912

08-36383

08-41330

09-52096

08-39233

Attachment

A-3

07-26065

07-30988

08-36471

08-41450

09-52351

08-39304

07-26326

07-30999

08-36539

08-41691

09-53214

08-39946

07-27423

07-31040

08-37026

08-41723

09-53275

08-46995

07-27469

07-31083

08-37250

08-41801

09-53803

08-47282

07-28007

07-31107

08-37304

08-42046

09-53938

08-47455

07-28012

07-31110

08-37318

08-42627

09-54227

08-47767

07-28471

07-31112

08-37320

08-42847

09-54737

09-58483

07-28724

07-31221

08-37330

08-43510

09-54836

09-58878

07-29217

07-31350

08-37373

08-44047

09-55439

09-58985

07-30075

07-30383

08-37405

08-45833

09-56328

09-59541

07-30318

08-37676

08-37450

08-46143

09-57224

09-58355

07-30362

08-46883

08-37646

08-46662

09-57244

07-22603

07-28652

08-38049

08-41776

08-47368

08-47539

08-48966

09-53197

09-53372

09-53569

09-55916

09-57165

07-12368

07-16667

07-17938

07-19218

07-20942

07-23163

07-23960

07-24034

07-25474

07-27222

07-28474

08-34940

08-35010

08-36384

08-37168

08-37252

08-40090

08-40292

08-47830

08-48144

08-48160

08-49360

08-49836

09-51664

09-54128

09-54942

09-55267

09-56250

09-56291

09-56315

09-57553

09-57617

09-58071

09-58215

09-58481

09-58495

09-59460

09-59654

09-60890

• 09-63801

• 09-63391

• 09-63416

• 09-63982

• 09-63532

• 09-63546

• 09-63536

• 09-63454

• 09-63479

• 09-63441

• 09-63916

• 09-63975

• 09-63998

• 09-63999

• 09-64004

• 09-64015

• 09-64040

• CR written as a result of NRC inspection

Audits and Self-assessments

BV-SA-08-086, "BVPS Inservice Testing (1ST) Program Snapshot Self-Assessment Plan."

BV-SA-08-007, "CAP Effectiveness."

Fleet Self-assessment of Use of Operating Experience at Beaver Valley, Perry and Davis Berry,

May 2008.

BV-SA-08-009, "Focused Self-Assessment of Beaver Valley Work Management Performance

Indicators"

BV-SA-08-080

Operating Experience

OE 28133

OE 24688

OE 24689

IN 2008-06

SEN 274, "Multiple Reactor Coolant Pump Seal Failures During Cooldown"

Attachment

A-4

Procedures

NOP-LP-2001, Corrective Action Program, Rev. 22

NOBP-LP-2011, FENOC Cause Analysis, Rev. 9

1/2-EPP-IP-7.1, Emergency Equipment Inventory and Maintenance Procedure, Rev. 22

1/2-EPP-IP-7.1, Emergency Equipment Inventory and Maintenance Procedure, Rev. 23

1/2-EPP-IP-7.1.F09, Emergency Inventory Checklist - Primary Assembly Areas, Rev. 4

1/2-EPP-IP-7.1.F09, Emergency Inventory Checklist - Primary Assembly Areas, Rev. 5

EPP-PLAN-SECTION-6, Emergency Measures, Rev. 25

EPP-PLAN-SECTION-7, Emergency Facilities and Equipment, Rev. 25

NOP-LP-5004, Equipment Important to Emergency Response, Rev. 0

BVRM-EP-5003, Equipment Important to Emergency Response, Rev. 1

1/2-EPP-IP-7.2, Administration of Emergency Preparedness Plan Drills and Exercises, Rev. 13

1/2-EPP-IP-3.2, Site Assembly and Personnel Accountability, Rev. 18

10ST-15.1, [1CC-P-1A] Quarterly Test, Rev. 19

10ST-15.1, [1CC-P-1A] Quarterly Test, Rev. 20

10ST-15.1, [1CC-P-1A] Quarterly Test, Rev. 23

20ST-11.1, Low Head Safety Injection Pump [2SIS*P21A] Test, Rev. 25

20M-11.2.B, Setpoints, Rev. 4

2CMP-11SIS-P-21A-B-1M, Low Head Safety Injection Pump Overhaul, Issue 4, Rev. 9

10ST-24.4, Steam Turbine Driven Auxiliary Feed Pump Test [1 FW-P-2], Rev. 42

10ST-24.9, Turbine-Driven AFW Pump [1 FW-P-2] Operability Test, Rev. 40

20ST-24.4, Steam Driven Auxiliary Feed Pump [2FWE*P22] Quarterly Test, Rev. 64

20ST-24.4A, Steam Driven Auxiliary Feed Pump [2FWE*P22] Full Flow Test, Rev. 20

NOBP-LP-1107, Security Operating Experience Guidelines, Rev. 0

20M-53A.1.A-0.11, Beaver Valley Power Station Unit 2 Verification of Automatic

Actions, Rev. 6

20M-53A.1.A-0.11, Beaver Valley Power Station Unit 2 Containment Isolation Phase A

