IR 05000338/2008004

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IR 05000338-08-004, 05000339-08-004; 07/01/2008 - 09/30/2008; North Anna Power Station, Units 1 and 2; Routine Integrated Report, Other Activities
ML083020663
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 10/28/2008
From: Jim Dodson
NRC/RGN-II/DRP/RPB5
To: Christian D
Virginia Electric & Power Co (VEPCO)
References
IR-08-004
Download: ML083020663 (34)
v • d • e


Text

October 28, 2008

SUBJECT:

NORTH ANNA POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000338/2008004 AND 05000339/2008004

Dear Mr. Christian:

On September 30, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your North Anna Power Station Units 1 and 2. The enclosed integrated inspection report documents the inspection findings which were discussed on October 15, 2008, with Mr.

Larry Lane and other members of your staff.

The inspection examined activities conducted under your licenses as they related to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, one NRC-identified finding of very low safety significance (Green) was identified. This was determined to involve a violation of NRC requirements. However, because of its very low safety significance and because it was entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you wish to contest this non-cited violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-001; with copies to the Regional Administrator Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the North Anna Power Station.

VEPCO

In accordance with 10 CFR 2.390 of the NRCs 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 NRCs 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,

/RA/

James S. Dodson, Acting Chief

Reactor Projects Branch 5

Division of Reactor Projects

Docket Nos.: 50-338, 50-339 License Nos.: NPF-4, NPF-7

Enclosure:

Inspection Report 05000338/2008004 and 05000339/2008004

w/ Attachment: Supplemental Information

REGION II==

Docket Nos:

50-338, 50-339

License Nos:

NPF-4, NPF-7

Report No:

05000338/2008004 and 05000339/2008004

Licensee:

Virginia Electric and Power Company (VEPCO)

Facility:

North Anna Power Station, Units 1 and 2

Location:

1022 Haley Drive Mineral, Virginia 23117

Dates:

July 1, 2008 through September 30, 2008

Inspectors:

J. Reece, Senior Resident Inspector

R. Clagg, Resident Inspector

A. Vargas Mendez, Reactor Inspector, Section 1R07

E. Lea, Senior Operations Examiner, Section 4OA5.1

G. Laska, Senior Operations Examiner, Section 4OA5.1

J. Riveria-Ortiz, Senior Reactor Inspector, Sections 1R08, 4OA5.4

M. Coursey, Reactor Inspector in Training, Sections 1R08, 4OA5.4

Approved by:

James S. Dodson, Acting Chief Reactor Projects Branch 5 Division of Reactor Projects

.

Enclosure

SUMMARY OF FINDINGS

IR 05000338/2008-004, 05000339/2008-004; 07/01/2008 - 09/30/2008; North Anna Power

Station, Units 1 and 2; Routine Integrated Report, Other Activities.

The report covered a 3-month period of inspection by resident inspectors and two announced inspections by regional reactor inspectors. One finding was identified and determined to be an NCV. The significance of most findings is identified by their color (Green, White, Yellow,

Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process Revision 4, dated December 2006.

NRC Identified and Self-Revealing Findings

Cornerstone: Mitigating Systems

Green.

The inspectors identified a non-cited violation of 10 CFR 50.9 for failure to provide complete and accurate information for one licensed operator on the initial license application. The facility licensee submitted a NRC Form-396 (Certification of Medical Examination by Facility Licensee) without identifying a pre-existing medical condition. The facility licensee took prompt corrective actions, which included removing the operator from license duties and submitted an NRC Form-396 requesting to have the operators license amended with the appropriate restriction. The NRC imposed a no-solo restriction on the operators license after performing a medical review of supplemental information.

Because this issue affected the NRCs ability to perform its regulatory function, it was evaluated using the traditional enforcement process. This finding is of very low safety significance because there was no evidence that the operator endangered plant operations as a result of performing licensed duties since the original issuance of his license. However, the regulatory significance was important because the incorrect information was provided under sworn statement to the NRC and impacted a licensing decision for the individual. This issue is documented in the facility licensees corrective action program as Condition Report (CR) 090083. (Section 4OA5.3)

Licensee Identified Violations

None

REPORT DETAILS

Summary of Plant Status

Unit 1 began the period at full Rated Thermal Power (RTP) and operated at full power for the entire report period.

Unit 2 began the period at full RTP and operated at full power until September 14, 2008 when Unit 2 shutdown for a refueling outage.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

==1R01 Adverse Weather Protection

a. Inspection Scope

==

The inspectors performed a site specific weather related inspection due to anticipated adverse weather conditions. Between September 3, 2008 and September 5, 2008, the inspectors reviewed the licensee response to Tropical Storm Hanna which was expected to bring heavy winds and rains to the area. Specifically, the inspectors reviewed licensee adverse weather response procedures and site preparations including work activities that could impact the overall maintenance risk assessments.

b. Findings

No findings of significance were identified.

==1R04 Equipment Alignment

a. Inspection Scope

==

The inspectors conducted two equipment partial alignment walkdowns to evaluate the operability of selected redundant trains or backup systems with the other train or system inoperable or out of service. The inspectors reviewed the functional system descriptions, Updated Final Safety Analysis Report (UFSAR), system operating procedures, and Technical Specifications (TS) to determine correct system lineups for the current plant conditions. The inspectors performed walkdowns of the systems to verify that critical components were properly aligned and to identify any discrepancies which could affect operability of the redundant train or backup system.

