IR 05000338/1998010
| ML20199K328 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 01/14/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20199K325 | List: |
| References | |
| 50-338-98-10, 50-339-98-10, NUDOCS 9901260395 | |
| Download: ML20199K328 (18) | |
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U.S. NUCLEAR REGULATORY COMMISSION ;
l REGION 11
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l (. Docket Nos.: 50-338,50-339 )
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License Nos.:
I Report Nos.: 50-338/98-10,50-339/98-10
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l Licensee: Virginia Electric and Power Company (VEPCO) ;
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L Facility: North Anna Power Station, Units 1 & 2
Location: 1022 Haley Drive Mineral, Virginia 23117 Dates: November 8 through December 19,1998 Inspectors: M. Morgan, Senior Resident inspector R. Gibbs, Resident inspector J. Coley, Reactor inspector (Sections M1.1-partial and M1.2)
G. Salyers, Emergency Preparedness Specialist (Section P 3.1)
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Approved by R. Haag, Chief, Reactor Projects Branch 5 j Division of Reactor Projects i 9901260395 990114 5 gDR ADOCK 05000338 ENCLOSURE PDR e
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EXECUTIVE SUMMARY North Anna Power Station, Units 1 & 2 NRC Integrated Inspection Report Nos. 50-338/98-10, 50-339/98-10 1
This integrated inspection included aspects of licensee operations, engineering, maintenance, and plant support. The report covers a six-week period of resident inspection and the results of announced inspections by a regional inspector and specialis Operations
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Freeze protection procedures were comprehensive and effectively implemented. The overall condition of freeze protection systems was acceptable. Engineering had ,
evaluated long standing heat trace system deficiencies and initiated efforts to l improve system performance. A design change package had not yet been initiated (Section O1.2),
. The North Anna reservoir level during drought conditions was verified to meet Technical Specification 3.7.5.1 requirements. The Updated Final Safety Analysis Report minimum discharge flow rate of 40 standard cubic feet per second was also met (Section 01.3).
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The component cooling system was properly aligned and in good condition. Selected risk significant system components were properly labeled and well maintained. System operation was consistent with the Updated Final Safety Analysis Report description and operator knowledge of the system was excellent. Maintenance rule requirements for l system monitoring were satisfied (Secticn O2.1). :
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. Equipment needed for establishing auxiliary building ventilation for a control room fire l was in place, properly labeled, and in good condition (Section O3,1). 1
. The operator conducted auxiliary building rounds in a thorough and professional manner and was know!edgeable of plant systems. Housekeeping conditions in the auxiliary and fuel handling buildings were good as evidenced by proper lighting, proper storage of equipment, proper control of foreign material, and general cleanliness (Section 04.1)
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. Technical Specifications were satisfied for a Station Nuclear Safety and Operating Committee meeting. The meeting was effective because there was sufficient detail presented and discussed to properly disposition the issues (Section O8.1).
Maintenance
. Maintenance work activities observed on Service Water Pump 1- SW- P-1 A, Charging Pump 1-CH-P-1B, the Unit 2 Train A solid state protection system and a casing cooling tank recirculation spray temper &ture element were conducted in a thorough manner by skillful technicians (Sections M1.1 and M1.2).
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A modification of the North Anna reservoir spillway diesel generator control panel met design change package requirements (Section E2.1).
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Modifications of the outside recirculation spray pump (2-RS-P-2A) seal water head tank vent pathway met design change package requirements. Actions taken were appropriate in response to recurring high head tank level alarm conditions. Head tank level alarm frequency since performance of the modifications had significantly decreased (Section E2.2).
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The system engineer training program met 10 CFR 50.120 requirements. The program included the necessary elements of a systems approach to training. Periodic evaluations and revisions ar.d management review of training effectiveness were being performed (Section E5.1).
Plant Support
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Portions of Revisions 19,20, and 22 to the site emergency plan lacked specificity and were subject to interpretation. Following discussions with the licensee, the inspectors concluded that the changes did not have an adverse impact on the site emergency response program. The licensee plans to revise the parts discussed (Section P3.1).
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The fire team properly responded to an unannounced fire drill in the fuel oil pump hous Fire team members responded quickly to the fire scene, were generally familiar with fire fighting equipment, and knowledgeable of standard fire fighting tactics. Support personnel were effective in assisting the fire team (Section F1.1).
