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 NUCLEAR REGULATORY

REGION 475 ALLENDALE KING OF PRUSSIA, PA

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

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. 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 (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

Inspection

Report 05000334/2009008;

05000412/2009008

w/Attachment:

Supplemental

Information

cc w/encls: Distribution

via ListServ

P. 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

Inspection

Report 05000334/2009008;

05000412/2009008

w/Attachment:

Supplemental

Information

Distribution

w/encl: (via e-mail) S. Collins, RA (R10RAMAILRESOURCE)

M. Dapas, DRA

D. Spindler, DRP, RI D. Lew, DRP (R1

P. Garrett, DRP, OA J. Clifford, DRP (R1DRPMAIL

RESOURCE)

L. Trocine, RI OEDO R. Bellamy, RIDSNRRPMBEAVERVAllEY

RESOURCE G. Barber, ROPreportsResource@nrc.qov

C. Newport, Region I Docket Room (with concurrences)

J. Greives, DRP D. Werkheiser, DRP, SRI SUNSI Review Complete:

tcs (Reviewer's

ML092920008

DOCUMENT NAME: G:\DRP\BRANCH

TSAB\lnspection

Reports\Beaver

Valley PI&R 2009\BV

After declaring

this document "An Official Agency Record" it will be released to the To receive a copy of this document, indicate In the box: 'C' =Copy without attachment/enclosure

'E" =Copy with attachment/enclosure "N" =No OFFICE: RI/DRP NAME: TSetzer/tcs

RBeliamy/rjp

for DATE: 10/13109 10/14/09

Docket License Report Team

Approved 1 U.S. NUCLEAR REGULATORY

REGION 50-334, DPR-66, 05000334/2009008

and

FirstEnergy

Nuclear Operating

Company Beaver Valley Power Station, Units 1 and Post Office Box Shippingport, PA August 17 through September

3, Thomas Setzer, PE, Senior Project

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

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 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

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

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

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, 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

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

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

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

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 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

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. 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

KEY POINTS OF 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

LIST OF DOCUMENTS

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

07-26065 07-30988 08-36471 08-41450 09-52351

07-26326 07-30999 08-36539

08-41691 09-53214 07-27423 07-31040 08-37026 08-41723 09-53275

07-27469 07-31083 08-37250

08-41801 09-53803 07-28007 07-31107 08-37304 08-42046 09-53938 07-28012 07-31110 08-37318 08-42627

09-54227

07-28471 07-31112 08-37320 08-42847 09-54737

07-28724 07-31221 08-37330 08-43510 09-54836 07-29217 07-31350 08-37373 08-44047

09-55439 07-30075 07-30383 08-37405 08-45833 09-56328

07-30318 08-37676 08-37450 08-46143 09-57224 07-30362 08-46883 08-37646 08-46662

09-57244 07-28652 08-38049 08-41776 08-47368 08-47539 09-53197 09-53372 09-53569 09-55916 09-57165 07-16667 07-17938 07-19218 07-20942

07-23163 07-24034 07-25474 07-27222 07-28474 08-34940

08-36384 08-37168 08-37252 08-40090 08-40292

08-48144 08-48160 08-49360 08-49836 09-51664

09-54942 09-55267 09-56250 09-56291 09-56315 09-57617 09-58071 09-58215 09-58481 09-58495

09-59654 09-60890 *09-63801

• 09-63391

• 09-63416 *09-63532 *09-63546

• 09-63536

• 09-63454

• 09-63479

• 09-63916

• 09-63975

• 09-63998

• 09-63999

• 09-64004

• 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

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

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

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