'2H' EDG for coolant venting

  • Unit 1 'A' train casing cooling system due to planned preventative maintenance on the opposite train

b. Findings

No findings of significance were identified.

==1R05 Fire Protection

==

.1 Fire Protection - Tours

a. Inspection Scope

The inspectors conducted tours of the eleven areas listed below that are important to reactor safety to verify the licensees implementation of fire protection requirements as described in Virginia Power Administrative Procedure (VPAP)-2401, Revision 28, Fire Protection Program. The inspectors evaluated, as appropriate, conditions related to:

(1) licensee control of transient combustibles and ignition sources;
(2) the material condition, operational status, and operational lineup of fire protection systems, equipment, and features; and
(3) the fire barriers used to prevent fire damage or fire propagation.
  • Cable Tray Spreading Room Unit 1 (fire zone 4-1b / CSR-1)
  • Cable Tray Spreading Room Unit 2 (fire zone 4-2b / CSR-2)
  • Normal Switchgear Room Unit 1 (fire zone 5-1 / NSR-1)
  • EDG '1H' Unit 1 (fire zone 9A-1a / EDG-1H)
  • EDG '1J' Unit 1 (fire zone 9B-1a / EDG-1J)
  • Cable Vault and Tunnel Unit 1 (includes Control Rod Drive Room and Z-27-1)

(fire zone 3-1a / CV & T-1)

  • Cable Vault and Tunnel Unit 2 (includes Control Rod Drive Room and Z-27-2)

(fire zone 3-2a / CV & T-2)

  • Casing Cooling Tank & Pump House Unit 1 (fire zone Z-41-1 / CCT&PH-1)
  • Casing Cooling Tank & Pump House Unit 2 (fire zone Z-41-2 / CCT&PH-2)
  • Normal Switchgear Room Unit 2 (fire zone 5-2 / NSR-2)
  • Alternate AC Building (fire zone Z-52 / AAC)

b. Findings

No findings of significance were identified.

.2 Fire Protection - Drill Observation

a. Inspection Scope

During a fire protection drill on August 28, 2008, at the Unit 2 motor driven auxiliary feedwater (AFW) pump room the inspectors assessed the timeliness of the fire brigade in arriving at the scene, the fire fighting equipment brought to the scene, the donning of fire protection clothing, the effectiveness of communications, and the exercise of command and control by the scene leader. The inspectors also assessed the acceptance criteria for the drill objectives and reviewed the licensees corrective action program for recent fire protection issues.

b. Findings

No findings of significance were identified.

==1R06 Flood Protection Measures

a. Inspection Scope

==

The inspectors assessed the internal flooding vulnerability of the Unit 1 and 2 air conditioning (AC) Chiller Room and AC Fan Rooms with respect to adjacent safety-related areas to verify that the flood protection barriers and equipment were being maintained consistent with the UFSAR. The licensees corrective action documents were reviewed to verify that corrective actions with respect to flood-related items identified in condition reports were adequately addressed. The inspectors conducted a field survey of the selected areas to evaluate the adequacy of flood barriers, and floor drains to protect the equipment, as well as their overall material condition.

b. Findings

No findings of significance were identified.

==1R07 Triennial Heat Sink Performance

a. Inspection Scope

==

The inspectors reviewed inspection records, test results, and other documentation to ensure that heat exchangers (HX) deficiencies that could mask or degrade performance were identified and corrected. The test procedures and records were also reviewed to verify that these were consistence with Generic Letter 89-13 licensee commitments and industry guidelines. The inspectors reviewed documentation associated with the Component Cooling (CC) System HXs, Charging Pumps, and Recirculation Spray (RS) HX to assess the health of each. In addition, the inspectors reviewed documentation associated with the Service Water (SW)

System to assess its capabilities to support these and other risk significant HXs. All documents reviewed are listed in the attachment.

The inspectors reviewed site and corporate HX program procedures, Maintenance Procedures including testing and cleaning frequencies, design basis documents, CR documents, system health reports, and conducted interviews with Service Water System engineers. The inspectors reviewed visual inspection records, flow measurement trends, system walk down inspection results, and eddy current testing procedures.

In addition, the inspectors conducted a walk down of the SW system, intake structure, discharge canals, and selected HXs to assess general material condition and to identify any degraded conditions of selected components.

Condition Reports were reviewed for potential common cause problems and problems which could affect system performance to confirm that the licensee was entering issues into the corrective action program and initiating appropriate corrective actions.

b. Findings

No findings of significance were identified.

==1R08 Inservice Inspection (ISI) Activities (IP 71111.08P, Unit 2)

==

.1 Inservice Inspection Activities Other than Steam Generator Tube Inspections, PWR

Vessel Upper Head Penetration Inspections, and Boric Acid Corrosion Control

Program

.a Inspection Scope

The inspectors reviewed the implementation of the licensees ISI program for monitoring degradation of the reactor coolant system (RCS) boundary and risk significant piping boundaries. The inspectors activities consisted of an on-site review of nondestructive examination (NDE) and welding activities to evaluate compliance with the applicable edition of the American Society of Mechanical Engineers (ASME)

Boiler and Pressure Vessel Code,Section XI (Code of record for ISI: 1995 Edition with 1996 Addenda), and to verify that indications and defects (if present) were appropriately evaluated and dispositioned in accordance with the requirements of the ASME Code,Section XI acceptance standards.