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Report Details Summarv of Plant Status Units 1 and 2 operated at or near full power for the entiie inspection perio l. Operations 01 Conduct of Operations 01.1 Daily Plant Status Reviews (71707)
The inspectors conducted frequent control room tours to verify proper staffing, operator attentiveness, and adhereen to procedures. The inspectors attended daily plant status meetings to maintain awa iuss of overall facility operations and reviewed operator logs to verify operational safety und compliance with Technical Specifications (TSs).
Instrumentation and safety system lineups were periodically reviewed from control room indications to assess operability. Frequent plant tours were conducted to observe equipment status and housekeeping. Deviation reports (DRs) were reviewed to ensure that potential safety concerns were properly reported and resolved. The inspectors found that daily operations were generally conducted in accordance with regulatory requirements e.nd plant procedure .2 Freeze Protection Readiness Insoection Scope (71714. 37551)
Throughout the inspection period, the inspectors examined licensee actions, procedures, and equipment needed for plant freeze protection. Numerous plant walkdowns were performed. The inspectors also discussed the condition of the heat trace (HT) system and other freeze protection components with the system enginee Observations and Findinas The procedure for cold weather operatmo,0-GOP-4, " Cold Weather Operations,"
Revision 13, was in effect and had been initially performed on November 7,1998. This procedure is performed monthly during cold weather. The inspectors reviewed the requirements of 0-GOP-4 and verified many of its actions. The inspectors emphasized risk significant areas such as the auxiliary feedwater pump house, service air compressors, components associated with the low head safety injection system, and the emergency diesel generators. Typical checks for various plant buildings included verification of electrical breaker position for heater / fan units, proper operation of louvers and dampers, and proper position of heater / fan control switches. Important plant instrumentation, located outside or exposed to localized freezing wind drafts and which have had a history of freezing (including the Refueling Water Storage Tank level transmitters), was also checked by the inspectors and no problems were found. The inspectors determined that 0-GOP-4 had been properly implemented.
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The inspectors performed walkdowns of piping insulation and HT circuits for various plant systems exposed to freezing conditions. The inspectors noted that the general condition of these components was acceptable. The inspectors discovered several instances where the insulation needed repair. In many of these instances, the insulation appeared to have been walked on. The inspectors discussed these deficiencies with the license The inspectors discussed with a maintenance planner the status of preventive maintenance (PM) procedures on the HT system. The planner successfully demonstrated that PMs were being scheduled and performed yearl The inspectors also walked down numerous HT freeze protection panels. During these walkdowns, the inspectors found that most panels were clean and in good conditio Some panels were rusted at the bottom which had been discussed with the licensee during a previous inspectio The inspectors discussed with the system engineer the status of efforts to improve the HT system's reliability. As previously discussed in NRC Inspection Report Nos. 50-338, 339/97-12, Section O2.1, the system is antiquated and many parts (e.g., control cards)
are either no longer available or supported by vendors. In November 1997, engineering had proposed several initiatives to improve system performance. Since that time, a notable initiative was the engineering support which allowed defective control cards to be replaced with new ones manufactured by a different vendor. Engineering work had been initiated on Request for Engineering Assistance (REA)97-143 to resolve alarm and control card problems. At the time of the inspection, no design change package had been developed for the RE Conclusions Freeze protection procedures were comprehensive and effectively implemented. The overall condition of freeze protection systems was acceptable. Engineering had evaluated long standing heat trace system deficiencies and initiated efforts to improve system performance. A design change package had not yet been initiate .3 North Anna Reservoir Decreasina Level Trend Inspection Scope (71707)
The inspectors monitored the decreasing reservoir level trend and verified that TS requirements for the minimum level were satisfied. The inspectors also discussed with the spillway operator how the minimum spillway discharge was maintaine Observations and Findinas During the inspection period and for previous months drought conditions have resulted in a lower than normal North Anna reservoir level. Level is normally maintained by the spillway operator at about 250 feet mean sea level (MSL). This reservoir is important because it and the service water reservoir are the ultimate heat sinks. As of December 4, the North Anna reservoir level was 247.6 feet MS . .