Checklist, Issue 1 C Rev. 0

NOP-MS-4001, Warehousing, Rev. 6

NOBP-OM-2031, Outage Management Scheduling Process, Rev. 3

NOBP-OP-0004, Component Mispositioning, Rev. 2

NOP-OP-1001, Clearance/Tagging Program, Rev. 11

BVBP-OPS-0004, Operations Clearance Coordinator, Rev. 7

1/2-ADM-2017.F01, Beaver Valley Power Station Vendor Technical Information Review Form-

Low Head Safety Injection Pump Instruction Manual, Rev. 5

NOBP-CC-7003, Structured Spare Parts List, Rev. 5

BVPM-ER-3004, Maintenance Rule (MR) Program Supplemental Guidance, Rev. 0

BVBP-OPS-0008, Supplemental Instructions For the Control of Operating Manual Procedures.

BVPS-OPS-0022, Operating Procedure Development and Revision, Rev. 0

NOP-ER-3004, FENOC Maintenance Rule Program, Rev. 1

SAP Orders/Notifications

600556345

600544389

200287486

600519950

200221237

Attachment

A-5

200309431

200287583

200276981

200042681

200172902

200371419

200310030

200254994

600375319

600422084

600423831

200283954

Non-Cited Violations and Findings

NCV 05000334/2008003-01, Inadequate Maintenance Procedure Results in Unexpected Terry

Turbine Speed Increase

NCV 05000334/2007004-02, Inadequate Procedure and Monitoring Program for Turbine Driven

Auxiliary Feedwater Pump Turbine 1 FW-T-2

NCV 05000334/2008002-01, Incorrect Jumper Placement during Testing Renders

Quench Spray Chemical Addition Inoperable

NCV 05000334/2007005-05, Inadequate Inspection led to a subsequent failure of a Fuel Transfer

Up-Ender Cable

FIN 05000412/2008003-02, Deficient Control of Clearance Posting Interrupts Reactor Coolant

Charging Path while Vessel Water Level Drained Below the Flange

Surveillance Tests

20ST-11.1, Low Head Safety Injection Pump [2SIS-P21A] Test, Rev. 24, 07/28/08

20ST-11.1, Low Head Safety Injection Pump [2SIS-P21A] Test, Rev. 24, 10/20/08

20ST-11.1, Low Head Safety Injection Pump [2SIS-P21A] Test, Rev. 24, 06/30/09

10ST-24.9, Turbine-Driven AFW Pump [1 FW-P-2] Operability Test, Rev. 36,10/23/07

10ST-24.9, Turbine-Driven AFW Pump [1 FW-P-2] Operability Test, Rev. 40,05/11/09

Vendor Manual

2502.290-001-001, Low Head Safety Injection Pump Instruction Manual, Rev. S

2502.290-001-001, Low Head Safety Injection Pump Instruction Manual, Rev. T

Other

WO 200287486

Feedback Form #2008-1448

PM Change Request BV-REV.-08-4731

SAP Report - Bill of Materials for Low Head Safety Injection Pump 2SIS-P21A

SAP Report - Bill of Materials for Low Head Safety Injection Pump 2SIS-P21B

2SIS-P21A Vibration Trend Data 03/24/1998 - 06/30/2009

Beaver Valley System Health Report 2008-1

Beaver Valley System Health Report 2008-2

Beaver Valley System Health Report 2008-3

Beaver Valley System Health Report 2008-4

Attachment

A-6

Beaver Valley System Health Report 2009-1

Weekly Operating Experience Summary - August 3, 2009

Maintenance Rule System Basis Document Unit 2 System 47, Rev. 5

Maintenance Rule System Basis Document Unit 2 System 47, Rev. 6

Licensing Requirements Manual, Rev. 52

Protective Tagout 2BVP-CYC-013-1 2R13-07-EDS-00B

Unit 2 Shift Narrative Logs May 5, 2008 to May 7, 2008

Beaver Valley Unit 2 System Health Report 2009-2, "System 43 - Unit 2 Radiation Monitoring

System"

Beaver Valley Unit 1 System Health Report 2009-2, "System 43 - Unit 1 Radiation Monitoring

System"

ADAMS

BV

CAP

CFR

CR

DRP

ECP

FENOC

IMC

IR

1ST

MRB

NCV

NRC

OA

OE

PARS

PI&R

ROP

SCWE

SOP

TDAFWP

WO

LIST OF ACRONYMS

Agencywide Documents Access and Management System

Beaver Valley

Corrective Action Program

Code of Federal Regulations

Condition Report

Division of Reactor Projects

Employee Concerns Program

FirstEnergy Nuclear Operating Company

Inspection Manual Chapter

Inspection Report

Inservice Test

Management Review Board

Non-Cited Violation

Nuclear Regulatory Commission

Other Activities

Operating Experience

Publicly Available Records System

Problem Identification and Resolution

Reactor Oversight Process

Safety Conscious Work Environment

Significance Determination Process

Turbine Driven Auxiliary Feedwater Pump

Work Order

Attachment