The inspectors review of NDE activities specifically covered examination procedures, NDE reports, equipment and consumables certification records, personnel qualification records, and calibration reports (as applicable) for the following examinations:

pressurizer safety line C, ASME Class 1, 1.5-inch diameter pipe (Augmented ISI exam)

  • PT examination of weld 1-RC-511/SW-20, RCS - Pressurizer safety line A, ASME Class 1, 1.5-inch diameter pipe (Augmented ISI exam)

The inspectors also reviewed documentation for the following NDE indications, which were accepted for continuous service:

The inspectors review of welding activities specifically covered work orders, repair and replacement plans, weld data sheets, welding procedures, procedure qualification records, welder qualification records, and radiography films and reports for the following welding activities in order to evaluate compliance with procedures and the ASME Code.

  • Repair and Replacement Plan 07-021, Revision 1: Weld 2-RC-E-2/FW-12A (RCS), cutting and replacement of pipe on Pressurizer safety line, ASME Class 1
  • Repair and Replacement Plan 07-133: Welds 2-SI-MOV-2867B/24A and 26 (Safety Injection System), motor operated valve replacement, ASME Class 2

b. Findings

No findings of significance were identified.

.2 PWR Vessel Upper Head Penetration (VUHP) Inspection Activities

a. Inspection Scope

The licensee did not perform volumetric or bare metal visual (BMV) examinations of the VUHPs during the fall 2008 refueling outage. The licensee replaced the Unit 2s reactor vessel upper head (RVUH) in the winter of 2003 and performed a BMV inspection in the spring of 2007 (NRC Inspection Report 2007003). For the fall 2008 refueling outage, the inspectors reviewed licensee procedures and results of the visual inspection to identify potential boric acid leaks from pressure-retaining components above the RVUH. This was reviewed to verify licensee compliance with the regulatory requirements of NRC Order EA-03-009 Modifying Licenses dated February 20, 2004. In addition, the inspectors reviewed the licensees RVUH Effective Degradation Years calculation to ensure it had been performed and updated in accordance with the NRC Order.

b. Findings

No findings of significance were identified.

.3 Boric Acid Corrosion Control (BACC) Inspection Activities

a. Inspection Scope

The inspectors reviewed the licensees BACC program activities to ensure implementation with commitments made in response to NRC Generic Letter 88-05, Boric Acid Corrosion of Carbon Steel Reactor Pressure Boundary, and applicable industry guidance documents. Specifically, the inspectors performed an on-site record review of procedures and the results of the licensees containment walkdown inspections performed during the Unit 2 fall 2008 outage to evaluate compliance with licensees BACC program requirements and verify that degraded or non-conforming conditions were properly identified and corrected in accordance with the licensees BACC and Corrective Action Programs.

The inspectors also reviewed a sample of engineering evaluations completed for evidence of boric acid found on systems containing borated water to verify that the minimum design code required section thickness had been maintained for the affected components. The inspectors selected the following evaluations for review:

  • CR091977 - Boric acid on body to bonnet of valve 2-SI-MOV-2862B, Safety Injection System

b. Findings

No findings of significance were identified.

.4 Steam Generator Tube Inspection Activities

a. Inspection Scope

The licensee did not perform SG inspection during the fall 2008 refueling outage.

Based on plant Technical Specifications and SG effective full power months, the licensee determined that the inspection could be deferred until the next refueling outage.

b. Findings

No findings of significance were identified.

.5 Identification and Resolution of Problems

a. Inspection Scope

The inspectors performed a review of ISI-related problems, including welding, BACC, and SG inspections that were identified by the licensee and entered into the corrective action program as CRs. The inspectors reviewed the CRs to confirm that the licensee had appropriately described the scope of the problem and had initiated corrective actions. The review also included the licensees consideration and assessment of operating experience events applicable to the plant. The inspectors performed this review to ensure compliance with 10CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requirements. The corrective action documents reviewed by the inspectors are listed in the report attachment.

b. Findings

No findings of significance were identified.

==1R11 Licensed Operator Requalification Program

a. Inspection Scope

==

The inspectors reviewed a crew examination which involved an uncontrolled rod insertion, a loss of the C reserve station service transformer and associated oil spill, a loss of cooling accident with a failure of the boron injection tank injection path, and a RS HX tube leak. The inspectors observed crew performance in terms of communications; ability to take timely and proper actions; prioritizing, interpreting, and verifying alarms; correct use and implementation of procedures, including the alarm response procedures; timely control board operation and manipulation, including high-risk operator actions; and oversight and direction provided by the shift supervisor, including the ability to identify and implement appropriate TS actions. The inspectors observed the post training critique to determine that weaknesses or improvement areas revealed by the training were captured by the instructor and reviewed with the operators.

b. Findings

.

No findings of significance were identified.

==1R12 Maintenance Effectiveness

a. Inspection Scope

==

For the two equipment issues listed below, the inspectors evaluated the effectiveness of the corresponding licensee's preventive and corrective maintenance.

The inspectors performed walkdowns of the accessible portions of the systems, performed in-office reviews of procedures and evaluations, and held discussions with system engineers. The inspectors compared the licensees actions with the requirements of the Maintenance Rule (10 CFR 50.65) using ER-AA-MRL-10, Revision 2, Maintenance Rule Program, and related support documents.

