ML092920008
| 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;
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;
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
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:
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.
states, in part, that monitoring
as specified
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
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
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
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
Pump Work Order Attachment