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On December 4, the inspectors verified that the repnried North Anna reservoir level of i 247.6 feet MSL was accurate by independently checking the level at the spillway. The !
level is required to be greater than 244 feet MSL in accordance with TS 3.7.5.1. The ;
inspectors noted that notification of an unusual event is required at 247 feet MSL and J plant shutdown is required by operating procedures at 246 feet MSL. If the drought continues, the licensee projected that 246 feet MSL may occur in March 1999, l Thc inspectors also discussed with the spillway operator the requirement to maintain a 1 minimum spillway discharge of 40 standard cubic feet per second. This requirement is !
discussed in Chapter 2.0 of the Updated Final Safety Analysis Report (UFSAR). The operator was well aware of this requirement and successfuity demonstrated how the minimum discharge was maintained, Conclusions The North Anna reservoir level during drought conditions was verified to meet Technical Specification 3.7.5.1 requirements. The Updated Final Safety Analysis Report minimum discharge flow rate of 40 standard cubic feet per second was also me O2 Operational Status of Facilities and Equipment O2.1 Comoonent Coolina (CC) Svstem Walkdown Inspection Scope (71707. 62707)
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On November 25 and 26, the inspectors walked down risk significant components associated with the CC system. The inspectors also reviewed the system's performance criteria established by the licensee's maintenance rule (MR) progra Observations and Findinas l The inspectors focused on the CC pumps, heat exchangers, surge tank, and associated piping and valves. The inspectors also walked down accessible CC components for the residual heat removal system and the reactor coolant pump thermal barriers. The inspectors verified that all valves were in their required positions and properly labele Various items such as thread engagements, piping supports, pump oil levels, and pump bearing temperatures were checked and no significant problems were found. The Appendix 9 fire wrap for CC pump 2-CC-P-1 A was checked and was in good conditio The inspectors identified two minor deficiencies which were appropriately addressed by the licensee. The inspectors also walked down associated control room indications and controls and discussed system operation with a reactor operator. All system parameters were in their normal range and instruments were properly labeled. The operator's i knowledge of system operation, especially during accident conditions, was excellent.
l The inspectors reviewed the UFSAR and no discrepancies were identified.
I Housekeeping conditions for the CC system were good as evidenced by proper lighting and absence of spills and leaks.
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The inspectors checked the system's performance as monitored by the licensee's MR program. The inspectors discussed the system's performance criteria with the maintenance rule coordinator who successfully demonstrated that the system was being monitored for maintenance effectiveness. The system was in MR a(2) status. System unavailability hours were well below the performance criteria limit. The reliability performance criteria allows a maximum of two maintenance preventable functional failures (MPFFs) before an evaluation is required to determine if the system should be placed in the MR a(1) status and steps taken to improve system reliability. The system was assigned two MPFFs. The inspectors concluded that the licensee's system monitoring met MR requirement Conclusions The component cooling system was properly aligned and in good condition. Selected risk significant system components were properly labeled and well maintained. System l operation was consistent with the Updated Final Safety Analysis Report description and !
operator knowledge of the system was excellent. Maintenance rule requirements for system monitoring were satisfie Operations Procedures and Documentation O3.1 Accendix R Procedure Walkdown Inspection Scope (71707)
The inspectors walked down Attachments 4 and 5 of 0-FCA-1," Control Room Fire,"
Revision 14, which establishes auxiliary building ventilation for a control room fir Observations and Findinas During the inspection period the inspectors walked down the attachments and verified that all required equipment such as keys, storage lockers, and portable flexible duct work was in place. All equipment was clearly labeled and in good conditio Conclusions Equipment needed for establishing auxiliary building ventilation for a control room fire was in place, properly labeled, and in good conditio Operator Knowledge and Performance 04.1 Tour with Auxiliary Buildina Operator (71707)
On December 14, the inspectors accompanied the auxiliary building operator during rounds. The inspectors evaluated the operator's attention to detail, familiarity with plant systems and their status, thoroughness of ro.tr.ds, and radiological work practices. The inspectors also checked housekeeping conditions in the auxiliary and fuel handling buildings. The operator paid close attention to the condition of systems and their statu _ - _ _ -_ _
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In particular the operator reviewed previously identified work requests (i.e., orange cards) to determine their status. The operation of several systems was discussed including the isolation of instrument air in the event of a significant system lea Housekeeping conditions were good as evidenced by proper lighting, proper storage of equipment, proper control of foreign materia!, and general cleanliness. The operator conducted auxiliary building rounds in a thorough and professional manner and was knowledgeable of plant systems. Housekeeping conditions in the auxiliary and fuel handling buildings were good.