  • CR104604, 2J EDG Maintenance activity exceeded MRule performance criteria
  • CR095912, Exceedance of EDG (2H) System MRule Criteria

b. Findings

No findings of significance were identified.

==1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

==

The inspectors evaluated, as appropriate, the five activities listed below for the following:

(1) effectiveness of the risk assessments performed before maintenance activities were conducted;
(2) management of risk;
(3) upon identification of an unforeseen situation, necessary steps were taken to plan and control the resulting emergent work activities; and
(4) maintenance risk assessments and emergent work problems were adequately identified and resolved. The inspectors verified that the licensee was complying with the requirements of 10 CFR 50.65 (a)(4) and the data output from the licensees safety monitor associated with the risk profile of Units 1 and 2.
  • Emergent entry into abnormal procedure, 0-AP-41, "Severe Weather Conditions," Revision 39, due to a tornado warning which, when combined with other unavailable equipment, resulted in increased risk but below the Yellow risk threshold
  • Technical Support Center uninterruptible power supply failure and consequent inoperability of both units anticipated transient without scram mitigation actuation circuitry resulted in increased risk but below the Yellow risk threshold
  • Emergent work to repair Potential Transformer cubicle door required '2H' EDG inoperable resulted in increased risk but below the Yellow risk threshold
  • Emergent entry into 0-AP-41, Revision 40, due to Tropical Storm Hanna which combined with other unavailable equipment resulted in increased risk that remained below the Yellow risk threshold
  • Unit 2 planned outage work on CC expansion joint, 2-CC-REJ-23A, required isolation of heat exchangers, 2-CC-E-1A and 2-CC-E-1B. CC is a shared system, and this resulted in a Yellow risk condition on Unit 1 when combined with other unavailable equipment

b. Findings

No findings of significance were identified.

==1R15 Operability Evaluations

a. Inspection Scope

==

The inspectors reviewed five operability evaluations affecting the risk-significant mitigating system, listed below, to assess, as appropriate:

(1) the technical adequacy of the evaluations;
(2) whether continued system operability was warranted; (3)whether other existing degraded conditions were considered as compensating measures;
(4) whether the compensatory measures, if involved, were in place, would work as intended, and were appropriately controlled; and
(5) where continued operability was considered unjustified, the impact on TS Limiting Conditions for Operation and the risk significance in accordance with the SDP. The inspectors review included a verification that determinations of operability were made as specified by procedure OP-AA-102, Operability Determination, Revisions 2 and 3.
  • Engineering transmittal, ET-N-08-0043, Evaluating Results of 1-PT-75.2B.1 for Operability of 1-SW-P-1B, Service Water Pump, Revision 0
  • CR105580, 2H EDG PT fuse panel door is not fully closed
  • CR107667, 2-CH-P-1C IMB oil analysis reports marginal machine condition
  • CR108328, review of OD000190, Assign OD associated with UFOSTs non-missile protected vent lines

b. Findings

No findings of significance were identified.

==1R18 Plant Modifications

a. Inspection Scope

==

The inspectors reviewed the completed permanent plant modification Design Change Package (DCP)08-111, Replacement of EDG K1 contactors (2J EDG). The inspectors conducted a walkdown of the installation, discussed the desired improvement with system engineers, and reviewed the 10 CFR 50.59 Safety Review/Regulatory Screening, technical drawings, test plans and the modification package to assess TS implications.

b. Findings

No findings of significance were identified.

==1R19 Post Maintenance Testing

a. Inspection Scope

==

The inspectors reviewed five post maintenance test procedures and/or test activities, as appropriate, for selected risk-significant mitigating systems to assess whether: (1)the effect of testing on the plant had been adequately addressed by control room and/or engineering personnel;

(2) testing was adequate for the maintenance performed;
(3) acceptance criteria were clear and adequately demonstrated operational readiness consistent with design and licensing basis documents;
(4) test instrumentation had current calibrations, range, and accuracy consistent with the application;
(5) test were performed as written with applicable prerequisites satisfied;
(6) jumpers installed or leads lifted were properly controlled;
(7) test equipment was removed following testing; and
(8) equipment was returned to the status required to perform in accordance with licensee procedure VPAP-2003, Post Maintenance Testing Program, Revisions 12 and 13.
  • Work Order (WO) 00805863-03, Replace 6 inch spray array piping
  • WO 1017181-20, Perform testing/rebuild valve operator per engineering
  • WO 1017323-34, Uncouple motor from speed increaser/recouple and align 2-CH-P-1C

b. Findings

No findings of significance were identified.

==1R20 Refueling and Other Outage Activities

a. Inspection Scope

==

The inspectors reviewed the Outage Safety Plan (OSP) and contingency plans for the Unit 2 refueling outage, which began September 14, 2008, to confirm that the licensee had appropriately considered risk, industry experience, and previous site-specific problems in developing and implementing a plan that assured maintenance of defense-in-depth. The inspectors used Inspection Procedure 71111.20, Refueling and Outage Activities, to observe portions of the shutdown, cooldown, and maintenance activities to verify that the licensee maintained defense-in-depth commensurate with the outage risk plan and applicable TS. The inspectors monitored licensee controls over the outage activities listed below.

.

  • Licensee configuration management, including daily outage reports, to evaluate defense-in-depth commensurate with the outage safety plan and compliance with the applicable TS when taking equipment out of service.
  • Adequate implementation of the boric acid corrosion control program by performing a containment walkdown after shutdown to identify boric acid leaks.
  • Installation and configuration of reactor coolant instruments to provide accurate indication and an accounting for instrument error.
  • Controls over the status and configuration of electrical systems and switchyard to ensure that TS and OSP requirements were met.
  • Licensee implementation of clearance activities to ensure equipment was appropriately configured to safely support the work or testing
  • Controls to ensure that outage work was not impacting the ability to operate the spent fuel pool cooling system during and after core offload.
  • Reactor water inventory controls including flow paths, configurations, and alternative means for inventory addition, and controls to prevent inventory loss.
  • Reactivity controls to verify compliance with TS, and activities which could affect reactivity were reviewed for proper control within the outage risk plan.

b. Findings

No findings of significance were identified.

==1R22 Surveillance Testing

a. Inspection Scope

==

For the four surveillance tests listed below, the inspectors examined the test procedure, witnessed testing, reviewed test records and data packages, to determine whether the scope of testing adequately demonstrated that the affected equipment was functional and operable, and that the surveillance requirements of TS were met.

The inspectors also determined whether the testing effectively demonstrated that the systems or components were operationally ready and capable of performing their intended safety functions. The inspectors reviewed an in-service testing activity for a risk significant pump or valve as part of the surveillance activities.

In-Service Test:

  • 2-PT-71.3Q, 2-FW-P-3B Motor Driven AFW Pump and Valve Test, Revision RCS Leakage

Revision 31

Other Surveillance Tests:

  • 2-PT-31.1.1, Delta T/Tave Protection Channel I (2-RC-T-2412) Channel Operational Test, Revision 53

b. Findings

No findings of significance were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation

a. Inspection Scope

On June 24, 2008, the inspectors reviewed and observed the performance of an emergency planning exercise drill that involved an earthquake, an injured and contaminated technician, loss of offsite power to the 1H emergency bus, a main turbine condenser vacuum leak, a failure of a manual reactor trip, a failure of the turbine driven AFW pump, fuel damage, a failure of the A charging pump, a B SG tube rupture with respective safety valve failed open, and conditions requiring safety injection. The above conditions led to the declaration of emergency action levels for an Alert, Site Area Emergency and General Emergency.

The inspectors assessed emergency procedure usage, emergency plan classification, notifications, and the licensees identification and entrance of any problems into their corrective action program. This inspection evaluated the adequacy of the licensees conduct of the drill and critique performance. Exercise issues were captured by the licensee in their corrective action program as CR102130.

Requalification training deficiencies were captured within the operator training program.

b. Findings

No findings of significance were identified.

OTHER ACTIVITIES

4OA1 Performance Indicator (PI) Verification

a. Inspection Scope

The inspectors reviewed the licensees procedures for developing the Unit 1 and 2 data for the Mitigating Systems MSPI which include:

(1) Emergency AC Power System;
(2) High Pressure Injection System;
(3) Auxiliary Feedwater System;
(4) Residual Heat Removal System; and
(5) Support Cooling Water System. The inspectors examined data reported to the NRC for the period July 2007 through June 2008.

The inspectors reviewed the licensees procedures for developing the data for the Scrams with Complications Initiating Events PI. The inspectors examined Unit 1 and Unit 2 data reported to the NRC for the period January 2007 through December 2007 for the Initiating Event PI.

Procedural guidance for reporting PI information and records used by the licensee to identify potential PI occurrences were also reviewed for both units. The inspectors reviewed the licensee event reports, corrective action program documents, and maintenance rules records as part of the verification process. These inspections were conducted in accordance with NRC Inspection Procedure 71151, Performance Indicator Verification. The applicable planning standards, 10 CFR 50.0 and NEI 99-02, Revision 5, Regulatory Assessment Performance Indicator Guidelines, were used as reference criteria.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

Review of Items Entered into the Corrective Action Program:

As required by Inspection Procedure 71152, Identification and Resolution of Problems, and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees corrective action program. This review was accomplished by reviewing daily CR report summaries and periodically attending daily CR Review Team meetings.

4OA5 Other Activities

.1 (Closed) URI 05000339/2007009-01: Lack of Procedural Guidance During Spurious

Safety Injection and Procedure Usage Flexibility Acceptability As described in Unresolved Item (URI)05000339/2007009-01, NRC inspectors identified an issue related to the adequacy of procedures, and the amount of flexibility allowed in using these procedures, for responding to a spurious Safety Injection.

Upon further review, the NRC has determined that the licensees procedures, and the

guidance for using these procedures, were adequate. This determination was made

after a review of the licensees applicable Emergency Operating Procedures (EOPs),

Westinghouse Owner Group guidelines governing the content and use of these

EOPs, the licensees response to a Westinghouse recommendation to review these

EOPs with respect to an inadvertent safety injection, and the licensees administrative

procedures governing the use of EOPs. Based on these reviews, the inspectors

determined that the URI is not a performance deficiency. This URI is closed.