l 07 Quality Assurance in Operations
07.1 Irtstjtute of Nuclear Power Operations Evaluation Review (71707)
On December 11, a report for an October / November 1998 Institute of Nuclear Power l Operations (INPO) site evaluation was issued. The inspectors reviewed the report and determined that the results were not significantly different from results of similar NRC evaluation <
l 08 Miscellaneous Operations issues (40500,71707,92901) !
l 08.1 Station Nuclear Safety and Operatina Committee (SNSOC) Meetina On November 12, the inspectors attended a SNSOC meeting to verify that TS requirements were satisfied. The inspectors also evaluated the SNSOC's assessment of issues. The meeting was held to approve Licensee Event Report (LER) N1-98-007-00 and a 10 CFR Part 21 evaluation. The LER addressed inappropriate mode changes made on Unit 1 with an inoperable casing cooling pump and the Part 21 evaluation addressed Cycle N1C13 fuel failurek The inspectors verified that several TS requirements associated with the SNSOC were satisfied. A quorum was properly established and all alternate merraers had been properly pre-approved by the SNSOC chairman. Appropriate meeting minutes were prepared and reviewed by the site vice-president. The inspectors judged that sufficient detail was provided to the SNSOC to properly disposition the issues. There were a number of probing questions addressed ;
which demonstrated to the inspectors that the meeting was effectiv .2 Orance County Local Officials Plant Visit On November 18, the inspectors met with the Orange County Emergency Preparedness (EP) Coordinator and two of his staff members at the North Anna site. The following items were discussed:
. EP coordinator and EP staff responsibilities / activities and their interface with the licensee's emergency response group
. Licensee support to the Orange County EP staff
. Communications with the NRC during routine office hours and emergencies 4
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Discussions about a recent installation of an emergency diesel generator at the l
Orange County EP facility l
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Discussions about Orange County "911" notifications and the "911" interface with j the Orange County EP facility i
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Orange County EP funding issues The inspectors found that the visit was informative. At the Orange County EP Coordinator's request, the inspectors will schedule a visit of the Orange County Emergency Management Center, issues which involved questions of communications,
"911" notifications and EP faciiity funding were forwarded to the license .3 (Closed) Violation (VIO) 50-339/98002-01: failure to perform step 6.3.6.a of 2-PT-8 .
On April 6,1998, a Senior Reactor Operator (SRO) improperly initialed step 6.3.6.a of 2-PT-83.1 as having been performed without sufficient knowledge of step completio The SRO used uncontrolled information from a control board magnetic sign which indicated an inside recirculation spray pump breaker was in the TEST position. The breaker, however, was in the CONNECT position. When the pump circuitry was tested, the pump unexpectedly started. The licensee determined that the causes for the event were inadequate communications, inattention to detail, and inadequate status control The inspectors reviewed the corrective actions for the violation and considered them comprehensive, in particular, the inspectors noted that the licensee had revised the Operations Standard for equipment status and visual cues to include guidance for the use of magnetic signs. This guidance states, in part, that :nagnets are not to be used to ;
replace component configuration status verification. In addition, required reading on the '
event was initiated for all operators. The inspectors reviewed the required reading and discussed it with several operators to ensure the revised guidance was understood and no problems were foun . Maintenance M1 Conduct of Maintenance M1.1 Maintenance Activities Inspection Scope (61726. 62707)
Throughout the inspection period, the inspectors observed activities associated with all or portions of the following work orders (WOs) and periodic test (PT):
. WO 400394 01 Unit 1 Main Turbine Control Board impulse ("lMP-IN/ IMP-OUT") Card Replacement
. WO 396965 01 Inspect, Repair or Replace Outboard Pump Bearing on Charging Pump 1-CH-P-1B
. WO 396965 02 Disassembly / Repair Charging Pump 1-CH-P-1B
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. WO 400714 01 Pump Head Curves for Service Water Pump No.1-SW-P-l 1 A Indicated Degraded Pump - Tear down and Inspect !