.2 (Closed) URI 05000339/2007009-02: Lack of an Effective Program to Detect and

Correct Degradations in Unit 2 SSPS Cards

As described in URI 05000339/2007009-02, NRC inspectors identified an issue for the lack of an effective program to detect and correct degradations in the Unit 2 SSPS logic cards.

Upon extensive review by NRC headquarters and regional inspectors, it was determined that there was no violation of NRC Requirements. However, this issue met the threshold for generic communication to the industry in the form of an Information Notice. Based on the evaluation of the event and review of immediate and long term corrective actions, the inspectors determined that the unresolved item could be closed. This URI is closed.

.3 (Closed) URI 0500338, 339/2008002-02, Failure to Report Accurate Medical

Information on Initial Licensing Application

a. Inspection Scope

In NRC Integrated Inspection Report 05000338, 339/2008002 the inspectors identified a URI for the licensee failure to report accurate medical information on an initial licensing application in 2006. The issue was unresolved pending additional guidance from NRC medical review of information provided by the licensee. The inspectors and the NRC medical contractor conducted a review of the additional information provided by the licensee.

b. Findings

Introduction.

The inspectors identified a Green (Severity Level IV) NCV of 10 CFR 50.9 for failure to provide complete and accurate information for one licensed operator on his initial license application.

Description.

The NRCs requirements related to the conduct and documentation of medical examinations for operators are contained in Subpart C, Medical Requirements, of 10 CFR Part 55, Operators Licenses. Specifically, Section 55.21, Medical examination, requires every operator to be examined by a physician when he or she first applies for a license. The physician must determine whether the operator meets the requirements of section 55.33(a)(1), i.e., the operators medical condition and general health will not adversely affect the performance of assigned operator duties or cause operational errors that endanger public health and safety.

Every time an operator applies for a license pursuant to Section 55.31, How to apply, or Section 55.57, Renewal of licenses, an authorized representative of the facility licensee must complete and sign NRC Form-396, Certification of Medical Examination by Facility Licensee, attesting, pursuant to Section 55.23, Certification, that a physician has conducted the required medical examination and determined that the operators medical condition and general health meet the requirements of Section 55.33(a)(1). The facility licensee must also certify which industry standard (i.e., the 1983 or 1996 version of ANSI/ANS-3.4, Medical Certification and Monitoring of Personnel Requiring Operator Licenses for Nuclear Power Plants, or other NRC approved methods) was used in making the fitness determination.

The ANSI standards describe a number of specific operator health requirements and disqualifying conditions. If an operators health does not meet the minimum standards, the facility licensee must request a conditional license in accordance with Section 55.23(b) by submitting the appropriate medical evidence with NRC Form-396.

Pursuant to Section 55.33, Disposition of an initial application, and Section 55.57, as applicable, the Commission will review the license application based on the facility licensees certification and include any conditions in the license that might be necessary based on the supporting medical evidence.

While reviewing medical records, the inspectors discovered that an individual, who was issued an operator license in 2006, had a pre-existing medical condition since 1999 that had not been reported on their original license application. The information submitted would have allowed the NRC to evaluate/disposition the operators initial application as required by 10 CFR 55.33, Disposition of an initial application.

Analysis.

The inspectors determined that the licensees failure to provide complete and accurate information to the NRC, which resulted in an incorrect licensing action, is a performance deficiency because the licensee is expected to comply with 10 CFR 50.9 and it was within the licensees ability to foresee and prevent. Because a violation of 10 CFR 50.9 is considered to be a violation that can potentially impede or impact the regulatory process, the violation was dispositioned using the traditional enforcement process. The finding was more than minor because information was provided to the NRC signed under oath by the Site Vice President and erroneously impacted an NRC licensing decision. There was no evidence that the operator endangered plant operations as a result of the pre-existing medical condition while performing licensed duties since the original license was issued on July 24, 2006.

Inspectors determined that this issue did not meet the criteria for assignment of a cross-cutting aspect.

Enforcement.

10 CFR 50.9 states, in part, Information provided to the Commission by an applicant for a license or by a licensee or information required by statute or by the Commissions regulations, orders, or license conditions to be maintained by the applicant or the licensee shall be complete and accurate in all material respects. 10 CFR 55.23 requires that an authorized representative of the facility licensee shall certify the medical fitness of an applicant by completing and signing a NRC Form-396. NRC Form-396, when signed by an authorized representative of the facility licensee, certifies that a physician conducted a medical examination of the applicant as required in 10 CFR 55.21, and the guidance contained in ANSI/ANS 3.4-1983 was followed in conducting the examination and making the determination of medical qualification.

Contrary to this, on May 5, 2006, a senior licensee representative submitted NRC Form-396 for one individual applying for a reactor operator license that certified that the applicant met the medical requirements of ANSI/ANS 3.4-1983 and that the applicant would not require any restrictions to his license. In fact, the applicant had a pre-existing medical condition which required a no-solo restriction on the operators license in order to meet the medical standards. This information was material to the NRC because the NRC relied on this certification to determine whether the applicant met the requirements to operate the controls of a nuclear power plant pursuant to 10 CFR Part 55. The finding is not suitable for SDP evaluation, but has been reviewed by NRC management and is determined to be a green finding of very low safety significance. Because the failure to provide the information requesting appropriate restrictions on the operators license was of very low safety significance and has been entered into the corrective action program under CR090083, this violation is being treated as a Severity Level IV NCV consistent with Section VI.A.1 of the NRC Enforcement Policy: NCV 05000338, 339/2008004-01, Failure to Provide Complete and Accurate Medical Information to the NRC Which Impacted a Licensing Decision.

The licensee took prompt corrective actions and removed the individual from licensed duties. The licensee entered this issue into their corrective action program under CR090083.

.4 Quarterly Resident Inspector Observations of Security Personnel and Activities

a. Inspection Scope

During the inspection period, the inspectors conducted observations of security force personnel and activities to ensure that the activities were consistent with the licensee security procedures and regulatory requirements relating to nuclear plant security.

These observations took place during both normal and off-normal plant working hours.

These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors normal plant status review and inspection activities.

b. Findings

No findings of significance were identified.

.5 Institute of Nuclear Power Operations (INPO) Plant Assessment Report Review

a. Inspection Scope

The Senior Resident Inspector and the DRP Branch Chief reviewed the final report for the INPO plant assessment of North Anna Power Station issued in December, 2007. The report was reviewed to ensure that issues identified were consistent with the NRC perspectives of licensee performance and to verify if any significant safety issues were identified that required further NRC follow-up.

b. Findings

No findings of significance were identified.

.6 (Opened) NRC Temporary Instruction (TI) 05000339/2515/172, Reactor Coolant

System Dissimilar Metal Butt Welds (DMBWs) - Unit 2

a. Inspection Scope

The inspectors reviewed the licensees activities related to the inspection and mitigation of DMBWs in the RCS to ensure that the licensee activities were consistent with the industry requirements established in the Materials and Reliability Program (MRP) document MRP-139, Primary System Piping Butt Weld Inspection and Evaluation Guidelines, July 2005. The inspection activities covered the following for primary system piping 1-inch nominal pipe size or larger: a) review of documentation for volumetric examinations performed on mitigated DMBWs, and b) review of welding documentation for DMBWs that were mitigated by Full Structural Weld Overlay (FSWOL).

b. Findings and Observations

No findings of significance were identified.

MRP-139 Baseline Inspections

1)

Have the baseline inspections been performed or are they scheduled to be performed in accordance with MRP-139 guidance?

The scope of this inspection did not include the review of baseline inspections to verify that they were performed in accordance with MRP-139 guidance.

This inspection requirement will be completed in a future inspection activity.

2)

Is the licensee planning to take any deviations from MRP-139 requirements?

The scope of this inspection did not include the review of deviations from MRP-139 requirements with regard baseline inspections. This inspection requirement will be completed in a future inspection activity.

Volumetric Examinations

The inspectors selected the following DMBW for the volumetric examination review:

Unit 2: Pressurizer Surge Line DMBW after mitigation by FSWOL (Weld RC-410/

SW-5)

1)

For each examination inspected, was the activity performed in accordance with the examination guidelines in MRP-139, Section 5.1, for unmitigated welds or mechanical stress improved welds and consistent with NRC staff relief request authorization for overlaid welds?

Yes, the volumetric examination of the weld listed above was performed in accordance with a qualified procedure for UT examination, consistent with MRP-139 requirements and the proposed alternatives approved by the NRC in a safety evaluation report (SER) dated December 19, 2007 (ADAMS Accession Number ML072220228). The vendors procedure was developed in accordance with procedure Performance Demonstration Initiative (PDI) UT-8, Generic Procedure for UT of Weld Overlaid Austenitic Pipe Welds, Revision F, which was qualified in accordance with ASME Section XI, Appendix VIII, as implemented through the Electric Power Research Institute PDI Program.

The inspectors reviewed work orders, UT examination reports, and equipment certification records to ensure that the examination was performed in accordance with the procedure and the approved alternative, including holding time after the completion of the FSWOL and examination coverage.

2)

For each examination inspected, was the activity performed by qualified personnel?

Yes, the personnel involved in the UT examination listed above were qualified in accordance with MRP-139 requirements and the licensees proposed alternative. The examiners were qualified Level II in the UT method as required by the UT procedure and in accordance with the vendors written practice for NDE personnel. The UT examiners were also PDI qualified for the specific UT procedure they implemented.

3)

For each examination inspected, was the activity performed such that deficiencies were identified, dispositioned, and resolved?

Yes, the inspectors reviewed documentation and interviewed plant personnel to verify that deficiencies were evaluated and corrected. Based on the inspection activities, the inspectors determined that the examination was conducted in a manner such that deficiencies were identified, dispositioned, and resolved.

Weld Overlays

The inspectors selected the following FSWOL for review:

Unit 2: Pressurizer Surge Line DMBW mitigated by FSWOL (Weld RC-410/ SW-5)

1)

For each weld overlay inspected, was the activity performed in accordance with ASME Code welding requirements and consistent with NRC staff relief requests authorizations? Has the licensee submitted a relief request and obtained NRR staff authorization to install weld overlays?

Yes, the licensee installed the FSWOL listed above in accordance with the applicable sections of the ASME Code and consistent with NRC staff relief request authorization. The licensee submitted alternative relief requests CMP-022 (Revision 1) and CMP-023 (Revision 1) requesting approval to use full structural preemptive weld overlay with temper bead welding for repair of pressurizer DMBWs and the PDI program for their inspection as alternatives to the requirements of the ASME Code,Section XI. On December 19, 2007, the NRC issued a SER to approve the proposed alternative (ADAMS Accession Number ML072220228).