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- PT-36.1A Unit 2 Train A Sc id State Protection System (SSPS),
Revision 22 b. Observations and Findinas l All work had been properly approved by operations and was included on the licensee's plan of the day. Work associated with risk significant structures, systems, or components, was evaluated to determine impact on the plant's core damage frequenc When applicable, appropriate TS action statements were implemented. The inspectors found that work performed under these activities was professional and thorough. Work was performed with the work package present and in use. Accompanying documents such as procedures and supplemental work instructions were properly followe Personnel were properly trained, experienced, skillful and knowledgeable of their assignments. The inspectors noted that supervisors and system engineers monitored the job Conclusions Maintenance work activities observed on a turbine control card, Service Water Pump 1- SW- P-1 A, Charging Pump 1-CH-P-1B, and the Unit 2 Train A solid state protection system were conducted in a thorough manner by skillful technician M1.2 Casino Coolina Tank Temoerature Recirculation Sorav Element Calibratios Insoection Scoce (61726)
The inspectors observed portions of the casing cooling tank recirculation spray temperature element calibration to verify that the temperature element, which is used in a Technical Specification surveillance activity, was properly calibrate Observations and Findinas The calibration of the casing cooling tank recirculation spray temperature element was conducted in accordance with WO 00390114 01 and Procedure 2-lCP-RS-TE-200 The inspectors verified that the required administrative approvals and tagouts were obtained, test instrumentation was within its current calibration cycle and testing was accomplished by qualified personnel in accordance with the approved procedure, Conclusions Calibration activities for the casing cooling tank recirculation spray temperature element i were performed in a thorough manner by skillful technician j l
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111. Enaineerina E2 Engineering Support of Facilities and Equipment ,
E Modification of the North Anna Hydro Electric Station Soillway Diesel Inspection Scope (37551)
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The inspectors evaluated a modification of the spillway diesel generator local control panel. ' The spillway diesel is described in the UFSAR and is an important component for controlling North Anna reservoir level, one of the plant's ultimate heat sink i Observations and Findinas The inspectors reviewed modification design change package (DCP)98-134 associated with the spillway diesel generator. The diesel's control panel was originally mounted directly on the generator housing. The licensee modified the control panel because the diesel housing vibrated and caused problems within the control panel when the diesel operated. Problems such as loose internal components and broken electrical j connections had occurred at a greater than expected frequency, i The inspectors noted that the control panel was relocated to a separate steel stand next i to the generator unit. The stand was designed so that it could be removed during i maintenance. Wiring from the original diesel-mounted Junction box was replaced with new wiring due to the new location and in order to allow for movement of the panet/ stand for maintenance. The inspectors confirmed that the control panel was located as specified in the DCP, the installation met drawing requirements, and j specified materials were use Conclusions A modification of the North Anna reservoir spillway diesel generator control panel met design change package requirement E2.2 Outside Recirculation Sorav (ORS) Pumo 2-RS-P-2A Seal Modifications Inspection Scope (37551) ,
The inspectors evaluated modifications performed on 2-RS-P-2A. In 1997 and early 1998, recurring problems with the pump seal were noted, (see inspection Reports 50-339/97001, Section M1.1; 50-339/97007, Section M1.7; and 50-339/98-006, Section 07.1). As a result, modifications to the pump sea! vent assembly and replacement of the motor were performed as part of DCP 97-01 ! Observations and Findinas The inspectors, during their evaluation of the modification, noted that from October 1997 '
to April 1998, the licensee experienced numerous 2-RS-P-2A pump seal head tank
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alarms. It was believed that the primary cause of the alarms was a bent pump shaft which resulted in air intrusion to the pump's seal water subsystem. The bent shaft was determined to have been caused by previous pump motor maintenance. The air in-leakage, and the subsequent displacement of the seal water by the air, presented high water level conditions in the pump s6al head tank. Plant annunciation for this condition was indicated by a common "high-low" level alarm. Therefore, each time an improper level condition was indicated, the pump had to be removed from service to ensure the condition was not, in reality, a very undesirable " low level" condition. .The licensee's initial corrective actions involved replacement of the pump motor during an April 1998 refueling outag The licensee also determined that the alarms could have been caused by the original configuration of the vent piping for the pump seal. During pump seal filling operations, air intrusion into the seal area was common because the vent opening was too low relative to the pump seal elevation. After the April outage, the vent piping was modified to extend and redirect the piping. During this modification, the licensee also replaced O-rings for the head tan During the inspection period the inspectors verified that the above corrective actions and vent piping modifications had been adequately performed. Modification package drawings, safety evaluations, and pertinent documentation were reviewed by the l inspectors. The inspectors also performed a walkdown of the modified pump seal ]
piping. The inspectors noted that alarm frequency since implementation of the modifications had significantly decrease Conclusions Modifications of the outside recirculation spray pump (2-RS-P-2A) seal water head tank vent pathway met design change package requirements. Actions taken were appropriate in response to recurring high head tank level alarm conditions. Head tank level alarm frequency since performance of the modifications had significantly decrease I E5 Engineering Staff Training and Qualification ES.1 System Enaineer Trainino Proaram Review Inspection Scope (37551)
The inspectors evaluated the system engineer training program to ensure that 10 CFR 50.120 requirements were satisfied. The inspectors conducted interviews with training and engineering personnel, reviewed training documentation, and attended a training review board (TRB) meetin Observations and Findinas The inspectors found that a systems approach to training was being performed. The licensee used an INPO document entitled " Guidelines for Training and Qualification of
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Engineering Personnel" to meet the requirements for completion of a job task analysis (JTA) The licensee's training program guide outlined the necessary training to address the JTA. The training was divided into three categories which included orientation training, position-specific training, and continuing training. The inspectors reviewed the program guide and compared it to the JTA and concluded that regulatory requirements were met. The inspectors reviewed selected training records to verify the licensee had conducted exams to ensure training effectivenes The inspectors reviewed a list of completed continuing training subjects for the past ;
year. The list included various subjects which addressed industry experience and I changes to the plant, procedures, and regulations. The subject matter satisfied j regulatory requirement j The inspectors attended a Training Review Board (TRB) meeting on December 9 and reviewed minutes from past meetings. It was evident from the discussions and minutes l
that engineering management was actively involved in addressing training needs. In ,
discussions with several engineering personnel, the efforts of the TRB had recently !
improved the quality of continuing trainin I The inspectors reviewed training records of several engineers with their supervisio l The supervisors demonstrated that appropriate training records were being maintaine I The supervisors also demonstrated that the individuals were evaluated for both j orientation and position-specific training based on previous work experienc I Conclusions The system engineer training program met 10 CFR 50.120 requirements. The program included the necessary elements of a s', stems approach to training. Periodic evaluations and revisions and management review of training effectiveness were being performe E8 Misce-Ilaneous Engineering issues (92700,92903)
E8.1 (Closed) Insoection Followuo item (IFI) 50-338. 339/97002-02: potentialinadequate boron concentration in the accumulator discharge lin On February 24,1997 the licensee had identified that operating procedures did not take into account that piping between the safety injection system accumulator discharge check valves could be at a lower boron concentration than either the reactor coolant system (RCS) or residual heat removal (RHR) system. As a result, the licensee initiated DR 97-494 to determine the cause and address appropriate corrective action The licensee had previously initiated Engineering Transmittal (ET) SE 97-013, "Si Accumulator Sampling Techniques," Revision 0, to answer a concern that the Operations Department had raised regarding the adequacy of sampling techniques used to meet TS requirements for accumulator boron concentration. The TS required minimum boron concentration is 2200 parts per million (ppm). An analysis showed that as long as the measured boron concentration in the accumulators was greater than
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piping would meet the accumulator minimum boron concentration TS requirement of 2200 ppm. The analysis took into account that the section of pipe in question could contain a boron concentration as low as O ppm. The inspectors reviewed ET SE 97-013 and discussed it with an engineering supervisor. The inspectors determined that the analysis had a sound technical basis. The insper';rs also reviewed revised sampling procedures to ensure the guidance reflected the i:T's recommendations and no problems were found. The inspectors also reviewed selected accumulator samples for the past two years and found that TS requirements had been met. The inspectors concluded that the licensee had taken appropriate actions to address the issu E8.2 (Closed) Licensee Event Report (LER) 50-338/97007-00: nuclear instrumentation system high flux trip setpoint errors due to calorimetric uncertainties at low powe The inspectors reviewed corrective actions for LER 50-338/97007-00. On August 18, 1997, the licensee had determined that the calorimetric process did not account for ,