The inspectors reviewed welding procedure specifications, procedure qualification records, weld filler metal certifications, and welding process control sheets for the FSWOL listed above to verify compliance with ASME Section IX requirements and adherence to the SER. The inspectors also reviewed non-conformance reports regarding weld overlay quality issues to ensure that they were properly evaluated and corrected without deviations from the approved alternatives.

2)

For each weld overlay inspected, was the activity performed by qualified personnel?

Yes, welding personnel involved in the FSWOLs listed above were qualified in accordance with the requirements identified in ASME Code Section IX, Qualification Standard for Welding and Brazing Procedures, Welders, Brazers, and Welding and Brazing Operators. The inspectors reviewed the welder performance qualification test records and welding process control sheets to verify that welders were qualified for the specific welding method they implemented.

3)

For each weld overlay inspected, was the activity performed such that deficiencies were identified, dispositioned, and resolved?

Yes, the inspectors reviewed non-conformance documentation to verify that deficiencies were evaluated and corrected. Based on inspection activities, the inspectors determined that the installation of the FSWOL was conducted in a manner such that deficiencies were identified, dispositioned, and resolved.

Mechanical Stress Improvement (Not Applicable)

The licensee has not implemented Mechanical Stress Improvement as a mitigation method for DMBWs.

In-service Inspection Program

1)

Has licensee prepared an MRP-139 in-service inspection program?

The scope of this inspection did not include the review of the licensees ISI Program to verify that the licensee prepared a program in accordance with MRP-139 requirements. This inspection requirement will be completed in a future inspection activity.

2)

In the MRP-139 in-service inspection program, are the welds appropriately

categorized in accordance with MRP-139?

The scope of this inspection did not include the review of the licensees ISI Program to verify that the welds were appropriately categorized in accordance with MRP-139. This inspection requirement will be completed in a future inspection activity.

3)

Are inspection frequencies consistent with the requirements of MRP-139?

The scope of this inspection did not include the review of the licensees ISI Program to verify that the inspection frequencies were consistent with the requirements of MRP-139. This inspection requirement will be completed in a future inspection activity.

4)

What is the licensees basis for categorizing welds as H or I and plans for addressing potential PWSCC?

The scope of this inspection did not include the review of the licensees ISI Program to verify that the basis for categorizing welds as H or I was consistent with the description of these categories in MRP-139. This inspection requirement will be completed in a future inspection activity.

5)

What deviations has the licensee incorporated and what approval process was used?

The scope of this inspection did not include the review of deviations from the ISI Program requirements in MRP-139. This inspection requirement will be completed in a future inspection activity.

4OA6 Meetings, Including Exit

.1

Exit Meeting Summary

On October 15, 2008, the senior resident inspector presented the inspection results for the routine integrated quarterly report to Mr. Larry Lane and other members of the staff. The licensee acknowledged the findings. The inspectors asked the licensee whether any of the material examined during the inspection should be considered proprietary. No proprietary information was identified.

.2 Triennial Heat Sink Performance Exit Meeting

An interim exit meeting was conducted on July 18, 2008, with Jay Leberstien, Site Licensee Contact, and members of the plant staff. The inspectors confirmed that proprietary information was not reviewed during the inspection.

.3 Inservice Inspection Activities Exit Meeting

An interim exit meeting was conducted on September 26, 2008, with licensee

management

ATTACHMENT: SUPPPLEMENTAL INFORMATION

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

J. Bailey, Manager, Vendor Quality
J. Breeden, Supervisor, Radioactive Analysis and Material Control
R. Evans, Manager, Radiological Protection and Chemistry
R. Foster, Supply Chain Manager
E. Hendrixson, Director, Nuclear Safety and Licensing
T. Huber, Director, Nuclear Engineering
S. Hughes, Manager, Nuclear Operations
P. Kemp, Supervisor, Station Licensing
W. Anthes, Manager, Nuclear Maintenance
L. Lane, Plant Manager
G. Lear, Manager, Organizational Effectiveness
T. Maddy, Manager, Nuclear Protection Services
G. Marshall, Manager, Nuclear Outage and Planning
C. McClain, Manager, Nuclear Training
J. McHale, Engineering Supervisor
F. Mladen, Manager, Nuclear Site Services
S. Morris, ISI Program Manager
B. Morrison, Supervisor, Nuclear Engineering
J. Scott, Supervisor, Nuclear Training (operations)
D. Stoddard, Site Vice President

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

Opened

05000339/2515/172 TI Reactor Coolant System Dissimilar Metal Butt Welds

- Unit 2 (Section 4OA5.4)

Opened and Closed

05000338, 339/2008004-01 NCV Failure to Provide Complete and Accurate Medical

Information to the NRC Which Impacted a Licensing

Decision (Section 4OA5.3)

Closed

05000339, 2007009-01 URI Lack of Procedural Guidance During Spurious Safety Injection and Procedure Usage Flexibility Acceptability
05000339, 2007009-02 URI Lack of an Effective Program to Detect and Correct Degradations in Unit 2 SSPS Cards
05000338, 339/2008002-02 URI Failure to Report Accurate Medical Information on Initial

Licensing Application

Discussed

NONE

LIST OF DOCUMENTS REVIEWED

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