potential effects of increasing measurement uncertainty at power levels below 85 l percent power. The licensee had reviewed vendor technical bulletin, "Decalibration 4 Effects of Calorimetric Power Measurements on the NIS High Power Reactor Trip at Power Levels Less Than 70 Percent Rated Thermal Power (RTP)" to make this determination. As stated in the bulletin, decalibration could add process errors. These errors could cause the nine percent design tolerance (between the 109 percent trip setpoint and the 118 percent safety analysis setpoint) to be exceeded. The licensee reviewed past calorimetric practices and calculations and noted that the plant had not actually experienced the bulletin-described conditions. As a precaution to preclude such a condition, the licensee revised calibration procedures to include the appropriate high power trip setpoints. This was performed to ensure that the safety analysis assumptions, as described in the bulletin, would be met. The licensee also addressed necessary actions for adjusting the NIS following any low power calorimetric. The inspectors reviewed the revised NIS calibration procedmes and other corrective actions and concluded that the licensee had taken proper actions to address the issu E8.3 (Closed) LER 50-338/97009-00: incomplete surveillance on solid state protection circuits due to procedure erro On November 18,1997, the licensee had determined that automatic logic testing for the main feedwater isolation on steam generator high-high level (P-14) and source range automatic block (P-10) circuits were not properly tested. The cause of the incomplete surveillance was due to inadequate test designs that had been originally supplied by the vendor. The original test designs did not allow for a full verification of P-14 and P-10 circuits. The inspectors noted that original test procedures were developed based upon instructions contained in the vendor's technical manuals. These manuals were inadequate because they failed to provide the necessary in-depth instructions for a thorough testing of all circuitry. Test procedures were revised to include the required in-l depth instructions. The licensee reviewed other solid state protection system circuits
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and no other circuits had similar testing problems. When this item was originally j
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presented in 1997, the NRC issued Non-cited Violation (NCV) 50-338,339/97011-0 The inspectors reviewed the revised test procedures, associated circuitry drawings and
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i 12 l the LER work package and concluded that the licensee had taken appropriate actions to I address the issu I IV. Plant Support l
R1 Radiological Protection and Chemistry (RP&C) Controls (71750) I l
On numerous occasions during the inspection period, the inspectors reviewed radiation l protection (RP) practices including radiation control area entry and exit, survey results, i and radiological area material conditions and no discrepancies were noted. The inspectors determined that RP practices were prope P3 Emergency Preparedness (EP) Precedures snd Documentation P3.1 Emeraency Plan Implementina Procedures 1 Inspection Scope (82701)
l The inspectors reviewed selected revisions to the North Anna Power Station Emergency i Plan (Plan) to evaluate the impact of the changes on the site emergency response l program. Requirements applicable to this area are found in 10 CFR 50.47(b)(16), I 10 CFR 50.54(q), and Appendix E to 10 CFR Patt 5 Observations and Findinos The licenses submitted Revisions 19,20, and 22 to the Plan to the NRC as required in 10 CFR 50.54(q). The inspectors met with responsible licensee personnel to discuss selected changes to the P.la Change number 32 in Revision 19 omitted from Section 8.6.5 of the Plan, the statement, l
" corrective actions will be identified." The licensee has continued to identify corrective actions although the statement was omitted. In the next revision to the Plan, the licensee will re-instate the words " corrective actions will be identified." l Change number 34 in Revision 19 did not clearly state the mechanism for verifying that a secure container had not been opened as discussed in Section 8.7 of the Plan. In the next revision to the Plan, the licensee stated they would clarify the mechanism for verifying a secure container.
, Change number 16 in Revision 20 replaced Section 8.5.8," Emergency Callout Drills."
! This section stated," Emergency Callout Drilk shall be conducted at least once per calendar quarter with a maximum allowable grace period not to exceed 25%." The section was replaced by a line item "p" under the heading Maintaining Emergency Preparedness in Section 8.1 which read:" Coordinating the conduct of an augmentation capability assessment at least once each calendar quarter." To clarify the licensee's intent, the licensee planned to move the change to follow Section 8.5.7 of the Plan, and to clarify it by providing additional expectations in the next revision to the Pla __ _ _ _ _ _ _ _ _ _ . . _ - . _ _ _ _ _ _ . - _ _ .__ .. .
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Change number 5 in Revision 22 was associated with Section 8.3.3, " Emergency '
Response Personnel Training," and Table 8.1, " Emergency Preparedness Training."
These changes were in response to observations discussed in NRC Integrated Inspection Report Nos. 50-338,339/98-03 in which EP training requirements for shift technical advisors (STAS) had been omitted from the EP training program. During that inspection the inspectors noted that STAS had received EP trainin The inspectors determined that the change did not clearly place the responsibility for l Emergency Preparedness Training with the Emergency Preparedness Organization. In the reext revision to the Plan, the licensee planned to clearly state that the Emergency ,
Preparedness Organizations is responsibility for Emergency Preparedness Training as required in 10 CFR Part 50, Appendix Conclusions i
Portions of Revisions 19,20, and 22 to the site emergency plan lacked specificity and were subject to interpretation. Following discussions with the licensee, the inspectors concluded that the changes did not have an adverse impact on the site emergency response program. The licensee plans to revise the parts discusse S1 Conduct of Security and Safeguards Activities (71750)
On numerous occasions during the inspection period, the inspectors performed walkdowns of the protected area perimeter to assess security and general barrier conditions and no deficiencies were noted. The inspectors concluded that perimeter barrier's material condition was properly maintaine !
F1 Control of Fire Protection Activities F Unannounced Fire Drill in Fuel Oil Pumo House Inspe'etion Scope (71750)
On November 17, the inspectors observed an unannounced fire drill in the fuel oil pump hous Observations and Findings Prior to the fire team's arrival to the simulated fire, the inspectors observed support l personnel run fire hoses and provide backup fire fighting equipment. The inspectors checked that the hoses were properly configured and no problems were found. The inspectors noted that a knowledgeable operator arrived at the fire scene to provide an initial assessment to the control room. in addition, an SRO also provided local management oversight. Use of the knowledgeable operator and the SRO was viewed by the inspectors as an effective means to manage plant fire Overall performance of the fire team was evaluated. The fire team responded to the fire scene quickly. All members were at the fire scene in less than 10 minutes. Standard
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fire fighting tactics were observed and no problems were found. During the drill a fire fighter's air bottle alarmed due to low air pressure. The fire fighter immediately left the i fire area which was appropriate. The fire fighter's mask had not sealed properly due to i personnel error and most of the air had blown out of the seal. During the post drill critique, the fire fighters were reminded about the importance of establishing a proper seal before attacking fires, l c. Conclusions The fire team properly responded to an unannounced fire drill in the fuel oil pump hous Fire team members responded quickly to the fire scene, were generally familiar with fire fighting equipment, and knowledgeable of standard fire fighting tactics. Support personnel were effective in assisting the fire tea V. Manacement Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at i the conclusion of the inspection on December 22,1998. The licensee acknowledged l the findings presented.
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The inspectors asked the licensee whether any materials examined during the I inspection should be considered proprietary. The licensee stated that the INPO l evaluation report was proprietar !
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PARTIAL LIST OF PERSONS CONTACTED Licensee D. Christian, Vice President, Nuclear Operations B. Foster,' Superintendent Station Engineering C. Funderburk, Manager, Station Safety and Licensing J. Hayes, Director, Nuclear Oversight D. Heacock, Manager, Station Operations and Maintenance P. Kemp, Supervisor, Licensing L Lane, Superintendent, Operations .
T. Maddy, Superintendent, Security W. Matthews, Site Vice President H.' Royal, Superintendent, Nuclear Training D. Schappell, Superintendent, Site Services R. Shears, Superintendent, Maintenance
- A. Stafford, Superintendent, Radiological Protection l
INSPECTION PROCEDURES USED IP 37551: Onsite Engineering IP 40500: Effectiveness of Licensee Controls in identifying, Resolving, and Preventing Problems IP 61726: Surveillance Observations IP 62707: Maintenance Observations IP 71707: Plant Operations IP 71714: Cold Weather Preparations IP 71750: Plant Support Activities IP 82701: Operational Status of the Emergency Preparedness Program -
IP 92700: Onsite Followup of Written Reports of Nonroutine Events at Power Reactor Facilities IP 92901: Followup - Plant Operations IP 92903: Followup - Engineering i ITEMS CLOSED 50-339/98002-01 VIO failure to perform step 6.3.6.a of 2-PT-83.1 (Section 08.3)
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50-338, 339/97002-02 IFl potential inadequate boron concentration in the accumulator discharge line (Section E8.1)
50-338/97007-00 LER nuclear instrumentation system high flux trip setpoint errors due to calometric uncertainties at low power (Section E8.2)
50-338/97009-00 LER incomplete surveillance on solid state protection circuits due to procedure error (Section E8.3) ;
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